20190035 Ver 1_Individual_20190104

U.S. Army Corps of Engineers (USACE)
Form Approved -
APPLICATION FOR DEPARTMENT OF THE ARMY PERMIT
OMB No. 0710-0003
33 CFR 325. The proponent agency is CECW-CO-R.
Expires: 01-08-2018
The public reporting burden for this collection of information, OMB Control Number 0710-0003, is estimated to average 11 hours per response, including the time
for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of
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be subject to any penalty for failing to comply with a collection of information if it does not display a currently valid OMB control number. PLEASE DO NOT
RETURN YOUR APPLICATION TO THE ABOVE EMAIL.
PRIVACY ACT STATEMENT
Authorities: Rivers and Harbors Act, Section 10, 33 USC 403; Clean Water Act, Section 404, 33 USC 1344; Marine Protection, Research, and Sanctuaries Act,
Section 103, 33 USC 1413; Regulatory Programs of the Corps of Engineers; Final Rule 33 CFR 320-332. Principal Purpose: Information provided on this form
will be used in evaluating the application for a permit. Routine Uses: This information may be shared with the Department of Justice and other federal, state, and
local government agencies, and the public and may be made available as part of a public notice as required by Federal law. Submission of requested information
is voluntary, however, if information is not provided the permit application cannot be evaluated nor can a permit be issued. One set of original drawings or good
reproducible copies which show the location and character of the proposed activity must be attached to this application (see sample drawings and/or instructions)
and be submitted to the District Engineer having jurisdiction over the location of the proposed activity. An application that is not completed in full will be returned.
System of Record Notice (SORN). The information received is entered into our permit tracking database and a SORN has been completed (SORN #A1 145b)
and may be accessed at the following website: http://docld.defense.gov/Privacv/SORNslndex/DOD-wide-SORN-Article-View/Article/570115/al l45b-ce.asi)
(ITEMS 1 THRU 4 TO BE FILLED BY THE CORPS)
1. APPLICATION NO.
2. FIELD OFFICE CODE
3. DATE RECEIVED
4. DATE APPLICATION COMPLETE
(ITEMS BELOW TO BE FILLED BYAPPLICANT)
5. APPLICANT'S NAME
8. AUTHORIZED AGENT'S NAME AND TITLE (agent is not required)
First - Patrick Middle -H. Last - Brindle
First - Kelly Middle -M. Last - Thames
Company - Piedmont Lithium, Inc.
Company - HDR
E-mail [e-mail]
E-mail [e-mail]
6. APPLICANT'S ADDRESS:
9. AGENT'S ADDRESS:
Address- 5706 Dallas-Cherryville Highway
Address- 440 S. Church Street, 9th Floor
City - Bessemer City State - NC Zip - 28016 Country - USA
City - Charlotte State - NC Zip - 28202 Country -USA
7. APPLICANT'S PHONE NOs. w/AREA CODE
10. AGENTS PHONE NOs. w/AREA CODE
a. Residence b. Business c. Fax
a. Residence b. Business c. Fax
412-818-0376
704-338-6710
STATEMENT OF AUTHORIZATION
11. 1 hereby authorize, Kelly Thames to act in my behalf as my agent in the processing of this application and to furnish, upon request,
supplemental information in support of this permit application.
Patrick H. Brindle �'ae�2018g1zde;P5524 o 00 °'e 2018-12-27
SIGNATURE OF APPLICANT DATE
NAME, LOCATION, AND DESCRIPTION OF PROJECT OR ACTIVITY
12. PROJECT NAME OR TITLE (see instructions)
Piedmont Lithium Project
13. NAME OF WATERBODY, IF KNOWN (if applicable)
14. PROJECT STREET ADDRESS (if applicable)
Little Beaverdam and Beaverdam Creeks (HUC 03050102)
Address 1501 Hephzibah Church Road
15. LOCATION OF PROJECT
Latitude: -N 35.3878691 Longitude: �W 81.286758°
City - Bessemer City State- NC Zip- 28016
16. OTHER LOCATION DESCRIPTIONS, IF KNOWN (see instructions)
State Tax Parcel ID multiple, see supplemental info. Municipality unincorporated Gaston County
Section - Township - Range -
ENG FORM 4345, MAY 2018 PREVIOUS EDITIONS ARE OBSOLETE. Page 3 of 1

17. DIRECTIONS TO THE SITE
The Piedmont Lithium mine is centered around 1501 Hephzibah Church Road in Bessemer City, North Carolina (Figure 1, Appendix A).
From US -321 N, take Exit 12B for NC -275 W/NC-279 W. Take a right onto NC -275 W, then continue onto NC -279 W for 7.3 miles. Take a
right onto Hephzibah Church Road and continue to follow Hephzibah Church Road for 0.9 miles, then turn left to stay on Hephzibah Church
Road for another 1.5 miles. Address above is the locality for the bridge crossing of Beaverdam Creek on Hephzibah Church Road, which is
the approximate center of the site. On-site waters include Little Beaverdam Creek and Beaverdam Creek, which ultimately drain to the South
Fork Catawba River.
18. Nature of Activity (Description of project, include all features)
The proposed project would involve the development of a hard rock lithium mine, which includes the construction of an open pit, awaste
rock area, a concentrator plant site, access roads, and applicable National Pollutant Discharge and Elimination System (NPDES) best
management practices (BMPs). The project would result in impacts to 1,263 linear feet of perennial stream channel and 4,547.5 linear feet of
intermittent stream channel (5,810.5 linear feet total), 0.14 acre of wetlands, and 0.16 acre of pond. Approximately 781 linear feet of
perennial stream channel, 2,283 linear feet of intermittent stream channel, 0.14 acre of wetlands, and 0.16 acre of ponds will be impacted by
waste rock areas. Approximately 249 linear feet of perennial stream channel and 2,264.5 of intermittent stream channel will be impacted by
pit shell areas. Approximately 178 linear feet of perennial stream channel will be impacted by an internal access road stream crossing and 55
linear feet of perennial channel will be impacted by a stormwater BMP. Figure 3 (Appendix A) depicts the proposed site layout. (see
supplemental document for additional information).
19. Project Purpose (Describe the reason or purpose of the project, see instructions)
The global transition away from hydrocarbons toward energy alternatives has increased demand for many scarce metals. Among these is
lithium (Li), a key component in lithium -ion batteries for electronic devices, particularly electric and hybrid vehicles, laptop computers, and
cell phones. Forecasted growth in both global lithium demand and supply varies among analysts and industry experts; however, Roskill
forecasts overall growth in lithium consumption to average 15.3% per year to 2027 (Roskill's Base -Case Scenario). Consumption of lithium
will continue to be driven by the rechargeable battery sector, which is forecast to register 22.4% per year growth through to 2027. The global
leaders in lithium supply are Australia, Chile, and Argentina at 37%, 36%, and 17%, respectively, while the U.S. supplies only 2% to the
global market. And although there are untapped lithium reserves in the U.S., the U.S. imports two-thirds of the lithium needed to meet
domestic demand. Expanding the lithium supply in the U.S. would ensure a domestic source and insulate domestic prices in a global market.
Thus, a domestic lithium source is needed to supplement demands in the U.S. (see supplemental document)
USE BLOCKS 20-23 IF DREDGED AND/OR FILL MATERIAL IS TO BE DISCHARGED
20. Reason(s) for Discharge
There are multiple disposal sites (impacts) located throughout the project site. Impact 1 is the only stream crossing. Impacts 2-7 are those
associated with pit construction. Impacts 8-16 are those associated with waste rock area construction. Figure 4 (Appendix A) depicts the
impact site locations.
With the exception of one impact (Impact 1), all other impacts are located on shallow, first order streams that originate on site. The impact
sites would contain no flow or be dewatered prior to construction which would eliminate the stream velocities and prevent and control
turbidity, stratification, and other factors typically associated with mixing soil with water. All fill material would be clean fill material
originating from on site and readily available to the applicant. (see supplemental document for additional information)
21. Type(s) of Material Being Discharged and the Amount of Each Type in Cubic Yards:
Type Type Type
Amount in Cubic Yards Amount in Cubic Yards Amount in Cubic Yards
see supplemental document
22. Surface Area in Acres of Wetlands or Other Waters Filled (see instructions)
Acres 0.14 acre of wetland, 0.16 acre of ponds, and 0.36 acre of stream channel (see supplemental information)
or
Linear Feet 5,810.5 linear feet of stream channel (0.36 acre)
23. Description of Avoidance, Minimization, and Compensation (see instructions)
The applicant conducted an off-site and on-site alternatives analysis to determine the least environmentally damaging practicable alternative
that also still met the project's purpose and need. An in-depth discussion of the alternatives analysis is available in the Environmental
Assessment (Appendix Q. (see supplemental information)
ENG FORM 4345, MAY 2018 Page 3 of 2

24. Is Any Portion of the Work Already Complete? Yes allo IF YES, DESCRIBE THE COMPLETED WORK
25. Addresses of Adjoining Property Owners, Lessees, Etc., Whose Property Adjoins the Waterbody (if more than can be entered here, please attach a supplemental list).
a. Address- see Figure 12 (Appendix A) and Appendix D for a list of property owners adjoining the project boundary.
City - State - Zip -
b. Address-
City - State - Zip -
c. Address-
City - State - Zip -
d. Address-
City - State - Zip -
e. Address-
City - State - Zip -
26. List of Other Certificates or Approvals/Denials received from other Federal, State, or Local Agencies for Work Described in This Application.
AGENCY TYPE APPROVAL' IDENTIFICATION DATE APPLIED DATE APPROVED DATE DENIED
NUMBER
NCDENR-NCDWR 401 Water Quality IP WQC
NCDENR-DEMLR GP for Mining Activit NCG020000
see attached for additional required permit approvals
Would include but is not restricted to zonina, building, and flood i3lain i3ermits
27. Application is hereby made for permit or permits to authorize the work described in this application. I certify that this information in this application is
complete and accurate. I further certify that I possess the authority to undertake the work described herein or am acting as the duly authorized agent of the
applicant.
Patrick H. Brindle Digitally
te`zo 8gZab27 ip55:56 osoonale 2018-12-27 Thames, Kelly Marye° ..... �5 -=��a a ° =a=a1LPA 2018-12-30
SIGNATURE OF APPLICANT DATE SIGNATURE OF AGENT DATE
The Application must be signed by the person who desires to undertake the proposed activity (applicant) or it may be signed by a duly
authorized agent if the statement in block 11 has been filled out and signed.
18 U.S.C. Section 1001 provides that: Whoever, in any manner within the jurisdiction of any department or agency of the United States
knowingly and willfully falsifies, conceals, or covers up any trick, scheme, or disguises a material fact or makes any false, fictitious or fraudulent
statements or representations or makes or uses any false writing or document knowing same to contain any false, fictitious or fraudulent
statements or entry, shall be fined not more than $10,000 or imprisoned not more than five years or both.
ENG FORM 4345, MAY 2018 Page 3 of 3

ENG Form 4345 Supplemental Document
Piedmont Lithium
SAW -2018-01129
Piedmont Lithium
Gaston County, North Carolina
ACOE File No. SAW -2018-01129
Application for §404 Standard Individual Permit
Supplemental Information
Block 16. Other Location Descriptions
There are 74 parcels associated with the proposed project. See the Tax Parcel ID Map (Figure 2,
Appendix A) and the list of property ownership in Appendix B.
Block 18. Nature of Activit
The Piedmont Lithium mine would generate approximately 11.2 million cubic yards of lithium bearing
spodumene ore and 83.2 million cubic yards of waste rock and tailings. The project proposes to extract
lithium bearing spodumene from the open pit, which is within host rock in a geologic formation called a
pegmatite dyke and would then be separated into ore, waste, and byproduct.
The separation of lithium bearing spodumene ore and marketable byproducts from the host rock would be
conducted at an on-site concentrator plant. The project boundary has been developed to encompass
open pits, waste rock areas, appropriate NPDES BMPs, internal access roads, the concentrator unit, and
all other necessary support facilities. Large waste rock areas would be required to accommodate as much
as all pit waste as possible since offsite removal of waste rock is not practicable due to the volume of
material that would be generated. The full 200 -acre open pit areas and 145 -acre waste rock areas are
needed for the applicant to meet the project purpose.
The construction sequence would first require the establishment of 300 foot mining buffers around the
entire perimeter of the project site as required by Gaston County. The Federal Emergency Management
Act (FEMA) 100 -year floodplain would also be maintained along the entirety of Beaverdam and Little
Beaverdam Creeks. Next, the sediment and erosion control measures would be installed around the
perimeter of the site to control stormwater flows. The North Carolina Mine Permit requires that all
sediment and erosion control measures such as ditches, ponds, rock dams, be designed for the 25 -year
storm. Underdrains would be placed in the waste rock areas to capture normal groundwater flows in
areas where existing streams will be filled. Additional NPDES BMPs would be installed in appropriate
areas to treat stormwater runoff of the site in general as needed. Clearing of the pit and waste area sites
would occur before the open pit and waste rock area are constructed and only cleared as needed during
the development of the pit and waste rock areas. Internal roads would be constructed for pit and waste
rock area access throughout the mine site. The open pits will have design parameters similar to batter
face angles of 80 degrees, a batter height of 40 feet (12.2 meters), a berm width of 20 feet (6.1 meters),
an overall wall angle of 52 degrees, and a ramp width of 80 feet (24.8 meters) for transportation of
material.
The waste rock area would contain as much pit waste as possible since offsite removal of waste rock is
not practicable due to the volume of material that would be generated. The majority of remaining waste
will be returned to the pit as backfill once pit voids have been established. A percentage of waste will also
be separated as marketable byproducts, such as mica and feldspar. Filter cake waste from the
concentrator will also be placed in the waste rock area and co -disposed with waste rock.
Page 11

ENG Form 4345 Supplemental Document
Piedmont Lithium
SAW -2018-01129
The Piedmont Lithium site was acquired by the applicant for the purpose of managing all the
aforementioned mining activities in close proximity to one another. The proposed impacts would result
from the construction of open pits, waste rock areas, and one access road crossing.
There are multiple disposal sites (impacts) located throughout the project site. Impact 1 is the only stream
crossing. This impact would consist of a culvert installation. Impacts 2-7 are those associated with pit
construction. Impacts 8-16 are those associated with waste rock area construction. All impacts would be
the result of discharge (fill) material consisting of clean fill material originating from on site and readily
available to the applicant. The impact sites would contain no flow or be dewatered prior to construction
which would eliminate the stream velocities and prevent and control turbidity, stratification, and other
factors typically associated with mixing soil with water. Figure 4 depicts the impact site locations, which
are described in detail in Blocks 20-22.
Block 19. Project Purpose
The main sources of lithium used in cathodes of lithium -ion batteries are spodumene (a mineral) and sub -
saline brines. Lithium -ion batteries require lithium hydroxide (LiOH), which is expected to be the fastest
growing product of the lithium market. Global Lithium, LLC projects sustained relatively firm lithium
hydroxide pricing over the next five to seven years based on the consensus opinion of lithium producers,
purchasers and industry experts that lithium demand to produce lithium hydroxide will grow a minimum of
300% between 2017 and 2025.
To produce lithium hydroxide, lithium must be extracted from either hard rock sources such as
spodumene or extracted through an evaporative process from sub -saline brines. Extracting spodumene-
containing lithium is accomplished by utilizing traditional hard rock mining techniques of open pit drilling
and separation of lithium from host rock using a series of physical and chemical processes to produce
lithium concentrate. This process can be completed as fast as the material can be moved from an open
pit to a concentrator plant. Saline -based projects rely upon pumping saline -containing lithium from
underground reserves to the earth's surface, which is then pumped through a series of evaporation
ponds, each having a higher concentration of lithium than the last. This process can take months to a
year or more, depending on weather, to yield adequate lithium concentrate. Both spodumene- and saline -
based projects require conversion of lithium concentrate through purification and crystallization into
battery -grade quality lithium hydroxide of the type which can be used in cathodes for the manufacturing of
electric car batteries. According to Roskill Industry Cost Curves, it is more cost efficient to produce
battery -grade quality lithium hydroxide from lithium concentrates extracted from spodumene-based
projects than with saline -based projects.' Lithium conversion with spodumene-based projects cost
approximately $2,500 to $3,500 per metric tonne (1.1023 US tons) of lithium hydroxide produced while
lithium conversion with saline -based projects cost approximately $4,500 to $6,500 per metric tonne of
lithium hydroxide produced. Moreover, if lithium concentrates are shipped to China (a common practice in
the industry) for this conversion/purification process (vs. on-site or nearby conversion locations), costs
increase to approximately $7,500 to $9,500 per metric tonne of lithium hydroxide produced.
Since spodumene-based lithium extraction projects are more cost efficient than saline -based lithium
extraction projects to produce battery -grade lithium hydroxide and since there is a need for a domestic
supply of lithium, spodumene reserves containing lithium located in the U.S. were considered for
development. Spodumene based lithium reserves located outside the US were not considered
Roskill Market Reports and Consultancy. 2018. Lithium Industry Cost Curves. https://roskill.com/roskill-Product/lithium-industry-
cost-curves/
Page 12

ENG Form 4345 Supplemental Document
Piedmont Lithium
SAW -2018-01129
reasonable or practicable alternative to provide domestic sources of lithium. While there are a few lithium
reserves contained in mineralized spodumene in the US, the largest lithium reserves are located within
the Carolina Tin-Spodumene Belt (TSB), in North Carolina, according to the US Geological Survey
(USG S).2 The Carolina TSB was the world's largest producer of lithium after World War II, from the
1950's through the 1980's and infrastructure such as rail and highway are still existing which can be
utilized to access and support mining operations today .3 An attractive draw for potential investors and
local labor forces, the Carolina TSB is also close (< 30 minutes) to multiple metropolitan areas, such as
Gastonia and Charlotte. Therefore, the purpose of the project is to develop a hard rock lithium mine in the
Carolina TSB, to extract and refine mineralized spodumene to a high quality lithium bearing spodumene
concentrate; which, upon conversion to a battery grade lithium hydroxide, will provide a domestic source
of lithium to meet growing demands in the U.S.
Block 20. Reason(s) for Discharge
Impact 1: Stream crossing
The proposed reinforced concrete pipe (RCP) would be placed directly in 178 linear feet of jurisdictional
Perennial Stream 2 (Figure 5, Appendix A). The existing stream substrate in these areas would be
buried/removed. The discharge would consist of suitable fill material and would not include any trash,
debris, car bodies, asphalt, etc. The fill material would also be free of toxic pollutants in toxic amounts.
Proper sediment and erosion control measures would be installed prior to and during construction to
ensure that the substrate of remaining waters of the United States would not change or be affected. The
pipe will be buried 1 foot if larger than 48 inches in diameter or will be buried 20% of the diameter if less
than 48 inches, so as not to impede low flows and aquatic life movement.
Impacts 2 — 7: Those associated with pit construction.
The proposed pit material would be directly removed from the following on-site jurisdictional streams:
1,090 linear feet of Intermittent Stream 3, 548.5 linear feet of Intermittent Stream 8, 249 linear feet of
Perennial Stream 8, 76.5 linear feet of Intermittent Stream 9, 520 linear feet of Intermittent Stream 10,
and 30 linear feet of Intermittent Stream 11 (Figures 6-8, Appendix A). The existing stream substrate in
these areas would be buried/removed. The discharge would consist of suitable fill material and would not
include any trash, debris, car bodies, asphalt, etc. The fill material would also be free of toxic pollutants in
toxic amounts. All fill material would be clean fill material originating on site from adjacent areas to be
mined and readily available to the applicant. Proper sediment and erosion control measures would be
installed prior to and during construction to ensure that the substrate of remaining waters of the United
States would not change or be affected.
Impacts 8 — 16: Those associated with waste rock area construction.
The proposed waste rock material would be placed directly in the following on-site jurisdictional streams:
917 linear feet of Intermittent Stream 12, 755 linear feet of Perennial Stream 12, 240 linear feet of
Intermittent Stream 8, 76.5 linear feet of Intermittent Stream 9, 240 linear feet of Intermittent Stream 13,
1,125.5 linear feet of Intermittent Stream 15, and 81 linear feet of Perennial Stream 15 (Figures 9-11,
Appendix A). The existing stream substrate in these areas would be buried/removed. The discharge
would consist of suitable fill material and would not include any trash, debris, car bodies, asphalt, etc. The
fill material would also be free of toxic pollutants in toxic amounts. All fill material would be clean fill
material originating on site from adjacent areas to be mined and readily available to the applicant. Proper
2 Norton, J. and McKenney Schlegel, D. 1955. Lithium resources of North America. U.S. Department of the Interior Geological
Survey Bulletin 1027-G. https://pubs.uscis.gov/bul/1027g/report.pdf
3 ibid
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ENG Form 4345 Supplemental Document
Piedmont Lithium
SAW -2018-01129
sediment and erosion control measures would be installed prior to and during construction to ensure that
the substrate of remaining waters of the United States would not change or be affected.
Table 1 (below) summarizes the impact amounts per activity type of the proposed project.
Table 1. Summary of impacts per activity type.
Block 21. Type(s) of Material Being Discharged
There are multiple disposal sites (impacts) located throughout the project site. Impact 1 is the only stream
crossing. Impacts 2-7 are those associated with pit construction. Impacts 8-16 are those associated with
waste rock area construction. Refer to Block 20 for additional details. Table 2 (below) summarizes each
impact by impact activity and impact materials. Approximately 2,714.53 cubic yards of fill is proposed in
jurisdictional waters for the project.
Table 2. Summary of type of discharge material per impact.
Impact
Impact Type
Type of
Feature Type
Waste Area
Pit Shell
Access Roads BMPs
Total
Intermittent Streams I
2,283
2,264.50
0 0
4,547.5 If
Perennial Streams (If)
781
249
178 55
1,208 If
Wetlands (ac.)
0.14
0
0 0
0.14 ac.
Ponds (ac.)
0.16
0
0 0
0.16 ac.
Stream Crossing
Concrete
4
Total Stream Impacts
5,810.5 If
0.02
79.11
Total Wetland Impacts
0.14 ac.
(Culvert)
Total Pond Impacts
0.16 ac.
Block 21. Type(s) of Material Being Discharged
There are multiple disposal sites (impacts) located throughout the project site. Impact 1 is the only stream
crossing. Impacts 2-7 are those associated with pit construction. Impacts 8-16 are those associated with
waste rock area construction. Refer to Block 20 for additional details. Table 2 (below) summarizes each
impact by impact activity and impact materials. Approximately 2,714.53 cubic yards of fill is proposed in
jurisdictional waters for the project.
Table 2. Summary of type of discharge material per impact.
Impact
Type of
Width
CubAcres
#
Feature
Activity
Material
Depth
Amount
Amount
Yards
(ft)
(ft)
(yd3)
1
Perennial
Stream Crossing
Concrete
4
3
178 If
0.02
79.11
Stream 2
(Culvert)
Intermittent
Native rock/soil
2
Stream 3
Pit Construction
mixture
3
2
809 If
0.06
179.78
Intermittent
Native rock/soil
2
Pit Construction
3
2
281 If
0.02
62.44
Stream 3
mixture
Perennial
Native rock/soil
3
Stream 8
Pit Construction
mixture
4
3
249 If
0.02
110.67
Intermittent
Native rock/soil
4-1
Pit Construction
2
2
337.5 If
0.02
50.00
Stream 8
mixture
Intermittent
Native rock/soil
4-2
Stream 8
Pit Construction
mixture
2
2
211 If
0.01
31.26
5
Intermittent
Pit Construction
Native rock/soil
3
2
76.5 If
0.01
17.00
Stream 9
mixture
Intermittent
Native rock/soil
6
Stream 10
Pit Construction
mixture
3
1.5
520 If
0.04
86.67
7
Intermittent
Pit Construction
Native rock/soil
2
1.5
30 If
0.00
3.33
Stream 11
mixture
Intermittent
Waste Rock Area
Native rock/soil
8-1
2
1.5
312 If
0.01
34.67
Stream 15
Construction
mixture
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ENG Form 4345 Supplemental Document
Piedmont Lithium
SAW -2018-01129
Impact
Type of
Width
Impact
Cub
#
Feature
Activity
Material
Depth
Amount
Acres
Yards
ft)
(ft)
d3
Intermittent
Waste Rock Area
Native rock/soil
8-2
Stream 15
Construction
mixture
2
1.5
813.5 If
0.04
90.39
Perennial
Waste Rock Area
Native rock/soil
9
Stream 15
Construction
mixture
3
3
81 If
0.01
27.00
Waste Rock Area
Native rock/soil
10
Pond 3
3
0.08 ac.
0.08
387.20
Construction
mixture
Intermittent
Waste Rock Area
Native rock/soil
11
Stream 12
Construction
mixture
2
1.5
917 If
0.04
101.89
Perennial
Waste Rock Area
Native rock/soil
12
4
2
700 If
0.06
207.41
Stream 12
Construction
mixture
Perennial
BMP for Waste
13
Stream 12
Rock Area
Rock
4
2
55 If
0.01
16.30
Waste Rock Area
Native rock/soil
14
Wetland 9
--
3
0.14 ac.
0.14
677.60
Construction
mixture
Waste Rock Area
Native rock/soil
15
Pond 4
Construction
mixture
--
4
0.08 ac.
0.08
516.27
Intermittent
Waste Rock Area
Native rock/soil
16
Stream 13
Construction
mixture
2
2
240 If
0.01
35.56
Stream Totals
5810.5 If
0.36 ac.
1133.46
Wetland Totals
0.14 ac.
0.14 ac.
677.60
Pond Totals
0.16 ac.
0.16 ac.
903.47
Cubic Yards Total:
2,714.53
Block 22. Surface Area in Acres of Wetlands or Other Waters Filled
Refer to Blocks 18, 20, and 21 for impact descriptions and locations for each impact. All discharge
impacts will be conducted by backhoes. Typical construction equipment such as bobcats, dump trucks,
and excavators would also provide construction support. Proper sediment and erosion control measures
would be installed prior to and during construction to ensure that remaining waters of the United States
would not change or be affected.
Block 23. Description of Avoidance, Minimization, and Compensation
According to the applicant, the applicant's preferred alternative would avoid impacts to the entirety of
Beaverdam Creek (13,741 feet) and Little Beaverdam Creek (2,848 feet). Impacts to Stream 2 have been
minimized through utilization of the footprint of an existing crossing for an access road, and impacts to the
majority of the stream have also been avoided (1,762 feet). Avoiding disturbance in the FEMA floodplain
will prevent impacts to the entirety of Wetlands 1, 3-8, and 11-14 (7.62 acres). Wetlands 2, 10, and 15-16
(0.40 acre) will also be avoided due to site design. Finally, adhering to the 300 -foot mining buffer setback
as required by Gaston County Zoning Ordinance, the preferred alternative also avoids impacts to 10,603
feet of stream. Indirect impacts to remaining streams will be avoided through the use of 100 -foot stream
buffers and stormwater management through NPDES BMPs. The applicant has considered alternatives
including off-site alternatives, a no -build option, an on-site no impact option, an on-site additional impact
option, and an on-site avoidance option. Construction equipment would be kept in upland areas.
Sediment and erosion control measures would be used to prevent impacts to downstream waters. No live
Page 15

ENG Form 4345 Supplemental Document
Piedmont Lithium
SAW -2018-01129
concrete would be allowed to come in contact with surface waters. Water quality monitoring would be
conducted to monitor site discharge and runoff. A Section 401 Individual Water Quality Permit is being
submitted concurrently with this IP application. A Stormwater Pollution Prevention Plan (SWPP) is also
being developed and will be submitted upon completion to the North Carolina Department of
Environmental Quality (NCDEQ) Division of Energy, Mineral, and Land Resources (NCDEMLR) under the
General Permit (No. NCG020000) for Mining Activities.
There are no active private mitigation banks within HUC 03050102; therefore, the applicant proposes
compensatory mitigation for all permanent impacts through the purchase of stream and wetland mitigation
credits from the North Carolina Division of Mitigation Services (DMS). The applicant provided supporting
documentation from DMS in a letter dated December 21, 2018 (attached to the Environmental
Assessment in Appendix C), indicating that they are willing to accept compensatory mitigation payment
for 5,810.5 linear feet of stream impacts and 0.14 acre of riparian wetland within the South Fork Catawba
Sub -Basin within the Catawba River Basin (03050102).
Block 25. Addresses of Adioining Property Owners
Figure 12 (Appendix A) depicts those parcels adjoining to the project boundary. Appendix D provides the
list of adjoining property owners and associated addresses.
Block 26. List of Other Certifications
Work would not commence until all approvals are obtained. Those approvals will be forwarded on, as
applicable, once received.
Additional certifications are included in Table 3 (below).
Table 3. Additional certifications required for work described in this application.
Agency
Type Approval
Identification
Date Applied
Date Approved
Date Denied
Number
NCDENR —
General Permit
DEMLR
(Construction
NCG01
Stormwater
NCDENR —
Construction
Division of Air
and Operation
Quality
(Greenfield
Permit
NCDENR —
NC Mining
DEMLR
Permit
Page 16

ENG Form 4345 Supplemental Document
Piedmont Lithium
SAW -2018-01129
Appendix A:
Figure 1. Project Location
Figure 2. Tax Parcel ID Map
Figures 3. Preferred Alternative Site Layout
Figure 4. Proposed Impacts — Overview
Figures 5-11. Proposed Impacts
Figure 12. Adjoining Property Owners

LEGEND
IP Project Bound
(971 ac.)
DATA SOURCE: Esn, OpenStreetMap
contributors, and the GIS User Commul
0 Miles
1 in = 2 miles
L
P-:s'�! mer City
NC -279 W
:QLN
High Shoa Is
Iron S
on�3 C- 41%r
41 le�-
DaIhs
Rankin
Lake Par
e4
+
Ivortn uarollna Gastonia
L� •cek
i I P � r.nulder� GTe�+
_ PIEDMONT LITHIUM PROJECT
F)l PIEDMONT PROJECT LOCATION
,1TH uM
FIGURE 1
PATH: IICLTSMAWGIS DATA\GIS\PROJECTS71135_ PIEDMONTLITHIUM\100896d0_PIEDMONTLITHIUM7.2_ WORK _ IN_PROGRESSIMAP_DOCSIM%D11P1DRAFT_20181225101 PIEDMONTLITHIUM PROJVIC.M%D INDIVIDUAL PERMIT
USER: KTHAMES - DATE: 12Q6QO18

LEGEND
IP Project Boundary (971 ac.)
Gaston County Parcels
DATA SOURCE: http:/Iwww.bing.com/maps
0 Feet 2,000
1 inch = 2,000 feet
Parcel # Parcel property Index
on Map Identification Number (PIN)
Number (PID)
1 215731 3610851099
2 213460 3610960050
3 213461 3610955009
4 159240 3620032400
5 215730 3610832948
6 198928 3610834913
7 198472 3610836980
8 205287 3610932526
9 159640 3610826932
10 159641 3610920720
11 159642 3610923504
12 159638 3610824264
13 159639 3610814717
14 159637 3610818724
15 218752 3610903700
16 223454 3610901364
17 209087 3610900090
18 160753 3610804266
19 218192 3610718456
20 216007 3610625635
21 218191 3610742004
22 216006 3610537691
23 159632 3610520605
24 159633 3610520962
25 159634 3610531136
26 159628 3610531398
27 159635 3610532577
28 159631 3610543083
29 159177 3610545560
30 159176 3610543921
31 159173 3610553181
32 159171 3610548973
33 159168 3610650474
34 159167 3610554561
35 159166 3610555519
36 159165 3610555687
37 159164 3610556754
FN PIEDMONT
T
L TN AI
Ids:
Parcel # on
Parcel
Property Index
Map
Identification
Number (PIN)
Number PID)
38
159162
3610557896
39
159160
3610559928
40
159159
3610660017
41
159155
3610660267
42
159156
3610661196
43
159153
3610655959
44
198919
3610662421
45
198920
3610664312
46
159154
3610663552
47
159178
3610447462
48
159179
3610447644
49
159181
3610447747
50
159182
3610458027
51
159184
3610454454
52
226475
3610466002
53
226474
3610468123
54
159186
3610550611
55
159187
3610550766
56
159188
3610551930
57
159157
3610562023
58
159150
3610461307
59
159152
3610563958
60
157923
3610579909
61
214055
3610670678
62
157925
3610673134
63
157922
3610676719
64
159195
3610679156
65
159194
3610667558
66
159199
3610668429
67
1 591 92
3610763884
68
226286
3610760164
69
226287
3610762374
70
159196
3610767263
71
159191
3610754682
72
159190
3610757641
74 1 223135 1 3620070197
PIEDMONT LITHIUM PROJECT
GASTON COUNTY PARCEL IDS
_ FIGURE 2
INDIVIDUAL PERMIT

LEGEND
IP Project Boundary 100 -Year FEMA
(971 ac.) Floodplain
HDR Delineated Culverts
Streams
HDR Delineated
Wetlands 0 Feet 1,400
HDR Delineated Ponds 1 inch =1,400 feet
Waste Rock• • \
BMPs
0
existing bridge
crossing of
Whitesides Rd
LEGEND: MINE FEATURES
Concentrator Plant Site
Pit Shell
Waste Rock Areas
- — — Existing Roads
Proposed Access Roads
Setback Buffers
100 Ft Lot Line Setback
200 Ft Structure Setback
300 Ft Residential Setback
FN PIED M NO T
L -1 - UN
r-
t. . . . . .. . .
................ f
r1...J ffJ �V■
fl �
Q.......r •
DESKTOP JD FEATURES
Desktop Streams
® Desktop NWI Wetland
APPROXIMATE IMPACTS
Delineated Stream
Impacts
Delineated Wetland
Impacts
-Delineated Pond
Impacts
Desktop Stream
Impacts
Preferred Site Layout Approximate Impacts
tore Type
Waste Area Pit Shell Access Roads Waste Area Pit Shell SMPs Total
rm ittent Streams (If)
2,283 1,983.50 0 0 281 0 4,547.5 If
ennial Streams (If)
81 249 178 700 0 55 1,208 If
lands (ac.)
0.14 0 0 0 0.14 ac.
ds (.r.)
0.16 0 0� 0 0.16 ac.
Total Stream Impacts 5,810.5 If
Total Well Ind Impacts 0.+4 so.
Total Pond Impacts 0.16 so.
PIEDMONT LITHIUM PROJECT
PREFERRED ALTERNATIVE SITE LAYOUT
FIGURE 3
�..°'°
INDIVIDUAL PERMIT

LEGEND
IP Project Boundary
(971 ac.)
HDR Delineated
Streams
- HDR Delineated
Wetlands
HDR Delineated Ponds
100 -Year FEMA
Floodplain
Culverts
0 Feet 1,400
1 inch = 1,400 feet
G-"tG1'-Webb,,Chape1 Rd
DESKTOP JD FEATURES
Desktop Streams
® Desktop NWI Wetland
APPROXIMATE IMPACTS
Delineated Stream
Impacts
Delineated Wetland
Impacts
EmDelineated Pond
Impacts
Desktop Stream
Impacts
Inn acct 2
i y . . . . . (Figure 6)
L. .. • .
10).� Ir• 1
r
.i -�
.... ........
Impacts 6. . . . . . .. .. .. . .
(Figure 8)p -
LEGEND: MINE FEATURES
Concentrator Plant Site
Pit Shell
0 Waste Rock
- — — Existing Roads
Proposed Access
Setback Buffers
100 Ft Lot Line Setback
200 Ft Structure Setback
300 Ft Residential Setback
PIEDPAONT
Preferred Site Layout Approximate Impacts
Feature Type Waste Area PR Shell Access Roatls Waste Area• Ph Shell BMP.
Intermi08n1 Stmams(if) 2,283 1,983.50 0 0 281 0 4,547.5 If
Perennial SO.... (19 81 249 178 700 0 55 1,208 If
Wetlands (ac.) 0.14 0 0 0 0.14 ac.
Ponds(ac.) 0.16 0 0 0 016 ac.
Total Stream Impacts 5,810.5 If
Total Wetland Impacts 0.14...
- Total Pond Impacts 0.16 ac.
a�
PIEDMONT LITHIUM PROJECT
PROPOSED IMPACTS - OVERVIEW
FIGURE 4
INDIVIDUAL PERMIT

pact
DELINEATED FEATURES
HDR Delineated Streams
HDR Delineated Wetlands
HDR Delineated Ponds
100 -Year FEMA Floodplain
® Culverts
0 1 inch = 100 feet 100
.....................................................................
..................................................................
..................................................................
..................................................................
..................................................................
..................................................................
................................................................
.......................................................
.....................................................
....................................................
...................................................
.................................................
.......................................
---- --- - ---- -- ......................
Existing Culvert
.. 77 If ......................
.................................
Impact 1 -Perennial Stream 2 -
::::::: 178 1f delineated
(culvert installation)
::::: NCSAM: High...Bridge footprint• ; ::::::: ,-•
- - - - - Proposed Mitigation Rato: 2:1 - - - - - - - - • j156 stream credits
.....................................
......................................
.......................................
.........................................
..
...............................................
..............................................
.............................................
.............................................
.. .........................
• LEGEND: MINE FEATURES
• Concentrator Plant Site • ' • ' • ' • ' • ' • ' • ' '
.. ........................
' • ' • ' • ' • ' • '
.........
. �PitShell .............................
..............
�=flWasteRock ...........................
...,.............
- — —Existing Roads . . . . . . . . .. .. .. . . . . .
. . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . .
.....................................................
Proposed Access . . . . . . .. .. . . .. . .. . .
. . . . . . . . . . . . . . .. .. . . . . . . . .
...•r.• e -...r ...............................................
FN PIED/AONT
,, ­
PROPOSEDIMPACTS
Delineated Stream Impacts
Delineated Wetland Impacts
Delineated Pond Impacts
Desktop Stream Impacts
PIEDMONT LITHIUM PROJECT
IMPACT 1
FIGURE 5
INDIVIDUAL PERMIT

DELINEATED FEATURES
HDR Delineated Streams
HDR Delineated Wetlands
HDR Delineated Ponds
100 -Year FEMA Floodplain
::� Culverts
© .............
0 1 inch = 200 feet 200
..................... .....
\ Impact 2- Intermittent Stream 3
.................................................... 809 If delineated
281 If desktop
......... ::::::1,090if
,,,,,,;;;;;; ;', (removal for pit construction)
........................................................
........................................................
......................................................
....................................................
Existing Culvert
63 If
......... Existing Culvert :: :22 If
AA-0
LEGEND: MINE FEATURES
Concentrator Plant Site
Pit Shell -
"flWaste Rock Areas
—Existing Roads
Proposed Access Roads
100 Ft Lot Line Setback
200 Ft Structure Setback
=300 Ft Residential Setback r
NCSAM: High
Proposed Mitigation Ratio: 1:1
1,090 stream credits
PROPOSEDIMPACTS
Delineated Stream Impacts
Delineated Wetland Impacts
-Delineated Pond Impacts
Desktop Stream Impacts
PIEDMONT LITHIUM PROJECT
FNPIEDMONT IMPACT 2
L SHiuM
FIGURE 6

' DELINEATED FEATURES HDR Delineated Streams .....
HDR Delineated Wetlands .. .. .. .. .. .. .. .. .
HDR Delineated Ponds`�O .. .. .. . . . .. .. .. . . . . . . .. .. .. .
ti, ;
100 -Year FEMA Floodplain . . . .. .. .. .. .. .. . .. .. .
=3E=EE1Culverts................................................................
0 1 inch = 100 feet 100 . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . . . .
....................................................................
...................................................................
Impact 3 - Perennial Stream 8 ::::::::::::::::::::::::::::::
• 249 If delineated
(removal for pit construction)
NCSAM:High :::::::::;:::::::::::::::::::::
d3 Proposed Mitigation Rato: 2:1
;1498 stream credits
......:::: Impact4-1-IntermittentStream8
••••••••••••••••••••••••••••••••••••••••••• 337.5 If delineated
v► ••••••• ••••••••••••••••••••••••••••••••••••• (removal for pit construction)
d ......::::::::::::::::::::: N CSAM:Medium
:::::::: ' - ::::: • ' • • ' ' ' ::::::::::::::::::::::::. Proposed Mitigation Rato: 0.5:1
168.75 stream credits
-----------------
................................................................................
....... .................................,...,................................
........... .
.....................................................................
............. ....................................................................
•••••••••••••••• +Impact 5- Intermittent Stream 9 ••• Impact 4-2- Intermittent Stream 8 ••••••••••••
76.5 1f delineated ••• • 211 1f delineated
(removal for pit construction) :::: (removal for pit construction)
NCSAM:Low ;;;; NCSAM:Medium
Proposed Mitigation Rato:0 ;;; Proposed Mitigation Rato:0.5:1
Ostream credits ;;;;I105.5stream credits
`^ LEGEND: MINE FEATURES ............................................ ...........
Concentrator Plant Site .......................... ...................:. PROPOSED IMPACTS
77 -Pit Shell • ' • ' • ' • ' ' • ' • ' • ' • ' • ' • ' • ' • ' • ' • ' • ' • ' • ' • ' • ' Delineated Stream Impacts
Waste Rock Areas . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . =Delineated Wetland Impacts
Existing RoadsDelineated Pond Impacts
:: :: : : : : : : : : : : : : : : : : : : : :: :: :: : : : : : : : : :
Proposed Access Roads Desktop Stream Impacts
_ PIEDMONT LITHIUM PROJECT
FNPIEDMONT IMPACTS 3 - 5
FIGURE 7
INDIVIDUAL PERMIT

..........................................................................................
.. DELINEATED FEATURES.....................................................................
HDR Delineated Streams .. .. .. .. .. .. . . . . . . . . .. .. .. .
. HDR Delineated Wetlands .. .. .. .. .. .. .. .. .. .
. HDR Delineated Ponds .. .. .. .. .. .. .. .. .. .
. 100 -Year FEMA Floodplain .. . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . .
�Culverts....................................................................
.. 0 finch=100feet 100.....................................................................
. . . . . . .. .. . . . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . .
. . . . . . .. .. . . . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . .
. . . . . ... ... . . . . . . . . .. . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . .. . . . .. .. .. . . . .. . . . . . . . . . . . . . . .. .. .. . . .
. . . . . . .. .. . . . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . .
. . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . .
. . . . . . .. .. . . . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . .
. . . . . . .. .. . . . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . .
. . . . . . .. .. . . . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . . . .. .. . . .
. . . . . . .. .. . . . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . .
. . . . . . .. .. . . . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . .
. . . . . . .. .. . . . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . .
Impact 7- Intermittent Stream 11
................................................ 30 If delineated ............
...................................................: .............
• • - - • • • • • • • (removal for pit construction)
Impact 6- Intermittent Stream 10 ••••••••••••••••••••••••• :::::::::::::
520 1f delineated NCSAM: High ........... .
(removal for pit construction) Proposed Mitigation Rato: 1:1
......::::::::::: ' 30 stream credits
NCSAM: High
Proposed Mitigation Rato: 1:1 ..::::::............:::::::::::::::::::::
1520 stream credits::::::::::::::::::::::::'::::::::::.......::::::::::::::::::::::
.............................................................. __.........
..........................
Olt eev,
LEGEND: MINE FEATURES
Concentrator Plant Site PROPOSED IMPACTS
Pit Shell Delineated Stream Impacts
Waste Rock Areas Delineated Wetland Impacts
—Existing Roads -Delineated Pond Impacts
Proposed Access Roads
Desktop Stream Impacts
PIEDMONT LITHIUM PROJECT
PIEDPAONT IMPACTS 6 AND 7
FN
FIGURE 8
a°,o.o,. INDIVIDUAL PERMIT

DELINEATED FEATURES
HDR Delineated Streams
=HDR Delineated Wetlands
HDR Delineated Ponds
100 -Year FEMA Floodplain
=3ff=11, Culverts
0 1 inch = 150 feet 150
Impact 8-1 - Intermittent Stream 15
312 If delineated
(discharge for waste rock storage)
NCSAM: Low
Proposed Mitigation Rato: 0
0 stream credits
---------------------------------------
Impact 9 - Perennial Stream 15
81 If delineated
(discharge for waste rock storage)
NCSAM: High
Proposed Mitigation Rato: 2:1
1 A 9 -qtraam rrPdit- f\
Impact 8-2 - Intermittent Stream 15
813.5 If delineated
(discharge for waste rock storage)
NCSAM: Medium
Proposed Mitigation Rato: 0.5:1
406.75 stream credits.. • . " . • . • .
ZZ
Intermittent/ " " " " •
Perennial . . . . . . . .. .. .. .. .
Breakpoint . . . .. .. .. . .
PROPOSED IMPACTS
Delineated Stream Impacts
Delineated Wetland Impacts
-Delineated Pond Impacts
Desktop Stream Impacts
PIEDMONT LITHIUM PROJECT
IMPACTS 8 AND 9
FIGURE 9
INDIVIDUAL PERMIT

S
DELINEATED FEATURES
HDR Delineated Streams
HDR Delineated Wetlands
�HDRDelineatedPonds Impact 10 - Pond 3
0.08 ac. delineated
j 100 -Year FEMA Floodplain (discharge for waste rock storage)
J ,Culverts -
f DESKTOP JD FEATURES no mitigation required
Desktop Streams
r ®DesktopNWIWetland
0 1 inch = 200 feet 200
f �
`
'Impact 12 - Perennial Stream 12
700 If desktop `
(discharge for waste rock storage)
l`
NCSAM: High
Proposed Mitigation Rato: 2:1
1,400 stream credits
r'4( PIEDPAONT
Impact 11 - Intermittent Stream 12
917 If delineated
(discharge for waste rock storage) .
NCSAM: Medium
Proposed Mitigation Rato: 0.5:1
\ \�` 458.5 stream credits
Intermittent/ `
Perennial
Breakpoint ��` �� ` �� •\ \ `,y�
Impact 13 - Perennial Stream 12
55 If desktop
` . (discharge for waste rock storage)
NCSAM: High
Proposed Mitigation Rato: 2:1
1110 stream credits
PROPOSEDIMPACTS
Delineated Stream Impacts
Delineated Wetland Impacts
Delineated Pond Impacts
Desktop Stream Impacts
PIEDMONT LITHIUM PROJECT
IMPACTS 10 - 13
FIGURE 10
INDIVIDUAL PERMIT
LEGEND: MINE FEATURES
Concentrator Plant Site
=Pit Shell
Waste Rock Areas
Existing Roads
dProposed Access Roads
r'4( PIEDPAONT
Impact 11 - Intermittent Stream 12
917 If delineated
(discharge for waste rock storage) .
NCSAM: Medium
Proposed Mitigation Rato: 0.5:1
\ \�` 458.5 stream credits
Intermittent/ `
Perennial
Breakpoint ��` �� ` �� •\ \ `,y�
Impact 13 - Perennial Stream 12
55 If desktop
` . (discharge for waste rock storage)
NCSAM: High
Proposed Mitigation Rato: 2:1
1110 stream credits
PROPOSEDIMPACTS
Delineated Stream Impacts
Delineated Wetland Impacts
Delineated Pond Impacts
Desktop Stream Impacts
PIEDMONT LITHIUM PROJECT
IMPACTS 10 - 13
FIGURE 10
INDIVIDUAL PERMIT

DELINEATED FEATURES
r_1IP Project Boundary (971 ac.)
HDR Delineated Streams
=HDR Delineated Wetlands
HDR Delineated Ponds
100 -Year FEMA Floodplain
=30=0Culverts
0 1 inch = 150 feet 150
Impact 14 - Wetland 9
0.14 ac. delineated
(discharge for waste rock storage)
NCWAM: High
Proposed Mitigation Rato: 1:1
0.5 acre wetland credit
:1m 13
t/aha 10 ---
Impact 16 - Intermittent Stream 13
240 If delineated
(discharge for waste rock storage)
ff �
NCSAM: High
f/ Proposed Mitigation Rato: 1:1
240 stream credits
Impact 15 - Pond 4
0.08 ac. delineated
(discharge for waste rock storage)
no mitigation required
LEGEND: MINE FEATURES
Concentrator Plant Site
Pit Shell
WWaste Rock Areas
PROPOSEDIMPACTS
- — — Existing Roads
f j / Delineated Stream Impacts
Proposed Access Roads /" r /�
i
100 Ft Lot Line Setback / ( Delineated Wetland Impacts
200 Ft Structure Setback /� i Delineated Pond Impacts
300 Ft Residential Setback r / ''! / f ' _
/ l . J� Desktop Stream Impacts
PIEDMONT LITHIUM PROJECT
PIEDPAONT IMPACTS 14 - 16
FN
FIGURE 11
INDIVIDUAL PERMIT

Piedmont Lithium
(971 ac.)
Gaston County
Parcels
DATA SOURCE: http://www.bing.com/maps
0 Feet 2,000
1,11' •,.
Parcel#
Parcel
pro pertIndex
p y
Parcel#
Parcel
Propertylndex
on Map
Identification
Number (PIN)
on Map
Identification
Number (PIN)
Number (PID)
Number (PID)
1
157896
3610-98-9877
23
218217
3519-79-8340
2
157874
3610-58-7192
j
t
24
218218
3519-89-2192
3
157877
3610-79-3295
25
223136
3620-08-8201
4
159148
3610-36-1924
26
224400
3610-42-0672
5
159151
3610-34-4975
J
27
224401
3610-43-0447
6
159203
3620-06-6325
28
225770
3620-00-1978
7
159206
3620-05-6701
" " ' • ,
29
204183
3620-01-2810
8
159621
3610-52-4344
30
204184
3620-02-5063
9
159208
3620-05-5979
31
215160
3610-47-9983
10
159644
3610-90-6974
32
157886
3610-99-5098
11
160762
3610-90-5504
f.
33
157898
3620-08-2518
1 2
157897
3620-08-1619
34
159207
3620-04-9956
13
157899
3620-08-3475
14
157901
3620-084367
35
159211
3620-16-5952
15
157985
3610-38-7144
36
207977
3620-23-4979
16
159623
3610-51-8451
+(�
37
208720
3620-06-7617
17
160683
3610-60-7137
( 38
211500
3610-69-0040
18
160757
3519-99-5555p
39
214150
3610-43-9502
19
206528
3610-88-3383r
40
217859
3519-79-0545
in
20
208719
3620-06-8405
j 41
217863
3519-79-4409
21
211499
3610-584936
�a
�.. 42
221723
3610-61-6428
22
218014
3519-98-1755
� 43
223454
3610-90-1364
LITHIUM PROJECT
��PIEDMONT
�
PIED M NO T
L-THIUM
ADJOINING
PROPERTY
OWNERS
FIGURE 12
INDIVIDUAL PERMIT

ENG Form 4345 Supplemental Document
Piedmont Lithium
SAW -2018-01129
Appendix B:
Block 16. Property Ownership within the Project Boundary

Piedmont Lithium Project
Block 16 — Property Ownership
Individual Permit (SAW -2018-01129)
Parcel Ownership
Parcel #
Parcel
Property
Deed
Deed
Mailing
on
Identification
Index
Book
Page
Current Owners
Mailing Address
Mailing City
Zip Code
Property Address
Figure 2
Number (PID)
Number (PIN)
1
215731
3610851099
4377
795
SISK SUSAN AMY
C/O SUSAN SISK
CROUSE
28033
HEPHZIBAH CHURCH
REYNOLDS
RD
2
213460
3610960050
4124
928
GUIGNARD
20 GLYN LAUREL
BESSEMER CITY
28016
HEPHZIBAH CHURCH
LEWIS
LANE
RD
GUIGNARD
20 GLYNLAUREL
3
213461
3610955009
4970
531
LEWIS B JR &
BESSEMER CITY
28016
20 GLYNLAUREL LN
PERRIN LYNNE M
LANE
CRAIG ELIZ B
HEPHZIBAH CHURCH
4
159240
3620032400
4900
132
HEIRS 1/2 &
3204 KILLIAN RD
LINCOLNTON
28092
OTHRS
RD
5
215730
3610832948
4377
791
REYNOLDS PAUL
1266 HEPZIBAH
CROUSE
28033
HEPHZIBAH CHURCH
DAVID
CHURCH RD
RD
6
198928
3610834913
3266
190
REYNOLDS PAUL
1266 HEPZIBAH
CROUSE
28033
HEPHZIBAH CHURCH
DAVID
CHURCH RD
RD
REYNOLDS PAUL
1266 HEPZIBAH
1266 HEPHZIBAH
7
198472
3610836980
3223
317
DAVID
CHURCH RD
CROUSE
28033
CHURCH RD
8
205287
3610932526
3949
119
REYNOLDS PAUL
1266 HEPZIBAH
CROUSE
28033
HEPHZIBAH CHURCH
DAVID
CHURCH RD
RD
9
159640
3610826932
3139
852
FORTENBERY
306 W 4TH ST
CHERRYVILLE
28021
HASTINGS RD
BART ALAN
10
159641
3610920720
3139
852
FORTENBERY
306 W 4TH ST
CHERRYVILLE
28021
HASTINGS RD
BART A
11
159642
3610923504
3139
855
FORTENBERY
306 W 4TH AVE
CHERRYVILLE
28021
HASTINGS RD
BART A
FORTENBERY
2408 MARSHALL
12
159638
3610824264
2193
860
FRANK A &
P O BOX 894
BESSEMER CITY
28016
CAROLYN A.
ALLEN TRL
MABE JOHN W
2409 MARSHALL
2409 MARSHALL
13
159639
3610814717
4727
1378
SR. & MABE
BESSEMER CITY
28016
GLINDA J
ALLEN TRL
ALLEN TRL
FORTENBERY
2400 MARSHALL
14
159637
3610818724
2193
860
FRANK A &
P O BOX 894
BESSEMER CITY
28016
ALLEN TRL
CAROLYN A.
15
218752
3610903700
4488
1544
ALLEN JAMES
110 HELTON RD
CHERRYVILLE
28021
HEPHZIBAH CHURCH
DAVID
RD
16
223454
3610901364
4789
459
HIGH JEFFREY H
5010 FAIRVIEW
LINCOLNTON
28092
1631 HEPHZIBAH
& VICKIE S
CHURCH RD
CHURCH RD
MARY M DEAL
1641 HEPHZIBAH
1641 HEPHZIBAH
17
209087
3610900090
4902
1303
IRREVOCABLE
CHURCH RD
BESSEMER CITY
28016
CHURCH RD
TRUST
18
160753
3610804266
2481
851
ALLEN SHARON
110 HELTON RD
CHERRYVILLE
28021
1630 HEPHZIBAH
MAUNEY
CHURCH RD
Appendix B — Block 16 — Page 11

Piedmont Lithium Project
Block 16 — Property Ownership
Individual Permit
Parcel #
Parcel
Property
on
Identification
Index
Deed
Deed
Current Owners
Mailing Address
Mailing City
Mailing
Property Address
Book
Page
Zip Code
Figure 2
Number PID
Number PIN
19
218192
3610718456
4478
1616
CLAUDE C BEAM
806 WOODHAVEN
CHERRYVILLE
28021
HEPHZIBAH CHURCH
LLC
DR
RD
BALLARD
1531 R W
20
216007
3610625635
2781
871
KENNETH WEBB
MCLAMB DR
CROUSE
28033
1531 RW MCLAMB DR
& CYNTHIA ANN
21
218191
3610742004
4478
1616
CLAUDE C BEAM
806 WOODHAVEN
CHERRYVILLE
28021
HEPHZIBAH CHURCH
LLC
DR
RD
MCLAMB
976 SABBATH
22
216006
3610537691
4391
2371
RANSOM W &
HOME ROAD
SUPPLY
28462
1523 RW MCLAMB DR
WENDI S
23
159632
3610520605
1930
331
GREEN ROBERT
708 WHITESIDES
CROUSE
28033
708 WHITESIDES RD
STEVEN & LISA L
RD
GREEN ROBERT
24
159633
3610520962
4595
1260
BRANDON &
722 WHITESIDES
CROUSE
28033
722 WHITESIDES RD
EMILY WALLACE
RD
HYLEMAN
1506 R W
25
159634
3610531136
2118
966
MARVIN D &
MCLAMB DR
CROUSE
28033
732 WHITESIDES RD
CYNTHIA M
26
159628
3610531398
1272
826
MCLAMB VERNA
CROUSE
28033
1514 RW MCLAMB DR
MCLAMB DR
MILLER
27
159635
3610532577
4683
479
DOUGLAS SCOTT
1515 R W
CROUSE
28033
1515 RW MCLAMB DR
& MELISSA
MCLAMB DR
SHAUN
28
159631
3610543083
1272
828
RAY PAUL D &
402 WINDWOOD
BESSEMER CITY
28016
WHITESIDES RD
JUDY O
DR
NGUYEN THAN
4601 HALSTEAD
29
159177
3610545560
3437
745
VAN & NGA
DR
CHARLOTTE
28209
WHITESIDES RD
30
159176
3610543921
4841
1323
JONES GENIA
824 WHITESIDES
CROUSE
28033
824 WHITESIDES RD
JENKINS
RD
CAMP DANNY
31
159173
3610553181
2527
591
RICHARD &
832 WHITESIDESCAMELLIA
CROUSE
28033
832 WHITESIDES RD
RD
WEAVER
BENNIS CHARLES
900 WHITESIDESB
32
159171
3610548973
4540
1666
RD
CROUSE
28033
900 WHITESIDES RD
33
159168
3610650474
4611
1395
REIMER BRIAN A
904 WHITESIDES&
CROUSE
28033
904 WHITESIDES RD
TRACEY J
RD
34
159167
3610554561
3162
198
LARO MARK J
908 WHIRTDESIDES
CROUSE
28033
908 WHITESIDES RD
35
159166
3610555519
3621
586
MAXWELL JANIS
912 WHITESIDESW
CROUSE
28033
912 WHITESIDES RD
RD
36
159165
3610555687
4420
223
WHITE WILLIAM H
920 WHIRTDESIDES
CROUSE
28033
916 WHITESIDES RD
Appendix B — Block 26 — Page 12

Piedmont Lithium Project
Block 16 — Property Ownership
Individual Permit
Parcel #
Parcel
Property
on
Identification
Index
Deed
Deed
Current Owners
Mailing Address
Mailing City
Mailing
Property Address
Book
Page
Zip Code
Figure 2
Number PID
Number PIN
37
159164
3610556754
4420
223
WHITE WILLIAM H
920 WHIRTDESIDES
CROUSE
28033
920 WHITESIDES RD
38
159162
3610557896
4485
1789
WILBUR RENEE M
928 WHIRR SIDES
CROUSE
28033
928 WHITESIDES RD
39
159160
3610559928
4366
1858
CURTISSTERESA
PO BOX 285
CROUSE
28033
936 WHITESIDES RD
40
159159
3610660017
4980
1858
RUIZ FRANCISCO
1963 KEITH DR
GASTONIA
28054
942 WHITESIDES RD
VAZQUEZ
LOVELACE
JERRY LEE &
41
159155
3610660267
4577
1460
BARBARAJ
PO BOX 952
DALLAS
28034
944 WHITESIDES RD
TUNSTALL
VAN CULIN
964 WHITESIDESEMILIE
42
159156
3610661196
4913
95
J
RD
CROUSE
28033
964 WHITESIDES RD
LEWALLEN
1136 HEPHZIBAH
1136 HEPHZIBAH
43
159153
3610655959
2176
111
DANNY &
CROUSE
28033
BEVERLY
CH RD
CHURCH RD
44
198919
3610662421
4891
339
RENTED HOUSE
2030 SALEM
LINCOLNTON
28092
968 WHITESIDES RD
LLC
CHURCH RD
45
198920
3610664312
827
2057
PRUITT HAROLD
1116 HEPHZIBAH
CROUSE
28033
1116 HEPHZIBAH
JR
CHURCH RD
CHURCH RD
46
159154
3610663552
2176
115
MCSWAIN DIANE
1112 HEPHZIBAH
CROUSE
28033
1112 HEPHZIBAH
L
CHURCH RD
CHURCH RD
WOODBURY
47
159178
3610447462
2358
52
WESLEY
805 WHITESIDES
CROUSE
28033
805 WHITESIDES RD
HOWARD & LINDA
RD
DANIELS
48
159179
3610447644
4351
1156
STARKS PAUL
819 WHRIDSIDES
CROUSE
28033
815 WHITESIDES RD
49
159181
3610447747
4351
1156
STARKS PAUL
819 WHRIDSIDES
CROUSE
28033
819 WHITESIDES RD
WISNER
50
159182
3610458027
4958
2256
RICHARD
937 FLOYD
KINGS
28086
831 WHITESIDES RD
STREET EXT B
MOUNTAIN
WILLIAM
JONES STEPHEN
51
159184
3610454454
4463
2188
TIMOTHY
217 DELVIEW DR
CHERRYVILLE
28021
WHITESIDES RD
52
226475
3610466002
4922
249
PAYNE WILLIAM
165 DONALDSON
LINCOLNTON
28092
WHITESIDES RD
JOSEPH
DR
53
226474
3610468123
2687
426
PAYNE WILLIAM E
PO BOX 153
CROUSE
28033
901 WHITESIDES RD
54
159186
3610550611
3150
19
TANNER RICKIE D
905 WHITESIDES
CROUSE
28033
905 WHITESIDES RD
& BEVERLY W
ROAD
55
159187
3610550766
3150
15
TANNER RICKIE D
905 WHITESIDES
CROUSE
28033
911 WHITESIDES RD
& BEVERLY W
ROAD
56
159188
3610551930
3330
83
ELLER WANDA B
915 WHRDSIDES
CROUSE
28033
915 WHITESIDES RD
Appendix B — Block 26 — Page 13

Piedmont Lithium Project
Block 16 — Property Ownership
Individual Permit
Parcel #
Parcel
Property
on
Identification
Index
Deed
Deed
Current Owners
Mailing Address
Mailing City
Mailing
Property Address
Book
Page
Zip Code
Figure 2
Number PID
Number PIN
57
159157
3610562023
2816
440
DENTON ANNA
C/O ANNA GAIL
GASTONIA
28052
921 WHITESIDES RD
GAIL
YARBOROUGH
58
159150
3610461307
4279
808
STEWARBT DORIS
PO BOX 893
DALLAS
28034
WHITESIDES RD
59
159152
3610563958
3870
929
STEWART DORIS
PO BOX 893
DALLAS
28034
1028 HEPHZIBAH
B
CHURCH RD
60
157923
3610579909
4704
1662
STEPHENS
1015 HEPHZIBAH
CROUSE
28033
1015 HEPHZIBAH
SAMUEL J
CHURCH RD
CHURCH RD
61
214055
3610670678
4332
1161
KNOWLES
1021 HEPHZIBAH
CROUSE
28033
1021 HEPHZIBAH
DOUGLAS E
CHURCH RD
CHURCH RD
62
157925
3610673134
4164
516
WEBB RANDY A &
PO BOX 120
CROUSE
28033
1035 HEPHZIBAH
ANDREA L
CHURCH RD
KNOWLES
63
157922
3610676719
1442
314
PATRICIA R &
P O BOX 58
CROUSE
28033
1029 HEPHZIBAH
DALLAS E
CHURCH RD
JOHNSON JOHN
1107 HEPHZIBAH
64
159195
3610679156
1768
90
ASR &
P O BOX 382
CROUSE
28033
CHURCH RD
CHARLENEF
65
159194
3610667558
2498
763
SIMMONS ANDY
1117 HEPZIBAH
CROUSE
28033
1117 HEPHZIBAH
CLYDE
CHURCH RD
CHURCH RD
JARRETT BRIAN
1121 HEPHZIBAH
1121 HEPHZIBAH
66
159199
3610668429
2504
483
FRANK
CHURCH RD
CROUSE
28033
CHURCH RD
67
159192
3610763884
2515
586
SHEALY GARY E
1131 HEPHZIBAH
CROUSE
28033
1131 HEPHZIBAH
& DELIA B
CHURCH RD
CHURCH RD
68
226286
3610760164
4661
336
RHYNE ROBYN P
1139 HEPHZIBAH
CROUSE
28033
1139 HEPHZIBAH
CHURCH RD
CHURCH RD
69
226287
3610762374
4913
734
BLACK REGINA O
1141 HEPHZIBAH
CROUSE
28033
1141 HEPHZIBAH
CHURCH RD
CHURCH RD
ARROWOOD
70
159196
3610767263
2385
639
CHARLES
701 MAPLE ST
CHERRYVILLE
28021
1145 HEPHZIBAH
ARTHUR & JAYNE
CHURCH RD
ASHE
71
159191
3610754682
2328
192
JOHNSON JAMES
1165 HEPHZIBAH
CROUSE
28033
1165 HEPHZIBAH
S & WANDA W
CHURCH RD
CHURCH RD
72
159190
3610757641
1432
83
JOHNSON SCOTT
1165 HEPHZIBAH
CROUSE
28033
HEPHZIBAH CHURCH
CHURCH RD
RD
73
157917
3610984163
692
531
ADERHOLDT
6100 PINTAIL RD
OAK RIDGE
27310
ADERHOLDT RD
CLAUDE H HEIRS
74
223135
3620070197
4770
2430
BUCHANAN
1095 LAUREL LN
GASTONIA
28054
761 ADERHOLDT RD
SUSAN M
Appendix B — Block 26 — Page 14

ENG Form 4345 Supplemental Document
Piedmont Lithium
SAW -2018-01129
Appendix C:
Environmental Assessment

CE SAW -RG -C (File Number, SAW 2018-01129)
MEMORANDUM FOR RECORD
SUBJECT: Department of the Army Environmental Assessment and Statement of
Findings for the Above -Referenced Standard Individual Permit Application
This document constitutes the Environmental Assessment, 404(b)(1) Guidelines
Evaluation, as applicable, Public Interest Review, and Statement of Findings for the
subject application.
1.0 Introduction and Overview: Information about the proposal subject to one or
more of the Corps' regulatory authorities is provided in Section 1, detailed
evaluation of the activity is found in Sections 2 through 11 and findings are
documented in Section 12 of this memorandum. Further, summary information
about the activity including administrative history of actions taken during project
evaluation is attached (ORM2 Summary) and incorporated in this memorandum.
1.1 Applicant: Piedmont Lithium, Inc.
Attn: Mr. Patrick H. Brindle
5706 Dallas-Cherryville Highway
Bessemer City, North Carolina 28016
Phone: [phone]
Email: [e-mail]
1.2 Activity location: The proposed Piedmont Lithium mine is centered around 1501
Hephzibah Church Road in Bessemer City, North Carolina (Figure 1). From US -
321 N, take Exit 12B for NC -275 W/NC-279 W. Take a right onto NC -275 W, then
continue onto NC -279 W for 7.3 miles. Take a right onto Hephzibah Church Road
and continue to follow Hephzibah Church Road for 0.9 miles, then turn left to stay
on Hephzibah Church Road for another 1.5 miles. Address above is the locality
for the bridge crossing of Beaverdam Creek on Hephzibah Church Road, which
is the approximate center of the site. On-site waters include Little Beaverdam
Creek and Beaverdam Creek, which ultimately drain to the South Fork Catawba
River.
Page 1 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
LEGEND
Piedmont Uhtium
Mine Site (971 ac.)
USGS Quadrangles
SD 11 RCE: 115G5 73 minute quad.
LAncaintan Wast, NC 11993) ;ai_. r• _ r �^�.' ��,- �I _
0 Feet 4.000 Rl� 7 V
? !.
I inch = 4.000 feet
e r j 7 R4 t
y Whitesides Road ! Hephzibah
Church Road
. �". : - A J LLL•
� �r1'- mss• r..v: ,;�,'. � -/,.- '�°:r !.'
may•-- _ _ .._ , v r w_ -
NC -279 W
474
J.
Gaston Coun Y.
North Carolina �•
Figure 1. Project location
Page 2 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
1.3 Description of activity requiring permit: The proposed project would involve the
development of a hard rock lithium mine, which includes the construction of an
open pit, a waste rock area, a concentrator plant site, access roads, and
applicable National Pollutant Discharge and Elimination System (NPDES) best
management practices (BMPs). The project would result in impacts to 1,263
linear feet of perennial stream channel and 4,547.5 linear feet of intermittent
stream channel (5,810.5 linear feet total), 0.14 acre of wetlands, and 0.16 acre of
pond. Approximately 781 linear feet of perennial stream channel, 2,283 linear
feet of intermittent stream channel, 0.14 acre of wetlands, and 0.16 acre of ponds
will be impacted by waste rock areas. Approximately 249 linear feet of perennial
stream channel and 2,264.5 of intermittent stream channel will be impacted by pit
shell areas (Figure 2). Approximately 178 linear feet of perennial stream channel
will be impacted by an internal access road stream crossing and 55 linear feet of
perennial channel will be impacted by a stormwater BMP.
LEGEND DESKTOP JO FEATURES
IP Project Boundary •• Desktop Streams
971 ac -y
Desktop f+fNR WetEand
HDR Delineatedex I
Streams r I APPROXIMATE IMPACTS
HDR Del ineatedDelineated Stream
- Wetlands1"
""H"` Impacts
HDR Delineated Ponds l Delineated Vletland
.— Y: "' J'� Impacts
100 -Year FEMA rr _ _ _ Delineated Pond
Floodplain =- _ l '
Impacts
Culverts i k' Desktop Stream
j�
Impacts
0 Feet 1.800 y Y- ..... • .. . • ..
` ly' •/ Wd�d,Rvck
Z.
... }zJ BIAPs
LEGEND: MINE FEA70RE5 .
f
Concentrator Plant Site
0 Pit Shell
Waste Rack Areas
r' y
- — — Existing Roads
— Proposed Access Roads
Setback Buffers
700 Ft Lot Lute Setback 9=2
-- w.. r...r o r o
200 Ft Structure Setback
300 Ft Residential Setback
Figure 2. Proposed impacts to Waters of the US
The Piedmont Lithium mine would generate approximately 11.2 million cubic
yards of lithium bearing spodumene ore and 83.2 million cubic yards of waste
rock and tailings. The project proposes to extract lithium bearing spodumene
from the open pit, which is within host rock in a geologic formation called a
pegmatite dyke (Figure 3), and would then be separated into ore, waste, and
byproduct.
Page 3 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
C - --
Drill interception area
1% J
Drill interception area
CT 002 CJ
ro 756+n 4
Host rock (native rock) —
interspaced between
resource in question
(depicted as blue color)
Lithium containing pegmatite
dyke — starts at surface and
continues at an angle downward
(depicted as red color)
50 m
{
C
Figure 3. Depiction of pegmatite dyke formation within host rock
The separation of lithium bearing spodumene ore and marketable byproducts
from the host rock would be conducted at an on-site concentrator plant. The
project boundary has been developed to encompass open pits, waste rock areas,
appropriate NPDES BMPs, internal access roads, the concentrator unit, and all
other necessary support facilities. Large waste rock areas would be required to
accommodate as much as all pit waste as possible since offsite removal of waste
rock is not practicable due to the volume of material that would be generated.
The full 200 -acre open pit areas and 145 -acre waste rock areas are needed for
the applicant to meet the project purpose.
The construction sequence would first require the establishment of 300 foot
mining buffers around the entire perimeter of the project site as required by
Gaston County. The Federal Emergency Management Act (FEMA) 100 -year
floodplain would also be maintained along the entirety of Beaverdam and Little
Beaverdam Creeks. Next, the sediment and erosion control measures would be
installed around the perimeter of the site to control stormwater flows. The North
Carolina Mine Permit requires that all sediment and erosion control measures
such as ditches, ponds, rock dams, be designed for the 25 -year storm.
Underdrains would be placed in the waste rock areas to capture normal
groundwater flows in areas where existing streams will be filled. Additional
NPDES BMPs would be installed in appropriate areas to treat stormwater runoff
of the site in general as needed. Clearing of the pit and waste area sites would
Page 4 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
occur before the open pit and waste rock area are constructed and only cleared
as needed during the development of the pit and waste rock areas. Internal roads
would be constructed for pit and waste rock area access throughout the mine
site. The open pits will have design parameters similar to batter face angles of 80
degrees, a batter height of 40 feet (12.2 meters), a berm width of 20 feet (6.1
meters), an overall wall angle of 52 degrees, and a ramp width of 80 feet (24.8
meters) for transportation of material (Figure 4).
52'Over all Slope Anile _A ■
Inter Ramp Angie
I
180 m
Figure 4. Representation of the Piedmont pit wall design based on wall design
configuration assumptions
The waste rock area would contain as much pit waste as possible since offsite
removal of waste rock is not practicable due to the volume of material that would
be generated. The majority of remaining waste will be returned to the pit as
backfill once pit voids have been established. A percentage of waste will also be
separated as marketable byproducts, such as mica and feldspar. Filter cake
waste from the concentrator will also be placed in the waste rock area and co -
disposed with waste rock.
The Piedmont Lithium site was acquired by the applicant for the purpose of
managing all the aforementioned mining activities in close proximity to one
another. The proposed impacts would result from the construction of open pits,
waste rock areas, and one access road crossing.
Page 5 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
1.3.1 Proposed avoidance and minimization measures:
According to the applicant, the applicant's preferred alternative would avoid
impacts to the entirety of Beaverdam Creek (13,741 feet) and Little Beaverdam
Creek (2,848 feet). Impacts to Stream 2 have been minimized through utilization
of the footprint of an existing crossing for an access road, and impacts to the
majority of the stream have also been avoided (1,762 feet). Avoiding disturbance
in the FEMA floodplain will prevent impacts to the entirety of Wetlands 1, 3-8,
and 11-14 (7.62 acres). Wetlands 2, 10, and 15-16 (0.40 acre) will also be
avoided due to site design. Finally, adhering to the 300 -foot mining buffer
setback as required by Gaston County Zoning Ordinance, the preferred
alternative also avoids impacts to 10,603 feet of stream. Indirect impacts to
remaining streams will be avoided through the use of 100 -foot stream buffers and
stormwater management through NPDES BMPs. The applicant has considered
alternatives including off-site alternatives, a no -build option, an on-site no impact
option, an on-site additional impact option, and an on-site avoidance option.
Construction equipment would be kept in upland areas. Sediment and erosion
control measures would be used to prevent impacts to downstream waters. No
live concrete would be allowed to come in contact with surface waters. Water
quality monitoring would be conducted to monitor site discharge and runoff. A
Section 401 Individual Water Quality Permit is being submitted concurrently with
this IP application. A Stormwater Pollution Prevention Plan (SWPP) is also being
developed and will be submitted upon completion to the North Carolina
Department of Environmental Quality (NCDEQ) Division of Energy, Mineral, and
Land Resources (NCDEMLR) under the General Permit (No. NCG020000) for
Mining Activities.
1.3.2 Proposed compensatory mitigation:
There are no active private mitigation banks within HUC 03050102; therefore, the
applicant proposes compensatory mitigation for all permanent impacts through
the purchase of stream and wetland mitigation credits from the North Carolina
Division of Mitigation Services (DMS). The applicant provided supporting
documentation from DMS in a letter dated December 21, 2018 (attached),
indicating that they are willing to accept compensatory mitigation payment for
5,810.5 linear feet of stream impacts and 0.14 acre of riparian wetland within the
South Fork Catawba Sub -Basin within the Catawba River Basin (03050102).
1.4 Existing conditions and any applicable project history:
The Piedmont Lithium project is located in the piedmont physiographic region of
North Carolina and encompasses 971 acres of land in Gaston County. The
project area is approximately 67% forested land, consisting of mixed medium
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aged hardwoods (34%), pines (17%), and young successional growth (16%). The
remaining areas (33%) are open crop fields, maintained pasture, or maintained
residential areas. Surrounding land use is rural residential and agricultural, with a
patchy landscape of discontinuous forested areas. Beaverdam Creek flows in a
southeast to northeast to eastwardly direction, bisecting the project area. Little
Beaverdam Creek flows northeast to a confluence with Beaverdam Creek in the
approximate center of the project area. Jurisdictional aquatic resources within the
project area include 11 unnamed tributaries to Beaverdam Creek, two unnamed
tributaries to Little Beaverdam Creek, and 16 wetlands.
At the time of this submittal, a portion of the site has been field -verified by the
USACE on August 29, 2018 and on October 24, 2018; written verification has not
yet been received. The majority of the site has been delineated and areas where
the applicant's environmental consultant did not have access were estimated
using desktop information. Therefore, this application references "desktop
features" as depicted on Figure 5. These features have all been partially
delineated either up or downstream and are good approximations of remaining
jurisdictional features. These features are included in all impact calculations for
this submission, as applicable. The applicant's environmental consultant will
submit a second and final JD Verification Request for the remaining areas
pending access.
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Figure 5. Jurisdictional features
Elevations on the site range from a low of approximately 738 feet above Mean
Sea Level (MSL) along Beaverdam Creek, to a high of approximately 912 feet
MSL in the southeastern corner of the site. The Soil Survey of Gaston County,
North Carolina (USDA-NRCS) depicts the project area as underlain by Cecil
sandy clay loam and Lloyd sandy clay loam in upland areas of the site, Congaree
loam along Beaverdam and Little Beaverdam Creeks, Chewacla loam in
floodplain pockets, Pacolet sandy loam on steep slopes, and one occurrence of
Udorthents in a northeast portion of the site.
In July 2018, the applicant's environmental consultant installed five groundwater
monitoring wells, four groundwater observation wells, and one groundwater
pumping well to facilitate periodic groundwater level, water quality monitoring,
and aquifer testing throughout the site. Depths to groundwater has been
measured monthly starting July 2018 and will be measured through July 2019.
To date, depths to water range from 8 to 48 feet, with the shallowest depths to
water in the northeast of the site near Beaverdam Creek and the deepest depths
to water in the northwest, southwest, and southeast reaches of the site.
Generally the direction of groundwater flow is from southwest to northeast across
the site. Bedrock was observed in the bottom of Beaverdam Creek during well
installation; therefore, the hydrologic regime of on-site surface waters are
influenced by both stormwater runoff from on-site forest land, agricultural fields,
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pasture fields, and rural residences and by groundwater baseflow. Overbank
flooding by Beaverdam and Little Beaverdam Creeks also influence their abutting
and adjacent wetlands. The site has been observed by the environmental
consultant over a period of a year and the on-site features have been observed
throughout all seasons.
Piedmont Lithium will acquire the necessary NCDEQ DEMLR General Permit for
Mining Activities parallel to this IP review and will not commence work until
approval. Approximately 217 acres (22%) of the site will be located in the 300
foot setback mine buffer and 109.5 acres (11 %) of the site is within the FEMA
floodplain; neither of these areas will experience disturbance. Of the disturbed
area, open pit would occupy 200 acres (21 %) of the site, waste rock area would
occupy 145 acres (15%), and the concentrator site (6%) and mine operation
structures would occupy 60 acres. Internal access roads consisting of existing
roads and new roads will occupy approximately 53 acres (5%) of the site.
The riparian areas along Beaverdam Creek, Little Beaverdam Creek, and their
tributaries are dominated by various oaks (Quercus spp.), hickories (Carya spp.),
loblolly pine (Pinus taeda), red maple (Acer rubrum), American beech (Fagus
grandifolia), red cedar (Juniperus virginiana), tulip poplar (Liriodendron tulipifera),
hornbeam (Carpinus caroliniana), sweetgum (Liquidambar styraciflua), river birch
(Betula nigra), The understory vegetation consists of laurel (Rhododenron spp.),
bamboo (Arundinaria spp.), spicebush (Lindera benzoin), strawberry bush
(Euonymus americanus), Christmas fern (Polystichum acrostichoides), Chinese
privet (Ligustrum sinense), autumn olive (Eleaganus umbellate), Japanese stilt
grass (Microstegium vimineum).
There is a FEMA 100 -year floodplain associated with both Beaverdam and Little
Beaverdam Creeks within the project area.
1.5 Permit Authority: Section 404 of the Clean Water Act (33 USC 1344).
2.0 Scope of review for National Environmental Policy Act (i.e. scope of
analysis), Section 7 of the Endangered Species Act (i.e. action area), and
Section 106 of the National Historic Preservation Act (i.e. permit area)
2.1 Determination of scope of analysis for National Environmental Policy Act (NEPA):
The scope of analysis includes the specific activity requiring a Department of the
Army permit. Other portions of the entire project: Select appropriate choice
included because the Corps Select appropriate choice have sufficient control and
responsibility to warrant federal review.
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Final description of scope of analysis: Describe here
2.2 Determination of the "action area" for Section 7 of the Endangered Species Act
(ESA):
Description of ESA scope with rationale here.
2.3 Determination of permit area for Section 106 of the National Historic Preservation
Act (NHPA):
The permit area includes Select first option if the permit area includes uplands in
addition to waters, and the second option if the permit area includes only waters
those areas comprising waters of the United States that will be directly affected
by the proposed work or structures Select first option if the permit area includes
uplands, and the second option if the permit area includes only waters
Final description of the permit area: Final description of permit area with rationale
here. Include in the rationale the specific upland areas that are determined to be
included or excluded from the permit area.
3.0 Purpose and Need
3.1 Purpose and need for the project as provided by the applicant and
reviewed by the Corps:
The global transition away from hydrocarbons toward energy alternatives has
increased demand for many scarce metals.' Among these is lithium (Li), a key
component in lithium -ion batteries for electronic devices, particularly electric and
hybrid vehicles, laptop computers, and cell phones. Forecasted growth in both
global lithium demand and supply varies among analysts and industry experts;
however, Roskill forecasts overall growth in lithium consumption to average
15.3% per year to 2027 (Roskill's Base -Case Scenario).2 Consumption of lithium
will continue to be driven by the rechargeable battery sector, which is forecast to
register 22.4% per year growth through to 2027.3 The global leaders in lithium
supply are Australia, Chile, and Argentina at 37%, 36%, and 17%, respectively,
while the U.S. supplies only 2% to the global market. And although there are
untapped lithium reserves in the U.S., the U.S. imports two-thirds of the lithium
needed to meet domestic demand. Expanding the lithium supply in the U.S.
Bradley, D., Munk, L., Jochens, H., Hynek, S., and Labay, K. 2013. A preliminary deposit model for lithium brines. U.S. Geological
Society Open -File Report 2013-1006. Reston, Virginia. https://pubs.usgs.gov/of/2013/1006/OF13-1006.pdf
2 Roskill Market Reports and Consultancy. 2018. Lithium: Global Industry, Markets & Outlook. https://roskill.com/market-
report/lithium/
s Roskill Market Reports and Consultancy. 2018. Lithium -ion Batteries: Market Development & Raw Materials.
https://roskill.com/market-report/lithium-ion-batteries/
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would ensure a domestic source and insulate domestic prices in a global market.
Thus, a domestic lithium source is needed to supplement demands in the U.S.
The main sources of lithium used in cathodes of lithium -ion batteries are
spodumene (a mineral) and sub -saline brines. Lithium -ion batteries require
lithium hydroxide (LiOH), which is expected to be the fastest growing product of
the lithium market. Global Lithium, LLC projects sustained relatively firm lithium
hydroxide pricing over the next five to seven years based on the consensus
opinion of lithium producers, purchasers and industry experts that lithium
demand to produce lithium hydroxide will grow a minimum of 300% between
2017 and 2025.
To produce lithium hydroxide, lithium must be extracted from either hard rock
sources such as spodumene or extracted through an evaporative process from
sub -saline brines. Extracting spodumene-containing lithium is accomplished by
utilizing traditional hard rock mining techniques of open pit drilling and separation
of lithium from host rock using a series of physical and chemical processes to
produce lithium concentrate. This process can be completed as fast as the
material can be moved from an open pit to a concentrator plant. Saline -based
projects rely upon pumping saline -containing lithium from underground reserves
to the earth's surface, which is then pumped through a series of evaporation
ponds, each having a higher concentration of lithium than the last. This process
can take months to a year or more, depending on weather, to yield adequate
lithium concentrate. Both spodumene- and saline -based projects require
conversion of lithium concentrate through purification and crystallization into
battery -grade quality lithium hydroxide of the type which can be used in cathodes
for the manufacturing of electric car batteries. According to Roskill Industry Cost
Curves, it is more cost efficient to produce battery -grade quality lithium hydroxide
from lithium concentrates extracted from spodumene-based projects than with
saline -based projects.' Lithium conversion with spodumene-based projects cost
approximately $2,500 to $3,500 per metric tonne (1.1023 US tons) of lithium
hydroxide produced while lithium conversion with saline -based projects cost
approximately $4,500 to $6,500 per metric tonne of lithium hydroxide produced.
Moreover, if lithium concentrates are shipped to China (a common practice in the
industry) for this conversion/purification process (vs. on-site or nearby conversion
locations), costs increase to approximately $7,500 to $9,500 per metric tonne of
lithium hydroxide produced.
Since spodumene-based lithium extraction projects are more cost efficient than
saline -based lithium extraction projects to produce battery -grade lithium
hydroxide and since there is a need for a domestic supply of lithium, spodumene
reserves containing lithium located in the U.S. were considered for development.
Spodumene based lithium reserves located outside the US were not considered
reasonable or practicable alternative to provide domestic sources of lithium.
While there are a few lithium reserves contained in mineralized spodumene in
4 Roskill Market Reports and Consultancy. 2018. Lithium Industry Cost Curves. https://roskill.com/roskill-product/lithium-industry-
cost-curves/
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the US, the largest lithium reserves are located within the Carolina Tin-
Spodumene Belt (TSB), in North Carolina, according to the US Geological
Survey (USGS).5 The Carolina TSB was the world's largest producer of lithium
after World War II, from the 1950's through the 1980's and infrastructure such as
rail and highway are still existing which can be utilized to access and support
mining operations today.6 An attractive draw for potential investors and local
labor forces, the Carolina TSB is also close (< 30 minutes) to multiple
metropolitan areas, such as Gastonia and Charlotte. Therefore, the purpose of
the project is to develop a hard rock lithium mine in the Carolina TSB, to extract
and refine mineralized spodumene to a high quality lithium bearing spodumene
concentrate; which, upon conversion to a battery grade lithium hydroxide, will
provide a domestic source of lithium to meet growing demands in the U.S.
3.2 Basic project purpose, as determined by the Corps: Select N/A or basic purpose
here.
3.3 Water dependency determination: Select correct choice. If choice is either, not
water dependent or water dependent please explain in further detail.
3.4 Overall project purpose, as determined by the Corps: Describe here.
4.0 Coordination
4.1 The results of coordinating the proposal on Public Notice (PN) are identified
below, including a summary of issues raised, any applicant response and the
Corps' evaluation of concerns.
Were comments received in response to the PN? Select Yes or No
Were comments forwarded to the applicant for response? Select Yes, No or
N/A
Was a public meeting and/or hearing requested and, if so, was one conducted?
Select appropriate response Provide additional description/rationale here as
needed.
Comments received in response to public notice:
Comment 1:
Agency/Person providing comment Summarize comment here.
e Norton, J. and McKenney Schlegel, D. 1955. Lithium resources of North America. U.S. Department of the Interior Geological
Survey Bulletin 1027-G. https://pubs.usgs.gov/bul/1027g/report.pdf
6 ibid
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Applicant's Response: Select N/A or provide applicant's response as appropriate.
Corps Evaluation: Summarize Corps evaluation here.
Comment 2: Agency/Person providing comment Summarize comment here.
Applicant's Response: Select N/A or provide applicant's response as appropriate.
Corps Evaluation: Summarize Corps evaluation here
Additional discussion of submitted comments, applicant response and/or Corps'
evaluation: Select N/A or provide discussion as appropriate.
4.2 Were additional issues raised by the Corps including any as a result of
coordination with other Corps offices? Select Yes or N, -
If yes, provide discussion including coordination of concerns with the applicant,
applicant's response and Corps' evaluation of the response: Select N/A or
provide discussion as appropriate.
4.3 Were comments raised that do not require further discussion because they
address activities and/or effects outside of the Corps' purview? Select Yes or No
If yes, provide discussion: Select N/A or provide discussion as appropriate.
5.0 Alternatives Analysis (33 CFR Part 325 Appendix B(7), 40 CFR 230.5(c) and
40 CFR 1502.14). An evaluation of alternatives is required under NEPA for all
jurisdictional activities. An evaluation of alternatives is required under the
Section 404(b) (1) Guidelines for projects that include the discharge of dredged
or fill material. NEPA requires discussion of a reasonable range of alternatives,
including the no action alternative, and the effects of those alternatives; under the
Guidelines, practicability of alternatives is taken into consideration and no
alternative may be permitted if there is a less environmentally damaging
practicable alternative.
5.1 Site selection/screening criteria: In order to be practicable, an alternative must be
available, achieve the overall project purpose (as defined by the Corps), and be
feasible when considering cost, logistics and existing technology.
Criteria for evaluating alternatives as evaluated and determined by the Corps:
A. Hard Rock Mine (technology and cost): The alternative would only be
considered practicable and achieve the overall project purpose if it relied on
open pit, hard rock mining techniques. This is a surface mining method of
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extracting a resource from an open pit in the earth's surface, utilizing drilling
and construction machinery. Because industry data concludes it is more cost
efficient to mine lithium from spodumene-based projects than with saline -
based projects,' spodumene containing lithium is the resource target;
therefore, open pit, hard rock mining techniques will be utilized. An open pit,
hard rock mine is the best mining technique for spodumene extraction
because the mineral is contained within host rock present at, or near, the
earth's surface. The extraction process begins at the pit's surface and goes
downward, narrowing as the pit becomes deeper — the pit will look like an
upside-down wedding cake, with the pit width largest at the surface and pit
width smallest at the deepest part of the pit. This mining process happens as
fast as the material can be extracted and concentrated, on a scale of a few
weeks to months. Also, the surface area footprint for an open pit lithium mine
is much smaller at a few hundred acres than that of what is needed for the
brine extraction process.
Brine mining is an alternative to open pit, hard rock lithium mining, and is the
extraction of lithium that is naturally dissolved in a brine/saline solution. The
saline solutions may be contained in salt lakes or salars (salt -encrusted
depressions) on the earth's surface or underground in saline groundwater that
are enriched in dissolved lithium; however, in the U.S. those brine -containing
lithium reserves are underground reserves. Saline brines -containing lithium
are pumped from underground reserves to the earth's surface. Once at the
surface, the solution is pumped through a series of evaporation ponds, each
having a higher concentration of lithium than the last. The evaporative
process can take months to a year or more to obtain adequate lithium
concentrates. This mining method is limited to arid climates, is highly
dependent on weather, depletes groundwater aquifers, and requires
thousands of acres of surface area for the evaporation ponds. Overall, the
open pit, hard rock mining method for spodumene-based projects is more
cost efficient, is not dependent on weather or climate, can yield adequate
spodumene-containing lithium concentrate over a smaller footprint and in a
faster timeframe than mining lithium from saline -based projects. Therefore; to
achieve the project purpose of extracting spodumene-containing lithium, the
alternative would only be considered practicable if it relied upon open pit, hard
rock mining techniques.
B. Location within Carolina Tin-Spodumene Belt with Previous Exploration
History (logistics): The alternative would only be considered practicable
and achieve the overall project purpose if it is located within the Carolina Tin-
Spodumene Belt (TSB) and if there was a history of previous exploration with
Roskill Market Reports and Consultancy. 2018. Lithium Industry Cost Curves. https://roskill.com/roskill-product/lithium-industry-
cost-curves/
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CE SAW -RG -C (File Number, SAW 2018-01129)
positive identification of mineralized spodumene within the alternative
identified. The USGS Mineral Resource Potential for Lithium in North and
South Carolina estimates the TSB to be approximately 24.5 miles long, 1.8
miles in maximum width, extending southwestward from Lincolnton, North
Carolina to Gaffney, South Carolina .8 Currently, the TSB contains the largest
North American lithium reserves (contained in spodumene),9 estimated to
contain 6.5 million tons (5.9 million metric tonnes) of lithium.10 Compared to
the total estimated domestic supply of 11.2 million tons (10.2 million metric
tonnes), the TSB contains over half of the U.S. lithium supply.11 Also,
according to the U.S. Department of the Interior, spodumene-based lithium
mines in the TSB were historically the world's leading producer of lithium after
World War II, from the 1950s to the 1980s.12 The historic knowledge (old
mines) of mineralized spodumene locations within the TSB helped to
immediately narrow potential mine sites and save capital exploration costs,
according to the applicant. Given the documentation and proven existence of
the resource in the TSB, the project should be located on previously explored
properties within the TSB.
C. Core Parcel Size & Mineable Area Needed for Reasonable Mine Design
(logistics): The alternative would only be considered practicable and achieve
the project purpose if an initial core parcel of at least 120 acres is identified to
warrant the assembly of other adjacent properties into a larger project area of
approximately 900 to 1,100 acres. This total mine area is of sufficient size to
extract the minimum amount of mineralized spodumene to produce sufficient
lithium hydroxide needed to balance capital investment costs and to operate a
mine designed to Mine Safety and Health Administration (MSHA) standards,
while also observing local and state requirements, such as a 300 -foot wide
mine buffer setbacks required by Gaston County Zoning Ordinance.
According to the applicant, a minimum of 14.3 million tons or more (roughly
17 million cubic yards) of mineralized spodumene is required to produce
approximately 265,500 tons of battery grade lithium hydroxide, which is the
minimum volume needed to be attractive to capital investors. Ideally, the total
mine area would handle an open pit design that captures adequate
mineralized spodumene needed to offset capital investment cost, in areas
where the resource presence was confirmed, waste rock areas that handle at
as much as all pit waste as possible, a site for the concentrator plant, internal
8 Horton, J.W., Jr. 1987. Mineral resource potential for lithium, kyanite-sillimanite, and barite in the Charlotte 1 ° x 20 quadrangle,
North Carolina and South Carolina. United States Geological Survey, Arlington, VA.
s Norton, J. and McKenney Schlegel, D. 1955. Lithium resources of North America. U.S. Department of the Interior Geological
Survey Bulletin 1027-G. https://pubs.usgs.gov/bul/1027g/report.pdf
10 Bradley, D.C., Stillings, L.L., Jaskula, B.W., Munk, LeeAnn, and McCauley, A.D., 2017, Lithium, chap. K of Schulz, K.J., DeYoung,
J.H., Jr., Seal, R.R., II, and Bradley, D.C., eds., Critical mineral resources of the United States—Economic and environmental
geology and prospects for future supply: U.S. Geological Survey Professional Paper 1802, p. K1–K21,
(https://doi.org/10.3133/ppl8O2
ibid
12 Norton, J. and McKenney Schlegel, D. 1955. Lithium resources of North America. U.S. Department of the Interior Geological
Survey Bulletin 1027-G. https://pubs.usgs.gov/bul/l027g/report.pdf
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access roads, machinery laydown areas, sediment and erosion control BMPs,
and 300 -foot mine buffer setbacks. Table 1 (below), summarizes an
approximate minimum total area needed to accommodate all mine features.
Table 1. Approximate area needed to accommodate reasonable mine design.
Mine Feature
Minimum Area Needed
Pit Shell
± 200-300 ac.
Waste Rock Area
± 140-200 ac.
Concentrator Plant Site
± 60-70 ac.
Mine Buffers, Erosion Control, Access Roads
± 250-450 ac.
Basic Mine Features
± 400-570 ac.
Property Dependent Mine Design Features
± 200-450 ac.
Total Mine Area Needed
± 650-1,020 ac.
Comparatively, the historic Hallman Beam lithium mine (Off -Site Alternative 2)
and the historic Foote Lithium Mine (Off -Site Alternative 3) were both roughly
700 acres; however, during these mines' operation between the 1930s to
1990s, environmental requirements, such as buffers and sediment and
erosion control practices, most likely did not require as much land to
accommodate. Currently, there are no operational lithium mines in the area
for size comparison. Given that there are few large parcels (>_120 acres)
remaining in the TSB, all those parcels identified of this size or greater are
examined as off-site alternatives in Section 5.2.2.
D. Property Availability (logistics): The alternative would only be considered
practicable and achieve the project purpose if it the current land owner(s)
would be willing to sell or lease the core parcel alternatives identified.
E. Minimization of Environmental Impacts: The alternative would only be
considered practicable and achieve the overall project purpose if only a
minimum of environmental impacts are required. A desktop analysis of
environmental impacts will be assessed for each alternative utilizing the
publically available National Wetland Inventory (NWI) and National
Hydrography Dataset (NHD) datasets. Additionally, those NWI and NHD
features depicted within 100 -Year Federal Emergency Management Act
(FEMA) Floodplains are assumed to be avoided due to the additional
permitting associated with impacting floodplains. Therefore, this allows for
equal comparison across off-site alternatives of NWI and NHD features
outside FEMA floodplains.
5.2 Description of alternatives
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CE SAW -RG -C (File Number, SAW 2018-01129)
5.2.1 No action alternative:
Under the no action alternative, a hard rock lithium mine would not be
constructed in the TSB and battery grade lithium hydroxide, made from lithium
bearing spodumene concentrates produced from hard rock mining, would not be
brought to the U.S. market from a domestic source to supplement current needs.
The majority of lithium chemicals would still be imported from outside the U.S. to
meet the domestic demand. If the majority of lithium chemicals were imported to
the U.S. the cost of these chemicals would ultimately drive up prices of lithium -
ion batteries and products that use them such as electric vehicles. Due to this
factor, the no action alternative is not considered a practicable alternative.
This alternative would not satisfy the following screening criteria:
B. Location within Carolina Tin-Spodumene Belt with Previous Exploration
History (logistics): The alternative would not occur and would therefore not
occur within the TSB.
C. Core Parcel Size & Mineable Area Needed for Reasonable Mine Design
(logistics): The alternative would not occur and would therefore not provide
minimum size needed to produce lithium hydroxide as a domestic supply.
D. Property Availability (logistics): The alternative would not occur; therefore,
property availability would not be considered practicable and achieve the
project purpose.
E. Minimization of Environmental Impacts: It can be assumed that there are
environmental impacts associated with mines located outside the U.S.,
especially in areas where environmental regulations may be less stringent,
although the amount of impacts is unknown.
This alternative would satisfy the following screening criteria:
A. Hard Rock Mine (technology and cost): There are hard rock lithium mines
outside the U.S.
5.2.2 Off-site alternatives
Off-site alternatives include alternatives located outside the TSB, which were
eliminated from consideration as it was not considered practicable or achievable
within the scope of the project's purpose and need. In addition to the Preferred
Alternative, three other off-site alternatives are discussed. Figure 6 (below)
illustrates the off-site alternatives discussed in the alternatives analysis relative to
their location to the Preferred Alternative in the TSB.
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CE SAW -RG -C (File Number, SAW 2018-01129)
Rnrlra J U]Ilk n
LEGEND- - - --_ -- --- - --- Catawba jl
`County- -- CAT weA
-Preferred LIHCOtk
Alternative 1+
Off -Site
Alternatives H
Carolina TSB od Lincoln
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USGS Mineral
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I
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Figure 6. Alternative analysis site locations.
Page 18 of 85
Gaston County,
North Carolina

CE SAW -RG -C (File Number, SAW 2018-01129)
Off-site alternative 1:
Constructing a hard rock lithium mine outside the Carolina Tin-Spodumene
Belt: According to the applicant, the demand for lithium hydroxide will grow at
least 300% between 2017 and 2025 due to its use in lithium -ion batteries
principally to power electric vehicles. Currently, the U.S. imports approximately
two-thirds of lithium chemicals needed to meet domestic demand. As demand
grows, the U.S. would need to import more lithium hydroxide to meet demand for
lithium chemicals. A number of active lithium mines are operational on the
international stage, some are large in scale, and have been operational for a
number of years. Entering into the international market to provide lithium
chemicals to the U.S. would be difficult to accomplish in a competitive manner.
In order for a lithium mining operation to be feasible, the extracted resource must
be present and of a suitable quality so that it can be mined, processed, and used
for downstream lithium chemical production, specifically lithium hydroxide. As
discussed in the purpose and need, and reported by USGS, the Carolina TSB
contains the largest North American lithium reserves within mineralized
spodumene;13 therefore, based on current known reserves, it would not be
economically feasible to locate a hard rock lithium mine in the United States
outside the Carolina TSB. It is unlikely that sufficient mineralized spodumene
containing lithium for a domestic supply would be available outside the TSB.
Alternatives located outside the TSB were eliminated from consideration
because it was determined that constructing a hard rock lithium mine
outside the TSB would be unreasonable considering the overall project
purpose and the presence and quantity of the resource within the Carolina
TSB.
13 Norton, J. and McKenney Schlegel, D. 1955. Lithium resources of North America. U.S. Department of the Interior Geological
Survey Bulletin 1027-G. https://pubs.usgs.gov/bul/1027g/report.pdf
Page 19 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
Off-site alternative 2:
Use of 142 -Acre Parcel within Carolina TSB: A 142 -acre core parcel within the
Carolina TSB was identified and considered as an alternative site. It is of
sufficient size to warrant the assembly of adjacent parcels for a larger total area
of approximately 1,010 acres (Figure 7Figure 7).
LEGEND
Off -Site Ailern 2 Na I•�na i n rd: u ar., u: i r
Care Parcel (1442 ac. j me
��
ON -Site Alternative 2
(1.010 ac-)
G•.t:i-cr
Martin Marietta
�.
Ownership (675 ac-)
F lowi
Gaston County Parcels
Nalhanal+nrin ld I.W. lacy
Carolina T56
alone
11SGS Llthlum Anomaly %
In Stream Sediments
Amount
ASID
game as ann.e
USGS Mineral Resource
0 Feat 2.000 �t
ren = z.00n rase �L I � -
i
1 [
LEGEND
FEIVIA 100 -Year Floodplain
un
Ir DESKTOP FEATURES WITHIN OFFSITE ALT 2
National Hydrography ❑ataset
CW -11"b AN G� —
�w+r National Wetland Inventory
AN s county
DESKTOP FEATURES OUTSIDE OFF SITE ALT 2
Alt 4 All 3 .' .-.
Nalanal Welland Inventory
°r National Hydrography Dataset
r cour,a -
Figure 7. Off -Site Alternative 2
There are 69 parcels associated with this alternative, of which 25 parcels (67% of
the land area) of this alternative are controlled by one owner, including the core
parcel of 142 acres. It is the site of the old Hallman -Beam lithium mine, formerly
owned and operated by FMC Lithium. The Hallman -Beam mine was one of the
largest producers of lithium between the 1950s and the 1990s and has historic
production records substantiating the presence of mineralized spodumeme within
the mine site. The mine closed in 1998 and was purchased by Martin Marietta,
which is currently processing construction aggregates materials on the site. This
alternative has been developed as a lithium hard rock mine in the past, and
continues to operate as a hard rock mine for construction aggregates. For equal
comparison across alternatives, a desktop analysis of NHD and NWI features for
the alternative was performed. These features would be subject to potential
impacts for this alternative. Table 2 summarizes the potential environmental
impacts to NHD and NWI features for this alternative.
Page 20 of 85
G•.t:i-cr
�.
F lowi
Nalhanal+nrin ld I.W. lacy
alone
Amount
ASID
game as ann.e
USGS Mineral Resource
0 Feat 2.000 �t
ren = z.00n rase �L I � -
i
1 [
LEGEND
FEIVIA 100 -Year Floodplain
un
Ir DESKTOP FEATURES WITHIN OFFSITE ALT 2
National Hydrography ❑ataset
CW -11"b AN G� —
�w+r National Wetland Inventory
AN s county
DESKTOP FEATURES OUTSIDE OFF SITE ALT 2
Alt 4 All 3 .' .-.
Nalanal Welland Inventory
°r National Hydrography Dataset
r cour,a -
Figure 7. Off -Site Alternative 2
There are 69 parcels associated with this alternative, of which 25 parcels (67% of
the land area) of this alternative are controlled by one owner, including the core
parcel of 142 acres. It is the site of the old Hallman -Beam lithium mine, formerly
owned and operated by FMC Lithium. The Hallman -Beam mine was one of the
largest producers of lithium between the 1950s and the 1990s and has historic
production records substantiating the presence of mineralized spodumeme within
the mine site. The mine closed in 1998 and was purchased by Martin Marietta,
which is currently processing construction aggregates materials on the site. This
alternative has been developed as a lithium hard rock mine in the past, and
continues to operate as a hard rock mine for construction aggregates. For equal
comparison across alternatives, a desktop analysis of NHD and NWI features for
the alternative was performed. These features would be subject to potential
impacts for this alternative. Table 2 summarizes the potential environmental
impacts to NHD and NWI features for this alternative.
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CE SAW -RG -C (File Number, SAW 2018-01129)
Table 2. Off -Site Alternative 2 NHD and NWI features.
Dataset
Amount
National Hydrography Dataset
Flowline
20,733 If
National Wetland Inventory
Riverine
same as above
Wetlands
n/a
Ponds
78 ac.
However, this core parcel is not for sale, Martin Marietta intends to continue
processing construction aggregates on the site, and it would require the
acquisition of 44 more parcels under multiple ownerships (33% of the land area).
Moreover, if the land were available for purchase, the applicant believes the land
would be unsuitable for lithium mining as the former lithium mine depleted the
resource beyond sufficient volume needed to offset capital investment costs. The
closure of Hallman -Beam in 1998 corroborates the lack of sufficient resource.
The unavailability of the land for purchase in combination with a lack of sufficient
resource to cover capital investments costs means that this alternative is not
practicable.
See Table 5 at the end of this section for the alternatives analysis siting criteria
summary.
This alternative would not satisfy the following screening criteria:
D. Property Availability (logistics): The alternative is not available for
purchase.
E. Minimization of Environmental Impacts: This alternative has the 2nd
highest amount of NHD and NWI features that are potentially subject to
impacts; therefore, it is not the least damaging alternative.
This alternative would satisfy the following screening criteria:
A. Hard Rock Mine (technology and cost): The alternative is currently a
construction aggregates processing facility and mining infrastructure is
already available, though this infrastructure is not well suited to processing
spodumene and a substantial retrofit would be necessary, thus increasing
costs.
B. Location within Carolina TSB with Previous Exploration History: The
alternative is both within the TSB and at least 25% of the area was the former
Hallman -Beam lithium mine, substantiating the previous exploration history of
mineralized spodumene.
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CE SAW -RG -C (File Number, SAW 2018-01129)
C. Core Parcel Size & Mineable Area Needed for Reasonable Mine Design
(logistics): The alternative core parcel size is of sufficient size and is also
surrounded by other land parcels already consolidated under one ownership.
This alternative contains 1,010 acres, which is large enough to operate a
lithium mine under the project's purpose and need.
Off-site alternative 3:
Use of 129 Acres within Carolina TSB: A 538 -acre parcel, of which 129 acres
is within the Carolina TSB, was considered as a core parcel. It is of sufficient
size to warrant the assembly of adjacent parcels for a total larger area of
approximately 977 acres (Figure 8).
LEGEND
Off- Site Ahemelive 3
Core Parcel (538 ac.)
Offsite Alternative 3
(977 ac .)
Rockwood Lithium
Ownership (Albemade)i
(710 ac.)
Cleveland County
Parcels
Carolina TSB
USG5 Lithium Anomaly
in Stream Sediments
USGS Mineral Resource
0 Feet 1,800 t -
,..
C rsnya
f
FWttrod Alt .
geveLad Ak I •}
cas�n
AN Las
c Torx
Figure 8. Off-site Alternative 3
f
e-1
LA
AL
Dario[ An nt
Natrona+ H y.ropraphy DOWS ai
Rm Wne x72900
N a Lona I Vk1=1 lilwnkory
Rive nnesame as a6vre
Wellen.. 2, ac.
Panels gg ac
eeca,aea nem r wvrerwe.. an Few raeaplrn
LEGEND
FEMA iDO- Yea r Floodplain
DESKTOP rEAWRES MI N OFF SlTIE ALT 9
National Hydrography Dataset
0 NatwnaIWetrandInventory
11 --OP FEA--S OUTSIDE OFF-51TEALT ]
NoIfonaI Hydrography Dataset
National VWftno Inventory
There are 35 parcels associated with this alternative, of which 8 parcels (73% of
the land area) is controlled by one owner, including the large core parcel.
Unfortunately, the core parcel is divided by a major highway (1-85), thus
separating the alternative's total area. This site, or parts of this site, were once
part of the Foote Lithium Mine, owned and operated from 1938 to its closure in
the 1980s by the Foote Mineral Company. The historic Foote Lithium Mine was
one of the largest producers of lithium between the 1930s and the 1980s and has
historic production records of lithium chemicals. Through a series of land
mergers, Rockwood Lithium acquired the land in 2012. Rockwood Lithium was
Page 22 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
acquired by Albemarle Corporation in 2015, a global company that specializes in
lithium chemicals, among others. The strategic purchase of Rockwood Lithium by
Albemarle Corporation (Figure 8), leads the applicant to believe that there is
sufficient mineralized spodumene within the site, or in adjacent land holdings, to
warrant a restart of a hard rock lithium mine at this location; however, the amount
of spodumene reserves are unknown. Moreover, the site has not been mined for
many years and much of the land has been reclaimed and naturalized, including
the on-site aquatic resources. For equal comparison across alternatives, a
desktop analysis of NHD and NWI features for the alternative was performed and
these features would be subject to potential impacts. Table 2 summarizes the
potential environmental impacts to NHD and NWI features for this alternative.
Table 3. Off -Site Alternative 3 NHD and NWI features.
Dataset
Amount
National Hydrography Dataset
Flowline
27,298 If
National Wetland Inventory
Riverine
same as above
Wetlands
21 ac.
Ponds
98 ac.
excludes NWI / NHD features within FEMA floodplain
As the core parcel is owned by a large, global market competitor to the applicant,
it is not available for purchase as an off-site alternative. It would also require the
acquisition of 27 additional parcels under multiple ownerships (27% of the land
area). Therefore, due to the unavailability of the land for purchase, the unknown
amount of resource reserves remaining, and potentially considerable aquatic
resource impacts, this alternative would not be practicable.
See Table 5 at the end of this section for the alternatives analysis siting criteria
summary.
This alternative would not satisfy the following screening criteria:
D. Property Availability (logistics): The alternative is not available for
purchase.
E. Minimization of Environmental Impacts: This alternative has the highest
amount of NHD and NWI features that are potentially subject to impacts;
therefore, it is not the least damaging alternative.
This alternative would satisfy the following screening criteria:
Page 23 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
A. Hard Rock Mine (technology and cost): The alternative has been, or partly
has been, a hard rock mine in the past. A retrofit would be necessary,
increasing costs.
B. Location within Carolina TSB with Previous Exploration History: The
alternative is within the TSB and at least 73% of the area was the former
Foote Lithium Mine, substantiating the previous exploration history of
mineralized spodumene.
C. Core Parcel Size & Mineable Area Needed for Reasonable Mine Design
(logistics): The alternative core parcel size is of sufficient size and is also
surrounded by other land parcels already consolidated under one ownership.
This alternative contains 977 acres, which is large enough to operate a lithium
mine under the project's purpose and need. A major highway divides access,
however, and is not ideal.
Off-site alternative 4:
Use of 192 -Acre Parcel within Carolina TSB: A 192 -acre core parcel within the
Carolina TSB was considered. It is of sufficient size, to warrant the assembly of
adjacent parcels for a larger total area of approximately 602 acres (Figure 9).
LEGEND 'd
0 OfFSite Altemailve 4 Core
Parcel (192 ac.)
C3Qtf-Allernative 4 I6D2 ac.)
Imerys Mica Kings Mountain
Inc. Clwnershlp {240 ac.} ila.
Cleveland CcurdY Parcels -�
Carolina T55
USGS Lsthium Anomaly In r
Stream Sediments
U505 Mineral Resaurca
e Fee} 2.200
r; -
C. \�, 0
FF�NnM AN Ami _
c Daman
AIt4 �
Figure 9. Off-site Alternative 4
National Hyyragraphyaalaset
r50WIIMQ 9.*0 if
r4ati—I V�69-d Inerdary
Rnenne same-ahme
WeHands Tat
Ponds 43 ac.
AT
LEGEND
1 00 -Year FEMA Floodplain
OnKSOF FU W REE W ITHIR Off -MME ALT 4
National Hydrography Datasal
National Weiland Invenlory
DESK SOP FRAM RES OvnMg OFM iM ALS 4
Nallonal Hydrography Dataset
National Wetlands Inventory
There are 105 parcels associated with this alternative, of which 4 parcels (40% of
the land area) are controlled by one owner, including the core parcel. The
alternative is currently a mica mine, owned and operated by Imerys Mica Kings
Mountain Inc. The site appears to have been in operation as a mica mine since
prior to the 1960s. To the best of the applicant's knowledge, this site is not known
Page 24 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
to contain lithium reserves and it has not been historically mined or explored for
lithium. There are no known records to substantiate the presence of mineralized
spodumene within the site. For equal comparison across alternatives, a desktop
analysis of NHD and NWI features for the alternative was performed. These
features would be subject to potential impacts for this alternative. Table 4
summarizes the potential environmental impacts to NHD and NWI features for
this alternative.
Table 4. Off -Site Alternative 4 NHD and NWI features.
Dataset
Amount
National Hydrography Dataset
Flowline
9,133 If
National Wetland Inventory
Riverine
same as above
Wetlands
7 ac.
Ponds
43 ac.
However, the core parcel is not for sale. The mica resource has likely not been
depleted and mining operations are ongoing at the site. The combination of
unavailability of the land for purchase, and the lack of exploration for mineralized
spodumene result in this alternative being impracticable.
See Table 5 at the end of this section for the alternatives analysis siting criteria
summary.
This alternative would not satisfy the following screening criteria:
B. Location within Carolina TSB with Previous Exploration History: The
alternative is not known to contain lithium reserves and does not have a
history of exploration for lithium containing -mineralized spodumene. It is
unknown if the alternative could provide adequate mineable lithium reserves
to cover capital investments costs.
C. Core Parcel Size & Mineable Area Needed for Reasonable Mine Design
(logistics): The alternative core parcel size is of sufficient size; however, the
total mine area is 602 acres and is less than the target area needed.
Moreover, the alternative is divided by a major highway (I-85).
D. Property Availability (logistics): The alternative is not available for
purchase.
E. Minimization of Environmental Impacts: This alternative has the 3rd
highest amount of NHD and NWI features that are potentially subject to
impacts; therefore, it is not the least damaging alternative.
This alternative would satisfy the following screening criteria:
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CE SAW -RG -C (File Number, SAW 2018-01129)
A. Hard Rock Mine (technology and cost): The alternative is currently set up
as a hard rock mine for mica. A retrofit would be necessary, increasing costs.
The siting criteria were used to compare the off-site alternatives and the
preferred alternative. See Table 5 for a summary of the siting criteria used in the
alternatives analysis and how the preferred alternative was chosen. The
preferred alternative is discussed in the following section.
Table 5. Summary of alternatives analysis siting criteria.
5.2.3 On-site alternatives
Applicant's Preferred Alternative: A 120 -acre core parcel within the Carolina
TSB was identified by the applicant to be of sufficient size to warrant the
assembly of adjacent parcels for a larger total area of approximately 971 acres
(Figure 10).
Page 26 of 85
Siting Criteria
Alternatives
Hard Rock
TSB
Core Parcel
Total Mine
Property
Environmental
Mine
Locality
Size
Area
Availability
Impacts *
NHD/NWI
Off -Site Alt 2
✓
✓
✓
(142 ac.)
✓X
(1,010 ac.)
X
(2nd
Off -Site Alt 3
✓
✓
✓
(129 ac.)
✓X
(977 ac.)
X
1st/most
Off -Site Alt 4
✓
✓
(192 ac.)
(602 ac.)
X
(3rd)
Preferred Alt✓
✓
✓
(120 ac.)
✓
(971 ac.)
✓
✓
(4th/least)
* excludes NWI / NHD features within FEMA floodplain
5.2.3 On-site alternatives
Applicant's Preferred Alternative: A 120 -acre core parcel within the Carolina
TSB was identified by the applicant to be of sufficient size to warrant the
assembly of adjacent parcels for a larger total area of approximately 971 acres
(Figure 10).
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CE SAW -RG -C (File Number, SAW 2018-01129)
nauortar nyomgra pn y u ...
Flowline
4.800 If'
Nahanal Wall and Imsrilory
R—nne
sameasabb-
V5@ ands
Ponds
cone
ers1dea MMI N-®f[re��ahxes w Ilm FF?.W Inc Jp...n
1+
std I f
LEGEND
100 -Year FEMA Floodplain
DESK TOP FEATURES W ITHIM P REFERR ED A LT
National Hydrography Dataset
National Wetland Inventory
DESKTOP FEATURES OUTSIDE PREFERRED ALT
National Hydrograptly Dataset
Figure 10. Preferred Alternative
There are 74 parcels associated with this preferred alternative, of which 48
parcels (78% of the land area) are controlled by the applicant, including the core
parcel. The core parcel and immediately adjacent areas in the preferred
alternative boundary were originally explored by Lithium Corporation of America,
which was eventually acquired by FMC Corporation. A Canadian exploration
company, North Arrow Minerals, completed a 19 drill-hole, 2,544 meter (8,346
feet) exploration drill program on the alternative in 2009-2010, which confirmed
the presence of lithium -bearing mineralized spodumene. Upon the acquisition of
this data and knowledge of the resource presence, the applicant acquired the
120 -acre parcel, and many adjacent parcels to create a larger contiguous area,
which is now considered the applicant's preferred alternative of 971 acres.
Subsequently, the applicant commenced additional exploration with a 230 -drill
hole, 35,293 meter (115,790 feet) drilling program between 2017 and 2018 on
the property. The acquisition of the 2009-2010 North Arrow drilling data enabled
the applicant to target a property with the resource present and ultimately save
on capital exploration costs during the subsequent 2017-2018 drilling program.
For equal comparison across alternatives, a desktop analysis of NHD and NWI
features for the preferred alternative was performed. These features would be
subject to potential impacts. Table 6 summarizes the potential environmental
impacts to NHD and NWI features for this alternative.
Page 27 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
Table 6. Preferred Alternative NHD and NWI features.
Dataset Amount
National Hydrography Dataset
Flowline
4,800 If
National Wetland Inventory
Riverine
same as above
Wetlands
0 ac.
Ponds
none
" excludes NWI / NHD features within FEMA floodplain
Since this alternative can be developed as a hard rock lithium mine, is within the
TSB, contains a core parcel of sufficient size to warrant the assembly of parcels
for a larger area, the applicant was able to acquire the core parcel along with
many other adjacent parcels; and, as the preferred alternative contains the least
amount of NHD and NWI features outside the floodplain of all the alternatives
potentially subject to impacts, this alternative was carried forward as the
preferred alternative.
This alternative would satisfy the following screening criteria:
A. Hard Rock Mine (technology and cost): The alternative creates the
opportunity to develop a hard rock lithium mine using proven hard rock mining
techniques to extract mineralized spodumene. No retrofit of existing
technology is required.
B. Location within Carolina TSB with Previous Exploration History: The
alternative and has a history of previous exploration for mineralized
spodumene, which substantiates the inferred and indicated resource amounts
of the existing resource. Moreover, the applicant has commenced their own
drilling program on the alternative, thus increasing the confidence of the
resource presence and location.
C. Core Parcel Size & Mineable Area Needed for Reasonable Mine Design
(logistics): The alternative core parcel size is of sufficient size and is also
surrounded by other land parcels already consolidated under control of the
applicant. The preferred alternative mine area is 971 acres and is sufficient to
accommodate the necessary size and design of the pit shell, waste rock
areas, and attendant mine features. The alternative is also large enough to
accommodate perimeter buffers, sediment and erosion controls, internal
access roads, and other features as approved by the approved mine design
D. Property Availability (logistics): The core parcel and 78% of the preferred
alternative is under the applicant's control. Negotiations are currently ongoing
for control of the remaining 22%. The applicant is confident that 100% control
will occur in 2019.
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CE SAW -RG -C (File Number, SAW 2018-01129)
E. Minimization of Environmental Impacts: This alternative has the least
amount of NHD and NWI features that are potentially subject to impacts;
therefore, it is the least damaging alternative. The FEMA floodplain, features
within the FEMA floodplain, and perennial streams originating offsite are
avoided. Buffers will be placed on remaining aquatic features.
In summary, the Preferred Alternative meets all of the siting criteria to be
practicable and achievable within the scope of the project's purpose and need. It
is the least environmentally damaging alternative when comparing sites equally
using publically available datasets. See Table 5 in the previous section for a
summary of the siting criteria used in the alternatives analysis and how the
preferred alternative was chosen.
Once the Preferred Alternative was chosen over the other off-site alternatives
using the siting criteria, multiple on-site alternatives were examined to determine
the best fit of mine features that can be practicably achieved within the project's
scope, while also balancing the mandate of avoidance and minimization to the
highest degree. These include the Applicant's Preferred Site Layout (On -Site
Alternative 1), a No Impact Site Layout (On -Site Alternative 2), a More Impact
Site Layout (On -Site Alternative 3), and an Avoidance Site Layout (On -Site
Alternative 4), discussed below.
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CE SAW -RG -C (File Number, SAW 2018-01129)
On-site alternative 1 (applicant's preferred alternative):
On -Site Alternative 1 — Applicant's Preferred Site Layout: The applicant's
preferred site layout was designed based on the data collected during the drilling
program conducted by the applicant, targeting areas of spodumene
mineralization (Figure 11 and Figure 12). Additionally, jurisdictional
determination field work was conducted by the applicant's consultant to locate
jurisdictional streams, wetlands, and ponds for impact determination.
Existing Roads
Proposed Access Roads
k Buffers
100 Ft Lot Line Setback
200 Ft Structure Setback
300 Ft Residential Setha
❑ESN TOP JO FEATURES
Desktop Streams
M' Desktop NN Wetland
APPROXIMATE IMPACTS
Delineated Stream
Impacts
0 Delineated Welland
Impacts
®Delineated Pond
Impacts
Desktop Stream
y Impacts
Figure 11. Preferred Site Layout (On -Site Alternative 1)
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CE SAW -RG -C (File Number, SAW 2018-01129)
LEGEND =
P Project Boundary
{97T ac.y
HDR Delineated �)
Streams -
®HDR Delineated
Wetlands
HDR' delineated Ponds
1D0 -Ye. FEMA
Floodplain
Culverts
LEGEND ',I:NE FEr,_1JRES
Concentrator Plant Site
Pit Shell
Waste Rock Areas
— — Existing Roads
Proposed Access Roads
4 Setback Butters
100 Ft Lot Line Setback
200 Ft Structure Setback
DESKTOP JD FEATURES
Desktop Streams
Desktop NW Wetland
APPROXIMATE IMPACTS
Delineated Stream
Impacts
0 Delineated Welland
Impacts
Delineated Pond
Impacts
Desktop Stream
Impacts
Figure 12. Concentrator plant site
It was determined that approximately 12.3 million tons (11.2 million metric
tonnes) or more of mineralized spodumene can be extracted over a 13 year
span, utilizing an approximately 200 -acre pit shell design. The waste rock areas
are approximately 145 acres and will contain roughly 24% (19.4 million cubic
yards) of the waste produced, the most of all the on-site alternatives. Any
remaining waste will be placed in the pit shell as backfill once final pit shell voids
have been defined. The pit shell and waste rock area designs include set
parameters for wall angles, ramp widths, and high wall angles, widths, and
heights necessary for stability and safety, while also avoiding FEMA floodplains
that bisect the alternative, major drainages, and streams originating off site.
Proposed impacts to jurisdictional waters include approximately 5,810.5 linear
feet of stream, 0.14 acre of wetlands, and 0.16 acre of pond (Table 7).
Approximately 781 linear feet of perennial stream channel, 2,283 linear feet of
intermittent stream channel, 0.14 acre of wetlands, and 0.16 acre of ponds would
be impacted by waste rock areas. Approximately 249 linear feet of perennial
stream channel and 2,264.5 of intermittent stream channel would be impacted by
pit shell areas. Approximately 178 linear feet of perennial stream channel would
be impacted by a stream crossing for an internal access road, and 55 linear feet
of perennial channel will be impacted by a BMP (Figure 2). All waste rock areas
are designed with underdrains at low points to capture groundwater discharges
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CE SAW -RG -C (File Number, SAW 2018-01129)
and all pit shell areas are designed with sump collection which would be pumped
to NPDES BMPs for treatment, as required by NCDEQ DEMLR under the
General Permit (No. NCG020000) for Mining Activities.
Table 7. Approximate impact amounts for On -Site Alternative 1 (applicant's preferred
alternative).
Internal access roads within the Preferred Site Layout utilize existing roads or are
located in areas within the pit and waste rock areas. At this time, the applicant is
proposing to NCDOT to abandon the existing roads within the project site.
Coordination with NDOT is ongoing and at this time, and no impacts associated
with road relocation are anticipated. The Mine Safety and Health Administration
(MSHA) requires design road widths to be 2.5x the width of mine trucks utilized.
The applicant will utilize 70 ton mine haul trucks, which are 40 feet in width;
therefore, internal access roads would be at minimum 100 feet in width with
additional width as needed once road embankments and fill slopes are designed.
Existing roads would be retrofitted/widened as necessary to MSHA standards.
The largest pit, largest waste rock area, and the concentrator plant site can all be
accessed without road crossings of aquatic features. The existing bridge crossing
of Hephzibah Church Road would be reinforced and utilized to avoid impacts
associated with a necessary crossing of Beaverdam Creek to access the eastern
pit and waste rock area. Two internal access road stream crossings are needed
to access pit areas separated by major perennial drainages in the north and
south of the site. The proposed crossing in the north of the site is designed to
utilize the footprint of an existing culverted crossing to minimize impacts (Figure
13). Approximately 178 linear feet of perennial stream channel will be impacted
by this crossing. The crossing will most likely be a reinforced concrete pipe
(RCP) and be designed to handle the 100 -year storm event once design is
finalized.
Page 32 of 85
Delineated Features
Desktop Features
Impacts
Feature Type
Waste
Pit
Access
Waste
Pit
BMPs
Total
Area
Shell
Roads
Area
Shell
Intermittent
2,283
1,983.50
0
0
281
0
4,547.5 If
Streams (If)
Perennial
81
249
178
700
0
55
1,208 If
Streams (If)
Wetlands (ac.)
0.14
0
0
0
0.14 ac.
Ponds (ac.)
0.16
0
0
0
0.16 ac.
Total Stream Impacts
5,810.5 If
Total Wetland Impacts
0.14 ac.
Total Pond Impacts
0.16 ac.
Internal access roads within the Preferred Site Layout utilize existing roads or are
located in areas within the pit and waste rock areas. At this time, the applicant is
proposing to NCDOT to abandon the existing roads within the project site.
Coordination with NDOT is ongoing and at this time, and no impacts associated
with road relocation are anticipated. The Mine Safety and Health Administration
(MSHA) requires design road widths to be 2.5x the width of mine trucks utilized.
The applicant will utilize 70 ton mine haul trucks, which are 40 feet in width;
therefore, internal access roads would be at minimum 100 feet in width with
additional width as needed once road embankments and fill slopes are designed.
Existing roads would be retrofitted/widened as necessary to MSHA standards.
The largest pit, largest waste rock area, and the concentrator plant site can all be
accessed without road crossings of aquatic features. The existing bridge crossing
of Hephzibah Church Road would be reinforced and utilized to avoid impacts
associated with a necessary crossing of Beaverdam Creek to access the eastern
pit and waste rock area. Two internal access road stream crossings are needed
to access pit areas separated by major perennial drainages in the north and
south of the site. The proposed crossing in the north of the site is designed to
utilize the footprint of an existing culverted crossing to minimize impacts (Figure
13). Approximately 178 linear feet of perennial stream channel will be impacted
by this crossing. The crossing will most likely be a reinforced concrete pipe
(RCP) and be designed to handle the 100 -year storm event once design is
finalized.
Page 32 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
LEND
IP Project Boundary
(971 ac.y
HDR Delineated
Streams
;GE
HDR Delineated
Wetlands
HDR Delineated Ponds
100 -Year FEMA
Floodplain
Culverts
h
ii
-• fl Fee! 8'J
'nxn=rsreel
....'�. - - - .......r
LEGEND: MINE FEATURES
Concentrator Plant Site
0 Plt Shell - - - -
[culvert installatianj
0 Waste Rork Areas ; ...1
- — — Existing Roads
Proposed Access Roads ..............
i. ...............\
Setback Buffers : ...........
100 FI. hat Line Setback
200 Ft Structure Setback......
300 Ft Residential Setbac
Figure 13. Access road crossing
DESK TOP JOFEATURES
Desktop Streams
Desktop NWT Wetland
APPROXI MATE IMPACTS
Delineated Stream
: - Impacts
0 Delineated Welland
Impacts
Delineated Pond
......... Impacts
_ Desktop Strean
l 1lpacts
�.. .........................
To access the southern pit area, a crossing of Beaverdam Creek is proposed in
the southwest of the Preferred Site Layout at the narrowest width of the FEMA
floodplain. This crossing will be designed with an arch span bridge to horizontally
and vertically avoid the 100 -year flood elevation entirely; therefore, this crossing
will not impact Beaverdam Creek or the FEMA floodplain.
The 971 -acre Preferred Alternative is large enough to accommodate the
Preferred Site Layout with a 200 -acre pit shell, 145 -acre waste rock area, a 60 -
acre concentrator plant site, 200 acres within the 300 -foot mine setback buffer,
internal access roads, and sediment and erosion control measures in order to
extract sufficient ore (12.3 million tons or more of mineralized spodumene) to
produce approximately 264,500 tons of lithium hydroxide. According to the
applicant, this amount of lithium hydroxide would be an adequate supply of
lithium to be economically viable, attractive to long-term capital investors, and
sufficient as a domestic supply of lithium.
This alternative would satisfy the following screening criteria:
A. Hard Rock Mine (technology and cost): The alternative creates the
opportunity to develop a hard rock lithium mine using proven hard rock mining
techniques to extract mineralized spodumene. No retrofit of existing
technology is required.
Page 33 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
B. Location within Carolina TSB with Previous Exploration History: The
alternative and has a history of previous exploration for mineralized
spodumene, which substantiates the inferred and indicated resource amounts
of the existing resource. Moreover, the applicant has commenced their own
drilling program on the alternative, thus increasing the confidence of the
resource presence and location.
C. Core Parcel Size & Mineable Area Needed for Reasonable Mine Design
(logistics): The alternative core parcel size is of sufficient size and is also
surrounded by other land parcels already consolidated under control of the
applicant. The preferred alternative land area is of adequate size to
accommodate the necessary size and design of the pit shell, waste rock
areas, and attendant mine features. The alternative is also large enough to
accommodate perimeter buffers, sediment and erosion controls, internal
access roads, and other features as approved by the approved mine design.
D. Property Availability (logistics): The core parcel and 78% of the preferred
alternative is under the applicant's control. Negotiations are currently ongoing
for control of the remaining 22%. The applicant is confident that 100% control
will occur in 2019.
E. Minimization of Environmental Impacts: This alternative has the least
amount of NHD and NWI features that are potentially subject to impacts;
therefore, it is the least damaging alternative. The FEMA floodplain, features
within the FEMA floodplain, and perennial streams originating offsite are
avoided. Buffers will be placed on remaining aquatic features.
See Table 10 at the end of this section for a summary of the on-site alternatives
analysis.
On-site alternative 2:
On -Site Alternative 2 — No Impact Site Layout: This alternative consists of a
pit shell design and waste rock areas completely located in upland portions of the
preferred alternative while entirely avoiding impacts to Waters of the United
States (Figure 14). This would result in pit shell and waste rock area designs that
are smaller than the preferred concept. To have a no impact scenario, this design
would also not have internal access roads due to impacts to streams for
crossings, thus separating the most northern and southern pits from access to
the concentrator plant site.
Page 34 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
LEGEND
Q IP Project Boundary (9 71 ac.]
HDR Delineated Streams
HDR Delineated Pond
0 HRR Delineated Wetlands
Desktop Streams
Desktop NWI Welland
"
100 -Year FEMA Floodplain
Culverts
Gaston Couty Parcels in TSB
0 Fae00
'Wh = 1 AM bei
badge crossing
LEGE NO: MINE FEATURES
Concentrator Plant Site
Pit Shell
Waste Rock Areas
Setback Buffers
100 Ft Lot Line Setback
200 Ft Structures Setback
Existing bridge
300 Ft Residential Setback { ' ` • 'Y '�
.
Figure 14. No Impact Site Layout (On -Site Alternative 2)
Avoiding all aquatic features in this alternative would reduce the acreage of the
pit shell and waste rock areas, diminish the mine life to 9 years, and decrease
the amount of mineable mineralized spodumene to approximately 9.7 million tons
(roughly a 29% reduction from the preferred alternative). This alternative would
generate the least amount of waste (62.2 million cubic yards) of all the
alternatives; however, the waste rock area design is only capable of handling
12% (8 million cubic yards) of the waste generated, and is the least capable of
the alternatives for waste capacity. Furthermore, this volume of spodumene will
only convert to a volume of approximately 137,700 tons of lithium hydroxide — an
almost 50% reduction in lithium hydroxide produced compared to the preferred
alternative, essentially cutting the potential domestic supply of lithium by half.
According to the applicant, prospective investors would not be enthusiastic about
the short mine life or the insufficient amount of lithium hydroxide produced for the
project. Additionally, as the no impact pit shell mineable area decreases, the pit
shell perimeter would increase in a non-linear fashion as it circumvents drainage
features. This prevents the technique of utilizing long stretches of linear batter
and berms, which would reduce mining efficiency and increase operational costs.
Essentially, this alternative does not practicably achieve a no impact scenario
while locating the pit shell, the waste rock areas, and the concentrator plant
Page 35 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
entirely in uplands. Therefore, this alternative is not practicable or reasonable for
the project purpose and need
This alternative would satisfy the following screening criteria:
A. Hard Rock Mine (technology and cost): The alternative creates the
opportunity to develop a hard rock lithium mine using proven hard rock mining
techniques to extract mineralized spodumene. No retrofit of existing
technology is required.
B. Location within Carolina TSB with Previous Exploration History: The
alternative and has a history of previous exploration for mineralized
spodumene, which substantiates the inferred and indicated resource amounts
of the existing resource.
D. Property Availability (logistics): The core parcel and 78% of the preferred
alternative is under the applicant's control. Negotiations are currently ongoing
for control of the remaining 22%. The applicant is confident that 100% control
will occur in 2019.
E. Minimization of Environmental Impacts: This alternative has the least
amount impacts to aquatic features.
This alternative would not satisfy the following screening criteria:
C. Core Parcel Size & Mineable Area Needed for Reasonable Mine Design
(logistics): The alternative core parcel size is of sufficient size and is also
surrounded by other land parcels already consolidated under control of the
applicant. However, the no impact alternative that avoids all aquatic features
decreases the ability for mining the necessary amount of mineralized
spodumene to meet project goals and contains as much as all pit waste as
possible since offsite removal of waste rock is not practicable due to the
volume of material that would be generated. Moreover, the no impact design
is not practicable as two pits cannot be accessed without impacts for access
roads, thus further decreasing the mineable area.
See Table 10 at the end of this section for a summary of the on-site alternatives
analysis.
On-site alternative 3:
On -Site Alternative 3 — More Impact Site Layout: The applicant considered a
site layout with a larger pit area, targeting areas of spodumene mineralization
(Figure 15). This site layout is similar to the applicant's preferred site layout
except for this design's central and northern pits are combined, thus impacting an
additional 1,430 linear feet of perennial stream that originates off site.
Page 36 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
LEGEND
IP Project Boundary
1971 ac.y
HRR Delineated
Streams
®HDR Delineated
Wetlands
HRR Delineated Ponds
100 -Year FEMA
Floodplain
err Culverts
i�
0 Feet 1.8010
1mh=1$00 Feet
LEGEND- MINE FEATURES
Concenlra[or Pi ant Slte
Pit Shell
Waste Rock
- — Existing Roads
--- Proposed Access
Setback Buffers
100 Fl Lot Line Setback
2110 Ft Structure Setback
300 Ft Residential Setback
DESKTOP JD FEATURES
----- Desktop Streams
Desktop NWl Welland
APPROXIMATE IMPACTS
Delineated Stream
Impacts
0 Delineated Wetland
Impacts
Delineated Pond
Impacts
_ Desktop Stream
Impacts
Figure 15. More Impact Site Layout (On -Site Alternative 3)
This alternative would extract roughly 14.3 million tons of mineralized
spodumene, utilizing an approximately 215 -acre pit shell design; however, the
waste rock areas design is the same as the preferred alternative. As such, this
alternative will generate more waste from the larger pit design (108 million cubic
yards), but the waste rock areas would only handle 18% (19.4 million cubic
yards) of pit -generated waste. Any remaining waste would be placed in the pit
shell as backfill once final pit shell voids have been defined.
Impacts for this alternative include approximately 7,185.5 linear feet of stream,
0.14 acre of wetlands, and 0.16 acre of pond (Table 8). Approximately 781 linear
feet of perennial stream channel, 2,283 linear feet of intermittent stream channel,
0.14 acre of wetlands, and 0.16 acre of ponds would be impacted by waste rock
areas. Approximately 1,857 linear feet of perennial stream channel and 2,264.5
of intermittent stream channel would be impacted by pit shell areas.
Approximately 178 linear feet of perennial stream channel would be impacted by
a stream crossing and 55 linear feet of perennial channel would be impacted by a
BMP. All waste rock areas are designed with underdrains at low points to capture
groundwater discharges and all pit shell areas are designed with sump collection
which would be pumped to NPDES controls for treatment, as required by
NCDEQ DEMLR under the General Permit (No. NCG020000) for Mining
Activities.
Page 37 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
Table B. ADnroximate impact amounts for On -Site Alternative 3.
Internal access roads within this alternative are the same as On -Site Alternative
1; however, impacts associated with the proposed road crossing for access to
the northern pit would no longer be needed as this area would already be
impacted by the pit.
To access the southern pit area, a crossing of Beaverdam Creek is proposed in
the southwest of the Preferred Site Layout at the narrowest width of the FEMA
floodplain. This crossing would be designed with an arch span bridge to
horizontally and vertically avoid the 100 -year flood elevation entirely; therefore,
this crossing would not impact Beaverdam Creek or the FEMA floodplain.
This alternative would satisfy the following screening criteria:
A. Hard Rock Mine (technology and cost): The alternative creates the
opportunity to develop a hard rock lithium mine using proven hard rock mining
techniques to extract mineralized spodumene.
B. Location within Carolina TSB with Previous Exploration History: The
alternative and has a history of previous exploration for mineralized
spodumene, which substantiates the inferred and indicated resource amounts
of the existing resource.
D. Property Availability (logistics): The core parcel and 78% of the preferred
alternative is under the applicant's control. Negotiations are currently ongoing
for control of the remaining 22%. The applicant is confident that 100% control
will occur in 2019.
This alternative would not satisfy the following screening criteria:
C. Core Parcel Size & Mineable Area Needed for Reasonable Mine Design
(logistics): The alternative core parcel size is of sufficient size and is also
surrounded by other land parcels already consolidated under control of the
applicant. The preferred alternative land area is of adequate size to
Page 38 of 85
Delineated Features
Desktop Features
Impacts
Feature Type
Waste Area
Pit Shell
Waste
Area
Pit
Shell
BMPs
Total
Intermittent Streams (if)
2,283
1,983.50
0
281
0
4,547.5 If
Perennial Streams (if)
81
1,857
700
0
55
2,638 If
Wetlands (ac.)
0.14
0.09
0
0.14 ac.
Ponds (ac.)
0.16
0.003
0
0.16 ac.
Total Stream Impacts
7,240.5 If
Total Wetland Impacts
0.14 ac.
Total Pond Impacts
0.16 ac.
Internal access roads within this alternative are the same as On -Site Alternative
1; however, impacts associated with the proposed road crossing for access to
the northern pit would no longer be needed as this area would already be
impacted by the pit.
To access the southern pit area, a crossing of Beaverdam Creek is proposed in
the southwest of the Preferred Site Layout at the narrowest width of the FEMA
floodplain. This crossing would be designed with an arch span bridge to
horizontally and vertically avoid the 100 -year flood elevation entirely; therefore,
this crossing would not impact Beaverdam Creek or the FEMA floodplain.
This alternative would satisfy the following screening criteria:
A. Hard Rock Mine (technology and cost): The alternative creates the
opportunity to develop a hard rock lithium mine using proven hard rock mining
techniques to extract mineralized spodumene.
B. Location within Carolina TSB with Previous Exploration History: The
alternative and has a history of previous exploration for mineralized
spodumene, which substantiates the inferred and indicated resource amounts
of the existing resource.
D. Property Availability (logistics): The core parcel and 78% of the preferred
alternative is under the applicant's control. Negotiations are currently ongoing
for control of the remaining 22%. The applicant is confident that 100% control
will occur in 2019.
This alternative would not satisfy the following screening criteria:
C. Core Parcel Size & Mineable Area Needed for Reasonable Mine Design
(logistics): The alternative core parcel size is of sufficient size and is also
surrounded by other land parcels already consolidated under control of the
applicant. The preferred alternative land area is of adequate size to
Page 38 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
accommodate the necessary size and design of the pit shell for this
alternative, but the waste rock areas would be insufficient to handle the pit
waste generated. Between topographic and mine buffer setback constraints, it
would not be achievable to increase the waste rock areas to handle the
additional waste and; therefore, not practicable for the project's purpose.
E. Minimization of Environmental Impacts: This alternative has the highest
amount of impacts to jurisdictional features of approximately 1,400 linear feet
more than the preferred alternative; therefore, it is the most environmentally
damaging alternative and was eliminated from consideration.
See Table 10 at the end of this section for a summary of the on-site alternatives
analysis.
On-site alternative 4:
On -Site Alternative 4 — Avoidance Site Layout: The applicant considered a
site layout with the same pit configuration as the preferred alternative, but with a
smaller waste rock area (Figure 16). This site layout is similar to the applicant's
preferred site layout except for this design's largest waste rock area was
designed to avoid approximately 1,450 linear feet streams.
LEGEND
IP Project Boundary
(971 ac.y
HDR Delrnealed
5traams
HOR Delineated
Wetlands
HDR L7ellneated Ponds
100 -Year FEMA f
Floodplain
Culverts
0 Feet 1.800
LEGEND- MINE FEATURES
Pit Shell
Concentrator Plant Site
Waste Rack Areas
- — — Existing Roads
— Proposed Access Roads
Setback Buffers
100 F1 Lot Line Setback
200 Ft Structure Setback
300 Ff Residential Setback
p mage
:- m
. de rm
proGgaeO rna0 Crasfrnp -
tum¢livpianaegt ltirchA 6i
FEMA Iddpl.
n)
Figure 16. Avoidance Site Layout (On -Site Alternative 4)
Page 39 of 85
- I i
ep • n 1Mt
•Rh�vY—n wl..n Hu�R
-„�
DESKTOP JD FEATURES
i
Desktop Streams
M Desktop NW Wetland
APPROXIMATE IMPACTS
Delineated Stream
Impacts
0 Delineated Wetland
Impacts
Dellnealed Pond
Impacts
Deskldp Sttesrrl
Impacts
- I i
ep • n 1Mt
•Rh�vY—n wl..n Hu�R

CE SAW -RG -C (File Number, SAW 2018-01129)
As the pit design in this alternative is the same as the preferred alternative, the
extracted mineralized spodumene would be the same, utilizing an approximately
200 -acre pit shell design; however, the waste rock area design is 72 acres less
than the preferred alternative. As such, this alternative would generate the same
waste as the preferred alternative (83.2 million cubic yards), but would only have
a capacity for 17% (14.4 million cubic yards) of pit -generated waste. Any
remaining waste would be placed in the pit shell as backfill once final pit shell
voids have been defined.
Impacts for this alternative include approximately 4,363.5 linear feet of stream,
0.14 acre of wetlands, and 0.08 acre of pond (Table 9). Approximately 971 linear
feet of intermittent stream channel, 0.14 acre of wetlands, and 0.09 acre of ponds
would be impacted by waste rock areas. Approximately 1,127 linear feet of
perennial stream channel and 2,264.5 of intermittent stream channel would be
impacted by pit shell areas. Approximately 178 linear feet of perennial stream
channel would be impacted by a stream crossing and 55 linear feet of perennial
channel would be impacted by a BMP. All waste rock areas are designed with
underdrains at low points to capture groundwater discharges and all pit shell
areas are designed with sump collection which would be pumped to NPDES
controls for treatment, as required by NCDEQ DEMLR under the General Permit
(No. NCG020000) for Mining Activities.
Table 9. ADDroximate imaact amounts for On -Site Alternative 4.
Internal access roads within this alternative are the same as On -Site Alternative
1.
The largest pit, largest waste rock area, and the concentrator plant site can all be
accessed without road crossings of aquatic features. The existing bridge crossing
of Hephzibah Church Road would be reinforced and utilized to avoid impacts of a
necessary crossing of Beaverdam Creek to access the eastern pit and waste
rock area. However, two internal access road crossings are still needed to
Page 40 of 85
Delineated Features
Desktop Features
Impacts
Feature Type
Waste
Area
Pit Shell
Access
Roads
Waste
Area
Pit
Shell
BMPs
Total
Intermittent Streams (If)
917
1,983.50
0
0
281
0
3,181.5 If
Perennial Streams (If)
0
249
178
700
0
55
1,182 If
Wetlands (ac.)
0.14
0
0
0
0.14
Ponds (ac.)
0.08
0
0
0
0.08
Total Stream Impacts
4,363.5 If
Total Wetland Impacts
0.14 ac.
Total Pond Impacts
0.08 ac.
Internal access roads within this alternative are the same as On -Site Alternative
1.
The largest pit, largest waste rock area, and the concentrator plant site can all be
accessed without road crossings of aquatic features. The existing bridge crossing
of Hephzibah Church Road would be reinforced and utilized to avoid impacts of a
necessary crossing of Beaverdam Creek to access the eastern pit and waste
rock area. However, two internal access road crossings are still needed to
Page 40 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
access pit areas separated by major perennial drainages in the north and south
of the site. The proposed crossing in the north of the site is designed to utilize the
footprint of an existing crossing to minimize impacts (Figure 13). Approximately
178 linear feet of perennial stream channel would be impacted by this crossing.
The crossing would most likely be a reinforced concrete pipe (RCP) and be
designed to handle the 100 -year storm event once design is finalized.
To access the southern pit area, a crossing of Beaverdam Creek is proposed in
the southwest of the Preferred Site Layout at the narrowest width of the FEMA
floodplain. This crossing would be designed with an arch span bridge to
horizontally and vertically avoid the 100 -year flood elevation entirely; therefore,
this crossing would not impact Beaverdam Creek or the FEMA floodplain.
This alternative would satisfy the following screening criteria:
A. Hard Rock Mine (technology and cost): The alternative creates the
opportunity to develop a hard rock lithium mine using proven hard rock mining
techniques to extract mineralized spodumene.
B. Location within Carolina TSB with Previous Exploration History: The
alternative and has a history of previous exploration for mineralized
spodumene, which substantiates the inferred and indicated resource amounts
of the existing resource.
C. Property Availability (logistics): The core parcel and 78% of the preferred
alternative is under the applicant's control. Negotiations are currently ongoing
for control of the remaining 22%. The applicant is confident that 100% control
will occur in 2019.
E. Minimization of Environmental Impacts: With the exception of the No
Impact Alternative, this alternative has the least amount of impacts to
jurisdictional features.
This alternative would not satisfy the following screening criteria:
D. Core Parcel Size & Mineable Area Needed for Reasonable Mine Design
(logistics): The alternative core parcel size is of sufficient size and is also
surrounded by other land parcels already consolidated under control of the
applicant. The preferred alternative land area is of adequate size to
accommodate the necessary size and design of the pit shell for this
alternative, but the waste rock areas would be insufficient to handle as much
as all pit waste as possible since offsite removal of waste rock is not
practicable due to the volume of material that would be generated. Between
topographic, jurisdictional feature locations, and mine buffer setback
constraints, it would not be achievable to increase the waste rock areas to
handle the additional waste and; therefore, this alternative is not practicable
for the project's purpose.
Table 10 (below) summarizes the on-site alternatives analysis.
Page 41 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
Table 10. Summary of on-site alternatives analvsis.
5.3 Evaluate alternatives and whether or not each is practicable under the Guidelines
or reasonable under NEPA:
Section 5.1 details which alternatives are not feasible and/or practicable and
why.
5.4 Least environmentally damaging practicable alternative under the 404(b)(1)
Guidelines (if applicable) and the environmentally preferable alternative under
NEPA:
The Applicant's preferred alternative is the least environmentally damaging
practicable alternative.
6.0 Evaluation for Compliance with the Section 404(b)(1) Guidelines. The
following sequence of evaluation is consistent with 40 CFR 230.5
6.1 Practicable alternatives to the proposed discharge consistent with 40 CFR
230.5(c) are evaluated in Section 5. The statements below summarize the
analysis of alternatives.
In summary, based on the analysis in Section 5.0 above, the no -action
alternative, which would not involve discharge into waters, is not practicable.
For those projects that would discharge into a special aquatic site and are not
water dependent, the applicant has demonstrated there are no practicable
alternatives that do not involve special aquatic sites.
It has been determined that there are no alternatives to the proposed discharge
that would be less environmentally damaging. (Subpart B, 40 CFR 230.10(a)).
Page 42 of 85
Preferred
No Impact
More Impact
Avoidance
Pit
200 ac.
168 ac.
215 ac.
200 ac.
Waste Rock Area
145 ac.
118 ac.
145 ac.
128 ac.
Ore
12.4 million tons
9.7 million tons
14.1 million tons
12.4 million tons
Pit -Generated Waste
83.2 million yd'
62.2 million yd'
108 million yd'
83.2 million yd3
Waste Rock Area Capacity
19.4 million yd3
8 million yd'
19.4 million yd'
14.4 million yd'
% of Waste Stored
24%
13%
18%
17%
Total Stream Impacts
5,801.5 If
0 ac.
7,240.5 If
4,363.5 If
Total Wetland Impacts
0.14 ac.
0 ac.
0.14 ac.
0.14 ac.
Total Pond Impacts
0.16 ac.
0 ac.
0.16 ac.
0.09 ac.
5.3 Evaluate alternatives and whether or not each is practicable under the Guidelines
or reasonable under NEPA:
Section 5.1 details which alternatives are not feasible and/or practicable and
why.
5.4 Least environmentally damaging practicable alternative under the 404(b)(1)
Guidelines (if applicable) and the environmentally preferable alternative under
NEPA:
The Applicant's preferred alternative is the least environmentally damaging
practicable alternative.
6.0 Evaluation for Compliance with the Section 404(b)(1) Guidelines. The
following sequence of evaluation is consistent with 40 CFR 230.5
6.1 Practicable alternatives to the proposed discharge consistent with 40 CFR
230.5(c) are evaluated in Section 5. The statements below summarize the
analysis of alternatives.
In summary, based on the analysis in Section 5.0 above, the no -action
alternative, which would not involve discharge into waters, is not practicable.
For those projects that would discharge into a special aquatic site and are not
water dependent, the applicant has demonstrated there are no practicable
alternatives that do not involve special aquatic sites.
It has been determined that there are no alternatives to the proposed discharge
that would be less environmentally damaging. (Subpart B, 40 CFR 230.10(a)).
Page 42 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
The proposed discharge in this evaluation is the practicable alternative with the
least adverse impact on the aquatic ecosystem, and it does not have other
significant environmental consequences.
6.2 Candidate disposal site delineation (Subpart B, 40 CFR 230.11(f)). Each disposal
site shall be specified through the application of these Guidelines:
There are multiple disposal sites (impacts) located throughout the project site.
Impact 1 is the only stream crossing. Impacts 2-7 are those associated with pit
construction. Impacts 8-16 are those associated with waste rock area
construction. Figure 17 below depicts the impact site locations.
LEGEND
1P Project Boundary
074 a¢y
_ HDR Delineated
Streams
HDR Delineated
Wetlands
HDR Delineated Ponds
100 -Year FEMA
Floodplain
Culverts
i�
0 Feet 1,800
1 —h ='.ON fee[
DESKTOP JD FEATURES
Desktop Streams
Desktop NN Wetland
13,rentl l6 im p,irt i
APPROXIMATE IMPACTS
Delineated Stream
Impacts
� ^Delineated Welland
r Impacts
Delineated Pond
`❑ Impacts
Desktop Stream
�- NN .� Impacts
FNNE FEATURES �
centrator Plant Site g
1
hellle R -c Areas
ting Roads
osed Access Roads
ffersFt Lot Line Setback
Ft Structure Setback
Ft Residential Setback
Figure 17. Overview of Impact Locations
Discussion:
In, I,.- nd _ .•
a
!7 � 10
-7.!7F
•ou e e o
With the exception of one impact (Impact 1), all other impacts are located on
shallow, first order streams that originate on site. The impact sites would contain
no flow or be dewatered prior to construction which would eliminate the stream
velocities and prevent and control turbidity, stratification, and other factors
typically associated with mixing soil with water. All fill material would be clean fill
material originating from on site and readily available to the applicant.
Page 43 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
6.3 Potential impacts on physical and chemical characteristics of the aquatic
ecosystem (Subpart C 40 CFR 230.20). See Table 11:
Impact 1
Impact 1 - Perennial Stream 2
178 1f delineated
; ::
{culvert installation}
NCSAM:High
Proposed Mitigation Rata: 2.1 Bridge fflotprint
356 stream credits
' LEGEND: MINE FEATURES :...........
IMPACTS
�.. P¢ SnHI • ........................... Deirre•xed SVeam ImPaCs
�Naste Rock Rreac ..............................
D --ted VYsV lope
E.ieanp R—d, • . �Dalneaped P-4 Rrpeds
—Pro .d Accee.: .. ... .......... ... .. .flop Stream I-Ve
Figure 18. Impact 1 - Stream crossing for internal access road.
Table 11. Potential Impacts on Physical and Chemical Characteristics for Impact 1
DELINEATED FEAWRE5
................................... ............ .......
—HDR Del mama S[reams
....... . ................... ............... - .
-HDR OMr .d 1 t1e
.... . ... .. ... ... .......... .. .. .. ...... .
HDR Delineated Pwws
•.............................................. .
1W. rear+ EWA VkWpW
Effect
aC�h'erts
DESKTOP JD FEATV RES
..........•................... ... ............
::.::::::............::::.::::::::
.....................................
—0ktM Srte3ms
.
Effect
I
(Short
Existing Culvert
r-"�
::::::::::::.::: :.. .
-
........,...........................
Term)
Impact 1 - Perennial Stream 2
178 1f delineated
; ::
{culvert installation}
NCSAM:High
Proposed Mitigation Rata: 2.1 Bridge fflotprint
356 stream credits
' LEGEND: MINE FEATURES :...........
IMPACTS
�.. P¢ SnHI • ........................... Deirre•xed SVeam ImPaCs
�Naste Rock Rreac ..............................
D --ted VYsV lope
E.ieanp R—d, • . �Dalneaped P-4 Rrpeds
—Pro .d Accee.: .. ... .......... ... .. .flop Stream I-Ve
Figure 18. Impact 1 - Stream crossing for internal access road.
Table 11. Potential Impacts on Physical and Chemical Characteristics for Impact 1
Discussion:
Page 44 of 85
Minor
Minor
Physical and Chemical
No
Negligible
Effect
Effect
Characteristics
NSA
Effect
Effect
(Short
(Long
Major Effect
Term)
Term)
Substrate
x
Suspended particulates/
turbidity
X
Water
x
Current patterns and
water circulation
X
Normal water fluctuations
x
Salinity gradients
x
Discussion:
Page 44 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
Substrate: The proposed reinforced concrete pipe (RCP) would be placed
directly in 178 linear feet of jurisdictional Perennial Stream 2. The existing stream
substrate in these areas would be buried/removed. The discharge would consist
of suitable fill material and would not include any trash, debris, car bodies,
asphalt, etc. The fill material would also be free of toxic pollutants in toxic
amounts. Proper sediment and erosion control measures would be installed prior
to and during construction to ensure that the substrate of remaining waters of the
United States would not change or be affected. The pipe will be buried 1 foot if
larger than 48 inches in diameter or will be buried 20% of the diameter if less
than 48 inches, so as not to impede low flows and aquatic life movement.
Suspended particulates/turbidity: During construction, there may be a minimal
increase in suspended particulates that may lead to increased turbidity
downstream. However, the increase would be minimal and temporary due to the
installation and maintenance of proper sediment and erosion control measures
during construction and shortly thereafter.
Water Quality: The proposed discharge of dredge and fill material should not
cause increased chemical contamination levels within the aquatic ecosystem.
Specifically, changes in clarity, color, odor, and taste of water in addition to
possible chemical contamination would be minimized by the applicant's storm
water management and sediment and erosion control plan. The proposed fill
material would consist of a reinforced concrete pipe (RCP).
Current patterns in water circulation: The proposed discharged dredge and fill
material is not expected to modify current downstream water circulation patterns
by obstructing flow, changing direction or velocity of water, or changing velocity
or flow of circulation.
Normal water fluctuations: There is an existing pipe at this location (77 linear
feet), whose footprint will be utilized to minimize impacts. The new pipe will be
placed appropriately as to not impede low flows as described above. The
discharge of fill material associated with this impact is not anticipated to have
more than a minimal effect on the downstream hydrologic regimes.
Page 45 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
Impacts 2 — 7: Those associated with pit construction.
DELINEATED FEATURES t - _ • ; :: ' ; ; ; ; ; : ; ; -
-HDR Ow—W St— �. ..... .....
-RDR oen.e Yee 6me �. .... .. . ............ . .
r:41HPR D.h-R N— lVI ' _ ..::. ..... .
10 1—PrtIAfmuF�in `' •�
aCu�ei!a........................................... ......:::
DESKTOP JU PEATURES ................. ......................... .:' ..-.
P�G x,,nw :•r• npact 2 Internsittent 51rea 3:
... ... 809 1f delineated
281 If desktGD
1,090 1f
U limn =7sa wr 250 ............... .......................
(removal for pit construction)
..... ' .. .. isl:n_c 0, 1 ief1 ::::: :......... NCSAM: High
- - - - - - - - - - - - 53 r ' ..::: • :. : - - .Proposed Mitigation Ratio: 1:1
....:::.:...._.----- 1.090 stream credits
Existing Culvert
22 If
LEGEND' MINE FEAT.;.:: ::::............. .
�Rn snnll j, ... •...
- — —E�-W R d. _ PROPaSEOIMPRCTS
�epo:BG lvcass Reeds - - fkl��erxpr. tiuezT�lmpaery
'1W Let Lirve Sellae•• �oelmeaeu YlNlard irtpxd
2W Fr S di �Dw—d Pord:mpecv
' X110 F1 Fe—"I SeAuc� ... .. �be6hmp 9netrit Hrpw:m
Figure 19. Impact 2 — Impacts to Intermittent Stream 3 due to removal for pit construction
'
OELINEAT@P FEATURES
—�uRn.�.=ie�s... eE bra, ::•: :. :::"....... .'------:::
Impact 3 - Perennial Stream a ;
a 249 If delineated
(removal for pit cons truction)
I.QLY fFFMAFycgyam _....... ........ ...... ...........
—C-- NCSAM: High
DESKTUPJU FEATURES ° Proposed Mitigation Rata: 2: ! : - - - - -:... - ... I .::: -. I- I
nv.�xw s�sc.re ' 498 stream credits.............:...._ .....:.._ ' ....... -
lmpact 4.2 •' Intermittent Strearn a - _ : • -
... _ • 211 if delineated : . • • .. .
P a
6 . (re rnovaI for pit ccnstruclion) ..... ::: :
0 1.p =2W kr eau �� ::
NCSAM: Medium :...::::....... _.:. .
Proposed Mitigation Rata: 0.5:1
Impact 5 - Intermittent Stream 9.. 105.5 stream credits .
76.5 If delineated , : :rte– .:............... _ .. .
[removal for pit COnslruction] ; ....... ::.: _ .. _ .:... .
NCSAM:Low ::::::::: :::::::::::'::-- - --:-.....
Proposed Mitigation Rato; 0 npact 4-1.'Intermittent Stream 8r-:
0 stream credits :::::::::::::::::::::...: ::: ' : 337-5 If delineated ; :........... .
[removal for pit construction] _
NCSAM: Medium ":...•..•....
.. - . .. . - Proposed Mitigation Rato. 0-5-1
16 8.7 5 strcenT ;.rr_dlts
LEGEND: MINE FEATURES • • • • • • • ' •_ _
Cwunh pmW Si. -.. -• ...... PROFDS€D IMPACTS
�, Fn Snell �• :::::.::::. :: :::: .....:::.... _ .x.ine�e Sean •mparn.
W[Ec Poch nrgg . . . ' . . • . . . . ...�C ineauu NnfnAnu vrp b
F, .wa Rwu. - - - --- - - - --- - - • - - ... ... ......... ��xocemeo Pard ,o�+.
Figure 20. Impacts 3 — 5. Impacts to Intermittent and Perennial Stream 8 and Intermittent
Stream 9 due to removal for pit construction.
Page 46 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
FEi.1 UR...................__..............................................................
DELINERTEp E5............................................................... .....................
-HDR De -1.,: iirrs ... .. .."• .. .... .. :......::.........................................•
IIIIIIIII1H1]R fx.rc— -- Wenme: ....................... ................................................................ .
10 -Ye FEM Fmpi. .... .... ....................................................
�4YeM.......':................................................................ .............
:
DESKTOP JO FEAlLrR6S " ... ...... _ _ .. .. .... .. .. .....:.. . :ilmpact 7 • Intermittent Stream 1 1
........................................ ....... ............
::.....:................ 36 H delineated ..: l
M_� * vw we -, ::: :: :: :::::: ' : ' : : (removal for pit cons(ruction}
. 1 NCSAM' High
0 1ix 7w bo A Proposed Mitigation Rato 171
J[mo
-. '_-"... ...... 30 stream credits.......pact B - Intermittent Stream 1 Q0 It delineated , , , , .. ' moval for pit construct on} .. _ . - •.•SAM: High :: ...... posed Mitigation Rata: 1:1 :::::......:----:."0 stream credits
::::::....:.-.._.. f
LEGEND-- MINE FEATURES 1_ .................. - _
C-__ P-1.9 .. P ........ . ... . . . ... '• yy PROPOSED IMPACTS
5Tel� • Grircme Stmvn inpun
®M]_-liaM�+ewc ,,//• ��eai�nunJ'M�an'�.ry]eev
�Ea tali I Peevf _ :..:� I; ' _ ��enrcYed Pmdrmpuct
Figure 21. Impacts 6 and 7 — Impacts to Intermittent Streams 10 and 11 due to removal for
pit construction.
Table 12. Potential Impacts on Physical and Chemical Characteristics for Im acts 2 — 7.
Discussion:
Substrate: The proposed pit material would be directly removed from the
following on-site jurisdictional streams: 1,090 linear feet of Intermittent Stream 3,
548.5 linear feet of Intermittent Stream 8, 249 linear feet of Perennial Stream 8,
76.5 linear feet of Intermittent Stream 9, 520 linear feet of Intermittent Stream 10,
and 30 linear feet of Intermittent Stream 11. The existing stream substrate in
these areas would be buried/removed. The discharge would consist of suitable fill
material and would not include any trash, debris, car bodies, asphalt, etc. The fill
Page 47 of 85
Minor
Minor
Physical and Chemical
NSA
No
Negligible
Effect
Effect
Major Effect
Characteristics
Effect
Effect
(Short
(Long
Term)
Term)
Substrate
x
Suspended particulates/
turbidity
X
Water
x
Current patterns and
water circulation
X
Normal water fluctuations
x
Salinity gradients
x
Discussion:
Substrate: The proposed pit material would be directly removed from the
following on-site jurisdictional streams: 1,090 linear feet of Intermittent Stream 3,
548.5 linear feet of Intermittent Stream 8, 249 linear feet of Perennial Stream 8,
76.5 linear feet of Intermittent Stream 9, 520 linear feet of Intermittent Stream 10,
and 30 linear feet of Intermittent Stream 11. The existing stream substrate in
these areas would be buried/removed. The discharge would consist of suitable fill
material and would not include any trash, debris, car bodies, asphalt, etc. The fill
Page 47 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
material would also be free of toxic pollutants in toxic amounts. All fill material
would be clean fill material originating on site from adjacent areas to be mined
and readily available to the applicant. Proper sediment and erosion control
measures would be installed prior to and during construction to ensure that the
substrate of remaining waters of the United States would not change or be
affected.
Suspended particulates/turbidity: During construction, there may be a minimal
increase in suspended particulates that may lead to increased turbidity
downstream. However, the increase would be minimal and temporary due to the
installation and maintenance of proper sediment and erosion control measures
during construction and shortly thereafter.
Water Quality: The proposed discharge of dredge and fill material should not
cause increased chemical contamination levels within the aquatic ecosystem.
Specifically, changes in clarity, color, odor, and taste of water in addition to
possible chemical contamination would be minimized by the applicant's storm
water management and sediment and erosion control plan. The proposed fill
material would consist of clean fill material originating from on site from the
adjacent areas to be mined. The fill material used on-site would be clear and free
of chemical contamination.
Current patterns in water circulation: The proposed discharged dredge and fill
material is not expected to modify downstream current water circulation patterns
by obstructing flow, changing direction or velocity of water, or changing velocity
or flow of circulation.
Normal water fluctuations: For all Impacts 2-7, the affected watersheds are
completely contained within the project area and are relatively small, headwater
catchments. The discharge of fill material associated with this project is not
anticipated to have more than a minimal effect on the downstream hydrologic
regimes.
Page 48 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
Impacts 8 — 16: Those associated with waste rock area construction.
IL
,�.
DELINEATEO FEATURES
—H[]R DH"eaoaa areae. �� •`L`�`��
Ir
�t l
HDR❑ reap
•- loareerFEW rvaIplmn � • � �y' �'��; � r `' r/ ; r �� —
ac�rra,+• w •'= s ! �� �f !r Im ar:t 8-1 - Intermittent Stream 15
DES KTO P JO FEATURES P .::.
312 If delineated
lfa ! (discharge for waste rock storage) ;
ffJlJneuw 1 SSS 111 [ . !!rf/� / NCSAM: Low
Proposed Mitigation Rata: fl�
r g streacredits 1e y ......... r .
i Impact 8-2 - Intermittent Stream 15
Impact 9 - Perennial Stream 15 813.5 If delineated
81 tf delineated – (discharge forwaste rock storage)
(discharge for waste rock storage)
NCSAM: Medium
NCSAM: High Proposed Mitigation Rato: 0.5:1
Proposed Mitigation Rate: 2:1 1406.75 stream credits
182 stream credits +.rprrly� ;` - • • • - -
LEGEND: NNE FEATURES
.......... _ ................. • 7 • i.' �i
Cniw•nlrRlw F4M S _ ......... _ • . _' - .'- . PROPOSED IMPACTS
...::..........:Impact 6'• ....:: _
rre��sea sm,on, a,tin.
�� 1'6afe Pnc• - ::... .....::.......... ... ��elnayee Nell.M ma•en
Li•n^9 Roods � ... - ................. - -Lrinemed FoM fever-ta
�rorKyvd F[cesc � �.caian Btre.m r�ca e
Figure 22. Impacts 8 and 9 — Impacts to Intermittent and Perennial Stream 15 due to
discharge for waste rock storage
DELNEATED FEATURES-
HbR beiewtee svearn . Ina
Impact 10 - Pond 3
-HnRnw�ea�wecvnnl="a. ' 008ac" delineated
='PR U•ino•ree Pwx RMIIgallon required
IOr.Y•gr FEMA Fyn)pl- - '
�C'W—
DESKTOPJOFFATURlS _
neetmF s�.m. .'.-,rFr1 _f�rCjr--
vrnn.eev,�y Nwt wet�,,
= a wo
mrnH=r:
Impact 13- Pe ren nial Strea m 12
55 If desktop
(discharge for waste rock storage) :—=y
NCSAM: High -------
Proposed
_---Proposed Mitigation Rato: 2:1
110 stream credits
----- .
Impact 11 - Interrnittent Stream 1
917 If delineated
(discharge for waste rock sloragl
NCSAM: Medlum
Proposed Mitigation Rato: 0.5:1
4585 stream credits
LEGEND: MINE FEATU REB–
�.,�nlramr Panl s,e • -- – — ��>] I mpacl 12 Perennia] Stream 12V
700 H desktop
Roti l (discharge for waste rack storage)
---ir•nnrRooa. r -NCSAM: High
—+ow•wn��•' ._ • Proposed Mitgation Rato 2:1
1,400 stroam credits _� a• �s
Hq Fr ft— SelexA - - _ t 4 { Iy 51 ., .�•d F+wJ I^Pscia
am n x*awmlw sem•c+
Figure 23. Impacts 10 — 13. Impacts to Intermittent and Perennial Stream 12 due to
discharge for waste rock storage and a sediment and erosion control structure.
Page 49 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
DELINEATED FEATURES
�F P,L�c1 do err ierl ec
�DR Del:—rc S ­—
HDR Da.A"lI4MWN
�HUR 9eBiv� NM.
1W.Yq, FENIA Fqp .
�tA"
DESKTOP Ja FEATURES
De J, Seen
MN..p N NMUM
0 1 meh =100 rest /dl
Impact 14 - Wetland 9
0.14 ac. delineated
[discharge for waste rock
NCWAW High
Proposed Mitigation Rato: 1:1
0.5 acre Wetland credit
'Impact 15 - Pond 4 r
0.08 ac. delineated
LEGEND: MINE FEATURES ` � _
Impact 16 - Intermittent Stream 13
•�oncenvalw ulvil::ta f no mitigation required
240 If delineated
0^^�� (discharge for waste rock storage) �
I� YeunAecF � �
NCSAM: High f / PRO POS ED IMPACTS
°s Proposed Mitigation Rato: 1:1
240 stream credits s K�
1p0 Riot Lime SNW[k - '� �� __ �Da+neenJ NbilaM nmxb
2CU Ft Sbumxe Eemaca .� �/ ` _` � � J -DelreeBeO FbnP loia[1s
_ _ _ ]� FIf�iAenNal3elh�ek� _ �ppp $ueR,n lopv�la
Figure 24. Impacts 14 — 16. Impacts to Wetland 9, Pond 4, and Intermittent Stream 13 due
to discharge for waste rock storage.
Table 13. Potential Imoacts on Phvsical and Chemical Characteristics for Impacts 8 - 16.
Discussion:
Substrate: The proposed waste rock material would be placed directly in the
following on-site jurisdictional streams: 917 linear feet of Intermittent Stream 12,
755 linear feet of Perennial Stream 12, 240 linear feet of Intermittent Stream 8,
76.5 linear feet of Intermittent Stream 9, 240 linear feet of Intermittent Stream 13,
1,125.5 linear feet of Intermittent Stream 15, and 81 linear feet of Perennial
Stream 15. The existing stream substrate in these areas would be
buried/removed. The discharge would consist of suitable fill material and would
Page 50 of 85
Minor
Minor
Physical and Chemical
NSA
No
Negligible
Effect
Effect
Major Effect
Characteristics
Effect
Effect
(Short
(Long
Term)
Term)
Substrate
x
Suspended particulates/
turbidity
X
Water
x
Current patterns and
water circulation
X
Normal water fluctuations
x
Salinity gradients
x
Discussion:
Substrate: The proposed waste rock material would be placed directly in the
following on-site jurisdictional streams: 917 linear feet of Intermittent Stream 12,
755 linear feet of Perennial Stream 12, 240 linear feet of Intermittent Stream 8,
76.5 linear feet of Intermittent Stream 9, 240 linear feet of Intermittent Stream 13,
1,125.5 linear feet of Intermittent Stream 15, and 81 linear feet of Perennial
Stream 15. The existing stream substrate in these areas would be
buried/removed. The discharge would consist of suitable fill material and would
Page 50 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
not include any trash, debris, car bodies, asphalt, etc. The fill material would also
be free of toxic pollutants in toxic amounts. All fill material would be clean fill
material originating on site from adjacent areas to be mined and readily available
to the applicant. Proper sediment and erosion control measures would be
installed prior to and during construction to ensure that the substrate of remaining
waters of the United States would not change or be affected.
Suspended particulates/turbidity: During construction, there may be a minimal
increase in suspended particulates that may lead to increased turbidity
downstream. However, the increase would be minimal and temporary due to the
installation and maintenance of proper sediment and erosion control measures
during construction and shortly thereafter.
Water Quality: The proposed discharge of dredge and fill material should not
cause increased chemical contamination levels within the aquatic ecosystem.
Specifically, changes in clarity, color, odor, and taste of water in addition to
possible chemical contamination would be minimized by the applicant's storm
water management and sediment and erosion control plan. The proposed fill
material would consist of clean fill material originating from on site from the
adjacent areas to be mined. The fill material used on-site would be clear and free
of chemical contamination.
Current patterns in water circulation: The proposed discharged dredge and fill
material is not expected to modify downstream current water circulation patterns
by obstructing flow, changing direction or velocity of water, or changing velocity
or flow of circulation.
Normal water fluctuations: For Impacts 8-16, the affected watersheds are
completely contained within the project area and are relatively small, headwater
catchments. The discharge of fill material associated with this project is not
anticipated to have more than a minimal effect on the downstream hydrologic
regimes.
6.4 Potential impacts on the living communities or human uses (Subparts D, E and
F):
6.4.1 Potential impacts on the biological characteristics of the aquatic ecosystem
(Subpart D 40 CFR 230.30). See Table 14:
Page 51 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
Table 14. Potential Imaacts on Bioloaical Characteristics for all Imaacts
Discussion:
Threatened and endangered species: See Section 10.1.
Fish, crustaceans, mollusks, and other aquatic organisms. Discharges of
dredge and/or fill material in the stream channels on the site would alter the food
web in these locations by impacting animals, such as invertebrates, that make up
the basis of a food chain. The release of contaminants or an increase in turbidity
has the potential to negatively affect certain aspects of the food web
in/downstream/surrounding these areas. Such releases may also potentially
increase the opportunities for exotic species to colonize disturbed areas which
can cause shifts in the makeup of the food web. However, sediment and erosion
control measures would also be implemented to ensure that indirect/secondary
effects to nearby aquatic organisms would also not be impacted. Impacts to
primary food chain production within the waters of the US on the project site is
expected to be minimal and temporary. The project site is similar to surrounding
landscapes and does not represent a rare landscape or contain any unique
landscape elements in general. As such, the activities in on-site waters are not
expected to have more than a minimal/temporary effect on aquatic wildlife as
there is available and similar habitat surrounding the project area for species to
migrate and maintain primary food chain production.
Other wildlife: The discharge of dredge and/or fill material has the potential to
negatively affect breeding and nesting areas, escape cover, travel corridors, and
preferred food sources for resident and migrant wildlife species in the immediate
vicinity of the impact areas. Vegetation and trees would be removed which would
eliminate existing and future habitat for terrestrial and avian species in the area.
However, the avoidance of the FEMA floodplain preserves a forested and
vegetated habitat corridor through the site. As such, the activity is not expected
to have more than a minimal/temporary effect on wildlife as there is available and
similar habitat surrounding the project area for species to migrate.
Page 52 of 85
Minor
Minor
No
Negligible
Effect
EffectMajor
Biological characteristics
N/A
Effect
Effect
(Short
(Long
Effect
Term)
Term)
Threatened and
endangered species
X
Fish, crustaceans, mollusk,
and other aquatic
X
organisms
Other wildlife
X
Discussion:
Threatened and endangered species: See Section 10.1.
Fish, crustaceans, mollusks, and other aquatic organisms. Discharges of
dredge and/or fill material in the stream channels on the site would alter the food
web in these locations by impacting animals, such as invertebrates, that make up
the basis of a food chain. The release of contaminants or an increase in turbidity
has the potential to negatively affect certain aspects of the food web
in/downstream/surrounding these areas. Such releases may also potentially
increase the opportunities for exotic species to colonize disturbed areas which
can cause shifts in the makeup of the food web. However, sediment and erosion
control measures would also be implemented to ensure that indirect/secondary
effects to nearby aquatic organisms would also not be impacted. Impacts to
primary food chain production within the waters of the US on the project site is
expected to be minimal and temporary. The project site is similar to surrounding
landscapes and does not represent a rare landscape or contain any unique
landscape elements in general. As such, the activities in on-site waters are not
expected to have more than a minimal/temporary effect on aquatic wildlife as
there is available and similar habitat surrounding the project area for species to
migrate and maintain primary food chain production.
Other wildlife: The discharge of dredge and/or fill material has the potential to
negatively affect breeding and nesting areas, escape cover, travel corridors, and
preferred food sources for resident and migrant wildlife species in the immediate
vicinity of the impact areas. Vegetation and trees would be removed which would
eliminate existing and future habitat for terrestrial and avian species in the area.
However, the avoidance of the FEMA floodplain preserves a forested and
vegetated habitat corridor through the site. As such, the activity is not expected
to have more than a minimal/temporary effect on wildlife as there is available and
similar habitat surrounding the project area for species to migrate.
Page 52 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
6.4.2 Potential impacts on special aquatic sites (Subpart E 40 CFR 230.40). See Table
15:
Refer to Figure 24 for the only impact to a special aquatic site (Impact 14 —
Wetland 9). This impact is relatively minor at 0.14 acres of fill to Wetland 9.
Table 15. Potential Imnacts on one Snecial Aauatic Site (Wetland 9).
Discussion:
Wetlands: The discharge of dredge and/or fill material has the potential to
negatively affect wetlands on the project site through modification of regime
and/or loss or disruption of ecological function. The project specific activities of
altering the natural drainage regimes or moderating natural flows of streams and
wetlands during mining operations may also cause increased flows causing more
permanent flooding of wetlands. Alternatively, the alteration of natural drainage
regimes may cause reduced groundwater and overland flows, which may cause
the opposite effect by reducing the hydrologic function of on-site wetlands. It
should be noted that this wetland has been degraded by domestic animal grazing
(cattle, donkey) and has diminished functional value. Sediment and erosion
control measures would be implemented to ensure that increased flows do not
negatively inundate on-site and nearby wetlands. Additionally, the capture of
normal stormwater and construction runoff and subsequent treatment and
discharge as required by NCDEQ DEMLR under the General Permit (No.
NCG020000) for Mining Activities would also ensure the reduction of hydrologic
regimes would not negatively affect on-site and nearby wetlands. Impacts to
wetlands within the project are expected to be minimal and temporary.
The project proposes only one wetland impact, consisting of 0.14 acre of
permanent impact to Wetland 9. The discharge of fill material for a waste rock
area will permanently affect this wetland; however, the applicant is proposing a
2:1 mitigation ratio for this impact, which would be a 0.5 acre wetland credit. The
mitigation proposed for this impact allows for a no net loss of wetlands and
effectively mitigates for an almost 30% larger wetland area. Therefore, the overall
impact to this wetland is negligible.
Page 53 of 85
Minor
Minor
No Negligible Effect
Effect
Special Aquatic Sites N/A
Effect Effect (Short
Major Effect
(Long
Term)
Term)
Sanctuaries and refuges x
Wetlands
x
Mud flats x
Vegetated shallows x
Coral reefs x
Discussion:
Wetlands: The discharge of dredge and/or fill material has the potential to
negatively affect wetlands on the project site through modification of regime
and/or loss or disruption of ecological function. The project specific activities of
altering the natural drainage regimes or moderating natural flows of streams and
wetlands during mining operations may also cause increased flows causing more
permanent flooding of wetlands. Alternatively, the alteration of natural drainage
regimes may cause reduced groundwater and overland flows, which may cause
the opposite effect by reducing the hydrologic function of on-site wetlands. It
should be noted that this wetland has been degraded by domestic animal grazing
(cattle, donkey) and has diminished functional value. Sediment and erosion
control measures would be implemented to ensure that increased flows do not
negatively inundate on-site and nearby wetlands. Additionally, the capture of
normal stormwater and construction runoff and subsequent treatment and
discharge as required by NCDEQ DEMLR under the General Permit (No.
NCG020000) for Mining Activities would also ensure the reduction of hydrologic
regimes would not negatively affect on-site and nearby wetlands. Impacts to
wetlands within the project are expected to be minimal and temporary.
The project proposes only one wetland impact, consisting of 0.14 acre of
permanent impact to Wetland 9. The discharge of fill material for a waste rock
area will permanently affect this wetland; however, the applicant is proposing a
2:1 mitigation ratio for this impact, which would be a 0.5 acre wetland credit. The
mitigation proposed for this impact allows for a no net loss of wetlands and
effectively mitigates for an almost 30% larger wetland area. Therefore, the overall
impact to this wetland is negligible.
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6.4.3 Potential impacts on human use characteristics (Subpart F 40 CFR 230.50). See
Table 16
Table 16. Potential Imaacts on Human Use Characteristics
Discussion:
Municipal and private water supplies: Municipal water does not serve the area
or the project site. Wells are the primary source of drinking water and other water
needs in the area.
The proposed project is expected to need approximately 600-800 gallons per
minute and will be supplemented by collecting on-site stormwater runoff for a
closed circuit recirculating water supply, before being treated and discharged. If
the project demands water in excess of what is naturally produced on site, then a
high capacity well or stream withdraw permit may be needed (and appropriately
permitted, as applicable).
The applicant's environmental consultant has installed five groundwater
monitoring wells, four groundwater observation wells, and one groundwater
pumping wells to facilitate periodic groundwater level, water quality monitoring,
and aquifer testing throughout the site. Measurements have been taken monthly
starting July 2018 and will be measured through July 2019. The purpose of these
studies is to determine if the mining activities will have an effect on the area's
aquifer and groundwater supply. The results will be shared once complete.
At this time, groundwater supply in the surrounding area is not expected to
increase or decrease due to activities at the proposed project site.
Page 54 of 85
Minor
Minor
Human Use
NSA
No
Negligible
Effect
Effect
Major Effect
Characteristics
Effect
Effect
(Short
(Long
Term)
Term)
Municipal and private
water supplies
x
Recreational and
commercial fisheries
x
Water -related recreation
x
Aesthetics
x
Parks, national and
historical monuments,
national seashores,
wilderness areas,
x
research sites, and
similar preserves
Discussion:
Municipal and private water supplies: Municipal water does not serve the area
or the project site. Wells are the primary source of drinking water and other water
needs in the area.
The proposed project is expected to need approximately 600-800 gallons per
minute and will be supplemented by collecting on-site stormwater runoff for a
closed circuit recirculating water supply, before being treated and discharged. If
the project demands water in excess of what is naturally produced on site, then a
high capacity well or stream withdraw permit may be needed (and appropriately
permitted, as applicable).
The applicant's environmental consultant has installed five groundwater
monitoring wells, four groundwater observation wells, and one groundwater
pumping wells to facilitate periodic groundwater level, water quality monitoring,
and aquifer testing throughout the site. Measurements have been taken monthly
starting July 2018 and will be measured through July 2019. The purpose of these
studies is to determine if the mining activities will have an effect on the area's
aquifer and groundwater supply. The results will be shared once complete.
At this time, groundwater supply in the surrounding area is not expected to
increase or decrease due to activities at the proposed project site.
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Recreational and commercial fisheries: The on-site stream channels are not
part of or any close proximity to any recreation or commercial fishery. Therefore,
the project would not affect these resources/uses.
Water -related recreation: Activities taking place at the proposed project site
would not increase or decrease waterborne recreation ion, or in the vicinity of the
project. The stream channels that would be impacted by the project are not used
for water related recreation. Therefore, the project would not affect these
resources/uses.
Aesthetics: The project area is in a rural residential and rural agricultural area.
The project may have short term, minor effects to the aesthetics of the area.
However, the North Carolina Division of Mining requires a minimum of 25 feet of
natural (vegetated) screening between the boundary and mining operations.
Additionally, Gaston County requires 300 -foot setback buffers from the boundary
as well. The 25 -foot natural screening buffer will be left as is (i.e. not cleared and
remaining in its current state pre -mining operations) and a berm will be built from
stripping material between the 25- and 300 -foot buffer areas. The berm will serve
as a visual screen and the natural 25 -foot vegetated natural buffer will act as an
aesthetic buffer as well. Therefore, the aesthetics of the area will only experience
minor and short term effects.
6.5 Pre -testing evaluation (Subpart G, 40 CFR 230.60):
The following has been considered in evaluating the biological availability of
possible contaminants in dredged or fill material. See Table 17:
Table 17. Possible Contaminants in Dredaed/Fill Material
Physical characteristics
Hydrography in relation to known or anticipated sources of contaminants
Results from previous testing of the material or similar material in the vicinity of the
project
Known, significant sources of persistent pesticides from land runoff or percolation
Spill records for petroleum products or designated (Section 331 of CWA) hazardous
substances
Other public records or significant introduction of contaminants from industries,
municipalities, or other sources
Known existence of substantial material deposits of substances which could be released
in harmful quantities to the aquatic environment by man -induced discharge activities
Discussion:
It has been determined that testing is not required because the discharge and
extraction sites are adjacent, subject to the same sources of contaminants and
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have substantially similar materials. Although the discharge material may be a
carrier of contaminants, it is not likely to degrade the disposal site.
The applicant has engaged a consultant to provide a sampling and analysis plan
that will identify and assess potential contaminants associated with the proposed
waste rock disposal areas. Testing is currently underway and results will be
provided once complete. At that time if contaminants are determined present,
then a mitigation plan will be developed, as necessary. The applicant's
environmental consultant also conducted research at the NC Division of Mining
office to determine if historical, similar mining sites provided substantive evidence
that mines of this type were known to have contaminants. Of two sites
researched, neither were known be sources of harmful contaminants.
6.6 Evaluation and testing (Subpart G, 40 CFR 230-61):
Discussion: N/A
6.7 Actions to minimize adverse impacts (Subpart H). The following actions, as
appropriate, have been taken through application of 40 CFR 230.70-230.77 to
ensure minimal adverse effects of the proposed discharge. See Table 18:
Table 18_ Actions to Ensure Adverse Effects are Minimized
Actions concerning the location of the discharge
x
Actions concerning the material to be discharged
x
Actions controlling the material after discharge
x
Actions affecting the method of dispersion
x
Actions affecting plant and animal populations
x
Actions affecting human use
x
Discussion:
Actions concerning the location of the discharges: The discharge of fill
material has been designed to minimize or prevent the creation of standing
bodies of water and provide for normal flow of water, the extent of any plume,
and the disruption of periodic water inundation patterns. The material to be
discharged would be similar to the existing site substrate but mixed due to the
nature of mining.
Actions concerning the material to be discharged: The fill material would
consist of waste rock and top soil taken from onsite. The fill material would be
free of toxic pollutants in toxic amounts. The rock is not expected to contain
natural constituents that are toxic or could become toxic and/or bioavailable as a
result of the discharge. This would ensure that physiochemical conditions are
maintained and the potency and availability of pollutants are reduced.
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Actions controlling the material after discharge: The fill material would be
stabilized after discharge to prevent erosion and slumping by using grade
controls; sediment containment fencing; cover seeding; sediment basins; and
storm water controls.
Actions affecting the method of dispersion: Sediment fencing, sediment
basins, and dewatering structures would aid in minimizing the potential of the fill
material to disperse.
Actions affecting plant and animal populations: Fill material would be placed
in disposal sites that would contain no flow or be dewatered prior to the
placement of fill and aquatic life movement would be negligible. The activities in
waters of the U.S. are not expected to create habitat conducive to the
development of undesirable predators or species which have a competitive edge
ecologically over indigenous plants or animals. The project site is similar to
surrounding landscapes and does not represent a rare landscape or contain any
unique landscape elements in general; thus, the surrounding area is
representative of similar plant and animal populations on the project site and the
activities in waters of the U.S. would have minimal effects to plant and animal
populations relative to their presence in the surrounding area.
Actions affecting human use: The proposed project site is located outside of
public and private water intakes. Procedures for discharging fill material would
minimize the disturbance of aesthetic features of the aquatic resources onsite.
The activities in waters of the U.S. are internal to the project site and are
generally not visible, accessible, or considered aesthetically pleasing to humans.
6.8 Factual Determinations (Subpart B, 40 CFR 230.11). The following
determinations are made based on the applicable information above, including
actions to minimize effects and consideration for contaminants. See Table 19:
Table 19. Factual Determinations of Potential Impacts
Page 57 of 85
Minor
Minor
No
Negligible
Effect
Effect
Site
N/A
Effect
Effect
(Short
(Long
Major Effect
Term)
Term)
Physical substrate
x
Water circulation,
fluctuation and salinity
x
Suspended
particulates/turbidity
x
Contaminants
x
Aquatic ecosystem and
organisms
X
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CE SAW -RG -C (File Number, SAW 2018-01129)
Discussion:
Physical substrate: A stream crossing will be installed directly in Perennial
Stream 2. The substrate in this area would be buried and aquatic functions
eliminated. The discharge would consist of a RCP that is yet to be designed. All
work will be conducted in the dry. The pit material and waste rock would be
placed directly in 4,547.5 linear feet of onsite intermittent stream and 1,208 linear
feet of perennial stream. The substrate in these areas would be buried and
aquatic functions eliminated. The discharge would consist of onsite pit material
and waste rock and would not include any trash, debris, car bodies, asphalt, etc.
The fill material would also be free of toxic pollutants in toxic amounts. Proper
sediment and erosion control measures would be installed prior to and during
construction to ensure that the substrate of all remaining waters on the property
would not be change or affected.
Water circulation, fluctuation, and salinity: The proposed discharged dredge
and fill material is not expected to modify current downstream water circulation
patterns by obstructing flow, changing direction or velocity of water, or changing
velocity or flow and circulation. This project is not anticipated to have more than a
minimal effect on the downstream hydrologic regimes associated with naturally
occurring hydro -period fluctuations. On-site storm water management facilities
would ensure that downstream hydro periods are not altered beyond minimal
levels. Because this project is located inland and away from tidally influenced
waters and wetlands, no modification to the salinity of on-site or adjacent waters
is expected.
Suspended particulates/turbidity: During construction activities on the site,
there may be a minimal increase in suspended particulates that may lead to
increased turbidity downstream. However, the increase would be minimal and
temporary due to the installation and maintenance of proper sediment and
erosion control measures before and during mine operation.
Contaminants: The proposed discharge of dredge and fill material should not
cause increased chemical contamination levels within the aquatic ecosystem.
Page 58 of 85
Minor
Minor
No
Negligible
Effect
Effect
Site
N/A
Effect
Effect
(Short
(Long
Major Effect
Term)
Term)
Proposed disposal site
x
Cumulative effects on the
aquatic ecosystem
x
Secondary effects on the
aquatic ecosystem
X
Discussion:
Physical substrate: A stream crossing will be installed directly in Perennial
Stream 2. The substrate in this area would be buried and aquatic functions
eliminated. The discharge would consist of a RCP that is yet to be designed. All
work will be conducted in the dry. The pit material and waste rock would be
placed directly in 4,547.5 linear feet of onsite intermittent stream and 1,208 linear
feet of perennial stream. The substrate in these areas would be buried and
aquatic functions eliminated. The discharge would consist of onsite pit material
and waste rock and would not include any trash, debris, car bodies, asphalt, etc.
The fill material would also be free of toxic pollutants in toxic amounts. Proper
sediment and erosion control measures would be installed prior to and during
construction to ensure that the substrate of all remaining waters on the property
would not be change or affected.
Water circulation, fluctuation, and salinity: The proposed discharged dredge
and fill material is not expected to modify current downstream water circulation
patterns by obstructing flow, changing direction or velocity of water, or changing
velocity or flow and circulation. This project is not anticipated to have more than a
minimal effect on the downstream hydrologic regimes associated with naturally
occurring hydro -period fluctuations. On-site storm water management facilities
would ensure that downstream hydro periods are not altered beyond minimal
levels. Because this project is located inland and away from tidally influenced
waters and wetlands, no modification to the salinity of on-site or adjacent waters
is expected.
Suspended particulates/turbidity: During construction activities on the site,
there may be a minimal increase in suspended particulates that may lead to
increased turbidity downstream. However, the increase would be minimal and
temporary due to the installation and maintenance of proper sediment and
erosion control measures before and during mine operation.
Contaminants: The proposed discharge of dredge and fill material should not
cause increased chemical contamination levels within the aquatic ecosystem.
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Specifically, changes in clarity, color, odor, and taste of water in addition to
possible chemical contamination would be minimal. All discharges of dredge and
fill material would be controlled with a sediment and erosion control plan. The pit
material and waste rock that would be discharged would be taken from on-site
areas. The material would be clear and free of chemical contamination.
Proposed disposal sites: The discharges for the impacts associated with the
waste rock areas would be controlled and confined to fill areas and constructed
in the dry to the maximum extent possible. All fill placed would be contained
using sediment and erosion control measures. Some minor and short term
suspended sediment plumes and related turbidity in adjacent waters may occur
due to sediment movement as a result of the construction during heavy rainfall
events.
Cumulative effects on the aquatic ecosystem: See Section 9.0.
Secondary effects on the aquatic ecosystem: See Section 9.0.
6.9 Findings of compliance or non-compliance with the restrictions on discharges (40
CFR 230.10(a -d) and 230.12). Based on the information above, including the
factual determinations, the proposed discharge has been evaluated to determine
whether any of the restrictions on discharge would occur. See Table 20:
Table 20. Compliance with Restrictions on Discharge
Subject
Yes
No
1. Is there a practicable alternative to the proposed discharge that would be less
x
damaging to the environment (any alternative with less aquatic resource effects,
or an alternative with more aquatic resource effects that avoids other significant
adverse environmental consequences?)
2. Will the discharge cause or contribute to violations of any applicable water
quality standards?
x
3. Will the discharge violate any toxic effluent standards (under Section 307 of the
Act)?
x
4. Will the discharge jeopardize the continued existence of endangered or
threatened species or their critical habitat?
x
5. Will the discharge violate standards set by the Department of Commerce to
protect marine sanctuaries?
x
6. Will the discharge cause or contribute to significant degradation of waters of the
U.S.?
x
7. Have all appropriate and practicable steps (Subpart H, 40 CFR 230.70) been
taken to minimize the potential adverse impacts of the discharge on the aquatic
x
ecosystem?
Discussion:
1) See Section 5.
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CE SAW -RG -C (File Number, SAW 2018-01129)
2) A 401 Water Quality Certification was submitted on December 31, 2018 and
is pending review.
3) A 401 Water Quality Certification was submitted on December 31, 2018 and
is pending review.
4) See Section 10.1.
5) The project area is not within a marine sanctuary.
6) See Sections 6 and 8.
7) Section 1.3.1.
7.0 General Public Interest Review (33 CFR 320.4 and RGL 84-09)
The decision whether to issue a permit will be based on an evaluation of the
probable impacts, including cumulative impacts, of the proposed activity and its
intended use on the public interest as stated at 33 CFR 320.4(a). To the extent
appropriate, the public interest review below also includes consideration of
additional policies as described in 33 CFR 320.4(b) through (r). The benefits
which reasonably may be expected to accrue from the proposal are balanced
against its reasonably foreseeable detriments.
7.1 All public interest factors have been reviewed and those that are relevant to the
proposal are considered and discussed in additional detail. See Table 21 and
any discussion that follows.
Table 21. Public Interest Factors
Page 60 of 85
Effects
d
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m
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Factorsc
2
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Z
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Z r+
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d
Q
Z
m
C
Z
1. Conservation: See below for discussion.
x
2. Economics: See below for discussion.
x
3. Aesthetics: See below for discussion.
x
4. General Environmental Concerns: See below for discussion.
x
5. Wetlands: See below for discussion.
X
6. Historic Properties: See Section 10.3
x
7. Fish and Wildlife Values: See below for discussion.
x
8. Flood Hazards: See below for discussion.
x
9. Floodplain Values: See below for discussion.
x
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CE SAW -RG -C (File Number, SAW 2018-01129)
Additional discussion of effects on factors above:
Conservation: The proposed project has committed to avoid disturbance in the
FEMA 100 -year floodplains within the project boundary.
Economics: The project would provide an overall benefit to the local economy.
The project would provide work for local labor forces in the Charlotte/Gastonia
metro area, including Cherryville and northwest Gaston County. It would also
provide a competitive source of lithium which would likely keep lithium prices in
the domestic market area relatively low. According to the applicant, the
appropriate economic evaluations have been completed and the project as
proposed is economically viable.
Aesthetics: The project area is in a rural residential and rural agricultural area
and the project may have short term, minor effects to the aesthetics of the area.
Page 61 of 85
Effects
m
M
a,
2
Factorsc
E
Z
L
Z �r
d
Q
Z
in
O
Z
10. Land Use: See below for discussion.
x
11. Navigation: The project area does not contain navigable
waters and the proposed project is not expected to indirectly or
directly affect navigation.
x
12. Shoreline Erosion and Accretion: The project area does not
contain shoreline.
x
13. Recreation: The project area is not recreation in nature and is
not expected to affect current recreational activities as the project
x
area is privately held land.
14. Water Supply and Conservation: See below for discussion.
x
15. Water Quality: See below for discussion.
x
16. Energy Needs: See below for discussion.
x
17. Safety: See below for discussion.
x
18. Food and Fiber Production: See below for discussion.
x
19. Mineral Needs: See below for discussion.
x
20. Consideration of Property Ownership: See below for
discussion.
x
21. Needs and Welfare of the People: See below for discussion.
x
Additional discussion of effects on factors above:
Conservation: The proposed project has committed to avoid disturbance in the
FEMA 100 -year floodplains within the project boundary.
Economics: The project would provide an overall benefit to the local economy.
The project would provide work for local labor forces in the Charlotte/Gastonia
metro area, including Cherryville and northwest Gaston County. It would also
provide a competitive source of lithium which would likely keep lithium prices in
the domestic market area relatively low. According to the applicant, the
appropriate economic evaluations have been completed and the project as
proposed is economically viable.
Aesthetics: The project area is in a rural residential and rural agricultural area
and the project may have short term, minor effects to the aesthetics of the area.
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CE SAW -RG -C (File Number, SAW 2018-01129)
However, there will be 300 -foot setback buffers from surrounding properties.
Additionally, rezoning applications will be made as necessary to observe local
rezoning regulations. Through the 300 -foot buffer setback and land use rezoning,
the project is not expected to diminish the aesthetic value of the area or cause
disharmony from an aerial or neighboring view.
General Environmental Concerns: All applicable federal, state, and local laws
and regulations would be observed, and construction would not commence
before applicable permit approvals. The proposed project would occur within the
realm of those constraints, which are put in place to make sure minimal effects
occur. Additionally, mitigation for stream and wetland impacts ensures a no net
loss of aquatic resources. A Stormwater Pollution Prevention Plan under the
General Permit (No. NCG020000) for Mining Activities would also ensure that the
proposed project would not negatively affect remaining on-site and downstream
streams and wetlands.
Wetlands: The wetlands found on the project site are typical for the
physiographic region. Sediment and erosion control measures would be
implemented to ensure that increased flows do not negatively inundate on-site
and nearby wetlands. Additionally, the capture of normal stormwater and
construction runoff and subsequent treatment and discharge as required by
NCDEQ DEMLR under the General Permit (No. NCG020000) for Mining
Activities would also ensure the reduction of hydrologic regimes would not
negatively affect on-site and nearby wetlands. Finally, as compensatory
mitigation will be required for wetlands impact, there is effectively no net loss of
wetlands with activities association with this project. Impacts to wetlands within
the project are expected to be minimal and temporary.
Fish and Wildlife Values: The terrestrial and aquatic species found on the
project site are typical for the physiographic region. In order to construct the
proposed facility, the vegetation in this area would be removed with typical
mechanized land clearing equipment. This vegetation in the form of wooded
buffers and transitional/fallow fields provides habitat for small mammals, reptiles,
birds, insects, etc. A majority of these species can and would probably relocate
to surrounding/adjacent habitats once construction activities begin on the site.
Flood Hazards: Due to the relatively small sizes of the watersheds per each
impact area (i.e. all headwater catchment areas), the proposed activities within
the project boundary are not expected to increase or decrease the natural rate of
flooding at the site or downstream. Therefore, no effects are anticipated.
Floodplain Values: There is a mapped floodplain and floodway on Beaverdam
and Little Beaverdam Creeks that bisect the project site. However, all site
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CE SAW -RG -C (File Number, SAW 2018-01129)
development would take place outside of the designated 100 -year floodplain and
floodway. Therefore, no effects are anticipated.
Land Use: The proposed project would be in compliance with local zoning
regulations and ordinances and/or rezoning would be applicable. Therefore, no
effect is anticipated.
Water Supply and Conservation: The proposed project would utilize existing
water sources but it is not expected to substantially affect the availability of water
in this area. Private water supply in the surrounding area is not expected to
increase or decrease due to activities at the proposed project site. Private water
supply servicing the project is expected to range about 600-800 gallons per
minute and will be supplemented by collecting on-site stormwater runoff for a
closed circuit recirculating water supply, before being treated and discharged. If
the project demands water in excess of what is natural produced on site, then a
high capacity well or stream withdraw permit may be needed (and appropriately
permitted, as applicable).
Water Quality: The proposed discharge of dredge and fill material should not
cause increased chemical contamination levels within the aquatic ecosystem.
Specifically, changes in clarity, color, odor, and taste of water in addition to
possible chemical contamination would be minimized by the applicant's storm
water management and sediment and erosion control plan. The proposed fill
material would consist of clean fill material originating from on site from the
adjacent areas to be mined. The fill material used on-site would be clear and free
of chemical contamination. The applicant's environmental consultant has
installed five groundwater monitoring wells, four groundwater observation wells,
and one groundwater pumping well to facilitate baseline monitoring.
Energy Needs: Rutherford Electric Membership Corporation (EMC), has an
easement within the project boundary. The applicant and Rutherford EMC are
coordinating a substation install to occur within the concentrator plant site. From
this interface point, all electricity needs would be provided to the site. As the
easement for the utility in place, additional energy needs for the area were
expected. Therefore, no impacts to energy needs in the area are anticipated. The
easement and subsequent aerial transmission line will not cause any impacts to
jurisdictional features.
Safety: The proposed project would be designed and operated in accordance
with federal, state, local, and MSHA laws and regulations that address issues of
public safety. Therefore, the proposed activity is not expected to affect public
safety.
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Food and Fiber Production: The project site is currently a mix of forestry, rural
residential, and agricultural land uses. Development of the proposed project
would result in the conversion of agricultural land and forestry land to a
commercial mining operation. However, agricultural lands form only a small part
of the project area. There are extensive agricultural lands available in Gaston
County. Therefore, the Corps believe the project would have a negligible on food
and fiber production.
Needs and Welfare of the Public: The proposed project would positively
address the needs and welfare of the public by providing a competitive source of
lithium to the domestic market. Also, new jobs at the mine would boost the
Charlotte/Gastonia metro area economy, including Cherryville and northwest
Gaston County.
Mineral Needs: The proposed project would positively address the need for a
domestic source of lithium by targeting the extraction of mineralized spodumene.
The mineral needs for this project is the identified pit shell areas where
mineralized spodumene has been indicated.
Consideration of property ownership: The properties within the project
boundary are 78% controlled by the applicant at the time of this submission.
Negotiations are currently ongoing for control of the remaining 22%. The
applicant is confident that 100% control will occur in 2019.
7.1.1 Climate Change. The proposed activities within the Corps federal control and
responsibility likely will result in a negligible release of greenhouse gases into the
atmosphere when compared to global greenhouse gas emissions. Greenhouse
gas emissions have been shown to contribute to climate change. Aquatic
resources can be sources and/or sinks of greenhouse gases. For instance,
some aquatic resources sequester carbon dioxide whereas others release
methane; therefore, authorized impacts to aquatic resources can result in either
an increase or decrease in atmospheric greenhouse gas. These impacts are
considered de minimis and are negated through compensatory mitigation.
Greenhouse gas emissions associated with the Corps' federal action may also
occur from the combustion of fossil fuels associated with the operation of
construction equipment, increases in traffic, etc. The Corps has no authority to
regulate emissions that result from the combustion of fossil fuels. These are
subject to federal regulations under the Clean Air Act and/or the Corporate
Average Fuel Economy (CAFE) Program. Greenhouse gas emissions from the
Corps action have been weighed against national goals of energy independence,
national security, and economic development and determined not contrary to the
public interest.
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7.2 The relative extent of the public and private need for the proposed structure or
work:
The proposed project serves the private need of the applicant to create a
profitable business by entering the domestic lithium market, but also serves the
public need for a domestic source of lithium to insulate domestic prices in a
global market.
7.3 If there are unresolved conflicts as to resource use, explain how the practicability
of using reasonable alternative locations and methods to accomplish the
objective of the proposed structure or work was considered.
Discussion: There are no unresolved conflicts identified as to resource use.
7.4 The extent and permanence of the beneficial and/or detrimental effects that the
proposed work is likely to have on the public and private use to which the area is
suited:
Detrimental effects are expected to be minimal and temporary.
Beneficial effects are expected to be minimal and temporary.
Based on the analysis above there would be minimal/negligible detrimental
effects to aquatic/other biological/terrestrial resources on the site when compared
to the beneficial effects on the human uses/characteristics and public interest.
8.0 Mitigation(33 CFR 320.4(r), 33 CFR Part 332, 40 CFR 230.70-77, 40 CFR
1508.20 and 40 CFR 1502.14)
8.1 Avoidance and Minimization: When evaluating a proposal including regulated
activities in waters of the United States, consideration must be given to avoiding
and minimizing effects to those waters. Avoidance and minimization measures
are described above in Sections 1 and 3.
Were any other mitigative actions including project modifications discussed with
the applicant implemented to minimize adverse project impacts? (see 33 CFR
320.4(r)(1)(i)) Yes
The applicant engaged its environmental consultants to provide the expertise of
conducting threatened and endangered species surveys pursuant to Section
7(a)(2) of the Endangered Species Act, conducting a cultural resources survey
pursuant to Section 6 of the National Historic Preservation Act, conducting
groundwater, aquifer, and water quality monitoring for baseline environmental
conditions, and pre-emptive testing of waste rock/tailings material for potential
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contaminants. Results of all studies have been or will be provided once
completed.
8.2 Is compensatory mitigation required to offset environmental losses resulting from
proposed unavoidable impacts to waters of the United States? Yes
Provide rationale:
As there is over 300 linear feet of stream channel proposed for impacts,
compensatory mitigation is required to offset the unavoidable impacts to waters
of the U.S.
8.3 Type and location of compensatory mitigation
8.3.1 Is the impact in the service area of an approved mitigation bank? No
If yes, does the mitigation bank have appropriate number and resource type of
credits available? N/A
8.3.2 Is the impact in the service area of an approved in -lieu fee program? Yes
If yes, does the in -lieu fee program have the appropriate number and resource
type of credits available? Yes
8.3.3 Selected compensatory mitigation type/location(s). See Table 22:
apse 11. mitigation i ype ana Location
Mitigation bank credits
In -lieu fee program credits x
Permittee -responsible mitigation under a watershed approach
Permittee -responsible mitigation, on-site and in-kind
Permittee -responsible mitigation, off-site and/or out of kind
8.3.4 Does the selected compensatory mitigation option deviate from the order of the
options presented in §332.3(b)(2)-(6)? No
If yes, provide rationale for the deviation, including the likelihood for ecological
success and sustainability, location of the compensation site relative to the
impact site and their significance within the watershed, and/or the costs of the
compensatory mitigation project (see 33 CFR §332.3(a)(1)): N/A
8.4 Amount of compensatory mitigation:
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CE SAW -RG -C (File Number, SAW 2018-01129)
The North Carolina Stream and Wetland Assessment Methodologies (NCSAM
and NCWAM) were utilized to determine functional scores for features that would
be impacted. These functional scores were then assigned ratios that would
determine amount of mitigation required.
The following mitigation ratios are proposed:
NCSAM
• 2:1 for perennial channels that scored `High' (1,263 linear feet for 2,526
credits);
• 1:1 for intermittent channels that scored `High" (1,880 linear feet for 1,880
credits);
• 0.5:1 for intermittent channels that scored `Medium' (2,279 linear feet for
1,139.5 credits); and
• 0:1 for intermittent channels that scored `Low" (two reaches of stream that
are degraded due to agricultural and husbandry practices (388.5 linear
feet of stream for 0 credits).
NCWAM
• 2:1 for wetlands that scores `High' (0.14 acre for 0.5 acre of wetland).
Rationale for required compensatory mitigation amount: The current project
impacts are beyond any threshold that would be considered individually minimal.
Various compensatory mitigation ratios are proposed. See Table 23 for a
summary of proposed mitigation rationale. The NCSAM and NCWAM data forms
and the NCDWQ Stream Identification Forms are attached to this submittal.
Table 23. Proposed mitigation ratios.
Impact #
Feature
NCSAM/
NCWAM
Score
Ratio
Amount of
Impact
Credits
Proposed
Impact 1
Perennial Stream 2
High
2:1
178 If
356
Impact 2
Intermittent Stream 3
High
1:1
1,090 If
1,090
Impact 3
Perennial Stream 8
High
2:1
249 If
498
Impact 4-1
Intermittent Stream 8
Medium
0.5:1
337.5 If
168.75
Impact 4-2
Medium
0.5:1
211 If
105.5
Impact 5
Intermittent Stream 9
Low
0
76.5 If
0
Impact 6
Intermittent Stream 10
High
1:1
520 If
520
Impact 7
Intermittent Stream 11
High
1:1
30 If
30
Impact 8-1
Intermittent Stream 15
Low
0
312 If
0
Impact 8-2
Medium
0.5:1
813.5 If
406.75
Page 67 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
Impact #
Feature
NCSAM/
NCWAM
Score
Ratio
Amount of
Impact
Credits
Proposed
Impact 9
Perennial Stream 15
High
2:1
81 If
162
Impact 11
Intermittent Stream 12
Medium
1:1
917 If
548.8
Impact 12
Perennial Stream 12
High
2:1
700 If
1,400
Impact 13
Perennial Stream 12
High
2:1
55 If
110
Impact 14
Wetland 9
High
2:1
0.14 ac
0.5
Impact 16
Intermittent Stream 13
High
1:1
240 If
240
Total Perennial Streams:
1,263 If
2,526
Total Intermittent Streams:
4,547.5 If
3,019.5
Stream Totals:
5,810.5 If
5,545.5
Wetland Totals:
0.14 ac.
0.5
8.5 For permittee responsible mitigation identified in 9.3.3 above, the final mitigation
plan must include the items described in 33 CFR 332.4(c)(2) through (c)(14) at a
level of detail commensurate with the scale and scope of the impacts. As an
alternative, the district engineer may determine that it would be more appropriate
to address any of the items described in (c)(2) through (c)(14) as permit
conditions, instead of components of a compensatory mitigation plan. Presence
of sufficient information related to each of these requirements in the applicant's
mitigation plan is indicated by "Yes" in Table 21. "No" indicates absence or
insufficient information in the plan, in which case, additional rationale must be
provided below on how these requirements will be addressed through special
conditions or why a special condition is not required:
Table 24. Perm itee-Responsible Mitigation Plan Requirements
Requirement Yes No
Objectives
Site selection
Site protection instrument
Baseline information
Determination of credits
Mitigation work plan
Maintenance plan
Performance standards
Monitoring requirements
Long-term management plan
Adaptive management plan
Financial assurances
Other
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CE SAW -RG -C (File Number, SAW 2018-01129)
For any "No", provide rationale on how the subject component(s) of the
compentatory mitigation plan will be addressed as special conditions or why no
special conditions are required: Provide discussion here
9.0 Consideration of Cumulative Impacts
(40 CFR 230.11(g) and 40 CFR 1508.7, RGL 84-9) Cumulative impact is the
impact on the environment which results from the incremental impact of the
action when added to other past, present, and reasonably foreseeable future
actions regardless of what agency (Federal or non -Federal) or person
undertakes such other actions. Cumulative impacts can result from individually
minor direct and indirect but collectively significant actions taking place over a
period of time. A cumulative effects assessment should consider how the direct
and indirect environmental effects caused by the proposed activity requiring DA
authorization (i.e., the incremental impact of the action) contribute to cumulative
effects, and whether that incremental contribution is significant or not. .
9.1 Identify/describe the direct and indirect effects caused by the proposed activity:
The direct effects of the proposed activity in waters would include the loss of
jurisdictional waters (as specified in Section 1.3) and their associated aquatic
resource functions. The proposed activities also have the potential to result in
indirect effects to waters including excess sedimentation in downstream waters,
disruption and/or killing of aquatic life in the direct vicinity of the project area, and
a potential increase in downstream flows. These indirect effects are expected to
be minimal due to the applicant's proposed avoidance, minimization, and
mitigation measures. Additionally, indirect effects would be further reduced
through the implementation of best management practices required by state,
local, and federal ordinances and regulations.
Another potential indirect effect would be the construction of a chemical
conversion plant associated with the proposed project. However, the proposed
project would occur regardless of whether a conversation plant would be
constructed or not. Additionally, the future plans, if any, for this facility are
unknown; therefore, potential impacts associated with it are unknown and not
quantifiable at this time.
9.2 The geographic scope for the cumulative effects assessment is:
The geographic area for this assessment is the South Fork Catawba sub -basin
which is part of the Santee (Catawba) River Basin (Figure 25). This watershed
contains the proposed project area and the areas that would potentially be
affected by the proposed project. The general South Fork Catawba sub -basin
watershed characteristics and land uses are summarized in Table 25.
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CE SAW -RG -C (File Number, SAW 2018-01129)
LEGEND
- Piedmont Lithium
8 -Digit Hydro]oglc unit
I
MagarAon
Code(03050102)
D Miles 8
1mch=8rtrtes �• "
yn
S�
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Rulhertordon n
Sprndale '-
_ Forest City
F.
s
A
lr.n � -u•.� ��
}(IrKjS
. ht•xxlf:rul
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f
i
r
I
1
s •I 'It0
idtir iJp�m-N� (
1
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r l
i
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I Hunierr
ley 1
rb n r
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syr vis
` - - - Ai:J YI"h..^.A���)1 •rye
Ari•�l-: F1A - - - - - - -
4s* Purl
I .•r
Figure 25. HUC-8 Sub -Basin Level Watershed - South Fork Catawba River (03050102)
Table 25. HUC-8 (03020102) USGS Streamstats Watershed Characteristics
Parameter Description
Value
Unit
General Characteristics
Mean Basin Elevation
1010
feet
Elevation of the stream outlet in thousands of feet above NAVD88.
564
feet
Mean Annual Precipitation
49
inches
Area that drains to a point on a stream
660
miles'
Minimum basin elevation
564
feet
Maximum basin elevation
2990
feet
Maximum 24-hour precipitation that occurs on average once in 50 years
7.15
inches
Percent of area of protected Federal and State owned land
3.24
percent
National Land Cover Dataset (NLCD) 1992
Percentage of forest from NLCD 1992 classes 41-43
58.206
percent
Percent of area covered by barren rock using 1992 NLCD
0.302
percent
Percent of area covered by all densities of developed land using 1992 NLCD
11.082
percent
Percent of area in cultivation using 1992 NLCD
29.38
percent
Percent of area covered by water using 1992 NLCD
0.575
percent
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CE SAW -RG -C (File Number, SAW 2018-01129)
Parameter Description
Value
Unit
Percent of area covered by wetland using 1992 NLCD
0.455
percent
NLCD 2001
Percentage of forest from NLCD 2001 classes 41-43
47.392
percent
Percentage of area barren land, NLCD 2001 category 31
0.057
percent
Percentage of land -use from NLCD 2001 classes 21-24
18.303
percent
Percent imperviousness of basin area 2001 NLCD
4.53
percent
Percentage of cultivated crops and hay, classes 81 and 82, from NLCD 2001
28.278
percent
Percentage of herbaceous upland from NLCD 2001 class 71
3.604
percent
Percent of area covered by shrubland using 2001 NLCD
1.435
percent
Percentage of open water, class 11, from NLCD 2001
0.425
percent
Percentage of wetlands, classes 90 and 95, from NLCD 2001
0.506
percent
NLCD 2006
Percentage of forest from NLCD 2006 classes 41-43
47.381
percent
Percent of area covered by barren rock using 2006 NLCD
0.127
percent
Percentage of land -use from NLCD 2006 classes 21-24
18.747
percent
Percentage of impervious area determined from NLCD 2006 impervious
dataset
4.71
percent
Percent of area in cultivation using 2006 NLCD
27.001
percent
Percent of area covered by grassland/herbaceous using 2006 NLCD
4.032
percent
Percent of area covered by shrubland using 2006 NLCD
1.364
percent
Percent of open water, class 11, from NLCD 2006
0.806
percent
Percent of area covered by wetland using 2006 NLCD
0.542
percent
NLCD 2011
Percentage of forest from NLCD 2011 classes 41-43
45.935
percent
Percentage of barren from NLCD 2011 class 31
0.088
percent
Percentage of developed (urban) land from NLCD 2011 classes 21-24
19
percent
Average percentage of impervious area determined from NLCD 2011
impervious dataset
4.85
percent
Percentage of cultivated crops and hay, classes 81 and 82, from NLCD 2011
26.736
percent
Percent of area covered by grassland/herbaceous using 2011 NLCD
4.375
percent
Percent of area covered by shrubland using 2011 NLCD
2.486
percent
Percent of open water, class 11, from NLCD 2011
0.801
percent
Percentage of wetlands, classes 90 and 95, from NLCD 2011
0.545
percent
Soils
Percent of area of protected Federal and State owned land
3.24
percent
Percentage of area of Hydrologic Soil Type A from SSURGO
0.78
percent
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CE SAW -RG -C (File Number, SAW 2018-01129)
Parameter Description
Value
Unit
Percentage of area of Hydrologic Soil Type B from SSURGO
89.2
percent
Percentage of area of Hydrologic Soil Type C from SSURGO
7.54
percent
Percentage of area of Hydrologic Soil Type D from SSURGO
0.74
percent
9.3 The temporal scope of this assessment covers:
The temporal scope for this assessment is May 11, 2006 to 2030. The date May
11, 2006 was chosen because no data is available in the Corps ORM2 for
cumulative impacts prior to that date due to database migration issues.
Information for expected future growth and development in the geographic area
was gathered from an urban growth study that was conducted by The University
of North Carolina at Charlotte for the Charlotte metropolitan area.
9.4 Describe the affected environment:
The U.S. Geological Survey (USGS) National Hydrography Dataset (NHD)
provides digital geospatial datasets to the public that map a network of surface
waters and catchments of the U.S., which provides crude estimates of the type
and quantity of various types of aquatic resources within the watershed (Table
26 and Table 27). The U.S. Fish and Wildlife Service also provide estimates of
the quantity and types of aquatic resources as part of their publically available
National Wetland Inventory (NWI) dataset (Table 28). These estimates are
usually made using remote sensing methods which are known to be inaccurate
and not representative of what would be considered jurisdictional under the
Corps regulatory program (normally underestimated). According to a Ph.D.
Dissertation completed by Thomas P. Colson of North Carolina State University
in 2005, the NHD 1:24,000 dataset only identified 65% of streams mapped in the
field using the North Carolina Division of Water Quality stream identification
methods.14
Table 26. USGS NHD Stream Features for South Fork Catawba Sub -Basin
USGS Stream Features
Miles
Blueline Stream
1,540
Perennial
597
Intermittent
744
Ephemeral
0
Other
199
Canals/Ditches
0
Connectors/Artificial Paths
180
Impounded Streams
0
" Colson, T.P. 2006. Steam network delineation from high-resolution digital elevation models. NC State University. Raleigh, NC.
https://repository.Iib.ncsu.edu/handle/1840.16/4432
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CE SAW -RG -C (File Number, SAW 2018-01129)
USGS Stream Features Miles
Total 1,720
Table 27. USGS NHD Water Features for South Fork Catawba Sub -Basin
USGS Features
Acres
Lakes/Ponds
11,777
Reservoirs
118
Swamps/Marshes
14.3
Canals/Ditches
0
Streams/Rivers
0
Table 28. USFWS NWI for South Fork Catawba Sub -Basin
NWI Wetlands
Total ac.
Estuarine/Marine Wetland
0
FW -Emergent Wetland
52
FW-Forested/Shrub
Wetland
2,500
FW -Pond
1,167
Lacustrine
11,052
Other
0
Riverine
4,356
Total
19,127
Approximately 1,720 miles of streams have been mapped by the U.S. Geological
Survey as part of the National Hydrologic Database (1:24,000 high resolution)
within the South Fork Catawba sub -basin. According to the ORM2 database,
171,930 linear feet (Table 29) were impacted in some manner from May 11,
2006 to July 27, 2017. The authorized linear foot measure in the ORM2 database
account for stream impacts both temporary and permanent in nature. This
accounts for a rate of 83 linear foot of impact per day in the South Fork Catawba
sub -basin. The total stream impacts during this time period represents 0.76% of
the total streams currently mapped by the USGS within the South Fork Catawba
sub -basin. It is expected that many more linear feet of stream subject to the
Corps regulatory authority are present in the South Fork Catawba sub -basin due
to the inaccuracies in the NHD dataset.
Approximately 19,127 acres of wetlands have been identified as part of the U.S.
Fish and Wildlife National Wetland Inventory within the South Fork Catawba sub -
basin. According to the ORM2 database, 48 acres (Table 29) were impacted in
some manner from May 11, 2006 to July 27, 2017. The authorized fill measure in
the ORM2 database accounts for the area of filled for wetland and stream, both
temporary and permanent in nature. Assuming these were all wetland impacts,
this accounts for a rate of 0.01 acre of wetland impact per day in the South Fork
Catawba sub -basin. The total potential wetland impacts during this time period
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CE SAW -RG -C (File Number, SAW 2018-01129)
represents 0.2% of the total wetlands currently mapped by the U.S. Fish and
Wildlife Service within the South Fork Catawba sub -basin. It is expected that
many more acres of wetlands subject to the Corps regulatory authority are
present in the South Fork Catawba sub -basin due to the inaccuracies in the NWI
dataset.
Table 29. HUC-8 (03050102) Cumulative CorDs Permit Impacts 5/11/2007 to X/XX/XXXX
Action
Total #
Acres
Auth Fill
Mit Rqd
Mit Rqd
Type
Issued
Perm
Auth LF
Acres
Acres
LF
Loss
NWP
RGP
SP
There is not a publicly available detailed analysis of the development of Gaston
County. However, the mine would be located near the northern boundary of
Gaston County and would utilize supplies and labor from a large part of
Mecklenburg and Gaston County. Therefore, the development of Mecklenburg
County and surrounding area is an appropriate surrogate when looking at the
likely development trends in this part of Gaston County. Figure 28 to Figure 30
show the relative rate of development that has occurred in this area since 1985.
Mecklenburg County's population increased 117 percent between 1976 and 2006
according to an analysis on urban growth conducted in 2008 by the Urban
Institute at the University of North Carolina at Charlotte. Mecklenburg County
began to rapidly develop in the mid-1980s and has steadily increased to present
day (Figure 26 to Figure 28). This growth slowed for a period during an
economic recession that generally began in 2007 and ended in 2011. The rate of
growth in Mecklenburg County between 2015 and 2016 was 1.9% according to a
U.S. Census Bureau report released on May 25, 2017. This rapid development of
Mecklenburg has spilled over into adjacent communities such as Gaston County
and is forecasted to continue into the foreseeable future (Figure 29 and Figure
30).
Page 74 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
Figure 26. Mecklenburg County Developed Area 1985 - UNCC Landsat Study
Page 75 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
1996 41
3'
Yk
C Developed
ykt ■ Natural/Rural
■ Water
3f
' 2 -
n
+; Conversion Rate: 19 acres per day
Footprint: 0.22 acres per person
Figure 27. Mecklenburg County Developed Area 1996 - UNCC Landsat Study
Figure 28. Mecklenburg County Developed Area 2006 - UNCC Landsat Study
Page 76 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
2030
jW .9 r
3%
Developed
<' • ■ Natural/Rural
' ■ Water
Conversion Rate: 9 acres per day
Footprint: 0.22 acres per person
Figure 29. Mecklenburg County Projected Developed Area 1985 - UNCC Urban Growth
Model
Figure 30. Project Growth Area - UNCC Urban Growth Model
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CE SAW -RG -C (File Number, SAW 2018-01129)
9.5 Determine the environmental consequences:
Natural resource issues of particular concern (from Corps and non -Corps
activities) in the South Fork Catawba sub basin include decreases in water
quality in streams, decreases in wildlife habitat and fragmentation, and increases
in the amount and duration of storm water flows from urban developments
associated with residential, commercial, and industrial uses. Besides Corps
authorized projects, other activities include residential, commercial, institutional
and recreational development on uplands, as well as numerous infrastructure
and facility maintenance projects that do not require Corps authorization or
notification. Resulting natural resource changes and stresses include loss of
wildlife habitat, increases in storm water flows, and decreases in overall water
quality. Aquatic resources are also being affected by the increase in impervious
surfaces, and the application of numerous herbicides, pesticides, and fertilizers
associated with residential, commercial, and institutional developments and
roadway construction/expansion. Additional issues of concern in this watershed
are the decrease in floodwater retention capabilities, increase in storm water
flows and decreased water quality, specifically nitrogen and phosphorus inputs
from point sources, especially municipal wastewater, and non -point sources such
as urban storm water runoff and rural agricultural runoff.
9.6 Discuss any mitigation to avoid, minimize or compensate for cumulative effects:
During the period between May 11, 2006 and July 27, 2017, the Corps required
approximately 11 acres and 24,503 linear feet of compensatory wetland and
stream mitigation, respectively, in the form of restoration, preservation, and/or
enhancement (Table 29).
9.7 Conclusions regarding cumulative impacts:
When considering the overall impacts that will result from the proposed activity,
in relation to the overall impacts from past, present, and reasonably foreseeable
future activities, the incremental contribution of the proposed activity to
cumulative impacts in the area described in section 9.2, are not considered to be
significant. Compensatory mitigation Select will or will not be required to help
offset the impacts to eliminate or minimize the proposed activity's incremental
contribution to cumulative effects within the geographic area described in Section
9.2. Mitigation required for the proposed activity is discussed in Section 8.0.
10.0 Compliance with Other Laws, Policies, and Requirements
10.1 Section 7(a)(2) of the Endangered Species Act (ESA): Refer to Section 2.2 for
description of the Corps action area for Section 7.
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CE SAW -RG -C (File Number, SAW 2018-01129)
10.1.1 Are there listed species or designated critical habitat present or in the vicinity of
the Corps' action area? No. The Corps has determined that it has fulfilled its
responsibilities under Section 7(a)(2) of the ESA
Effect determination (s), including no effect, for all known species/habitat, and
basis for determination(s):
The applicant's consultant consulted the U.S. Fish and Wildlife (USFWS)
Information for Planning and Consultation (IPaC) database and the North
Carolina Natural Heritage Program (NCNHP) Data Explorer for a list of federally
protected species with potential to occur within and in proximity to the project
site. Table 30 summarizes federally listed in both databases that have the
potential to be located in proximity to the project site. The IPaC database was
last accessed on September 21, 2018 (IPac Resource List, attached) and the
NCNHP Data Explorer was last accessed on November 6, 2019 (NCNHDE-7459,
attached). The IPaC Resourse list indicated that no known occurrences or critical
habitat have been document within the project site. The NCNHP Data Explorer
query revealed that no known occurrences of federally protected species have
been documented within the project site; however, one historical occurrence
(pre -1917) of a federally protected species occurs within a one -mile radius of the
project site.
Table 30. Federally nrotected snecies list on the IPaC and NCNHP renorts
Common Name
Scientific Name
Federal
Status
List
Habitat Present
Y/N
Bald eagle
Haliaeetus leucocephalus
BGPA
NCNHP
No
Bog turtle
Glyptemys muhlenbergii
T (S/A)
NCNHP
No
Northern long-eared bat
Myotis septentrionalis
T
NCNHP,
USFWS
No-hibernacula;
Yes -roosting
Dwarf -flowered heartleaf
Hexastylis naniflora
T
NCNHP,
USFWS
Yes
Schweinitz's sunflower
Helianthus schweinitzii
E
NCNHP,
USFWS
No
Michaux's sumac
Rhus michauxii
E
NCNHP
No
On March 15th and 20th and on April 4th and 18th, 2018 the applicant's
environmental consultant, conducted pedestrian surveys of the site to verify the
presence or absence of potential habitat for federally threatened and endangered
species that may occur on the site. Additional field work has been conducted on
the site during two visits each in August, October, and November 2018, including
continued observation for habitat and individuals listed in Table 30. None have
been identified to date. Three areas that were not accessible during the 2018
surveys will be reviewed in 2019 (Figure 31).
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CE SAW -RG -C (File Number, SAW 2018-01129)
APO awA.Am; PPB
VV �.�D2 Cee, . Ld32 U82 PaE
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-
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_
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1122 Ld32
Figure 31. Federally and threatened and endangered species remaining review area.
During the 2018 March, April, August, October, and November surveys, no
suitable habitat for the bald eagle, bog turtle, Schweinitz's sunflower, or
Michaux's sumac were identified and none of these species were observed
during the field surveys. However, suitable habitat for the dwarf -flowered
heartleaf was identified (Figure 31) during the March field efforts and
subsequently surveyed for the species during the April field efforts. Utilizing
topographic and soil survey GIS files, target areas for the dwarf -flowered
heartleaf were identified on Pacolet soils on north facing slopes prior to field
work. These areas were surveyed in the field and suitable habitat for the species
was identified (Figure 11 and Figure 31). The field work was conducted during
the appropriate flowering window (March -May) for dwarf -flowered heartleaf and
although other species of Hexastylis were observed, no individuals of dwarf -
flowered heartleaf were identified. Areas identified as not being suitable for this
species were due to a number of factors such as the presence of pine
plantations, cattle disturbance, highly modified understory, or timber and
agricultural practices with heavy disturbance. These areas were still carefully
observed during periodic field work throughout this timeframe for individuals of
dwarf -flowered heartleaf and none were identified.
The project was also reviewed in accordance with the northern long-eared bat
(NLEB) Standard Local Operating Procedures for Endangered Species
Page 80 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
(SLOPES) between the USACE, Wilmington District, and the Asheville and
Raleigh U.S. Fish and Wildlife Service (Service) Offices, and determined that the
project is located outside of the highlighted areas/red 12 -digit HUCs and activities
in the project limits do not require prohibited incidental take; as such, this project
meets the criteria for the 4(d) rule and any associated take is
exempted/excepted. As established in the NLEB SLOPES, this project does not
require prohibited intentional take of the NLEB and it meets the criteria for the
4(d) rule.
Based on the desktop review of the IPaC and NCNHP Project Report, GIS files,
and field reviews, the project will have no effect on the bald eagle, bog turtle,
Schweinitz's sunflower, or Michaux's sumac. The project may affect, but is not
likely to adversely affect the northern long-eared bat.
The suitable habitat identified for the dwarf -flowered heartleaf within the
proposed project has been surveyed for the species during the appropriate
flowering window — no individuals of the species were observed. The three
remaining areas to be reviewed will not be impacted by the proposed project
(Figure 31); therefore, the project will have no effect on the dwarf -flowered
heartleaf. The results of the additional surveys will still be provided once
completed.
A letter has been sent to the USFWS by the applicant's environmental
consultant; however, a response has yet to be received.
10.1.2 Has another federal agency been identified as the lead agency for complying
with Section 7 of the ESA with the Corps designated as a cooperating agency
and has that consultation been completed? No
If yes, identify that agency, the actions taken to document compliance with
Section 7 and whether those actions are sufficient to ensure the activity(s)
requiring DA authorization is in compliance with Section 7 of the ESA:
If yes, identify agency and provide description here. Select appropriate
conclusion.
10.1.3 Consultation with either the National Marine Fisheries Service and/or the U.S.
Fish and Wildlife Service was initiated and completed as required, for any
determinations other than "no effect" (see the attached ORM2 Summary sheet
for begin date, end date and closure method of the consultation). Irovid(
additional discussion here as needed to describe consultation(s) with the
Service(s) Based on a review of the above information, the Corps has
determined that it has fulfilled its responsibilities under Section 7(a)(2) of the
ESA. The documentation of the consultation is incorporated by reference.
Page 81 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
10.2 Magnuson -Stevens Fishery Conservation and Management Act (Magnuson -
Stevens Act), Essential Fish Habitat (EFH). N/A, there is no essential fish
habitat in this district's area of responsibility.
10.2.1 Did the proposed project require review under the Magnuson -Stevens Act? No
10.2.2 If yes, EFH species or complexes considered: N/A
Effect(s) determination and basis for that determination(s): N/A
10.2.3 Has another federal agency been identified as the lead agency for complying
with the EFH provisions of the Magnuson -Stevens Act with the Corps designated
as a cooperating agency and has that consultation been completed? No
If yes, identify the agency, the actions taken to document compliance with the
Magnuson Stevens Act and whether those actions are sufficient to ensure the
activity(s) requiring DA authorization is in compliance the EFH provisions.
Identify agency and provide description here Select appropriate conclusion.
10.2.4 Consultation with the National Marine Fisheries Service was initiated and
completed as required (see the attached ORM2 Summary sheet for consultation
type, begin date, end date and closure method of the consultation). Enter
additional discussion here as needed. Based on a review of the above
information, the Corps has determined that it has fulfilled its responsibilities under
EFH provisions of the Magnuson -Stevens Act.
10.3 Section 106 of the National Historic Preservation Act (Section 106): Refer to
Section 2.3 for permit area determination.
10.3.1 Known historic properties present? Enter Yes or No and provide discussion as
appropriate Select appropriate conclusion.
Effect determination and basis for that determination: Provide determination and
, arionaie nere
10.3.2 Has another federal agency been identified as the lead federal agency for
complying with Section 106 of the National Historic Preservation Act with the
Corps designated as a cooperating agency and has that consultation been
completed? No
If yes, identify that agency, and whether the undertaking they consulted on
included the Corps undertaking(s). Briefly summarize actions taken by the lead
federal agency.
Identify agency and provide description here . Select appropriate conclusion.
Page 82 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
10.3.3 Consultation was initiated and completed with the appropriate agencies, tribes
and/or other parties for any determinations other than "no potential to cause
effects" (see the attached ORM2 Summary sheet for consultation type, begin
date, end date and closure method of the consultation). Provide additional
discussion here as needed or delete if not needed. Based on a review of the
information above, the Corps has determined that it has fulfilled its
responsibilities under Section 106 of the NHPA. Compliance documentation
incorporated by reference.
10.4 Tribal Trust Responsibilities
10.4.1 Was government -to -government consultation conducted with Federally -
recognized Tribe(s)?Select Yes or No
Provide a description of any consultation (s) conducted including results and how
concerns were addressed. Provide additional discussion here as needed or
delete if not needed The Corps has determined that it has fulfilled its tribal trust
responsibilities.
10.4.2 Other Tribal including any discussion of Tribal Treaty rights?
provide discussion.
10.5 Section 401 of the Clean Water Act — Water Quality Certification (WQC)
10.5.1 Is a Section 401 WQC required, and if so, has the certification been issued,
waived or presumed? Select appropriate option
10.6 Coastal Zone Management Act (CZMA)
10.6.1 Is a CZMA consistency concurrence required, and if so, has the concurrence
been issued, waived or presumed? N/A, a CZMA consistency concurrence is not
required.
10.7 Wild and Scenic Rivers Act
10.7.1 Is the project located in a component of the National Wild and Scenic River
System, or in a river officially designated by Congress as a "study river" for
possible inclusion in the system? No
If yes, summarize coordination and the determination on whether activity will
adversely affect the Wild and Scenic River designation or study status. Enter
additional discussion here as needed. The Corps has determined that it has
fulfilled its responsibilities under the Wild and Scenic Rivers Act.
Page 83 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
10.8 Effects on Corps Civil Works Projects (33 USC 408)
10.8.1 Does the applicant also require permission under Section 14 of the Rivers and
Harbors Act (33 USC 408) because the activity, in whole or in part, would alter,
occupy or use a Corps Civil Works project? No, there are no federal projects in
or near the vicinity of the proposal.
If yes, provide date that decision was made and whether permission was granted
or denied : Enter date received or delete this box if no 408 is required.
Provide additional discussion here as needed or delete.
10.9 Corps Wetland Policy (33 CFR 320.4(b))
10.9.1 Does the project propose to impact wetlands? Yes
10.9.2 Based on the public interest review herein, the beneficial effects of the project
outweigh the detrimental impacts of the project.
10.10 Other (as needed): Provide discussion here as needed.
11.0 Special Conditions
11.1 Are special conditions required to protect the public interest, ensure effects are
not significant and/or ensure compliance of the activity with any of the laws
above? Select Yes or No
If no, provide rationale: Describe rationale
11.2 Required special condition(s)
Special condition(s): Enter specific condition(s)
Rationale: Enter rationale here
12.0 Findings and Determinations
12.1 Section 176(c) of the Clean Air Act General Conformity Rule Review: The
proposed permit action has been analyzed for conformity applicability pursuant to
regulations implementing Section 176(c) of the Clean Air Act. It has been
determined that the activities proposed under this permit will not exceed
deminimis levels of direct or indirect emissions of a criteria pollutant or its
precursors and are exempted by 40 CFR Part 93.153. Any later indirect
emissions are generally not within the Corps' continuing program responsibility
and generally cannot be practicably controlled by the Corps. For these reasons
a conformity determination is not required for this permit action.
Page 84 of 85

CE SAW -RG -C (File Number, SAW 2018-01129)
12.2 Presidential Executive Orders (EO):
12.2.1 EO 13175, Consultation with Indian Tribes, Alaska Natives, and Native
Hawaiians: Select response or provide discussion here
12.2.2 EO 11988, Floodplain Management: Select response or provide discussion here
12.2.3 EO 12898, Environmental Justice: Select response or provide discussion here
12.2.4 EO 13112, Invasive Species: Select response or provide discussion here
12.2.5 EO 13212 and EO 13302, Energy Supply and Availability: Select response or
provide discussion her( -
12.3 Findings of No Significant Impact: Having reviewed the information provided by
the applicant and all interested parties and an assessment of the environmental
impacts, I find that this permit action will not have a significant impact on the
quality of the human environment. Therefore, an environmental impact
statement will not be required.
12.4 Compliance with the Section 404(b)(1) Guidelines: Having completed the
evaluation above, I have determined that
12.5 Public interest determination: Having reviewed and considered the information
above, I find that the proposed project is not contrary to the public interest.
PREPARED BY:
Date:
Project Manager
0 AN I ATA =1 of WS
Date:
Enter name of appropriate level reviewer
APPROVED BY:
Date:
Enter name of appropriate level approver
Page 85 of 85

ROY COOPER
Governor
MICHAEL S. REGAN
Secmw
71M BAUMGARTNER.
Director
Patrick Brindle
Piedmont Lithium, Inc.
5706 Dallas-Cherryville Highway
Bessemer City, NC 28016
Project: Piedmont Lithium, Inc.
NORTH CAROLINA
Environmenral Quality
December 21, 2018
Expiration of Acceptance: May 20, 2019
County: Gaston
The purpose of this letter is to notify you that the NCDEQ Division of Mitigation Services (DMS) is willing to
accept payment for compensatory mitigation for impacts associated with the above referenced project as
indicated in the table below. Please note that this decision does not assure that participation in the DMS in -
lieu fee mitigation program will be approved by the permit issuing agencies as mitigation for project impacts.
It is the responsibility of the applicant to contact permitting agencies to determine if payment to the DMS will
be approved. You must also comply with all other state, federal or local government permits, regulations or
authorizations associated with the proposed activity including G.S. § 143-214.11.
This acceptance is valid for six months from the date of this letter and is not transferable. If we have not
received a copy of the issued 404 Permit/401 Certification within this time frame, this acceptance will
expire. It is the applicant's responsibility to send copies of the permits to DMS. Once DMS receives a copy
of the permit(s) an invoice will be issued based on the required mitigation in that permit and payment must
be made prior to conducting the authorized work. The amount of the in -lieu fee to be paid by an applicant is
calculated based upon the Fee Schedule and policies listed on the DMS website.
Based on the information supplied by you in your request to use the DMS, the impacts for which you are
requesting compensatory mitigation credit are summarized in the following table. The amount of mitigation
required and assigned to DMS for this impact is determined by permitting agencies and may exceed the
impact amounts shown below.
River Basin impact Location Impact Type Impact Quantity
{8 -digit HUCy
Catawba 03050102 Warm Stream 5,810.500
Catawba 03050102 Riparian Wetland 0.140
Upon receipt of payment, DMS will take responsibility for providing the compensatory mitigation. The
mitigation will be performed in accordance with the In -Lieu Fee Program instrument dated July 28, 2010 and
15A NCAC 02B .0295 as applicable. Thank you for your interest in the DMS in -lieu fee mitigation program.
If you have any questions or need additional information, please contact Kelly Williams at [phone].
cc: Kelly Thames, agent
Sincerely,
Ja s B Stanfill
Asse anagement Supervisor
e:! 5: f Q. E Q,-.-. A�
North Carolina Department of Environmental Quality I Division of Mitigation Services
217 W.Jones Street 11652 Mail Service Center I Raleigh, North Carolina 27699-1652
919.7078976

N C (Avisl-an of Water Qual Ity -M ethod ofag y for I dentification of Interm ittent in n d
Perennlel Strums and Their Origins v_ 4.11
NC DWQ Strum m [detttz6cation Form Version 4A 1 F" - - I'
Date: j '� 1 ProjectlSite: dt oat� titude: 5 , �'33j�-0
Evaluator:C.L`e- County: �. Long itude:
Total Points: Stream Determinatlon (circle o Other L11"f 01 in'Vvt In) -r Jt
Stream is at least intermittent C� Ephemeral Intermittent erenni�l a -g. Quad Name: f
if? 19 or perennial if z 34" J iAt G
A. Geomorphology Subtotal = �' I
Absent
Weak
Moderate
Strong
1a Continuity of channel bed and bank
0
1
2
1. 1
2. Sinuosity of channel along thalweg
0
1
2
1
3. In -channel structure: ex. riffle-poDI, step -pool,
ri le- ool sequence
0
1
.2
1.5
4. Particle size of stream substrate
0
1
2
1.5
5. Active/relict floodplain
0
1
2
1.5
B. Depositional bars or benches
0
1
2
1.5
7. Recent alluvial deposits
0
1
2
3
S. Headcuts
1
2
3
9. Grade control
0
Notes:
1
1.5
10. Natural valley
0
1 0.5
1
1.5
11. Second or greater order channel
No 0 ?
Yes = 3
- artiticial bitches are not rated; see discussions in manual
R Hvrirninnv lSrihfnt•al = `1 1
12. Presence of Baseflow
0 1
2
r3
13. Iron oxidizing bacteria
( 0 1
2
3
14. Leaf litter
1. 1
0.5
0
15. Sediment an plants or debris
0 0.5
1
1.5
16. Organic debris Itnes or piles
0 0.5
1,
1.5
17. Soil -based evidence of high water table?
No = 0
Yes - 3
1 1
C _ KINOC1V f5uhtntal = ` I 1
18. Fibrous roots in streambed
; 3
2
1
0
19. Rooted upland plants in streambed
3,
2
_
1
4
20. Macrobenthos (note diversity and abundance)
0
2
3
21. Aquatic Mollusks
0
2
3
22. Fish
0
0.5
1 1
1.5
23. Crayfish
OS
1
1.5
24. Amphibians
p-5
1
1.5
25, Algae
100.5
1
1.5
26. Wetland plants in streambed
FACW = 0.75; DBL = 1.5 Other = 0
'perennial streams may also be identified using other methods. See p. 35 of manual
Notes:
Sketch:
ti
1
r �
41

NC SAM FIELD ASSESSMENT FORM II7113ACt 1 - Pprpnlllal Stream 2
user rvianuai version z. -i
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic quadrangle,
and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property, identify and
number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for detailed descriptions
and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were performed. See the
NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION:
1. Project name (if any): Piedmont Lithium
3. Applicant/owner name: Piedmont Lithium, Inc.
5. County: Gaston
2. Date of evaluation: March 15, 2018
Assessor name/organization: Thomas Blackwell/HDR
Nearest named water body Beaverdam Creek (HUC
7. River basin: Catawba on USGS 7.5 -minute quad: 01030102)
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.393417, -81.285785
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): Impact 1 10. Length of assessment reach evaluated (feet): 178 ft
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 4 ft ❑Unable to assess channel depth.
12. Channel width at top of bank (feet): 8 ft 13. Is assessment reach a swamp steam? ❑Yes ❑No
14. Feature type: ®Perennial flow ❑Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) ® Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic ❑A`J ®B
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip ❑Size 1 (< 0.1 mil) ®Size 2 (0.1 to < 0.5 mit) ❑Size 3 (0.5 to < 5 mit) ❑Size 4 (>_ 5 mit)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑Section 10 water ❑Classified Trout Waters ®Water Supply Watershed (❑I ❑II ❑III ®IV ❑V)
❑Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters
❑Anadromous fish ❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
❑Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in "Notes/Sketch" section or attached? ®Yes ❑No
1. Channel Water — assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
®A Water throughout assessment reach.
❑B No flow, water in pools only.
❑C No water in assessment reach.
2. Evidence of Flow Restriction — assessment reach metric
®A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
❑B Not
3. Feature Pattern — assessment reach metric
®A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
❑B Not
4. Feature Longitudinal Profile — assessment reach metric
❑A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming, over
widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of these
disturbances).
®B Not
5. Signs of Active Instability — assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
®A < 10% of channel unstable
❑B 10 to 25% of channel unstable
❑C > 25% of channel unstable

Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
0 Other: (explain in "Notes/Sketch" section)
®J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
10b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
®A Multiple aquatic macrophytes and aquatic mosses m w ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) CO ❑G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent w Y ❑H Low -tide refugia (pools)
vegetation NC El Sand bottom
®C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
®D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
® ❑ ❑ ❑ ❑ Bedrock/saprolite
® ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
❑ ❑ ® ❑ ❑ Cobble (64 — 256 mm)
❑ ❑ ® ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ® ❑ Sand (.062 — 2 mm)
❑ ® ❑ ❑ ❑ Silt/clay (< 0.062 mm)
❑ ® ❑ ❑ ❑ Detritus
® ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
Impact 1 - Perennial Stream 2
6. Streamside Area Interaction — streamside area metric
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
®A ®A
Little or no evidence of conditions that adversely affect reference interaction
❑B ❑B
Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area, leaky
or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C
Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision, disruption
of flood flows through streamside area] or too much floodplain/intertidal zone access [examples: impoundments, intensive
mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a man-made feature on an
interstream divide
Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
0 Other: (explain in "Notes/Sketch" section)
®J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
10b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
®A Multiple aquatic macrophytes and aquatic mosses m w ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) CO ❑G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent w Y ❑H Low -tide refugia (pools)
vegetation NC El Sand bottom
®C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
®D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
® ❑ ❑ ❑ ❑ Bedrock/saprolite
® ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
❑ ❑ ® ❑ ❑ Cobble (64 — 256 mm)
❑ ❑ ® ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ® ❑ Sand (.062 — 2 mm)
❑ ® ❑ ❑ ❑ Silt/clay (< 0.062 mm)
❑ ® ❑ ❑ ❑ Detritus
® ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12
Aquatic Life —assessment reach metric (skip for Tidal Marsh Streams) Impact 1 - Perennial Stream 2
12a. ®Yes ❑No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ❑No Water ❑Other:
12b. ®Yes ❑No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
® ❑Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
® ❑Beetles
❑ ®Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/shrimp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ®Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, fishily, dobsonfly larvae)
❑ ❑Midges/mosquito larvae
❑ ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Other fish
❑ ❑Salamanders/tadpoles
❑ ®Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
❑ ❑Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland runoff.
LB RB
®A ®A Little or no alteration to water storage capacity over a majority of the streamside area
❑B ❑B Moderate alteration to water storage capacity over a majority of the streamside area
El ❑C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil compaction,
livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water >_ 6 inches deep
❑B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
®C ®C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ❑Y Are wetlands present in the streamside area?
®N ®N
16. Baseflow Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
❑A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
❑D Evidence of bank seepage or sweating (iron in water indicates seepage)
®E Stream bed or bank soil reduced (dig through deposited sediment if present)
❑F None of the above
17. Basef low Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
®B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
❑C Urban stream (>_ 24% impervious surface for watershed)
❑D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
❑F None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
®A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
❑B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

Impact 1 - Perennial Stream 2
19. Buffer Width — streamside area metric (skip for Tidal Marsh Streams)
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
®A ®A ®A ®A >_ 100 feet wide or extends to the edge of the watershed
❑B ❑B ❑B ❑B From 50 to < 100 feet wide
❑C ❑C ❑C ❑C From 30 to < 50 feet wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
❑E ❑E ❑E ❑E < 10 feet wide or no trees
20. Buffer Structure — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
❑A ❑A Mature forest
®B ®B Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but is
within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
®A ®A Medium to high stem density
❑B ❑B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer — streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
®A ®A The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
®B ®B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
❑C ❑C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity — assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes ®No Was conductivity measurement recorded?
If No, select one of the following reasons. ®No Water ❑Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 ❑B 46 to < 67 ❑C 67 to < 79 ❑D 79 to < 230 ❑E >_ 230
Notes/Sketch:
This stream reach is affected by an existing culvert that restricts flows during low flow periods. There was also evidence of water withdrawls
(pipe), but not substantial water withdrawls.

Stream Site Name Piedmont Lithium
Stream Category Pb2
Impact 1 - Perennial Stream 2
Draft NC SAM Stream Rating Sheet
Accompanies User Manual Version 2.1
Date of Assessment March 15, 2018
Assessor Name/Organization Thomas Blackwell/HDR
Notes of Field Assessment Form (Y/N) YES
Presence of regulatory considerations (Y/N) NO
Additional stream information/supplementary measurements included (Y/N) YES
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream) Perennial
USACE/ NCDWR
Function Class Rating Summary
All Streams Intermittent
(1) Hydrology
HIGH
(2) Baseflow
HIGH
(2) Flood Flow
HIGH
(3) Streamside Area Attenuation
HIGH
(4) Floodplain Access
HIGH
(4) Wooded Riparian Buffer
HIGH
(4) Microtopography
NA
(3) Stream Stability
MEDIUM
(4) Channel Stability
HIGH
(4) Sediment Transport
MEDIUM
(4) Stream Geomorphology
MEDIUM
(2) Stream/Intertidal Zone Interaction
NA
(2) Longitudinal Tidal Flow
NA
(2) Tidal Marsh Stream Stability
NA
(3) Tidal Marsh Channel Stability
NA
(3) Tidal Marsh Stream Geomorphology
NA
(1) Water Quality
HIGH
(2) Baseflow
HIGH
(2) Streamside Area Vegetation
HIGH
(3) Upland Pollutant Filtration
HIGH
(3) Thermoregulation
HIGH
(2) Indicators of Stressors
NO
(2) Aquatic Life Tolerance
HIGH
(2) Intertidal Zone Filtration
NA
(1) Habitat
HIGH
(2) In -stream Habitat
MEDIUM
(3) Baseflow
HIGH
(3) Substrate
MEDIUM
(3) Stream Stability
HIGH
(3) In -stream Habitat
MEDIUM
(2) Stream -side Habitat
HIGH
(3) Stream -side Habitat
HIGH
(3) Thermoregulation
HIGH
(2) Tidal Marsh In -stream Habitat
NA
(3) Flow Restriction
NA
(3) Tidal Marsh Stream Stability
NA
(4) Tidal Marsh Channel Stability
NA
(4) Tidal Marsh Stream Geomorphology
NA
(3) Tidal Marsh In -stream Habitat
NA
(2) Intertidal Zone
NA
Overall
HIGH

N C Divi cion of Wate r Qu ality-Methodolog y for Id entificaiW on of Intermittent and
Pere nn al Streams ipn-d The Ir OtIlns v. 4.11
NC DWQ Stream Idgiadflcallen FurFn Version 4,11
Date: 1 S- 701 $
ProjectlSite: Ndowt U fl,
Latitude: l c
Evaluator: 11/1 DVA ok I;i(1'�
County: . f ��wti ",
Longitude:. S1,
Total Points:
Stream is at least intermittent
�
Stream Determinatlort (circle one)
Ephemeral. intermittenj) Perennial
n����
Other '
.g_
eQuad Name: qLA4LGl
z
r(7S or erennral if 34" y
t_ -
3
A. Geomorphology (Subtotal= '� )
Absent
Weak
Moderate
0 1 2
5tr g
1a Continuity of channel bed and bank
0
1
2
0.5 1
3
2. S Inu osity of channel along thalweg
0
1
17. Soil -based evidence of high water table?
No = 0 Yes = 3
3
3. tn-channel structure: ex. riffle -pool, step -pool,
ri ie- ooi sequence
0
1
25. Algae
0 0.5 1
3
4. Particle size of stream substrate
0
1
2
3
5, Activelreiict floodplain
0
1
2
3
6. Depositional bars or benches
0
(1 j
2
3
7. Recent alluvial deposits
1
2
2
3
B. Headcuts ( 1
3
9. Grade control
0
0.5
D
1
1.5
10, Natural valley
0
0.5
1
1.5
11, Second or greater order channel
No = 0 ?
Yes = 3
a artificiat ditches are not rated; see discBions In manual
B. Hydrology (Subtotal= ? )
12. Presence of Baseflow
0 1 2
3
13. Iron oxidizing bacteria
0 1 2
3
14. Leaf €itter1
1. 0.5
0
15. Sediment on plants or debris
0.5 1
1.5
16. Organic debris lines or piles
0 a 1
1.5
17. Soil -based evidence of high water table?
No = 0 Yes = 3
1.5
C. Biology (Subtotal = _ 4- )
18. Fibrous roots in streambed
2 1
0
19. Rooted upland plants in streambed
3 2 1
0
20. Macrobenthos (nota diversity and abundance)
0 1 2
3
21. Aquatic Mollusks
1 2
3
22. Fish
0.5 1
1.5
23. Crayfish
0,5 1
1.5
24, Amphibians
0 0.5 1
1.5
25. Algae
0 0.5 1
1.5
26. Wetland plants in streambed
FACW = 0.75; OBI = 1.5 Other = 0
'perennial streams may also be identified using other methods. See p. 35 of manual.
Notes_
Sketch:
j IICI�d PC. r� 1
41

NC SAM FIELD ASSESSMENT FORM Impact 2 - Intermittent Stream 3
user rvianuai version z. -i
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic quadrangle,
and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property, identify and
number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for detailed descriptions
and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were performed. See the
NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION:
1. Project name (if any): Piedmont Lithium
3. Applicant/owner name: Piedmont Lithium, Inc.
5. County: Gaston
2. Date of evaluation: March 15, 2018
Assessor name/organization: Thomas Blackwell/HDR
Nearest named water body Beaverdam Creek (HUC
7. River basin: Catawba on USGS 7.5 -minute quad: 01030102)
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.393616, -81.283275
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): Impact 2 10. Length of assessment reach evaluated (feet): 1,090 ft
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 4 ft ❑Unable to assess channel depth.
12. Channel width at top of bank (feet): 1-2 ft 13. Is assessment reach a swamp steam? ❑Yes ❑No
14. Feature type: ❑Perennial flow ®Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) ® Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic ❑A`J ®B
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip ®Size 1 (< 0.1 mil) ❑Size 2 (0.1 to < 0.5 mit) ❑Size 3 (0.5 to < 5 mit) ❑Size 4 (>_ 5 mit)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑Section 10 water ❑Classified Trout Waters ®Water Supply Watershed (❑I ❑II ❑III ®IV ❑V)
❑Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters
❑Anadromous fish ❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
❑Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in "Notes/Sketch" section or attached? ®Yes ❑No
1. Channel Water — assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
❑A Water throughout assessment reach.
®B No flow, water in pools only.
❑C No water in assessment reach.
2. Evidence of Flow Restriction — assessment reach metric
❑A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
®B Not
3. Feature Pattern — assessment reach metric
❑A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
®B Not
4. Feature Longitudinal Profile — assessment reach metric
❑A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming, over
widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of these
disturbances).
®B Not
5. Signs of Active Instability — assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
®A < 10% of channel unstable
❑B 10 to 25% of channel unstable
❑C > 25% of channel unstable

6. Streamside Area Interaction — streamside area metric Impact 2 - Intermittent Stream 3
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
®A ®A
Little or no evidence of conditions that adversely affect reference interaction
❑B ❑B
Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area, leaky
or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C
Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision, disruption
of flood flows through streamside area] or too much floodplain/intertidal zone access [examples: impoundments, intensive
mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a man-made feature on an
interstream divide
Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
0 Other: (explain in "Notes/Sketch" section)
®J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
10b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
®A Multiple aquatic macrophytes and aquatic mosses m w ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) (D ❑G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent w Y ❑H Low -tide refugia (pools)
vegetation N ❑I Sand bottom
®C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
®D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
® ❑ ❑ ❑ ❑ Bedrock/saprolite
® ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
® ❑ ❑ ❑ ❑ Cobble (64 — 256 mm)
❑ ® ❑ ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ® ❑ Sand (.062 — 2 mm)
❑ ❑ ❑ ® ❑ Silt/clay (< 0.062 mm)
❑ ❑ ❑ ® ❑ Detritus
® ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12
Impact 2 - Intermittent Stream 3
Aquatic Life — assessment reach metric (skip for Tidal Marsh Streams)
12a. ®Yes ❑No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ❑No Water ❑Other:
12b. ®Yes ❑No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
❑ ❑Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ ❑Beetles
® ❑Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/shrimp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ❑Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, fishily, dobsonfly larvae)
❑ ❑Midges/mosquito larvae
❑ ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Other fish
❑ ❑Salamanders/tadpoles
® ❑Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
❑ ❑Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland runoff.
LB RB
®A ®A Little or no alteration to water storage capacity over a majority of the streamside area
❑B ❑B Moderate alteration to water storage capacity over a majority of the streamside area
El ❑C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil compaction,
livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water >_ 6 inches deep
❑B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
®C ®C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ❑Y Are wetlands present in the streamside area?
®N ®N
16. Baseflow Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
❑A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
❑D Evidence of bank seepage or sweating (iron in water indicates seepage)
❑E Stream bed or bank soil reduced (dig through deposited sediment if present)
®F None of the above
17. Basef low Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
❑B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
❑C Urban stream (>_ 24% impervious surface for watershed)
❑D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
®F None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
®A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
❑B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

19. Buffer Width — streamside area metric (skip for Tidal Marsh Streams) Impact 2 -Intermittent Stream 3
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
®A ®A ®A ®A >_ 100 feet wide or extends to the edge of the watershed
❑B ❑B ❑B ❑B From 50 to < 100 feet wide
❑C ❑C ❑C ❑C From 30 to < 50 feet wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
❑E ❑E ❑E ❑E < 10 feet wide or no trees
20. Buffer Structure — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
❑A ❑A Mature forest
®B ®B Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but is
within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
®A ®A Medium to high stem density
❑B ❑B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer — streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
®A ®A The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
®B ®B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
❑C ❑C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity — assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes ®No Was conductivity measurement recorded?
If No, select one of the following reasons. ®No Water ❑Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 ❑B 46 to < 67 ❑C 67 to < 79 ❑D 79 to < 230 ❑E >_ 230
Notes/Sketch:
This stream reach is affected by an existing culvert that restricts flows during low flow periods. There was also evidence of water withdrawls
(pipe), but not substantial water withdrawls.

Draft NC SAM Stream Rating Sheet
Impact 2 - Intermittent Stream 3
Accompanies User Manual Version 2.1
Stream Site Name Piedmont Lithium Date of Assessment
March 15, 2018
Stream Category Pb1 Assessor Name/Organization
Thomas Blackwell/HDR
Notes of Field Assessment Form (Y/N)
YES
Presence of regulatory considerations (Y/N)
YES
Additional stream information/supplementary measurements included (Y/N)
YES
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream)
Intermittent
USACE/
NCDWR
Function Class Rating Summary All Streams
Intermittent
(1) Hydrology
HIGH
HIGH
(2) Baseflow
HIGH
HIGH
(2) Flood Flow
HIGH
HIGH
(3) Streamside Area Attenuation
HIGH
HIGH
(4) Floodplain Access
HIGH
HIGH
(4) Wooded Riparian Buffer
HIGH
HIGH
(4) Microtopography
NA
NA
(3) Stream Stability
HIGH
HIGH
(4) Channel Stability
HIGH
HIGH
(4) Sediment Transport
LOW
LOW
(4) Stream Geomorphology
HIGH
HIGH
(2) Stream/Intertidal Zone Interaction
NA
NA
(2) Longitudinal Tidal Flow
NA
NA
(2) Tidal Marsh Stream Stability
NA
NA
(3) Tidal Marsh Channel Stability
NA
NA
(3) Tidal Marsh Stream Geomorphology
NA
NA
(1) Water Quality
HIGH
HIGH
(2) Baseflow
HIGH
HIGH
(2) Streamside Area Vegetation
HIGH
HIGH
(3) Upland Pollutant Filtration
HIGH
HIGH
(3) Thermoregulation
HIGH
HIGH
(2) Indicators of Stressors
NO
NO
(2) Aquatic Life Tolerance
MEDIUM
NA
(2) Intertidal Zone Filtration
NA
NA
(1) Habitat
HIGH
HIGH
(2) In -stream Habitat
MEDIUM
MEDIUM
(3) Baseflow
HIGH
HIGH
(3) Substrate
LOW
LOW
(3) Stream Stability
HIGH
HIGH
(3) In -stream Habitat
HIGH
HIGH
(2) Stream -side Habitat
HIGH
HIGH
(3) Stream -side Habitat
HIGH
HIGH
(3) Thermoregulation
HIGH
HIGH
(2) Tidal Marsh In -stream Habitat
NA
NA
(3) Flow Restriction
NA
NA
(3) Tidal Marsh Stream Stability
NA
NA
(4) Tidal Marsh Channel Stability
NA
NA
(4) Tidal Marsh Stream Geomorphology
NA
NA
(3) Tidal Marsh In -stream Habitat
NA
NA
(2) Intertidal Zone
NA
NA
Overall
HIGH
HIGH

N C 0 Nision of Water Q lie I Ity -Methodology for Identification of Intermittent and
Perenn is I Streams and The Ir Orl q I n 6 v_ 4.11
NC D Q Streara Identification Farin Verleioe 4,11
%VW iI PhWVq I.
-
Date:3 n 1
Project)Slte: 17"L�lV�n�i + .
Latitude: 3� �� � •
trgjig
12 Continuity of channel bed and bank
0
1
Evaluator: �� 1/�'1.C�
County: (711. 1'� ` �{�uo:
0.5 1
Longitude:��
Total Points:
Stream is at least intermittent
�
Stream Determination (circle
Ephemeral
one)
Other L I I!t- d I•, 4•-,r-1
if a 19 or Perennial iia 3t7" 49
�P`retti�i
n
Intermittent --
e.. : • -�
gquad NameL1� c1FGr f.�
A. Geomorphology Subtotal =_L!!_ I
Absent
Weak
Moderate
0
trgjig
12 Continuity of channel bed and bank
0
1
2
0
0.5 1
2. Sinuosity of channel along thalweg
0
1
17. Soil -based evidence of high water table?
JOW 1
3
3, In -channel structure: ex. riffle -pool, step -pool,
ripple -pool sequence
0.5 1
1
2
0.5 1
0
4. Particie size of stream substrate
0
1
2
5. ActivWreiict floodplain
1
2
3
6. Depositional bars or benches
G vll( (KPV�
Fuvw - 10 t 4
1
2
7. Recent alluvial deposits
0
1
2
3
8. Headcuts
(
1
2
3
9. Grade control
0
0.5
1
.5
10. Natural valley
0
0.5
1
1.5
11. Second or greater order channel
No
0 l
Yes 3
aruriciai aacnes are nut rates: see discussions in manual -
R HWrimfnriv n9iihtntai = i'1Z 1
12. Presence of Baseflow
0
1 3
13. Iron oxidizing bacteria
0
1 2
14- Leaf litter
1.5
1 0.5 0
15. Sediment on plants or debris
0
0.5 1
16. Organic debris lines or piles
0
1 0.5 1
17. Soil -based evidence of high water table?
JOW 1
No = 0 Yes 3
L:_ Bent nov fSi ihtntat = tri 1
18. Fibrous roots in streambed
2 1
0
19. Rooted upland plants in streambed N2
1
0
20. Macrobenthos (note diversity and abundance) 0
1 ' 2
3
21. Aquatic Mollusks 0
1 2
3
22. Fish
0.5 1
1.5
23. Crayfish 0
JOW 1
1.5
24. Amphibians 10
0.5 1
1-5
25. Algae 0
0.5 1
1, 5
26. Wetland plants in streambed
FACW = 0.75; OBL = 1.5 Other = 0
*perennial streams may also be identified using other methods. See P. 35 of manual.
Notes:
Sketch:
G vll( (KPV�
Fuvw - 10 t 4
4 dIkt1vfI o�ia I�i �11arr-1;4a,�,
41

NC SAM FIELD ASSESSMENT FORM Impact 3 - Perennial Stream 8
user rvianuai version z. -i
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic quadrangle,
and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property, identify and
number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for detailed descriptions
and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were performed. See the
NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION:
1. Project name (if any): Piedmont Lithium
3. Applicant/owner name: Piedmont Lithium, Inc.
5. County: Gaston
2. Date of evaluation: April 4, 2018
4. Assessor name/organization: Kelly Thames/HDR
6. Nearest named water body Beaverdam Creek (HUC
7. River basin: Catawba on USGS 7.5 -minute quad: 01030102)
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.384178, -81.286771
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): Impact 3 10. Length of assessment reach evaluated (feet): 249 ft
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 2-6 ft ❑Unable to assess channel depth.
12. Channel width at top of bank (feet): 10-15 ft 13. Is assessment reach a swamp steam? ❑Yes ❑No
14. Feature type: ®Perennial flow ❑Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) ® Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic ❑A`J ®B
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip ®Size 1 (< 0.1 mil) ❑Size 2 (0.1 to < 0.5 mit) ❑Size 3 (0.5 to < 5 mit) ❑Size 4 (>_ 5 mit)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑Section 10 water ❑Classified Trout Waters ®Water Supply Watershed (❑I ❑ll ❑III ®IV ❑V)
❑Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters
❑Anadromous fish ❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
❑Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in "Notes/Sketch" section or attached? ®Yes ❑No
1. Channel Water - assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
®A Water throughout assessment reach.
❑B No flow, water in pools only.
❑C No water in assessment reach.
2. Evidence of Flow Restriction - assessment reach metric
®A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
❑B Not
3. Feature Pattern - assessment reach metric
❑A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
®B Not
4. Feature Longitudinal Profile - assessment reach metric
❑A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming, over
widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of these
disturbances).
®B Not
5. Signs of Active Instability - assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
❑A < 10% of channel unstable
®B 10 to 25% of channel unstable
❑C > 25% of channel unstable

6. Streamside Area Interaction — streamside area metric Impact 3 - Perennial Stream 8
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
®A ®A
Little or no evidence of conditions that adversely affect reference interaction
❑B ❑B
Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area, leaky
or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C
Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision, disruption
of flood flows through streamside area] or too much floodplain/intertidal zone access [examples: impoundments, intensive
mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a man-made feature on an
interstream divide
Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
0 Other: (explain in "Notes/Sketch" section)
®J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
101b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
❑A Multiple aquatic macrophytes and aquatic mosses m w ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) CO ❑G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent w Y ❑H Low -tide refugia (pools)
vegetation NC El Sand bottom
®C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
❑D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
® ❑ ❑ ❑ ❑ Bedrock/saprolite
® ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
❑ ® ❑ ❑ ❑ Cobble (64 — 256 mm)
❑ ❑ ❑ ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ® ❑ Sand (.062 — 2 mm)
❑ ❑ ❑ ® ❑ Silt/clay (< 0.062 mm)
❑ ❑ ❑ ® ❑ Detritus
® ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12
Impact 3 - Perennial Stream 8
Aquatic Life — assessment reach metric (skip for Tidal Marsh Streams)
12a. ®Yes ❑No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ❑No Water ❑Other:
12b. ®Yes ❑No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
❑ ❑Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ ❑Beetles
❑ ®Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/shrimp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ❑Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, fishily, dobsonfly larvae)
❑ ®Midges/mosquito larvae
❑ ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Other fish
❑ ❑Salamanders/tadpoles
® ❑Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
❑ ®Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland runoff.
LB RB
®A ®A Little or no alteration to water storage capacity over a majority of the streamside area
❑B ❑B Moderate alteration to water storage capacity over a majority of the streamside area
El ❑C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil compaction,
livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water >_ 6 inches deep
❑B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
®C ®C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ❑Y Are wetlands present in the streamside area?
®N ®N
16. Baseflow Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
❑A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
❑D Evidence of bank seepage or sweating (iron in water indicates seepage)
®E Stream bed or bank soil reduced (dig through deposited sediment if present)
❑F None of the above
17. Basef low Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
®B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
❑C Urban stream (>_ 24% impervious surface for watershed)
❑D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
❑F None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
®A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
❑B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

Impact 3 - Perennial Stream 8
19. Buffer Width — streamside area metric (skip for Tidal Marsh Streams)
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
®A ®A ®A ®A >_ 100 feet wide or extends to the edge of the watershed
❑B ❑B ❑B ❑B From 50 to < 100 feet wide
❑C ❑C ❑C ❑C From 30 to < 50 feet wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
❑E ❑E ❑E ❑E < 10 feet wide or no trees
20. Buffer Structure — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
❑A ❑A Mature forest
®B ®B Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but is
within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
®A ®A Medium to high stem density
❑B ❑B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer — streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
®A ®A The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
®B ®B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
❑C ❑C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity — assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes ®No Was conductivity measurement recorded?
If No, select one of the following reasons. ®No Water ❑Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 ❑B 46 to < 67 ❑C 67 to < 79 ❑D 79 to < 230 ❑E >_ 230
Notes/Sketch:
Culverts at downstream end of reach area severely buried with sediment, that backs up sediment and water into over 10% of the assessment
reach.

Stream Site Name Piedmont Lithium
Stream Category Pb1
Draft NC SAM Stream Rating Sheet Impact 3 - Perennial Stream 8
Accompanies User Manual Version 2.1
Date of Assessment April 4, 2018
Assessor Name/Organization Kelly Thames/HDR
Notes of Field Assessment Form (Y/N) YES
Presence of regulatory considerations (Y/N) YES
Additional stream information/supplementary measurements included (Y/N) YES
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream) Perennial
USACE/ NCDWR
Function Class Rating Summary
All Streams Intermittent
(1) Hydrology
HIGH
(2) Baseflow
MEDIUM
(2) Flood Flow
HIGH
(3) Streamside Area Attenuation
HIGH
(4) Floodplain Access
HIGH
(4) Wooded Riparian Buffer
HIGH
(4) Microtopography
NA
(3) Stream Stability
MEDIUM
(4) Channel Stability
MEDIUM
(4) Sediment Transport
LOW
(4) Stream Geomorphology
HIGH
(2) Stream/Intertidal Zone Interaction
NA
(2) Longitudinal Tidal Flow
NA
(2) Tidal Marsh Stream Stability
NA
(3) Tidal Marsh Channel Stability
NA
(3) Tidal Marsh Stream Geomorphology
NA
(1) Water Quality
HIGH
(2) Baseflow
MEDIUM
(2) Streamside Area Vegetation
HIGH
(3) Upland Pollutant Filtration
HIGH
(3) Thermoregulation
HIGH
(2) Indicators of Stressors
NO
(2) Aquatic Life Tolerance
HIGH
(2) Intertidal Zone Filtration
NA
(1) Habitat
MEDIUM
(2) In -stream Habitat
LOW
(3) Baseflow
MEDIUM
(3) Substrate
LOW
(3) Stream Stability
MEDIUM
(3) In -stream Habitat
MEDIUM
(2) Stream -side Habitat
HIGH
(3) Stream -side Habitat
HIGH
(3) Thermoregulation
HIGH
(2) Tidal Marsh In -stream Habitat
NA
(3) Flow Restriction
NA
(3) Tidal Marsh Stream Stability
NA
(4) Tidal Marsh Channel Stability
NA
(4) Tidal Marsh Stream Geomorphology
NA
(3) Tidal Marsh In -stream Habitat
NA
(2) Intertidal Zone
NA
Overall
HIGH

WC DivisEon of Water Qua liter-Methodol ogy for Ido inti 11 cation of Intermittent and
Perennial Strearns and Their Origins v. 4.11
e -I CT
N C DWQ Stream [dent Ar:i on Form
Vetsiun 4.11 +'' WOL ? -1 tl''}.
date: '3 0
ProjectlSite: Z. N VIA --Latitude:
3 '
Evaluator: [ 1. ��G W11 IS
County: �, �.l ir. �G ,- f
Longitude: -,g
Total Paints:
Stream Is arenas[ intermittent V f7
'!9
Stream Determination (circle one)
Ephemeral'hiterrnitten ere nnial
Other L'✓'�C*.d�irt1l�
e.g. Quad Name:
if 1, 2r30renr
❑r perennial if ? 3Q' ti"
4_ -
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A. Geomor holy Subtotal = I `- )
Absent
Weak
Moderate
Strong
18Continuity of channel bed and bank
0
1
.2
3
2. Sinuosity of channel along thalweg
0
1
2
1 �.
3. In -channel structure: ex. riffle -pool, step -pool,
ripple -pool sequence
0
1
tJ
3
4. Particle size of stream substrate
0
3
2
3
5. Activelrelict floodplain
0
1
2
3
6. Depositional bars or benches
1
2
3
7. Recent alluvial deposits
1
2
3
8. Headcuts
0
2
3
9. Grade control
0
0.5
1
1.
10. Natural valley
q
I 0.5
1
1.
11. Second or greater order channel
No = 0
Yes = 3
"artificial ditches are not rated; sea discus Ions in manual
B. Hydrology (Subtotal = )
12. Presence of Baseflow
0
2 3
13. Iron oxidizing bacteria
0 M
2 3
14. Leaf litter
1.5 1
.5 0
15. Sediment on plants or debris
0 0.5
3 1.5
16. Organic debris lines or piles
0 0.5
1 �.
17. Soil -based evidence of high water table?
No = 0
Yes 3
C. Biology (Subtotal
18. Fibrous roots in streambed 3
2 1 0
19. Rooted upland plants in streambed
2 1 0
20. Macrobenthos (note diversity and abundance) 0
1 2 3
21. Aquatic Mollusks
1 2 3
22. Fish 0
0.5 1 1.5
23. Crayfish
0.5 1 1.5
24. Amphibians
0.5 1 1.5
25. Algae 0 1
0.5 01.5
26. Wetland plants in streambed
FACW = 0.75; OBL = 1.5 Other 0
'perennial streams may also be identified using other methods- See p. 35 of manual.
Nates:
Sketch:
` G Wr
Vy
L
11' - l 0 r
41
Li

NC SAM FIELD ASSESSMENT FORM Impact 4-1 - Intermittent Stream 8
user rvianuai version z. -i
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic quadrangle,
and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property, identify and
number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for detailed descriptions
and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were performed. See the
NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION:
1. Project name (if any): Piedmont Lithium
3. Applicant/owner name: Piedmont Lithium, Inc.
5. County: Gaston
2. Date of evaluation: April 4, 2018
4. Assessor name/organization: Kelly Thames/HDR
6. Nearest named water body Beaverdam Creek (HUC
7. River basin: Catawba on USGS 7.5 -minute quad: 01030102)
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.383772, -81.285658
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): Impact 4 - 1 10. Length of assessment reach evaluated (feet): 337.5 ft
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 4-6 ft ❑Unable to assess channel depth.
12. Channel width at top of bank (feet): 10-15 ft 13. Is assessment reach a swamp steam? ❑Yes ❑No
14. Feature type: ❑Perennial flow ®Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) ® Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic ❑A`J ®B
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip ®Size 1 (< 0.1 mil) ❑Size 2 (0.1 to < 0.5 mit) ❑Size 3 (0.5 to < 5 mit) ❑Size 4 (>_ 5 mit)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑Section 10 water ❑Classified Trout Waters ®Water Supply Watershed (❑I ❑ll ❑III ®IV ❑V)
❑Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters
❑Anadromous fish ❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
❑Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in "Notes/Sketch" section or attached? ®Yes ❑No
1. Channel Water - assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
❑A Water throughout assessment reach.
®B No flow, water in pools only.
❑C No water in assessment reach.
2. Evidence of Flow Restriction - assessment reach metric
❑A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
®B Not
3. Feature Pattern - assessment reach metric
®A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
❑B Not
4. Feature Longitudinal Profile - assessment reach metric
®A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming, over
widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of these
disturbances).
❑B Not
5. Signs of Active Instability - assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
❑A < 10% of channel unstable
❑B 10 to 25% of channel unstable
®C > 25% of channel unstable

6. Streamside Area Interaction — streamside area metric Impact 4-1 - Intermittent Stream 8
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
❑A ❑A
Little or no evidence of conditions that adversely affect reference interaction
®B ®B
Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area, leaky
or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C
Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision, disruption
of flood flows through streamside area] or too much floodplain/intertidal zone access [examples: impoundments, intensive
mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a man-made feature on an
interstream divide
Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
®A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
®F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
❑I Other: (explain in "Notes/Sketch" section)
❑J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
101b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
❑A Multiple aquatic macrophytes and aquatic mosses m w ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) CO ❑G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent w Y ❑H Low -tide refugia (pools)
vegetation NC El Sand bottom
®C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
❑D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
❑ ® ❑ ❑ ❑ Bedrock/saprolite
❑ ❑ ® ❑ ❑ Boulder (256 — 4096 mm)
❑ ❑ ❑ ❑ ❑ Cobble (64 — 256 mm)
❑ ❑ ❑ ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ❑ ❑ Sand (.062 — 2 mm)
❑ ❑ ❑ ® ❑ Silt/clay (< 0.062 mm)
❑ ❑ ❑ ® ❑ Detritus
❑ ❑ ❑ ® ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12. Aquatic Life —assessment reach metric (skip for Tidal Marsh Streams) Impact 4-1 - Intermittent Stream 8
12a. ®Yes ❑No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ®No Water ❑Other:
12b. ®Yes ❑No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
❑ ❑Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ ❑Beetles
❑ ®Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/shrimp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ❑Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, fishily, dobsonfly larvae)
❑ ❑Midges/mosquito larvae
❑ ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Other fish
❑ ❑Salamanders/tadpoles
❑ ❑Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
® ❑Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland runoff.
LB RB
❑A ❑A Little or no alteration to water storage capacity over a majority of the streamside area
®B ❑B Moderate alteration to water storage capacity over a majority of the streamside area
❑C ®C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil compaction,
livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water >_ 6 inches deep
❑B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
®C ®C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ❑Y Are wetlands present in the streamside area?
®N ®N
16. Baseflow Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
❑A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
❑D Evidence of bank seepage or sweating (iron in water indicates seepage)
❑E Stream bed or bank soil reduced (dig through deposited sediment if present)
®F None of the above
17. Basef low Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
❑B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
❑C Urban stream (>_ 24% impervious surface for watershed)
®D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
❑F None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
®A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
❑B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

19. Buffer Width — streamside area metric (skip for Tidal Marsh Streams) Impact 4-1 -Intermittent Stream 8
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
®A ®A ®A ❑A >_ 100 feet wide or extends to the edge of the watershed
❑B ❑B ❑B ❑B From 50 to < 100 feet wide
❑C ❑C ❑C ®C From 30 to < 50 feet wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
❑E ❑E ❑E ❑E < 10 feet wide or no trees
20. Buffer Structure — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
❑A ❑A Mature forest
®B ®B Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but is
within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22: ❑
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ®D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
❑A ❑A Medium to high stem density
®B ®B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer — streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
®A ❑A The total length of buffer breaks is < 25 percent.
❑B ®B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
®B ®B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
❑C ❑C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity — assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes ®No Was conductivity measurement recorded?
If No, select one of the following reasons. ®No Water ❑Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 ❑B 46 to < 67 ❑C 67 to < 79 ❑D 79 to < 230 ❑E >_ 230
Notes/Sketch:
This stream reach is actively accessed by cattle and horses on both left and right banks. Vegetation structure is little to no shrub or herbaceous
growth due to livestock distrubance. Additionally, farm trash and large, unnatural rocks were observed in the reach. There was a gray discarge
of some sort, no odor, in the reach during the assessment.

Impact 4-1 - Intermittent Stream 8
Draft NC SAM Stream Rating
Sheet
Accompanies User Manual Version 2.1
Stream Site Name Piedmont Lithium Date of Assessment April 4, 2018
Stream Category Pb1 Assessor Name/Organization
Kelly Thames/HDR
Notes of Field Assessment Form (Y/N)
YES
Presence of regulatory considerations (Y/N)
YES
Additional stream information/supplementary measurements included (Y/N)
YES
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream)
Intermittent
USACE/
NCDWR
Function Class Rating Summary
All Streams Intermittent
(1) Hydrology
(2) Baseflow
MEDIUM
MEDIUM
(2) Flood Flow
(3) Streamside Area Attenuation
MEDIUM
MEDIUM
(4) Floodplain Access
MEDIUM
MEDIUM
(4) Wooded Riparian Buffer
MEDIUM
MEDIUM
(4) Microtopography
NA
NA
(3) Stream Stability
(4) Channel Stability
LOW
LOW
(4) Sediment Transport
(4) Stream Geomorphology
LOW
LOW
(2) Stream/Intertidal Zone Interaction
NA
NA
(2) Longitudinal Tidal Flow
NA
NA
(2) Tidal Marsh Stream Stability
NA
NA
(3) Tidal Marsh Channel Stability
NA
NA
(3) Tidal Marsh Stream Geomorphology
NA
NA
(1) Water Quality
MEDIUM
MEDIUM
(2) Baseflow
MEDIUM
MEDIUM
(2) Streamside Area Vegetation
HIGH
HIGH
(3) Upland Pollutant Filtration
HIGH
HIGH
(3) Thermoregulation
HIGH
HIGH
(2) Indicators of Stressors
YES
YES
(2) Aquatic Life Tolerance
HIGH
NA
(2) Intertidal Zone Filtration
NA
NA
(1) Habitat
HIGH
(2) In -stream Habitat
HIGH
(3) Baseflow
MEDIUM
MEDIUM
(3) Substrate
(3) Stream Stability
LOW
LOW
(3) In -stream Habitat
MEDIUM
HIGH
(2) Stream -side Habitat
HIGH
HIGH
(3) Stream -side Habitat
HIGH
HIGH
(3) Thermoregulation
HIGH
HIGH
(2) Tidal Marsh In -stream Habitat
NA
NA
(3) Flow Restriction
NA
NA
(3) Tidal Marsh Stream Stability
NA
NA
(4) Tidal Marsh Channel Stability
NA
NA
(4) Tidal Marsh Stream Geomorphology
NA
NA
(3) Tidal Marsh In -stream Habitat
NA
NA
(2) Intertidal Zone
NA
NA
Overall
MEDIUM

NC SAM FIELD ASSESSMENT FORM Impact 4-2 - Intermittent Stream 8
user rvianuai version z. -i
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic quadrangle,
and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property, identify and
number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for detailed descriptions
and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were performed. See the
NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION:
1. Project name (if any): Piedmont Lithium
3. Applicant/owner name: Piedmont Lithium, Inc.
5. County: Gaston
2. Date of evaluation: April 4, 2018
4. Assessor name/organization: Kelly Thames/HDR
6. Nearest named water body Beaverdam Creek (HUC
7. River basin: Catawba on USGS 7.5 -minute quad: 01030102)
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.38393, -81.286211
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): Impact 4 - 2 10. Length of assessment reach evaluated (feet): 211 ft
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 4-6 ft ❑Unable to assess channel depth.
12. Channel width at top of bank (feet): 10-15 ft 13. Is assessment reach a swamp steam? ❑Yes ❑No
14. Feature type: ❑Perennial flow ®Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) ® Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic ❑A`J ®B
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip ®Size 1 (< 0.1 mil) ❑Size 2 (0.1 to < 0.5 mit) ❑Size 3 (0.5 to < 5 mit) ❑Size 4 (>_ 5 mit)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑Section 10 water ❑Classified Trout Waters ®Water Supply Watershed (❑I ❑ll ❑III ®IV ❑V)
❑Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters
❑Anadromous fish ❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
❑Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in "Notes/Sketch" section or attached? ®Yes ❑No
1. Channel Water - assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
❑A Water throughout assessment reach.
®B No flow, water in pools only.
❑C No water in assessment reach.
2. Evidence of Flow Restriction - assessment reach metric
❑A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
®B Not
3. Feature Pattern - assessment reach metric
®A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
❑B Not
4. Feature Longitudinal Profile - assessment reach metric
®A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming, over
widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of these
disturbances).
❑B Not
5. Signs of Active Instability - assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
❑A < 10% of channel unstable
®B 10 to 25% of channel unstable
❑C > 25% of channel unstable

Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
®A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
❑I Other: (explain in "Notes/Sketch" section)
❑J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
101b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
❑A Multiple aquatic macrophytes and aquatic mosses m w ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) CO ❑G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent w Y ❑H Low -tide refugia (pools)
vegetation NC El Sand bottom
®C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
®D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
❑ ® ❑ ❑ ❑ Bedrock/saprolite
❑ ❑ ® ❑ ❑ Boulder (256 — 4096 mm)
❑ ❑ ® ❑ ❑ Cobble (64 — 256 mm)
❑ ❑ ❑ ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ❑ ❑ Sand (.062 — 2 mm)
❑ ❑ ❑ ® ❑ Silt/clay (< 0.062 mm)
❑ ❑ ❑ ® ❑ Detritus
❑ ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
Impact 4-2 - Intermittent Stream 8
6. Streamside Area Interaction — streamside area metric
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
®A ®A
Little or no evidence of conditions that adversely affect reference interaction
❑B ❑B
Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area, leaky
or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C
Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision, disruption
of flood flows through streamside area] or too much floodplain/intertidal zone access [examples: impoundments, intensive
mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a man-made feature on an
interstream divide
Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
®A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
❑I Other: (explain in "Notes/Sketch" section)
❑J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
101b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
❑A Multiple aquatic macrophytes and aquatic mosses m w ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) CO ❑G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent w Y ❑H Low -tide refugia (pools)
vegetation NC El Sand bottom
®C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
®D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
❑ ® ❑ ❑ ❑ Bedrock/saprolite
❑ ❑ ® ❑ ❑ Boulder (256 — 4096 mm)
❑ ❑ ® ❑ ❑ Cobble (64 — 256 mm)
❑ ❑ ❑ ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ❑ ❑ Sand (.062 — 2 mm)
❑ ❑ ❑ ® ❑ Silt/clay (< 0.062 mm)
❑ ❑ ❑ ® ❑ Detritus
❑ ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12
Impact 4-2 - Intermittent Stream 8
Aquatic Life — assessment reach metric (skip for Tidal Marsh Streams)
12a. ®Yes ❑No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ®No Water ❑Other:
12b. ®Yes ❑No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
❑ ❑Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ ❑Beetles
❑ ®Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/shrimp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ❑Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, fishily, dobsonfly larvae)
❑ ®Midges/mosquito larvae
❑ ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Other fish
❑ ❑Salamanders/tadpoles
❑ ❑Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
❑ ®Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland runoff.
LB RB
®A ®A Little or no alteration to water storage capacity over a majority of the streamside area
❑B ❑B Moderate alteration to water storage capacity over a majority of the streamside area
El ❑C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil compaction,
livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water >_ 6 inches deep
❑B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
®C ®C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ❑Y Are wetlands present in the streamside area?
®N ®N
16. Baseflow Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
❑A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
❑D Evidence of bank seepage or sweating (iron in water indicates seepage)
❑E Stream bed or bank soil reduced (dig through deposited sediment if present)
®F None of the above
17. Basef low Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
❑B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
❑C Urban stream (>_ 24% impervious surface for watershed)
❑D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
®F None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
®A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
❑B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

19. Buffer Width —streamside area metric (skip for Tidal Marsh Streams) Impact 4-2 - Intermittent Stream 8
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
®A ®A ®A ®A >_ 100 feet wide or extends to the edge of the watershed
❑B ❑B ❑B ❑B From 50 to < 100 feet wide
❑C ❑C ❑C ❑C From 30 to < 50 feet wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
❑E ❑E ❑E ❑E < 10 feet wide or no trees
20. Buffer Structure — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
❑A ❑A Mature forest
®B ®B Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but is
within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
❑A ❑A Medium to high stem density
®B ®B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer — streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
®A ®A The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
®B ®B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
❑C ❑C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity — assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes ®No Was conductivity measurement recorded?
If No, select one of the following reasons. ®No Water ❑Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 ❑B 46 to < 67 ❑C 67 to < 79 ❑D 79 to < 230 ❑E >_ 230
Notes/Sketch:
There was a gray discarge of some sort, no odor, in the reach during the assessment

Draft NC SAM Stream Rating Sheet Impact 4-2 - Intermittent Stream 8
Accompanies User Manual Version 2.1
Stream Site Name
Piedmont Lithium
Date of Assessment
April 4, 2018
Stream Category
Pb1
Assessor Name/Organization
Kelly Thames/HDR
(2) Baseflow
Notes of Field Assessment Form (Y/N) YES
Presence of regulatory considerations (Y/N) NO
Additional stream information/supplementary measurements included (Y/N) YES
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream) Intermittent
USACE/
NCDWR
Function Class Rating Summary
All Streams
Intermittent
(1) Hydrology
(2) Baseflow
HIGH
HIGH
(2) Flood Flow
(3) Streamside Area Attenuation
HIGH
HIGH
(4) Floodplain Access
HIGH
HIGH
(4) Wooded Riparian Buffer
MEDIUM
MEDIUM
(4) Microtopography
NA
NA
(3) Stream Stability
(4) Channel Stability
MEDIUM
MEDIUM
(4) Sediment Transport
(4) Stream Geomorphology
LOW
LOW
(2) Stream/Intertidal Zone Interaction
NA
NA
(2) Longitudinal Tidal Flow
NA
NA
(2) Tidal Marsh Stream Stability
NA
NA
(3) Tidal Marsh Channel Stability
NA
NA
(3) Tidal Marsh Stream Geomorphology
NA
NA
(1) Water Quality
HIGH
HIGH
(2) Baseflow
HIGH
HIGH
(2) Streamside Area Vegetation
HIGH
HIGH
(3) Upland Pollutant Filtration
HIGH
HIGH
(3) Thermoregulation
HIGH
HIGH
(2) Indicators of Stressors
NO
NO
(2) Aquatic Life Tolerance
HIGH
NA
(2) Intertidal Zone Filtration
NA
NA
(1) Habitat
HIGH
(2) In -stream Habitat
HIGH
(3) Baseflow
HIGH
HIGH
(3) Substrate
(3) Stream Stability
MEDIUM
MEDIUM
(3) In -stream Habitat
HIGH
HIGH
(2) Stream -side Habitat
HIGH
HIGH
(3) Stream -side Habitat
HIGH
HIGH
(3) Thermoregulation
HIGH
HIGH
(2) Tidal Marsh In -stream Habitat
NA
NA
(3) Flow Restriction
NA
NA
(3) Tidal Marsh Stream Stability
NA
NA
(4) Tidal Marsh Channel Stability
NA
NA
(4) Tidal Marsh Stream Geomorphology
NA
NA
(3) Tidal Marsh In -stream Habitat
NA
NA
(2) Intertidal Zone
NA
NA
Overall
MEDIUM

NG Div is ion of Water Qu alit} -Methodology fO r Ids nif ficstioin of Inte rme ttent a Md
Pe rennial Stm ams and Th6r PKk1jq!r, v. 4,11
NC DWO Strea}nk [filen tifi:c a I ion Form Vt! rsion 4.11 �1` � � �`'' 17
A. Geomorphology (Subtotal=
Date: I -f I
Project/Site: t,
Latitude. '3 �j❑US`
Strong
1a Continuitz of channel bed and bank
Evaluator: �, `' G WUj
County: buSi , o o+✓�1
Longitude:.-
3
2. Sinuosity of channel aloe thalweg
Total Points:
Stream is at least intermittent
Stream Determination (circle one)
r�
Ephemeral
Other L ►�- i" 0i 0 f'o
(.
3
3. In -channel structure: ex. riffle -pool, step -pool,
ripple -pool sequence
if 3 19 or erenntal if a 30m
Ir ttetl� Perennial
I
e.g. Quad varve:
t iJl�•
3
A. Geomorphology (Subtotal=
Absent
Weak
Moderate
Strong
1a Continuitz of channel bed and bank
0
1
2
3
2. Sinuosity of channel aloe thalweg
0
(y
2
3
3. In -channel structure: ex. riffle -pool, step -pool,
ripple -pool sequence
q
0.5
2
3
4. Particle size of stream substrate
0
1
1.5
3
5. Active/relict floodplain
1
1
2
3
6. Depositional bars or benches
0
1
2
3
7. Recent alluvial deposits
0
1
2
3
8. Headcuts
0
1
3
9. Grade control
0
0.5
1
1.5
10. Natural valley
0
0.5
1
1.
11. Second or greater order channel
No
0
Yes
= 3
"artificial ditches are not rated: see discusslons In manual
R Hvrirnlnnv ffii ihtntA = i 'C7 1
12. Presence of Baseflow
0 1 2 3
13. Iron oxidizing bacteria
0 1 3
14. Leaf litter
1.5 0.5 0
15. Sediment on plants or debris
0 0.5 1
16. Organic debris lines or piles
0 0.5 1 1.5
17. Soil -based evidence of high water table?
No = 0 Yes
C_ Hinlnciv ISuhtntal = '- 1 . <, 1
18. Fibrous roots in streambed 3
2
(17
0
19. Rooted upland plants in streambed
2
1
0
20. Macrobenthos (note diversity and abundance)
1
2
3
21. Aquatic Mollusks
1
2
3
22. Fish cel
0.5
1
1.5
23. Crayfish (017-
0
0.5
1
1.5
24. Amphibians 0
p'
1
1,5
25. Algae
tt
1
1.5
26. Wetland plants in streambed
FACW = 0.75; OBL = 1.5 Other = 0
'perennial streams may also be identified using other methods. See p. 35 of manual.
Notes:
Sketch-,
41

NC SAM FIELD ASSESSMENT FORM Impact 5 - Intermittent Stream 9
user rvianuai version z. -i
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic quadrangle,
and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property, identify and
number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for detailed descriptions
and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were performed. See the
NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION:
1. Project name (if any): Piedmont Lithium
3. Applicant/owner name: Piedmont Lithium, Inc.
5. County: Gaston
2. Date of evaluation: April 4, 2018
4. Assessor name/organization: Kelly Thames/HDR
6. Nearest named water body Beaverdam Creek (HUC
7. River basin: Catawba on USGS 7.5 -minute quad: 01030102)
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.383878, -81.286878
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): Impact 5 10. Length of assessment reach evaluated (feet): 76.5 ft
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 4 ft ❑Unable to assess channel depth.
12. Channel width at top of bank (feet): 5 ft 13. Is assessment reach a swamp steam? ❑Yes ❑No
14. Feature type: ❑Perennial flow ®Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) ® Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic ❑A`J ®B
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip ®Size 1 (< 0.1 mil) ❑Size 2 (0.1 to < 0.5 mit) ❑Size 3 (0.5 to < 5 mit) ❑Size 4 (>_ 5 mit)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑Section 10 water ❑Classified Trout Waters ®Water Supply Watershed (❑I ❑ll ❑III ®IV ❑V)
❑Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters
❑Anadromous fish ❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
❑Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in "Notes/Sketch" section or attached? ®Yes ❑No
1. Channel Water - assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
❑A Water throughout assessment reach.
❑B No flow, water in pools only.
®C No water in assessment reach.
2. Evidence of Flow Restriction - assessment reach metric
®A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
❑B Not
3. Feature Pattern - assessment reach metric
®A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
❑B Not
4. Feature Longitudinal Profile - assessment reach metric
®A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming, over
widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of these
disturbances).
❑B Not
5. Signs of Active Instability - assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
❑A < 10% of channel unstable
❑B 10 to 25% of channel unstable
®C > 25% of channel unstable

Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
®B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
❑I Other: (explain in "Notes/Sketch" section)
❑J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
101b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
❑A Multiple aquatic macrophytes and aquatic mosses m w ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) (D ❑G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent w Y ❑H Low -tide refugia (pools)
vegetation N ❑I Sand bottom
❑C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
❑D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
® ❑ ❑ ❑ ❑ Bedrock/saprolite
® ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
® ❑ ❑ ❑ ❑ Cobble (64 — 256 mm)
❑ ® ❑ ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ❑ ® Sand (.062 — 2 mm)
❑ ❑ ❑ ® ❑ Silt/clay (< 0.062 mm)
❑ ❑ ❑ ® ❑ Detritus
® ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
Impact 5 - Intermittent Stream 9
6. Streamside Area Interaction — streamside area metric
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
❑A ❑A
Little or no evidence of conditions that adversely affect reference interaction
❑B ®B
Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area, leaky
or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
®C ❑C
Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision, disruption
of flood flows through streamside area] or too much floodplain/intertidal zone access [examples: impoundments, intensive
mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a man-made feature on an
interstream divide
Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
®B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
❑I Other: (explain in "Notes/Sketch" section)
❑J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
101b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
❑A Multiple aquatic macrophytes and aquatic mosses m w ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) (D ❑G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent w Y ❑H Low -tide refugia (pools)
vegetation N ❑I Sand bottom
❑C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
❑D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
® ❑ ❑ ❑ ❑ Bedrock/saprolite
® ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
® ❑ ❑ ❑ ❑ Cobble (64 — 256 mm)
❑ ® ❑ ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ❑ ® Sand (.062 — 2 mm)
❑ ❑ ❑ ® ❑ Silt/clay (< 0.062 mm)
❑ ❑ ❑ ® ❑ Detritus
® ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12
Impact 5 - Intermittent Stream 9
Aquatic Life — assessment reach metric (skip for Tidal Marsh Streams)
12a. ❑Yes ®No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ®No Water ❑Other:
12b. ❑Yes ❑No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
❑ ❑Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ ❑Beetles
❑ ❑Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/shrimp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ❑Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, fishily, dobsonfly larvae)
❑ ❑Midges/mosquito larvae
❑ ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Other fish
❑ ❑Salamanders/tadpoles
❑ ❑Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
❑ ❑Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland runoff.
LB RB
❑A ❑A Little or no alteration to water storage capacity over a majority of the streamside area
❑B ®B Moderate alteration to water storage capacity over a majority of the streamside area
®C ❑C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil compaction,
livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water >_ 6 inches deep
❑B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
®C ®C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ❑Y Are wetlands present in the streamside area?
®N ®N
16. Baseflow Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
❑A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
❑D Evidence of bank seepage or sweating (iron in water indicates seepage)
❑E Stream bed or bank soil reduced (dig through deposited sediment if present)
®F None of the above
17. Basef low Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
❑B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
❑C Urban stream (>_ 24% impervious surface for watershed)
®D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
❑F None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
®A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
❑B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

19. Buffer Width —streamside area metric (skip for Tidal Marsh Streams) Impact 5 - Intermittent Stream 9
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
❑A ®A ❑A ®A >_ 100 feet wide or extends to the edge of the watershed
❑B ❑B ❑B ❑B From 50 to < 100 feet wide
❑C ❑C ❑C ❑C From 30 to < 50 feet wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
®E ❑E ®E ❑E < 10 feet wide or no trees
20. Buffer Structure — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
❑A ❑A Mature forest
®B ®B Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but is
within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
❑A ❑A Medium to high stem density
®B ®B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer — streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
❑A ®A The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
®C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
®B ®B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
❑C ❑C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity — assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes ®No Was conductivity measurement recorded?
If No, select one of the following reasons. ®No Water ❑Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 ❑B 46 to < 67 ❑C 67 to < 79 ❑D 79 to < 230 ❑E >_ 230
Notes/Sketch:
There was a gray discarge of some sort, no odor, in the reach during the assessment. There is a farm road paralleling the left bank of this stream,
less than 10 feet from top of bank. There is excessive sedimentation in the channel from runoff from this road. Channel is very incised and
downcutting.

D ft NC CAM Of R ' Ch t Impact 5 - Intermittent Stream 9
ra ream aL ng ee
Accompanies User Manual Version 2.1
Stream Site Name Piedmont Lithium Date of Assessment April 4, 2018
Stream Category Pb1 Assessor Name/Organization Kelly Thames/HDR
Notes of Field Assessment Form (Y/N) YES
Presence of regulatory considerations (Y/N) NO
Additional stream information/supplementary measurements included (Y/N) YES
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream) Intermittent
USACE/ NCDWR
Function Class Rating Summary All Streams Intermittent
(1) Hydrology LOW LOW
(2) Baseflow
MEDIUM
MEDIUM
(2) Flood Flow
LOW
LOW
(3) Streamside Area Attenuation
LOW
LOW
(4) Floodplain Access
LOW
LOW
(4) Wooded Riparian Buffer
LOW
LOW
(4) Microtopography
NA
NA
(3) Stream Stability
LOW
LOW
(4) Channel Stability
LOW
LOW
(4) Sediment Transport
LOW
LOW
(4) Stream Geomorphology
LOW
LOW
(2) Stream/Intertidal Zone Interaction
NA
NA
(2) Longitudinal Tidal Flow
NA
NA
(2) Tidal Marsh Stream Stability
NA
NA
(3) Tidal Marsh Channel Stability
NA
NA
(3) Tidal Marsh Stream Geomorphology
NA
NA
(1) Water Quality
LOW
LOW
(2) Baseflow
MEDIUM
MEDIUM
(2) Streamside Area Vegetation
MEDIUM
MEDIUM
(3) Upland Pollutant Filtration
LOW
LOW
(3) Thermoregulation
HIGH
HIGH
(2) Indicators of Stressors
YES
YES
(2) Aquatic Life Tolerance
OMITTED
NA
(2) Intertidal Zone Filtration
NA
NA
(1) Habitat
LOW
LOW
(2) In -stream Habitat
LOW
LOW
(3) Baseflow
MEDIUM
MEDIUM
(3) Substrate
LOW
LOW
(3) Stream Stability
LOW
LOW
(3) In -stream Habitat
LOW
MEDIUM
(2) Stream -side Habitat
MEDIUM
MEDIUM
(3) Stream -side Habitat
LOW
LOW
(3) Thermoregulation
HIGH
HIGH
(2) Tidal Marsh In -stream Habitat
NA
NA
(3) Flow Restriction
NA
NA
(3) Tidal Marsh Stream Stability
NA
NA
(4) Tidal Marsh Channel Stability
NA
NA
(4) Tidal Marsh Stream Geomorphology
NA
NA
(3) Tidal Marsh In -stream Habitat
NA
NA
(2) Intertidal Zone
NA
NA
Overall LOW LOW

MC BiVis inrr Of meter OuaJ ity-MetJiodology for IdentJfI08tJ 0 n of I me rm itte rnt and
Pere n n i al Streams and Thea r OrJ girns v. 4.11
NC DWQ Stream idemdriication Form rm Vergion 4.11
Date:
Project/Site: } 'VXY . INS
Latitude: S6, 386
Evaluator: �C Q 1 �• �. �
County: ��~;
Longitude: -g 1 • 7,1110
Total Points:r
Stream is at feast intermittent
Stream aetermin 'an (circle one)
Other biion-C+LA�o ��
WZ: is or tennia! if L 30'
Ephemeral tTtermitt nt Perennial
e_g. Quad Name: y.• d
A. Geomorphology (Subtotal= +
Absent
Weak
Moderate
3
Strong
1� Continuity of channel bed and bank
0
T
2
14. Leaf litter
3
2. Sinuosity of channel along thalweg
0
1 ;
2
0
M
3. In -channel structure: ex. riffle -pool, step -pool,
ri le- ool se uence
0
16. Organic debris lines or piles
2
0.5
3
4. Particle size of stream substrate
0
1022
No = 0
1
3
5. Active/rel ictf[aodpIa1nOJ
j"0
1
2
1
3
6. Depositional bars or benches
0
0,5
2
1
3
7. Recent alluvial deposits
0
0.5
2
1
3
S. Headcuts
1
2
3
9. Grade control
0
0.5
1
1
10. Natural valley
0
0.5
1
11. Second or 9 reater order channel
No
to
Yes = 3
' artgiclal ditches are not rated; see discussions in manual
B. Hvdrologv [Subtotal = l (Dl 5- 1
12. Presence of Baseflow
0
01
2
3
13. Iron oxidizing bacteria
0
1
2
�3
14. Leaf litter
1.5
1
0,
p
15. Sediment on plants or debris
0
0.5
1
r0
16. Organic debris lines or piles
0
0.5
1
5
17. Soil -based evidence of high water table?
0.5
No = 0
1
yes. -3 .
C. Biology {Subtotal = lr ]
18, Fibrous roots in strearnbed
'3)
2
1
0
19, Rooted upland plants in streambed
3
2
1
0
20_ Macrobenthos (note diversity and abundance)
1
2
3
21. Aquatic Mollusks
r0
1
2
3
22. Fish
0.5
1
1.5
23. Crayfish
j"0
O's
1
1.5
24. Amphibians
o
0,5
1
1.5
25. Algae
0
0.5
1
1.5
26. Wetland plants in strearnbed
FACW = 4.75; OBL = 1.5
Other = 0
"perennial streams may also be identified using other methods. See p. 35 of manual,
Notes:
Sketch:
u vufi
[�, t o ply rV e c�
r� L 4
41

NC SAM FIELD ASSESSMENT FORM Impact 6 - Intermittent Stream 10
user rvianuai version z. -i
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic quadrangle,
and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property, identify and
number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for detailed descriptions
and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were performed. See the
NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION:
1. Project name (if any): Piedmont Lithium
3. Applicant/owner name: Piedmont Lithium, Inc.
5. County: Gaston
2. Date of evaluation: March 20, 2018
Assessor name/organization: Kelly Thames/HDR
Nearest named water body Beaverdam Creek (HUC
7. River basin: Catawba on USGS 7.5 -minute quad: 01030102)
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.388456, -81.291671
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): Impact 6 10. Length of assessment reach evaluated (feet): 520 ft
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 2 ft ❑Unable to assess channel depth.
12. Channel width at top of bank (feet): 3 ft 13. Is assessment reach a swamp steam? ❑Yes ❑No
14. Feature type: ❑Perennial flow ®Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) ® Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic ®A` J ❑B
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip ®Size 1 (< 0.1 mil) ❑Size 2 (0.1 to < 0.5 mit) ❑Size 3 (0.5 to < 5 mit) ❑Size 4 (>_ 5 mit)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑Section 10 water ❑Classified Trout Waters ®Water Supply Watershed (❑I ❑II ❑III ®IV ❑V)
❑Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters
❑Anadromous fish ❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
❑Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in "Notes/Sketch" section or attached? ®Yes ❑No
1. Channel Water — assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
❑A Water throughout assessment reach.
®B No flow, water in pools only.
❑C No water in assessment reach.
2. Evidence of Flow Restriction — assessment reach metric
❑A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
®B Not
3. Feature Pattern — assessment reach metric
❑A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
®B Not
4. Feature Longitudinal Profile — assessment reach metric
❑A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming, over
widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of these
disturbances).
®B Not
5. Signs of Active Instability — assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
®A < 10% of channel unstable
❑B 10 to 25% of channel unstable
❑C > 25% of channel unstable

6. Streamside Area Interaction — streamside area metric Impact 6 - Intermittent Stream 10
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
®A ®A Little or no evidence of conditions that adversely affect reference interaction
❑B ❑B Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area, leaky
or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision, disruption
of flood flows through streamside area] or too much floodplain/intertidal zone access [examples: impoundments, intensive
mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a man-made feature on an
interstream divide
Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
0 Other: (explain in "Notes/Sketch" section)
®J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
10b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
®A Multiple aquatic macrophytes and aquatic mosses m w ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) (D ❑G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent w Y ❑H Low -tide refugia (pools)
vegetation N ❑I Sand bottom
®C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
❑D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
® ❑ ❑ ❑ ❑ Bedrock/saprolite
® ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
® ❑ ❑ ❑ ❑ Cobble (64 — 256 mm)
❑ ❑ ® ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ® ❑ Sand (.062 — 2 mm)
❑ ❑ ❑ ® ❑ Silt/clay (< 0.062 mm)
❑ ❑ ❑ ® ❑ Detritus
® ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12
Impact 6 - Intermittent Stream 10
Aquatic Life — assessment reach metric (skip for Tidal Marsh Streams)
12a. ®Yes ❑No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ®No Water ❑Other:
12b. ®Yes ❑No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
® ❑Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ ❑Beetles
❑ ❑Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/shrimp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ❑Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, fishily, dobsonfly larvae)
❑ ❑Midges/mosquito larvae
❑ ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Other fish
❑ ❑Salamanders/tadpoles
❑ ❑Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
❑ ❑Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland runoff.
LB RB
®A ®A Little or no alteration to water storage capacity over a majority of the streamside area
❑B ❑B Moderate alteration to water storage capacity over a majority of the streamside area
❑C El Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil compaction,
livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water >_ 6 inches deep
®B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
❑C ®C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ❑Y Are wetlands present in the streamside area?
®N ®N
16. Baseflow Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
®A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
❑D Evidence of bank seepage or sweating (iron in water indicates seepage)
®E Stream bed or bank soil reduced (dig through deposited sediment if present)
❑F None of the above
17. Basef low Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
❑B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
❑C Urban stream (>_ 24% impervious surface for watershed)
❑D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
®F None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
®A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
❑B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

19. Buffer Width — streamside area metric (skip for Tidal Marsh Streams) Impact 6 -Intermittent Stream 10
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
®A ®A ®A ®A >_ 100 feet wide or extends to the edge of the watershed
❑B ❑B ❑B ❑B From 50 to < 100 feet wide
❑C ❑C ❑C ❑C From 30 to < 50 feet wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
❑E ❑E ❑E ❑E < 10 feet wide or no trees
20. Buffer Structure — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
❑A ❑A Mature forest
®B ®B Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but is
within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
❑A ❑A Medium to high stem density
®B ®B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer — streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
®A ®A The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
®B ®B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
❑C ❑C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity — assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes ®No Was conductivity measurement recorded?
If No, select one of the following reasons. ®No Water ❑Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 ❑B 46 to < 67 ❑C 67 to < 79 ❑D 79 to < 230 ❑E >_ 230
Notes/Sketch:
Intermittent stream, seepy in nature

Draft NC SAM Stream Rating Sheet
Impact 6 - Intermittent Stream 10
Accompanies User Manual Version 2.1
Stream Site Name Piedmont Lithium Date of Assessment March 20,
2018
Stream Category Pal Assessor Name/Organization
Kelly Thames/HDR
Notes of Field Assessment Form (Y/N)
YES
Presence of regulatory considerations (Y/N)
NO
Additional stream information/supplementary measurements included (Y/N)
YES
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream)
Intermittent
USACE/
NCDWR
Function Class Rating Summary
All Streams
Intermittent
(1) Hydrology
HIGH
HIGH
(2) Baseflow
HIGH
HIGH
(2) Flood Flow
HIGH
HIGH
(3) Streamside Area Attenuation
HIGH
HIGH
(4) Floodplain Access
HIGH
HIGH
(4) Wooded Riparian Buffer
MEDIUM
MEDIUM
(4) Microtopography
HIGH
HIGH
(3) Stream Stability
HIGH
HIGH
(4) Channel Stability
HIGH
HIGH
(4) Sediment Transport
LOW
LOW
(4) Stream Geomorphology
HIGH
HIGH
(2) Stream/Intertidal Zone Interaction
NA
NA
(2) Longitudinal Tidal Flow
NA
NA
(2) Tidal Marsh Stream Stability
NA
NA
(3) Tidal Marsh Channel Stability
NA
NA
(3) Tidal Marsh Stream Geomorphology
NA
NA
(1) Water Quality
MEDIUM
MEDIUM
(2) Baseflow
HIGH
HIGH
(2) Streamside Area Vegetation
HIGH
HIGH
(3) Upland Pollutant Filtration
HIGH
HIGH
(3) Thermoregulation
HIGH
HIGH
(2) Indicators of Stressors
NO
NO
(2) Aquatic Life Tolerance
LOW
NA
(2) Intertidal Zone Filtration
NA
NA
(1) Habitat
HIGH
HIGH
(2) In -stream Habitat
MEDIUM
MEDIUM
(3) Baseflow
HIGH
HIGH
(3) Substrate
LOW
LOW
(3) Stream Stability
HIGH
HIGH
(3) In -stream Habitat
HIGH
HIGH
(2) Stream -side Habitat
HIGH
HIGH
(3) Stream -side Habitat
HIGH
HIGH
(3) Thermoregulation
HIGH
HIGH
(2) Tidal Marsh In -stream Habitat
NA
NA
(3) Flow Restriction
NA
NA
(3) Tidal Marsh Stream Stability
NA
NA
(4) Tidal Marsh Channel Stability
NA
NA
(4) Tidal Marsh Stream Geomorphology
NA
NA
(3) Tidal Marsh In -stream Habitat
NA
NA
(2) Intertidal Zone
NA
NA
Overall
HIGH
HIGH

AIC Divi sio n of Water Q uality -M eth c d o logy f or Identification of I rete rmitte nt an d
Patrenniaf StrcarnIS a n d Their 4rig i n s v. 4,11
SPC IDWO Strew T den lif eation Form Version 4.11 �a Irv; n -
Date:
Absent
- r
Projectlsite: Cl �
Latitude.
Evaluator: } ISL j U�.Gi
County: y� �ca V' �.t''•; +
Longitude: 'j�
Tata! Points:
Stream Determinat n [circle one]
Other
Stream is least intermittent �5
if 19ar arennlafifZ 30'
Ephemera! L.Intermitte t Perennial
_
e.9 Quad Name:
A. Geonorphology ISubtotal =
Absent
Weak
Moderate
Strong
,a Continuity of channel bed and bank
0
1
2
3
2. Sinuosity of channel along thalweg
0
1
2
3
3. In -channel structure: ex. riffle -pool, step -pool,
ripple -pool sequence
0
q
2
3
4. Particle size of stream substrate
0
1
1 L
3
5. Activelrelict floodplain
0
1
2
3
6. depositional bars or benches
0
26. Wetland plants in streambed
2
3
7. Recent alluvial deposits
1
2
3
S_ Headcuts
1
2
3
9. Grade control
0
0.5
1
1.5
10. Natural valley
0
.5
1
1.5
11. Second or greater order channel
No
Q
Yes
= 3
° artificial ditches are not rated; see discussions In manual
B. Hvdrolacty (Subtotal =
12. Presence of Baseflew
0
1
2
3
13. Iron oxidizing bacteria
02
1
2
3
14. Leaf litter
1.5
1
0.5
0
15. Sediment on plants or debris
01D
0.5
1
1.5
16. Organic debris lines or piles
0
0.5
1 L
1.5
17. Soil -based evidence of high water table?
1
No = 0 1
Yes - 3
0.5
C_ Biology [Subtotal = )
18. Fibrous roots in streambed 3
2
1
0
19. Rooted upland plants in streambed
2
1
0
20. Macrobenthos (note diversity and abundance)
1
2
3
21. Aquatic Mollusks
i
2
3
22. Fish 0
4.5
1
1.5
23. Crayfish 0
.5
1
1.5
24. Amphibians
0.5
1
1.5
25. Algae
0.5
1
1.5
26. Wetland plants in streambed
FACIlV = 0.75; OBL = 1.5 Other = 0
.perennial streams may also be identified using other methods. See p. 35 of manual.
Notes:
Sketch:
41
'0)

NC SAM FIELD ASSESSMENT FORM Impact 7 - Intermittent Stream 11
user rvianuai version z. -i
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic quadrangle,
and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property, identify and
number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for detailed descriptions
and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were performed. See the
NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION:
1. Project name (if any): Piedmont Lithium
3. Applicant/owner name: Piedmont Lithium, Inc.
5. County: Gaston
2. Date of evaluation: March 20, 2018
Assessor name/organization: Kelly Thames/HDR
Nearest named water body Beaverdam Creek (HUC
7. River basin: Catawba on USGS 7.5 -minute quad: 01030102)
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.388575, -81.291775
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): Impact 7 10. Length of assessment reach evaluated (feet): 30 ft
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 1 ft ❑Unable to assess channel depth.
12. Channel width at top of bank (feet): 2 ft 13. Is assessment reach a swamp steam? ❑Yes ❑No
14. Feature type: ❑Perennial flow ®Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) ® Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic ®A` J ❑B
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip ®Size 1 (< 0.1 mil) ❑Size 2 (0.1 to < 0.5 mit) ❑Size 3 (0.5 to < 5 mit) ❑Size 4 (>_ 5 mit)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑Section 10 water ❑Classified Trout Waters ®Water Supply Watershed (❑I ❑II ❑III ®IV ❑V)
❑Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters
❑Anadromous fish ❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
❑Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in "Notes/Sketch" section or attached? ®Yes ❑No
1. Channel Water — assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
❑A Water throughout assessment reach.
®B No flow, water in pools only.
❑C No water in assessment reach.
2. Evidence of Flow Restriction — assessment reach metric
❑A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
®B Not
3. Feature Pattern — assessment reach metric
❑A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
®B Not
4. Feature Longitudinal Profile — assessment reach metric
❑A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming, over
widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of these
disturbances).
®B Not
5. Signs of Active Instability — assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
®A < 10% of channel unstable
❑B 10 to 25% of channel unstable
❑C > 25% of channel unstable

6. Streamside Area Interaction — streamside area metric Impact 7 - Intermittent Stream 11
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
®A ®A
Little or no evidence of conditions that adversely affect reference interaction
❑B ❑B
Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area, leaky
or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C
Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision, disruption
of flood flows through streamside area] or too much floodplain/intertidal zone access [examples: impoundments, intensive
mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a man-made feature on an
interstream divide
Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
0 Other: (explain in "Notes/Sketch" section)
®J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
10b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
®A Multiple aquatic macrophytes and aquatic mosses m w ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) CO ❑G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent w Y ❑H Low -tide refugia (pools)
vegetation NC El Sand bottom
❑C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
❑D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
® ❑ ❑ ❑ ❑ Bedrock/saprolite
® ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
® ❑ ❑ ❑ ❑ Cobble (64 — 256 mm)
® ❑ ❑ ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ® ❑ Sand (.062 — 2 mm)
❑ ❑ ❑ ❑ ® Silt/clay (< 0.062 mm)
❑ ❑ ❑ ❑ ® Detritus
® ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12
Aquatic Life —assessment reach metric (skip for Tidal Marsh Streams) Impact 7 - Intermittent Stream 11
12a. ®Yes ❑No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ®No Water ❑Other:
12b. ❑Yes ®No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
❑ ❑Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ ❑Beetles
❑ ❑Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/shrimp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ❑Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, fishily, dobsonfly larvae)
❑ ❑Midges/mosquito larvae
❑ ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Other fish
❑ ❑Salamanders/tadpoles
❑ ❑Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
❑ ❑Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland runoff.
LB RB
®A ®A Little or no alteration to water storage capacity over a majority of the streamside area
❑B ❑B Moderate alteration to water storage capacity over a majority of the streamside area
El ❑C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil compaction,
livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water >_ 6 inches deep
❑B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
®C ®C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ❑Y Are wetlands present in the streamside area?
®N ®N
16. Baseflow Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
❑A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
❑D Evidence of bank seepage or sweating (iron in water indicates seepage)
®E Stream bed or bank soil reduced (dig through deposited sediment if present)
❑F None of the above
17. Basef low Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
❑B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
❑C Urban stream (>_ 24% impervious surface for watershed)
❑D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
®F None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
®A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
❑B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

19. Buffer Width —streamside area metric (skip for Tidal Marsh Streams) Impact 7 - Intermittent Stream 11
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
®A ®A ®A ®A >_ 100 feet wide or extends to the edge of the watershed
❑B ❑B ❑B ❑B From 50 to < 100 feet wide
❑C ❑C ❑C ❑C From 30 to < 50 feet wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
❑E ❑E ❑E ❑E < 10 feet wide or no trees
20. Buffer Structure — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
❑A ❑A Mature forest
®B ®B Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but is
within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
❑A ❑A Medium to high stem density
®B ®B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer — streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
®A ®A The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
®B ®B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
❑C ❑C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity — assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes ®No Was conductivity measurement recorded?
If No, select one of the following reasons. ®No Water ❑Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 ❑B 46 to < 67 ❑C 67 to < 79 ❑D 79 to < 230 ❑E >_ 230
Notes/Sketch:
Intermittent stream, seepy in nature

Draft NC SAM Stream Rating Sheet Impact 7 - Intermittent Stream 11
Accompanies User Manual Version 2.1
Stream Site Name Piedmont Lithium Date of Assessment March 20, 2018
Stream Category Pal Assessor Name/Organization
Kelly Thames/HDR
Notes of Field Assessment Form (Y/N)
YES
Presence of regulatory considerations (Y/N)
NO
Additional stream information/supplementary measurements included (Y/N)
YES
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream)
Intermittent
USACE/
NCDWR
Function Class Rating Summary
All Streams
Intermittent
(1) Hydrology
HIGH
HIGH
(2) Baseflow
HIGH
HIGH
(2) Flood Flow
HIGH
HIGH
(3) Streamside Area Attenuation
HIGH
HIGH
(4) Floodplain Access
HIGH
HIGH
(4) Wooded Riparian Buffer
MEDIUM
MEDIUM
(4) Microtopography
HIGH
HIGH
(3) Stream Stability
HIGH
HIGH
(4) Channel Stability
HIGH
HIGH
(4) Sediment Transport
LOW
LOW
(4) Stream Geomorphology
HIGH
HIGH
(2) Stream/Intertidal Zone Interaction
NA
NA
(2) Longitudinal Tidal Flow
NA
NA
(2) Tidal Marsh Stream Stability
NA
NA
(3) Tidal Marsh Channel Stability
NA
NA
(3) Tidal Marsh Stream Geomorphology
NA
NA
(1) Water Quality
MEDIUM
MEDIUM
(2) Baseflow
HIGH
HIGH
(2) Streamside Area Vegetation
HIGH
HIGH
(3) Upland Pollutant Filtration
HIGH
HIGH
(3) Thermoregulation
HIGH
HIGH
(2) Indicators of Stressors
NO
NO
(2) Aquatic Life Tolerance
LOW
NA
(2) Intertidal Zone Filtration
NA
NA
(1) Habitat
LOW
HIGH
(2) In -stream Habitat
LOW
MEDIUM
(3) Baseflow
HIGH
HIGH
(3) Substrate
LOW
LOW
(3) Stream Stability
HIGH
HIGH
(3) In -stream Habitat
MEDIUM
HIGH
(2) Stream -side Habitat
HIGH
HIGH
(3) Stream -side Habitat
HIGH
HIGH
(3) Thermoregulation
HIGH
HIGH
(2) Tidal Marsh In -stream Habitat
NA
NA
(3) Flow Restriction
NA
NA
(3) Tidal Marsh Stream Stability
NA
NA
(4) Tidal Marsh Channel Stability
NA
NA
(4) Tidal Marsh Stream Geomorphology
NA
NA
(3) Tidal Marsh In -stream Habitat
NA
NA
(2) Intertidal Zone
NA
NA
Overall
MEDIUM
HIGH

CYCDW Stream I d untdf cation Form Version 4,11 _
'I rI "? r >.
L
�
Strong
1a Continuity of channel bed and hank
0
1
Evaluator: ,! R'.�.:>
County:,,
Longitude:.. f 'rtj�J
v
1
0 0,5
Total Points: _
Stream is al least intermittent .11 i
Stream Determination (circle one)
Ephemera lnterrnitten Perennial
Other Lx ' -' v +" k�t VV rL
e.g- Quad Name: " �
if a 19 or perennial If a 30' ! j r
2
3 r.
i� T
A. Geomorphology Subtotal = 1 I'
Absent
Weak
Moderate
Strong
1a Continuity of channel bed and hank
0
1
0.5
3
2. Sinuosity of channel along thalweg
0
1
0 0,5
3
3. In -channel structure. ex. riffle -pool, step -pool,
ripple -pool sequence
0
Yes eJ3
2
3
4. Particle size of stream substrate
0
Cl -)2
3
5. Activelrelict floodplain
1
2
3
fi, Depositional bars or benches
0
(1-7--
2
3
7. Recent alluvial deposits
1
2
3
8. Headcuts
1
3
9. Grade control
0
0.5
1
1.5
10. Natural valley
0
0.5
1
11. Second or greater order channel
Na 0
Yes = 3
"artificial ditches are not rated; see discussions ift manual
B. Hvdroloov (Subtotal = 9 I
12. Presence of Baseflow
0
2 3
13. Iron oxidizing bacteria
0 1
2 3
14. Leaf litter
i,5 _1
0.5
15. Sediment on plants or debris
0 Co 3
1 1.5
18. Organic debris lines or piles
0 0,5
1 1.
17. Soil -based evidence of high water table?
No = 0
Yes eJ3
C. Biologv (Subtotal =
18, Fibrous roots in streambed 3
2 0
19. Rooted upland plants in streambed
2 1 0
20. Macrobenthos [note diversity and abundance)
1 2 3
21. Aquatic Mollusks 0
1 2 3
22. Fish D
0.5 1 1.5
23. Crayfish
0.5 1 1.5
24. Amphibians 0
15
25. Algae
0.5 1 1.5
26. Wetland plants in streambed
FACW = 0.75; DBL = 1.5 Other = 0
`perennial streams may also be identified us,ng other methods. See p. 35 of manual.
Notes:
Sketch:GIW-
>V1 i�� tM � � Ll

NC SAM FIELD ASSESSMENT FORM Impact 8-1 - Intermittent Stream 15
user rvianuai version z. -i
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic quadrangle,
and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property, identify and
number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for detailed descriptions
and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were performed. See the
NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION:
1. Project name (if any): Piedmont Lithium
3. Applicant/owner name: Piedmont Lithium, Inc.
5. County: Gaston
2. Date of evaluation: April 4, 2018
4. Assessor name/organization: Kelly Thames/HDR
6. Nearest named water body Beaverdam Creek (HUC
7. River basin: Catawba on USGS 7.5 -minute quad: 01030102)
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.391786, -81.294114
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): Impact 8-1 10. Length of assessment reach evaluated (feet): 312 ft
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 4 ft ❑Unable to assess channel depth.
12. Channel width at top of bank (feet): 6 ft 13. Is assessment reach a swamp steam? ❑Yes ❑No
14. Feature type: ❑Perennial flow ®Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) ® Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic ❑A`J ®B
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip ®Size 1 (< 0.1 mil) ❑Size 2 (0.1 to < 0.5 mit) ❑Size 3 (0.5 to < 5 mit) ❑Size 4 (>_ 5 mit)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑Section 10 water ❑Classified Trout Waters ®Water Supply Watershed (❑I ❑ll ❑III ®IV ❑V)
❑Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters
❑Anadromous fish ❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
❑Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in "Notes/Sketch" section or attached? ®Yes ❑No
1. Channel Water - assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
❑A Water throughout assessment reach.
®B No flow, water in pools only.
❑C No water in assessment reach.
2. Evidence of Flow Restriction - assessment reach metric
®A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
❑B Not
3. Feature Pattern - assessment reach metric
®A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
❑B Not
4. Feature Longitudinal Profile - assessment reach metric
®A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming, over
widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of these
disturbances).
❑B Not
5. Signs of Active Instability - assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
❑A < 10% of channel unstable
❑B 10 to 25% of channel unstable
®C > 25% of channel unstable

6. Streamside Area Interaction — streamside area metric Impact 8-1 - Intermittent Stream 15
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
❑A ❑A Little or no evidence of conditions that adversely affect reference interaction
®B ®B Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area, leaky
or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision, disruption
of flood flows through streamside area] or too much floodplain/intertidal zone access [examples: impoundments, intensive
mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a man-made feature on an
interstream divide
Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
0 Other: (explain in "Notes/Sketch" section)
®J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
101b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
❑A Multiple aquatic macrophytes and aquatic mosses m w ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) (D ❑G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent w Y ❑H Low -tide refugia (pools)
vegetation N ❑I Sand bottom
❑C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
❑D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
® ❑ ❑ ❑ ❑ Bedrock/saprolite
® ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
® ❑ ❑ ❑ ❑ Cobble (64 — 256 mm)
® ❑ ❑ ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ® ❑ Sand (.062 — 2 mm)
❑ ❑ ❑ ❑ ® Silt/clay (< 0.062 mm)
❑ ❑ ❑ ❑ ® Detritus
® ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12
Impact 8-1 - Intermittent Stream 15
Aquatic Life — assessment reach metric (skip for Tidal Marsh Streams)
12a. ®Yes ❑No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ®No Water ❑Other:
12b. ❑Yes ®No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
❑ ❑Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ ❑Beetles
❑ ❑Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/shrimp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ❑Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, fishily, dobsonfly larvae)
❑ ❑Midges/mosquito larvae
❑ ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Other fish
❑ ❑Salamanders/tadpoles
❑ ❑Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
❑ ❑Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland runoff.
LB RB
❑A ❑A Little or no alteration to water storage capacity over a majority of the streamside area
❑B ❑B Moderate alteration to water storage capacity over a majority of the streamside area
®C ®C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil compaction,
livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water >_ 6 inches deep
❑B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
®C ®C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ❑Y Are wetlands present in the streamside area?
®N ®N
16. Baseflow Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
❑A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
❑D Evidence of bank seepage or sweating (iron in water indicates seepage)
®E Stream bed or bank soil reduced (dig through deposited sediment if present)
❑F None of the above
17. Basef low Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
❑B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
❑C Urban stream (>_ 24% impervious surface for watershed)
❑D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
®F None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
❑A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
®B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

19. Buffer Width — streamside area metric (skip for Tidal Marsh Streams) Impact 8-1 -Intermittent Stream 15
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
®A ®A ❑A ❑A >_ 100 feet wide or extends to the edge of the watershed
❑B ❑B ❑B ❑B From 50 to < 100 feet wide
❑C ❑C ❑C ❑C From 30 to < 50 feet wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
❑E ❑E ®E ®E < 10 feet wide or no trees
20. Buffer Structure — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
❑A ❑A Mature forest
®B ®B Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but is
within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
®A ®A Medium to high stem density
❑B ❑B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer — streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
®A ®A The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
❑B ❑B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
®C ®C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity — assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes ®No Was conductivity measurement recorded?
If No, select one of the following reasons. ®No Water ❑Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 ❑B 46 to < 67 ❑C 67 to < 79 ❑D 79 to < 230 ❑E >_ 230
Notes/Sketch:
Streamside areas have been cleared recently and vegetation growth is severly altered, scrubby, and bare in areas. Trash and debris are
throughout reach, restricting flow. Channel is severely incised and downcutting in areas.

Draft NC SAM Stream Rating Sheet Impact 8-1 - Intermittent Stream 15
Accompanies User Manual Version 2.1
Stream Site Name Piedmont Lithium Date of Assessment April 4, 2018
Stream Category Pb1 Assessor Name/Organization
Kelly Thames/HDR
Notes of Field Assessment Form (Y/N)
YES
Presence of regulatory considerations (Y/N)
NO
Additional stream information/supplementary measurements included (Y/N)
YES
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream)
Intermittent
USACE/
NCDWR
Function Class Rating Summary
All Streams Intermittent
(1) Hydrology
LOW
LOW
(2) Baseflow
HIGH
HIGH
(2) Flood Flow
LOW
LOW
(3) Streamside Area Attenuation
LOW
LOW
(4) Floodplain Access
MEDIUM
MEDIUM
(4) Wooded Riparian Buffer
LOW
LOW
(4) Microtopography
NA
NA
(3) Stream Stability
LOW
LOW
(4) Channel Stability
LOW
LOW
(4) Sediment Transport
LOW
LOW
(4) Stream Geomorphology
LOW
LOW
(2) Stream/Intertidal Zone Interaction
NA
NA
(2) Longitudinal Tidal Flow
NA
NA
(2) Tidal Marsh Stream Stability
NA
NA
(3) Tidal Marsh Channel Stability
NA
NA
(3) Tidal Marsh Stream Geomorphology
NA
NA
(1) Water Quality
MEDIUM
MEDIUM
(2) Baseflow
HIGH
HIGH
(2) Streamside Area Vegetation
HIGH
HIGH
(3) Upland Pollutant Filtration
HIGH
HIGH
(3) Thermoregulation
MEDIUM
MEDIUM
(2) Indicators of Stressors
NO
NO
(2) Aquatic Life Tolerance
LOW
NA
(2) Intertidal Zone Filtration
NA
NA
(1) Habitat
LOW
LOW
(2) In -stream Habitat
LOW
LOW
(3) Baseflow
HIGH
HIGH
(3) Substrate
LOW
LOW
(3) Stream Stability
LOW
LOW
(3) In -stream Habitat
LOW
MEDIUM
(2) Stream -side Habitat
LOW
LOW
(3) Stream -side Habitat
LOW
LOW
(3) Thermoregulation
MEDIUM
MEDIUM
(2) Tidal Marsh In -stream Habitat
NA
NA
(3) Flow Restriction
NA
NA
(3) Tidal Marsh Stream Stability
NA
NA
(4) Tidal Marsh Channel Stability
NA
NA
(4) Tidal Marsh Stream Geomorphology
NA
NA
(3) Tidal Marsh In -stream Habitat
NA
NA
(2) Intertidal Zone
NA
NA
Overall
LOW
LOW

NC SAM FIELD ASSESSMENT FORM Impact 8-2 - Intermittent Stream 15
user rvianuai version z. -i
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic quadrangle,
and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property, identify and
number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for detailed descriptions
and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were performed. See the
NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION:
1. Project name (if any): Piedmont Lithium
3. Applicant/owner name: Piedmont Lithium, Inc.
5. County: Gaston
2. Date of evaluation: April 4, 2018
4. Assessor name/organization: Kelly Thames/HDR
6. Nearest named water body Beaverdam Creek (HUC
7. River basin: Catawba on USGS 7.5 -minute quad: 01030102)
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.389798, -81.294722
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): Impact 8-2 10. Length of assessment reach evaluated (feet): 813 ft
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 3 ft ❑Unable to assess channel depth.
12. Channel width at top of bank (feet): 6 ft 13. Is assessment reach a swamp steam? ❑Yes ❑No
14. Feature type: ❑Perennial flow ®Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) ® Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic ❑A`J ®B
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip ®Size 1 (< 0.1 mil) ❑Size 2 (0.1 to < 0.5 mit) ❑Size 3 (0.5 to < 5 mit) ❑Size 4 (>_ 5 mit)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑Section 10 water ❑Classified Trout Waters ®Water Supply Watershed (❑I ❑ll ❑III ®IV ❑V)
❑Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters
❑Anadromous fish ❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
❑Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in "Notes/Sketch" section or attached? ®Yes ❑No
1. Channel Water - assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
❑A Water throughout assessment reach.
®B No flow, water in pools only.
❑C No water in assessment reach.
2. Evidence of Flow Restriction - assessment reach metric
❑A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
®B Not
3. Feature Pattern - assessment reach metric
❑A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
®B Not
4. Feature Longitudinal Profile - assessment reach metric
®A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming, over
widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of these
disturbances).
❑B Not
5. Signs of Active Instability - assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
❑A < 10% of channel unstable
®B 10 to 25% of channel unstable
❑C > 25% of channel unstable

6. Streamside Area Interaction — streamside area metric Impact 8-2 - Intermittent Stream 15
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
®A ®A Little or no evidence of conditions that adversely affect reference interaction
❑B ❑B Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area, leaky
or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision, disruption
of flood flows through streamside area] or too much floodplain/intertidal zone access [examples: impoundments, intensive
mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a man-made feature on an
interstream divide
Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
0 Other: (explain in "Notes/Sketch" section)
®J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
101b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
❑A Multiple aquatic macrophytes and aquatic mosses m w ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) CO ❑G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent w Y ❑H Low -tide refugia (pools)
vegetation NC El Sand bottom
❑C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
❑D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
® ❑ ❑ ❑ ❑ Bedrock/saprolite
® ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
® ❑ ❑ ❑ ❑ Cobble (64 — 256 mm)
❑ ® ❑ ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ® ❑ ❑ Sand (.062 — 2 mm)
❑ ❑ ❑ ® ❑ Silt/clay (< 0.062 mm)
❑ ❑ ❑ ® ❑ Detritus
® ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12
Impact 8-2 - Intermittent Stream 15
Aquatic Life — assessment reach metric (skip for Tidal Marsh Streams)
12a. ®Yes ❑No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ®No Water ❑Other:
12b. ❑Yes ®No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
❑ ❑Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ ❑Beetles
❑ ❑Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/shrimp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ❑Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, fishily, dobsonfly larvae)
❑ ❑Midges/mosquito larvae
❑ ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Other fish
❑ ❑Salamanders/tadpoles
❑ ❑Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
❑ ❑Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland runoff.
LB RB
®A ®A Little or no alteration to water storage capacity over a majority of the streamside area
❑B ❑B Moderate alteration to water storage capacity over a majority of the streamside area
El ❑C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil compaction,
livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water >_ 6 inches deep
❑B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
®C ®C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ❑Y Are wetlands present in the streamside area?
®N ®N
16. Baseflow Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
❑A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
❑D Evidence of bank seepage or sweating (iron in water indicates seepage)
®E Stream bed or bank soil reduced (dig through deposited sediment if present)
❑F None of the above
17. Basef low Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
❑B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
❑C Urban stream (>_ 24% impervious surface for watershed)
®D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
❑F None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
❑A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
®B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

Impact 8-2 - Intermittent Stream 15
19. Buffer Width — streamside area metric (skip for Tidal Marsh Streams)
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
®A ®A ❑A ❑A >_ 100 feet wide or extends to the edge of the watershed
❑B ❑B ®B ®B From 50 to < 100 feet wide
❑C ❑C ❑C ❑C From 30 to < 50 feet wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
❑E ❑E ❑E ❑E < 10 feet wide or no trees
20. Buffer Structure — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
❑A ❑A Mature forest
®B ®B Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but is
within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
❑A ❑A Medium to high stem density
®B ®B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer — streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
®A ®A The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
®B ®B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
❑C ❑C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity — assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes ®No Was conductivity measurement recorded?
If No, select one of the following reasons. ®No Water ❑Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 ❑B 46 to < 67 ❑C 67 to < 79 ❑D 79 to < 230 ❑E >_ 230
Notes/Sketch:
Streamside areas (greater than 50 ft from stream) have been cleared recently and vegetation growth is severly altered, scrubby, and bare in
areas. Channel is severely incised and downcutting in areas.

Impact 8-2 - Intermittent Stream 15
Draft NC SAM Stream Rating
Sheet
Accompanies User Manual Version 2.1
Stream Site Name Piedmont Lithium Date of Assessment April 4, 2018
Stream Category Pb1 Assessor Name/Organization
Kelly Thames/HDR
Notes of Field Assessment Form (Y/N)
YES
Presence of regulatory considerations (Y/N)
YES
Additional stream information/supplementary measurements included (Y/N)
YES
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream)
Intermittent
USACE/
NCDWR
Function Class Rating Summary
All Streams Intermittent
(1) Hydrology
MEDIUM
MEDIUM
(2) Baseflow
MEDIUM
MEDIUM
(2) Flood Flow
MEDIUM
MEDIUM
(3) Streamside Area Attenuation
HIGH
HIGH
(4) Floodplain Access
HIGH
HIGH
(4) Wooded Riparian Buffer
MEDIUM
MEDIUM
(4) Microtopography
NA
NA
(3) Stream Stability
LOW
LOW
(4) Channel Stability
MEDIUM
MEDIUM
(4) Sediment Transport
LOW
LOW
(4) Stream Geomorphology
MEDIUM
MEDIUM
(2) Stream/Intertidal Zone Interaction
NA
NA
(2) Longitudinal Tidal Flow
NA
NA
(2) Tidal Marsh Stream Stability
NA
NA
(3) Tidal Marsh Channel Stability
NA
NA
(3) Tidal Marsh Stream Geomorphology
NA
NA
(1) Water Quality
MEDIUM
MEDIUM
(2) Baseflow
MEDIUM
MEDIUM
(2) Streamside Area Vegetation
HIGH
HIGH
(3) Upland Pollutant Filtration
HIGH
HIGH
(3) Thermoregulation
MEDIUM
MEDIUM
(2) Indicators of Stressors
NO
NO
(2) Aquatic Life Tolerance
LOW
NA
(2) Intertidal Zone Filtration
NA
NA
(1) Habitat
MEDIUM
HIGH
(2) In -stream Habitat
LOW
MEDIUM
(3) Baseflow
MEDIUM
MEDIUM
(3) Substrate
LOW
LOW
(3) Stream Stability
MEDIUM
MEDIUM
(3) In -stream Habitat
LOW
HIGH
(2) Stream -side Habitat
HIGH
HIGH
(3) Stream -side Habitat
HIGH
HIGH
(3) Thermoregulation
MEDIUM
MEDIUM
(2) Tidal Marsh In -stream Habitat
NA
NA
(3) Flow Restriction
NA
NA
(3) Tidal Marsh Stream Stability
NA
NA
(4) Tidal Marsh Channel Stability
NA
NA
(4) Tidal Marsh Stream Geomorphology
NA
NA
(3) Tidal Marsh In -stream Habitat
NA
NA
(2) Intertidal Zone
NA
NA
Overall
MEDIUM
MEDIUM

NC DWQ Streaw ]dentiFication Farm Version 4.11 i � ti I � J� •+ 1 ' . .-L ,
r"_
A. qt2Tor Bolo Subtotal =
Absent
Weak
Evaluator; , 71
County. ,� 1
Longitude, - r
Y►'1.�
1
2
Total Points. r
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Stream Determination [circ
Other
Stream is at least intermittent 3rft
N � i� or arennral fi z 3!] (/ ��
Ephemeral Intermittent ere vial
e.g. Quad Name: S f
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A. qt2Tor Bolo Subtotal =
Absent
Weak
Moderate
5 q
1° Continuity of channel bed and bank
0
1
2
3
2. Sinuosity of channel along thalweg
0
1
2
3
3. In -channel structure: ex. riffle -pool, step -pool,
r[ ie- ool s uence
0
1
2
3
4. Particle size of stream substrate
4
1
3
5• Activelrelict floodplain
0.5
1
Z
3
fi. Depositional bars or benches
0.5
1
3
7. Recent alluvial deposits
0.5
1
2
3
8. Headcuts
❑
1
2
3
9. Grade control
0
0.5
1
1.
10. Natural valley
0
0.5
1.5
11. Second or greater order channel
No
Yes = 3
Sketch:pfiti�-1-
a artificial ditches are not rated, see discussions in manual
B. Hydrology (Subtotal = 1- )
12. Presence of Baseflow
0
1
2
3
13. Iron oxidizing bacteria
0
1
2
3
14. Leaf litter
1.5
-1'
n__
0
15. Sediment on plants or debris
❑
0'P
1
1.5
16. Organic debris lines or piles
0
0.5
1.5
17. Soil -based evidence of high water table?
0.5
No = 0
Yes
1.5
C. Biology (Subtotal = ]
18. Fibrous roots in streambed 3
2
1
0
19. Rooted upland plants in streambed
2
1
0
20. Macrobenthos (note diversity and abundance) 0
1
2
3
21. Aquatic Mollusks
1
2
3
22. Fish
0.5
1
1.5
23. Crayfish
0.5
1
1.5
24. Amphibians
0.5
1
1.5
25. Algae 0
0.5
1
1.5
28. Wetland plants in streambed
FAGW.- 0. ; OBL
= 1.5 Other = 0
"perennial streams may also be identified using other methods. See p. 35 of manual.
Notes:
Sketch:pfiti�-1-
► f L f�L. r{lr�
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1 t

NC SAM FIELD ASSESSMENT FORM Impact 9 - Perennial Stream 15
user rvianuai version z. -i
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic quadrangle,
and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property, identify and
number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for detailed descriptions
and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were performed. See the
NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION:
1. Project name (if any): Piedmont Lithium
3. Applicant/owner name: Piedmont Lithium, Inc.
5. County: Gaston
2. Date of evaluation: April 4, 2018
4. Assessor name/organization: Kelly Thames/HDR
6. Nearest named water body Beaverdam Creek (HUC
7. River basin: Catawba on USGS 7.5 -minute quad: 01030102)
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.389636, -81.294886
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): Impact 9 10. Length of assessment reach evaluated (feet): 162 ft
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 4-10 ft ❑Unable to assess channel depth.
12. Channel width at top of bank (feet): loft 13. Is assessment reach a swamp steam? ❑Yes ❑No
14. Feature type: ®Perennial flow ❑Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) ® Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic ®A` J ❑B
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip ®Size 1 (< 0.1 mil) ❑Size 2 (0.1 to < 0.5 mit) ❑Size 3 (0.5 to < 5 mit) ❑Size 4 (>_ 5 mit)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑Section 10 water ❑Classified Trout Waters ®Water Supply Watershed (❑I ❑ll ❑III ®IV ❑V)
❑Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters
❑Anadromous fish ❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
❑Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in "Notes/Sketch" section or attached? ®Yes ❑No
1. Channel Water - assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
®A Water throughout assessment reach.
❑B No flow, water in pools only.
❑C No water in assessment reach.
2. Evidence of Flow Restriction - assessment reach metric
❑A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
®B Not
3. Feature Pattern - assessment reach metric
❑A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
®B Not
4. Feature Longitudinal Profile - assessment reach metric
❑A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming, over
widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of these
disturbances).
®B Not
5. Signs of Active Instability - assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
®A < 10% of channel unstable
❑B 10 to 25% of channel unstable
❑C > 25% of channel unstable

Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
0 Other: (explain in "Notes/Sketch" section)
®J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
10b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
®A Multiple aquatic macrophytes and aquatic mosses m w ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) CO ❑G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent w Y ❑H Low -tide refugia (pools)
vegetation NC El Sand bottom
®C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
®D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
® ❑ ❑ ❑ ❑ Bedrock/saprolite
® ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
® ❑ ❑ ❑ ❑ Cobble (64 — 256 mm)
❑ ❑ ® ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ® ❑ Sand (.062 — 2 mm)
❑ ❑ ® ❑ ❑ Silt/clay (< 0.062 mm)
❑ ❑ ® ❑ ❑ Detritus
® ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
Impact 9 - Perennial Stream 15
6. Streamside Area Interaction — streamside area metric
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
®A ®A
Little or no evidence of conditions that adversely affect reference interaction
❑B ❑B
Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area, leaky
or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C
Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision, disruption
of flood flows through streamside area] or too much floodplain/intertidal zone access [examples: impoundments, intensive
mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a man-made feature on an
interstream divide
Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
0 Other: (explain in "Notes/Sketch" section)
®J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
10b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
®A Multiple aquatic macrophytes and aquatic mosses m w ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) CO ❑G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent w Y ❑H Low -tide refugia (pools)
vegetation NC El Sand bottom
®C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
®D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
® ❑ ❑ ❑ ❑ Bedrock/saprolite
® ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
® ❑ ❑ ❑ ❑ Cobble (64 — 256 mm)
❑ ❑ ® ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ® ❑ Sand (.062 — 2 mm)
❑ ❑ ® ❑ ❑ Silt/clay (< 0.062 mm)
❑ ❑ ® ❑ ❑ Detritus
® ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12
Impact 9 - Perennial Stream 15
Aquatic Life — assessment reach metric (skip for Tidal Marsh Streams)
12a. ®Yes ❑No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ®No Water ❑Other:
12b. ❑Yes ®No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
❑ ❑Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ ❑Beetles
❑ ❑Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/shrimp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ❑Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, fishily, dobsonfly larvae)
❑ ❑Midges/mosquito larvae
❑ ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Other fish
❑ ❑Salamanders/tadpoles
❑ ❑Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
❑ ❑Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland runoff.
LB RB
®A ®A Little or no alteration to water storage capacity over a majority of the streamside area
❑B ❑B Moderate alteration to water storage capacity over a majority of the streamside area
El ❑C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil compaction,
livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water >_ 6 inches deep
®B ®B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
❑C ❑C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ❑Y Are wetlands present in the streamside area?
®N ®N
16. Baseflow Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
❑A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
❑D Evidence of bank seepage or sweating (iron in water indicates seepage)
®E Stream bed or bank soil reduced (dig through deposited sediment if present)
❑F None of the above
17. Basef low Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
❑B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
❑C Urban stream (>_ 24% impervious surface for watershed)
®D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
®F None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
®A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
❑B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

Impact 9 - Perennial Stream 15
19. Buffer Width — streamside area metric (skip for Tidal Marsh Streams)
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
®A ®A ®A ®A >_ 100 feet wide or extends to the edge of the watershed
❑B ❑B ❑B ❑B From 50 to < 100 feet wide
❑C ❑C ❑C ❑C From 30 to < 50 feet wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
❑E ❑E ❑E ❑E < 10 feet wide or no trees
20. Buffer Structure — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
❑A ❑A Mature forest
®B ®B Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but is
within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
❑A ❑A Medium to high stem density
®B ®B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer — streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
®A ®A The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
®B ®B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
❑C ❑C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity — assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes ®No Was conductivity measurement recorded?
If No, select one of the following reasons. ®No Water ❑Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 ❑B 46 to < 67 ❑C 67 to < 79 ❑D 79 to < 230 ❑E >_ 230
Notes/Sketch:
Perennial reach flattens out in a larger valley bottom, becomes more sinuous. Streamside area interaction good

Draft NC SAM Stream Rating Sheet Impact 9 - Perennial Stream 15
Accompanies User Manual Version 2.1
Stream Site Name Piedmont Lithium Date of Assessment April 4, 2018
Stream Category Pal Assessor Name/Organization Kelly Thames/HDR
Notes of Field Assessment Form (Y/N)
YES
Presence of regulatory considerations (Y/N)
YES
Additional stream information/supplementary measurements included (Y/N)
YES
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream)
Perennial
USACE/ NCDWR
Function Class Rating Summary
All Streams Intermittent
(1) Hydrology
HIGH
(2) Baseflow
HIGH
(2) Flood Flow
HIGH
(3) Streamside Area Attenuation
HIGH
(4) Floodplain Access
HIGH
(4) Wooded Riparian Buffer
MEDIUM
(4) Microtopography
HIGH
(3) Stream Stability
HIGH
(4) Channel Stability
HIGH
(4) Sediment Transport
MEDIUM
(4) Stream Geomorphology
HIGH
(2) Stream/Intertidal Zone Interaction
NA
(2) Longitudinal Tidal Flow
NA
(2) Tidal Marsh Stream Stability
NA
(3) Tidal Marsh Channel Stability
NA
(3) Tidal Marsh Stream Geomorphology
NA
(1) Water Quality
MEDIUM
(2) Baseflow
HIGH
(2) Streamside Area Vegetation
HIGH
(3) Upland Pollutant Filtration
HIGH
(3) Thermoregulation
HIGH
(2) Indicators of Stressors
NO
(2) Aquatic Life Tolerance
LOW
(2) Intertidal Zone Filtration
NA
(1) Habitat
HIGH
(2) In -stream Habitat
HIGH
(3) Baseflow
HIGH
(3) Substrate
MEDIUM
(3) Stream Stability
HIGH
(3) In -stream Habitat
HIGH
(2) Stream -side Habitat
HIGH
(3) Stream -side Habitat
HIGH
(3) Thermoregulation
HIGH
(2) Tidal Marsh In -stream Habitat
NA
(3) Flow Restriction
NA
(3) Tidal Marsh Stream Stability
NA
(4) Tidal Marsh Channel Stability
NA
(4) Tidal Marsh Stream Geomorphology
NA
(3) Tidal Marsh In -stream Habitat
NA
(2) Intertidal Zone
NA
Overall HIGH

NC SAM FIELD ASSESSMENT FORM Impact 11 - Intermittent Stream 12
user rvianuai version z. -i
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic quadrangle,
and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property, identify and
number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for detailed descriptions
and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were performed. See the
NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION:
1. Project name (if any): Piedmont Lithium
3. Applicant/owner name: Piedmont Lithium, Inc.
5. County: Gaston
2. Date of evaluation: August 20, 2018
4. Assessor name/organization: Kelly Thames/HDR
6. Nearest named water body Beaverdam Creek (HUC
7. River basin: Catawba on USGS 7.5 -minute quad: 01030102)
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.393725, -81.297913
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): Impact 11 10. Length of assessment reach evaluated (feet): 917 ft
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 1 ft ❑Unable to assess channel depth.
12. Channel width at top of bank (feet): 3 ft 13. Is assessment reach a swamp steam? ❑Yes ❑No
14. Feature type: ❑Perennial flow ®Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) ® Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic ❑A`J ®B
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip ®Size 1 (< 0.1 mil) ❑Size 2 (0.1 to < 0.5 mit) ❑Size 3 (0.5 to < 5 mit) ❑Size 4 (>_ 5 mit)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑Section 10 water ❑Classified Trout Waters ®Water Supply Watershed (❑I ❑II ❑III ®IV ❑V)
❑Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters
❑Anadromous fish ❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
❑Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in "Notes/Sketch" section or attached? ®Yes ❑No
1. Channel Water - assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
❑A Water throughout assessment reach.
❑B No flow, water in pools only.
®C No water in assessment reach.
2. Evidence of Flow Restriction - assessment reach metric
❑A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
®B Not
3. Feature Pattern - assessment reach metric
❑A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
®B Not
4. Feature Longitudinal Profile - assessment reach metric
❑A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming, over
widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of these
disturbances).
®B Not
5. Signs of Active Instability - assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
®A < 10% of channel unstable
❑B 10 to 25% of channel unstable
❑C > 25% of channel unstable

NC DWQ 11rettnk fdemiflutiou form Version 4,11 �Yr w` [Alf.
I M r -a7 ?:7 � I --? t -7 -, a- I Rrnkartjgft ti}; f-4-- to La1FtuAe; 2 e, _f Lil �Zi
Evaluator: 11--J�lGYK4 4 T. 1Gr c CGC.i'' County: Gf , ( ✓l C,0!i Longitude: -4 I. L " u`Ut-,
Total Points:Stream f]c
Li�11UI!O �n LW Lf
Stream is at least intermittent r] termination teirale one) ether
if? 19 or perennial if? 30" li �' Ephemeral fntrittenf Perennial a g. Quad Name: autg-d
A. Geomorphology (Subtotal = li�.i , )
Absent
Weak
Moderate
strum
1' Continuity of channel bed and bank
❑
1
2
3
2. Sinuosity of channel along thalweg
0
1
2i
3
3 In -channel structure: ex. riffle -pool, step -pool,
ri le- ooi s uence
0
j' `
l 11
2
3
4. Particle size of stream substrate
No = 0
{' 1
2
3
5. Active/relict floodplain
0
1
2
3
6 Depositional bars or benches
0
{ t
2
3
7. Recent alluvial deposits
0
1
2
3
8- Headcuts
0
11.
2
3
9. Grade control
0
05
1
1.-5v
10. Natural valley
0
0.5
1
1-5
11. Second or greater order channel
No 41 0
Yes
= 3
"artificial ditches are not rated; see discussions in manual
R I-IVrtrnlnnV t-Riihtntal; L, 1
12• Presence of Baseflow
0 1
2
3
13. Iron oxidizing bacteria
0 1
2
3
14 Leaf litter
(1.5 1
0.5
0
15 Sediment on plants cr debris
05
1
1.5
16. Organic debris lines or piles
Q 0.5
1
( 1.�)
17 Soil -based evidence of high water table?
No = 0
2
Yes =(3
C' Rinlnnu lCiihtntal = L, 1
1a- Fibrous roots In sire ambed
I
2
1
0
19 Rooted upland plants in streambed
2
1
0
20. Maerobenthos (note diversity and abundance)
[
1
2
3
21. Aquatic Mollusks
1
2
3
22- Fish
f 0
0.5
1
1
1.5
15
23, Crayfish 0.5
24. Amphibians
0.5
1
1 5
25. Algae
{ f]
0.5
1
1.5
26. Wetland plants in streambed
FACW = 0.75; DBL = 1.5 Other r 0
'perennial streams may also be identified using other methods. See p 35 of manual -
Notes:
Sketch:
' Iz
VN Cv �

6. Streamside Area Interaction —streamside area metric Impact 11 - Intermittent Stream 12
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
®A ®A Little or no evidence of conditions that adversely affect reference interaction
❑B ❑B Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area, leaky
or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision, disruption
of flood flows through streamside area] or too much floodplain/intertidal zone access [examples: impoundments, intensive
mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a man-made feature on an
interstream divide
Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
®F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
❑I Other: (explain in "Notes/Sketch" section)
❑J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
101b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
❑A Multiple aquatic macrophytes and aquatic mosses m w ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) CO ❑G Submerged aquatic vegetation
❑B Multiple sticks and/or leaf packs and/or emergent w Y ❑H Low -tide refugia (pools)
vegetation NC El Sand bottom
❑C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
❑D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
®E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
® ❑ ❑ ❑ ❑ Bedrock/saprolite
® ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
® ❑ ❑ ❑ ❑ Cobble (64 — 256 mm)
® ❑ ❑ ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ❑ ® Sand (.062 — 2 mm)
❑ ❑ ❑ ® ❑ Silt/clay (< 0.062 mm)
❑ ❑ ❑ ® ❑ Detritus
® ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12
Impact 11 - Intermittent Stream 12
Aquatic Life — assessment reach metric (skip for Tidal Marsh Streams)
12a. ❑Yes ®No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ®No Water ❑Other:
12b. ❑Yes ❑No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
❑ ❑Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ ❑Beetles
❑ ❑Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/shrimp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ❑Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, fishily, dobsonfly larvae)
❑ ❑Midges/mosquito larvae
❑ ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Other fish
❑ ❑Salamanders/tadpoles
❑ ❑Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
❑ ❑Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland runoff.
LB RB
❑A ❑A Little or no alteration to water storage capacity over a majority of the streamside area
®B ®B Moderate alteration to water storage capacity over a majority of the streamside area
El ❑C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil compaction,
livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water >_ 6 inches deep
❑B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
®C ®C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ❑Y Are wetlands present in the streamside area?
®N ®N
16. Baseflow Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
❑A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
❑D Evidence of bank seepage or sweating (iron in water indicates seepage)
❑E Stream bed or bank soil reduced (dig through deposited sediment if present)
®F None of the above
17. Basef low Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
❑B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
❑C Urban stream (>_ 24% impervious surface for watershed)
®D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
❑F None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
®A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
❑B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

19. Buffer Width — streamside area metric (skip for Tidal Marsh Streams) Impact 11 -Intermittent Stream 12
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
®A ®A ®A ®A >_ 100 feet wide or extends to the edge of the watershed
❑B ❑B ❑B ❑B From 50 to < 100 feet wide
❑C ❑C ❑C ❑C From 30 to < 50 feet wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
❑E ❑E ❑E ❑E < 10 feet wide or no trees
20. Buffer Structure — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
❑A ❑A Mature forest
®B ®B Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but is
within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
❑A ❑A Medium to high stem density
®B ®B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer — streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
®A ®A The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
®B ®B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
❑C ❑C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity — assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes ®No Was conductivity measurement recorded?
If No, select one of the following reasons. ®No Water ❑Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 ❑B 46 to < 67 ❑C 67 to < 79 ❑D 79 to < 230 ❑E >_ 230
Notes/Sketch:
Reach buffer has wooded canopy but there is little to no understory due to livestock. Streamside area soil compacted, accelerating runoff

Draft NC SAM Stream Rating Sheet Impact 11 - Intermittent Stream 12
Accompanies User Manual Version 2.1
Stream Site Name Piedmont Lithium Date of Assessment August 20, 2018
Stream Category Pb1 Assessor Name/Organization Kelly Thames/HDR
Notes of Field Assessment Form (Y/N) YES
Presence of regulatory considerations (Y/N) NO
Additional stream information/supplementary measurements included (Y/N) YES
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream) Intermittent
USACE/
NCDWR
Function Class Rating Summary
All Streams
Intermittent
(1) Hydrology
HIGH
HIGH
(2) Baseflow
MEDIUM
MEDIUM
(2) Flood Flow
HIGH
HIGH
(3) Streamside Area Attenuation
HIGH
HIGH
(4) Floodplain Access
HIGH
HIGH
(4) Wooded Riparian Buffer
MEDIUM
MEDIUM
(4) Microtopography
NA
NA
(3) Stream Stability
HIGH
HIGH
(4) Channel Stability
HIGH
HIGH
(4) Sediment Transport
LOW
LOW
(4) Stream Geomorphology
HIGH
HIGH
(2) Stream/Intertidal Zone Interaction
NA
NA
(2) Longitudinal Tidal Flow
NA
NA
(2) Tidal Marsh Stream Stability
NA
NA
(3) Tidal Marsh Channel Stability
NA
NA
(3) Tidal Marsh Stream Geomorphology
NA
NA
(1) Water Quality
MEDIUM
MEDIUM
(2) Baseflow
MEDIUM
MEDIUM
(2) Streamside Area Vegetation
HIGH
HIGH
(3) Upland Pollutant Filtration
HIGH
HIGH
(3) Thermoregulation
HIGH
HIGH
(2) Indicators of Stressors
YES
YES
(2) Aquatic Life Tolerance
OMITTED
NA
(2) Intertidal Zone Filtration
NA
NA
(1) Habitat
MEDIUM
MEDIUM
(2) In -stream Habitat
LOW
LOW
(3) Baseflow
MEDIUM
MEDIUM
(3) Substrate
LOW
LOW
(3) Stream Stability
HIGH
HIGH
(3) In -stream Habitat
LOW
LOW
(2) Stream -side Habitat
HIGH
HIGH
(3) Stream -side Habitat
HIGH
HIGH
(3) Thermoregulation
HIGH
HIGH
(2) Tidal Marsh In -stream Habitat
NA
NA
(3) Flow Restriction
NA
NA
(3) Tidal Marsh Stream Stability
NA
NA
(4) Tidal Marsh Channel Stability
NA
NA
(4) Tidal Marsh Stream Geomorphology
NA
NA
(3) Tidal Marsh In -stream Habitat
NA
NA
(2) Intertidal Zone
NA
NA
Overall
MEDIUM
MEDIUM

NC SAM FIELD ASSESSMENT FORM Impact 12 - Perennial Stream 12
Hies user manual version z. -i
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic quadrangle,
and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property, identify and
number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for detailed descriptions
and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were performed. See the
NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION:
1. Project name (if any): Piedmont Lithium
3. Applicant/owner name: Piedmont Lithium, Inc.
5. County: Gaston
7. River basin: Catawba
Date of evaluation: August 20, 2018
Assessor name/organization: Kelly Thames/HDR
Nearest named water body Beaverdam Creek (HUC
on USGS 7.5 -minute quad: 01030102)
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.392335, -81.299448
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): Impact 12 10. Length of assessment reach evaluated (feet): 700 ft
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 6 ft ❑Unable to assess channel depth.
12. Channel width at top of bank (feet): 8 ft 13. Is assessment reach a swamp steam? ❑Yes ❑No
14. Feature type: ®Perennial flow ❑Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) ® Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic ❑A ®B
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip ®Size 1 (< 0.1 mil) ❑Size 2 (0.1 to < 0.5 miz) ❑Size 3 (0.5 to < 5 miz) E] Size 4 (>_ 5 mit)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑Section 10 water ❑Classified Trout Waters ®Water Supply Watershed (❑I ❑II ❑III ®IV ❑V)
❑Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters
❑Anadromous fish ❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
❑Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in "Notes/Sketch" section or attached? ®Yes ❑No
1. Channel Water — assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
❑A Water throughout assessment reach.
®B No flow, water in pools only.
❑C No water in assessment reach.
2. Evidence of Flow Restriction — assessment reach metric
❑A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
®B Not A
3. Feature Pattern — assessment reach metric
❑A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
®B Not A
4. Feature Longitudinal Profile — assessment reach metric
❑A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming, over
widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of these
disturbances).
®B Not A
5. Signs of Active Instability — assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
®A < 10% of channel unstable
❑B 10 to 25% of channel unstable
❑C > 25% of channel unstable

6. Streamside Area Interaction — streamside area metric Impact 12 - Perennial Stream 12
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
®A ®A Little or no evidence of conditions that adversely affect reference interaction
❑B ❑B Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area, leaky
or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision, disruption
of flood flows through streamside area] or too much floodplain/intertidal zone access [examples: impoundments, intensive
mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a man-made feature on an
interstream divide
Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
01 Other: (explain in "Notes/Sketch" section)
®J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
10b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
❑A Multiple aquatic macrophytes and aquatic mosses N ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) m [:]G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent o❑H Low -tide refugia (pools)
vegetation YC ❑I Sand bottom
®C Multiple snags and logs (including lap trees) L m ❑J 5% vertical bank along the marsh
❑D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
IDA Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
® ❑ ❑ ❑ ❑ Bedrock/saprolite
® ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
® ❑ ❑ ❑ ❑ Cobble (64 — 256 mm)
❑ ❑ ® ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ❑ ® Sand (.062 — 2 mm)
❑ ❑ ❑ ® ❑ Silt/clay (< 0.062 mm)
❑ ❑ ❑ ® ❑ Detritus
® ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12
Aquatic Life —assessment reach metric (skip for Tidal Marsh Streams) Impact 12 - Perennial Stream 12
12a. ®Yes ❑No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ❑No Water ❑Other:
12b. ®Yes ❑No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
® ❑Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ ❑Beetles
❑ ®Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/shrimp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ❑Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, fishfly, dobsonfly larvae)
❑ ❑Midges/mosquito larvae
❑ ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Other fish
® ❑Salamanders/tadpoles
® ❑Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
❑ ®Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland runoff.
LB RB
®A ®A Little or no alteration to water storage capacity over a majority of the streamside area
❑B ❑B Moderate alteration to water storage capacity over a majority of the streamside area
❑C ❑C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil compaction,
livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water >_ 6 inches deep
❑B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
®C ®C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ❑Y Are wetlands present in the streamside area?
®N ®N
16. Basef low Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
❑A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
❑D Evidence of bank seepage or sweating (iron in water indicates seepage)
®E Stream bed or bank soil reduced (dig through deposited sediment if present)
❑F None of the above
17. Baseflow Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
❑B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
El Urban stream (> 24% impervious surface for watershed)
❑D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
®F None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
®A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
❑B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

19. Buffer Width — streamside area metric (skip for Tidal Marsh Streams) Impact 12 -Perennial Stream 12
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
®A ®A ®A ®A >_ 100 feet wide or extends to the edge of the watershed
❑B ❑B ❑B ❑B From 50 to < 100 feet wide
❑C ❑C ❑C ❑C From 30 to < 50 feet wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
❑E ❑E ❑E n < 10 feet wide or no trees
20. Buffer Structure — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
❑A ❑A Mature forest
®B ®B Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but is
within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
❑A ❑A Medium to high stem density
®B ®B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer — streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
®A ®A The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
®B ®B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
❑C ❑C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity— assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes ®No Was conductivity measurement recorded?
If No, select one of the following reasons. ®No Water ❑Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 EIB 46 to < 67 EIC 67 to < 79 ❑ D 79 to < 230 FIE >— 230
Notes/Sketch:
Good canopy/buffer with some non -natives introduced

Draft NC SAM Stream Rating Sheet Impact 12 - Perennial Stream 12
Accompanies User Manual Version 2.1
Stream Site Name Piedmont Lithium Date of Assessment August 20, 2018
Stream Category Pb1 Assessor Name/Organization Kelly Thames/HDR
Notes of Field Assessment Form (Y/N) YES
Presence of regulatory considerations (Y/N) YES
Additional stream information/supplementary measurements included (Y/N) YES
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream) Perennial
USACE/ NCDWR
Function Class Rating Summary
All Streams Intermittent
(1) Hydrology
HIGH
(2) Baseflow
HIGH
(2) Flood Flow
HIGH
(3) Streamside Area Attenuation
HIGH
(4) Floodplain Access
HIGH
(4) Wooded Riparian Buffer
MEDIUM
(4) Microtopography
NA
(3) Stream Stability
HIGH
(4) Channel Stability
HIGH
(4) Sediment Transport
LOW
(4) Stream Geomorphology
HIGH
(2) Stream/Intertidal Zone Interaction
NA
(2) Longitudinal Tidal Flow
NA
(2) Tidal Marsh Stream Stability
NA
(3) Tidal Marsh Channel Stability
NA
(3) Tidal Marsh Stream Geomorphology
NA
(1) Water Quality
HIGH
(2) Baseflow
HIGH
(2) Streamside Area Vegetation
HIGH
(3) Upland Pollutant Filtration
HIGH
(3) Thermoregulation
HIGH
(2) Indicators of Stressors
NO
(2) Aquatic Life Tolerance
HIGH
(2) Intertidal Zone Filtration
NA
(1) Habitat
MEDIUM
(2) In -stream Habitat
LOW
(3) Baseflow
HIGH
(3) Substrate
LOW
(3) Stream Stability
HIGH
(3) In -stream Habitat
MEDIUM
(2) Stream -side Habitat
HIGH
(3) Stream -side Habitat
HIGH
(3) Thermoregulation
HIGH
(2) Tidal Marsh In -stream Habitat
NA
(3) Flow Restriction
NA
(3) Tidal Marsh Stream Stability
NA
(4) Tidal Marsh Channel Stability
NA
(4) Tidal Marsh Stream Geomorphology
NA
(3) Tidal Marsh In -stream Habitat
NA
(2) Intertidal Zone
NA
Overall
HIGH

NC SAM FIELD ASSESSMENT FORM Impact 13 - Perennial Stream 12
Hies user manual version z. -i
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic quadrangle,
and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property, identify and
number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for detailed descriptions
and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were performed. See the
NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION:
1. Project name (if any): Piedmont Lithium
3. Applicant/owner name: Piedmont Lithium, Inc.
5. County: Gaston
7. River basin: Catawba
Date of evaluation: August 20, 2018
Assessor name/organization: Kelly Thames/HDR
Nearest named water body Beaverdam Creek (HUC
on USGS 7.5 -minute quad: 01030102)
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.39221, -81.299573
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): Impact 13 10. Length of assessment reach evaluated (feet): 55 ft
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 6 ft ❑Unable to assess channel depth.
12. Channel width at top of bank (feet): 8 ft 13. Is assessment reach a swamp steam? ❑Yes ❑No
14. Feature type: ®Perennial flow ❑Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) ® Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic ❑A ®B
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip ®Size 1 (< 0.1 mil) ❑Size 2 (0.1 to < 0.5 miz) ❑Size 3 (0.5 to < 5 miz) E] Size 4 (>_ 5 mit)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑Section 10 water ❑Classified Trout Waters ®Water Supply Watershed (❑I ❑II ❑III ®IV ❑V)
❑Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters
❑Anadromous fish ❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
❑Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in "Notes/Sketch" section or attached? ®Yes ❑No
1. Channel Water — assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
®A Water throughout assessment reach.
❑B No flow, water in pools only.
❑C No water in assessment reach.
2. Evidence of Flow Restriction — assessment reach metric
❑A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
®B Not A
3. Feature Pattern — assessment reach metric
❑A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
®B Not A
4. Feature Longitudinal Profile — assessment reach metric
❑A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming, over
widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of these
disturbances).
®B Not A
5. Signs of Active Instability — assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
®A < 10% of channel unstable
❑B 10 to 25% of channel unstable
❑C > 25% of channel unstable

6. Streamside Area Interaction — streamside area metric Impact 13 - Perennial Stream 12
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
®A ®A
Little or no evidence of conditions that adversely affect reference interaction
❑B ❑B
Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area, leaky
or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C
Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision, disruption
of flood flows through streamside area] or too much floodplain/intertidal zone access [examples: impoundments, intensive
mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a man-made feature on an
interstream divide
Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
❑F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
01 Other: (explain in "Notes/Sketch" section)
®J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
10b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
®A Multiple aquatic macrophytes and aquatic mosses N ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) m [:]G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent o❑H Low -tide refugia (pools)
vegetation YC ❑I Sand bottom
®C Multiple snags and logs (including lap trees) L m ❑J 5% vertical bank along the marsh
❑D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
IDA Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
® ❑ ❑ ❑ ❑ Bedrock/saprolite
® ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
❑ ® ❑ ❑ ❑ Cobble (64 — 256 mm)
❑ ❑ ® ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ❑ ® Sand (.062 — 2 mm)
❑ ❑ ❑ ® ❑ Silt/clay (< 0.062 mm)
❑ ❑ ❑ ® ❑ Detritus
® ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12
Impact 13 - Perennial Stream 12
Aquatic Life — assessment reach metric (skip for Tidal Marsh Streams)
12a. ®Yes ❑No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ❑No Water ❑Other:
12b. ®Yes ❑No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
❑ ®Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ ❑Beetles
❑ ®Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/shrimp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ❑Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, fishfly, dobsonfly larvae)
❑ ❑Midges/mosquito larvae
❑ ®Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Other fish
® ❑Salamanders/tadpoles
® ❑Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
❑ ®Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland runoff.
LB RB
®A ®A Little or no alteration to water storage capacity over a majority of the streamside area
❑B ❑B Moderate alteration to water storage capacity over a majority of the streamside area
❑C ❑C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil compaction,
livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water >_ 6 inches deep
❑B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
®C ®C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ❑Y Are wetlands present in the streamside area?
®N ®N
16. Basef low Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
❑A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
❑D Evidence of bank seepage or sweating (iron in water indicates seepage)
®E Stream bed or bank soil reduced (dig through deposited sediment if present)
❑F None of the above
17. Baseflow Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
❑B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
El Urban stream (> 24% impervious surface for watershed)
❑D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
®F None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
®A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
❑B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

19. Buffer Width — streamside area metric (skip for Tidal Marsh Streams) Impact 13 -Perennial Stream 12
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
®A ®A ®A ®A >_ 100 feet wide or extends to the edge of the watershed
❑B ❑B ❑B ❑B From 50 to < 100 feet wide
❑C ❑C ❑C ❑C From 30 to < 50 feet wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
❑E ❑E ❑E n < 10 feet wide or no trees
20. Buffer Structure — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
❑A ❑A Mature forest
®B ®B Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but is
within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
❑A ❑A Medium to high stem density
®B ®B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer — streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
®A ®A The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
®B ®B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
❑C ❑C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity— assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes ®No Was conductivity measurement recorded?
If No, select one of the following reasons. ®No Water ❑Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 EIB 46 to < 67 EIC 67 to < 79 ❑ D 79 to < 230 FIE >— 230
Notes/Sketch:
Good canopy/buffer with some non -natives introduced

Stream Site Name Piedmont Lithium
Stream Category Pb1
Draft NC SAM Stream Rating Sheet Impact 13 - Perennial Stream 12
Accompanies User Manual Version 2.1
Date of Assessment August 20, 2018
Assessor Name/Organization Kelly Thames/HDR
Notes of Field Assessment Form (Y/N) YES
Presence of regulatory considerations (Y/N) YES
Additional stream information/supplementary measurements included (Y/N) YES
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream) Perennial
USACE/ NCDWR
Function Class Rating Summary
All Streams Intermittent
(1) Hydrology
HIGH
(2) Baseflow
HIGH
(2) Flood Flow
HIGH
(3) Streamside Area Attenuation
HIGH
(4) Floodplain Access
HIGH
(4) Wooded Riparian Buffer
MEDIUM
(4) Microtopography
NA
(3) Stream Stability
HIGH
(4) Channel Stability
HIGH
(4) Sediment Transport
LOW
(4) Stream Geomorphology
HIGH
(2) Stream/Intertidal Zone Interaction
NA
(2) Longitudinal Tidal Flow
NA
(2) Tidal Marsh Stream Stability
NA
(3) Tidal Marsh Channel Stability
NA
(3) Tidal Marsh Stream Geomorphology
NA
(1) Water Quality
HIGH
(2) Baseflow
HIGH
(2) Streamside Area Vegetation
HIGH
(3) Upland Pollutant Filtration
HIGH
(3) Thermoregulation
HIGH
(2) Indicators of Stressors
NO
(2) Aquatic Life Tolerance
HIGH
(2) Intertidal Zone Filtration
NA
(1) Habitat
HIGH
(2) In -stream Habitat
MEDIUM
(3) Baseflow
HIGH
(3) Substrate
LOW
(3) Stream Stability
HIGH
(3) In -stream Habitat
HIGH
(2) Stream -side Habitat
HIGH
(3) Stream -side Habitat
HIGH
(3) Thermoregulation
HIGH
(2) Tidal Marsh In -stream Habitat
NA
(3) Flow Restriction
NA
(3) Tidal Marsh Stream Stability
NA
(4) Tidal Marsh Channel Stability
NA
(4) Tidal Marsh Stream Geomorphology
NA
(3) Tidal Marsh In -stream Habitat
NA
(2) Intertidal Zone
NA
Overall
HIGH

NC WAM FIELD ASSESSMENT RESULTS Impact 14 - Wetland 9
USACE AID #
NCDWR#
Project Name
Piedmont Lithium
Date of Evaluation
August 20, 2018
Applicant/Owner Name
Piedmont Lithium, Inc
Wetland Site Name
Wetland 9
Wetland Type
Headwater Forest
Assessor Name/Organization
Kelly Thames/HDR
Level III Ecoregion
Piedmont
Nearest Named Water Body
Beaverdam Creek
River Basin
Catawba
USGS 8 -Digit Catalogue Unit
01030102
County
Gaston
NCDWR Region
Mooresville
❑ Yes ® No
Precipitation within 48 hrs?
Latitude/Longitude (deci-deqrees)
35.397074, -81.298328
Evidence of stressors affecting the assessment area (may not be within the assessment area)
Please circle and/or make note on the last page if evidence of stressors is apparent. Consider departure from reference, if appropriate, in
recent past (for instance, within 10 years). Noteworthy stressors include, but are not limited to the following.
• Hydrological modifications (examples: ditches, dams, beaver dams, dikes, berms, ponds, etc.)
• Surface and sub -surface discharges into the wetland (examples: discharges containing obvious pollutants, presence of nearby septic
tanks, underground storage tanks (USTs), hog lagoons, etc.)
• Signs of vegetation stress (examples: vegetation mortality, insect damage, disease, storm damage, salt intrusion, etc.)
• Habitat/plant community alteration (examples: mowing, clear -cutting, exotics, etc.)
Is the assessment area intensively managed? ❑ Yes ® No
Regulatory Considerations - Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑ Anadromous fish
❑ Federally protected species or State endangered or threatened species
❑ NCDWR riparian buffer rule in effect
❑ Abuts a Primary Nursery Area (PNA)
❑ Publicly owned property
❑ N.C. Division of Coastal Management Area of Environmental Concern (AEC) (including buffer)
❑ Abuts a stream with a NCDWQ classification of SA or supplemental classifications of HQW, ORW, or Trout
❑ Designated NCNHP reference community
❑ Abuts a 303(d) -listed stream or a tributary to a 303(d) -listed stream
What type of natural stream is associated with the wetland, if any? (check all that apply)
❑ Blackwater
® Brownwater
❑ Tidal (if tidal, check one of the following boxes) ❑ Lunar ❑ Wind ❑ Both
Is the assessment area on a coastal island? ❑ Yes ® No
Is the assessment area's surface water storage capacity or duration substantially altered by beaver? ❑ Yes ® No
Does the assessment area experience overbank flooding during normal rainfall conditions? ❑ Yes ® No
Ground Surface Condition/Vegetation Condition — assessment area condition metric
Check a box in each column. Consider alteration to the ground surface (GS) in the assessment area and vegetation structure (VS) in the
assessment area. Compare to reference wetland if applicable (see User Manual). If a reference is not applicable, then rate the assessment
area based on evidence an effect.
GS VS
IDA ®A Not severely altered
❑B ❑B Severely altered over a majority of the assessment area (ground surface alteration examples: vehicle tracks, excessive
sedimentation, fire -plow lanes, skidder tracks, bedding, fill, soil compaction, obvious pollutants) (vegetation structure
alteration examples: mechanical disturbance, herbicides, salt intrusion [where appropriate], exotic species, grazing, less
diversity [if appropriate], hydrologic alteration)
Surface and Sub -Surface Storage Capacity and Duration — assessment area condition metric
Check a box in each column. Consider surface storage capacity and duration (Surf) and sub -surface storage capacity and duration (Sub).
Consider both increase and decrease in hydrology. A ditch <_ 1 foot deep is considered to affect surface water only, while a ditch > 1 foot
deep is expected to affect both surface and sub -surface water. Consider tidal flooding regime, if applicable.
Surf Sub
❑A ❑A Water storage capacity and duration are not altered.
®B ®B Water storage capacity or duration are altered, but not substantially (typically, not sufficient to change vegetation).
❑C ❑C Water storage capacity or duration are substantially altered (typically, alteration sufficient to result in vegetation change)
(examples: draining, flooding, soil compaction, filling, excessive sedimentation, underground utility lines).
3. Water Storage/Surface Relief — assessment area/wetland type condition metric (skip for all marshes)
Check a box in each column. Select the appropriate storage for the assessment area (AA) and the wetland type (WT).
AA WT
3a. ❑A ❑A Majority of wetland with depressions able to pond water > 1 deep
❑B ❑B Majority of wetland with depressions able to pond water 6 inches to 1 foot deep
❑C ®C Majority of wetland with depressions able to pond water 3 to 6 inches deep
®D ❑D Depressions able to pond water < 3 inches deep
3b. ❑A Evidence that maximum depth of inundation is greater than 2 feet
❑B Evidence that maximum depth of inundation is between 1 and 2 feet
®C Evidence that maximum depth of inundation is less than 1 foot

4. Soil Texture/Structure — assessment area condition metric (skip for all marshes)
Check a box from each of the three soil property groups below. Dig soil profile in the dominant assessment area landscape feature.
Make soil observations within the top 12 inches. Use most recent National Technical Committee for Hydric Soils guidance for regional
indicators.
4a. ❑A Sandy soil
®B Loamy or clayey soils exhibiting redoximorphic features (concentrations, depletions, or rhizospheres)
❑C Loamy or clayey soils not exhibiting redoximorphic features
❑D Loamy or clayey gleyed soil
❑E Histosol or histic epipedon
41b. ®A Soil ribbon < 1 inch
❑B Soil ribbon >_ 1 inch
4c. ®A No peat or muck presence
❑B A peat or muck presence
5. Discharge into Wetland — opportunity metric
Check a box in each column. Consider surface pollutants or discharges (Surf) and sub -surface pollutants or discharges (Sub). Examples
of sub -surface discharges include presence of nearby septic tank, underground storage tank (UST), etc.
Surf Sub
®A ®A Little or no evidence of pollutants or discharges entering the assessment area
❑B ❑B Noticeable evidence of pollutants or discharges entering the wetland and stressing, but not overwhelming the
treatment capacity of the assessment area
El 7 Noticeable evidence of pollutants or discharges (pathogen, particulate, or soluble) entering the assessment area and
potentially overwhelming the treatment capacity of the wetland (water discoloration, dead vegetation, excessive
sedimentation, odor)
6. Land Use — opportunity metric (skip for non -riparian wetlands)
Check all that apply (at least one box in each column). Evaluation involves a GIS effort with field adjustment. Consider sources draining
to assessment area within entire upstream watershed (WS), within 5 miles and within the watershed draining to the assessment area (5M),
and within 2 miles and within the watershed draining to the assessment area (2M).
WS 5M 2M
❑A ❑A ❑A > 10% impervious surfaces
❑B ❑B ❑B Confined animal operations (or other local, concentrated source of pollutants
®C ®C ❑C >_ 20% coverage of pasture
®D ®D ®D >_ 20% coverage of agricultural land (regularly plowed land)
®E ®E ®E >_ 20% coverage of maintained grass/herb
❑F ❑F ❑F >_ 20% coverage of clear-cut land
❑G ❑G ❑G Little or no opportunity to improve water quality. Lack of opportunity may result from little or no disturbance in
the watershed or hydrologic alterations that prevent drainage and/or overbank flow from affecting the
assessment area.
7. Wetland Acting as Vegetated Buffer — assessment area/wetland complex condition metric (skip for non -riparian wetlands)
7a. Is assessment area within 50 feet of a tributary or other open water?
®Yes ❑No If Yes, continue to 7b. If No, skip to Metric 8.
Wetland buffer need only be present on one side of the water body. Make buffer judgment based on the average width of wetland.
Record a note if a portion of the buffer has been removed or disturbed.
7b. How much of the first 50 feet from the bank is wetland? (Wetland buffer need only be present on one side of the .water body. Make
buffer judgment based on the average width of wetland. Record a note if a portion of the buffer has been removed or disturbed.)
❑A >_ 50 feet
❑B From 30 to < 50 feet
❑C From 15 to < 30 feet
®D From 5 to < 15 feet
❑E < 5 feet or buffer bypassed by ditches
7c. Tributary width. If the tributary is anastomosed, combine widths of channels/braids for a total width.
®<— 15 -feet wide ❑> 15 -feet wide ❑ Other open water (no tributary present)
7d. Do roots of assessment area vegetation extend into the bank of the tributary/open water?
❑Yes ®No
7e. Is stream or other open water sheltered or exposed?
®Sheltered — adjacent open water with width < 2500 feet and no regular boat traffic.
EJ Exposed — adjacent open water with width >_ 2500 feet or regular boat traffic.
8. Wetland Width at the Assessment Area — wetland type/wetland complex condition metric (evaluate WT for all marshes and
Estuarine Woody Wetland only; evaluate WC for Bottomland Hardwood Forest, Headwater Forest, and Riverine Swamp Forest
only)
Check a box in each column for riverine wetlands only. Select the average width for the wetland type at the assessment area (WT) and
the wetland complex at the assessment area (WC). See User Manual for WT and WC boundaries.
WT WC
❑A ❑A >_ 100 feet
❑B ❑B From 80 to < 100 feet
❑C ❑C From 50 to < 80 feet
❑D ❑D From 40 to < 50 feet
®E ❑E From 30 to < 40 feet
❑F ®F From 15 to < 30 feet
❑G ❑G From 5 to < 15 feet
❑H ❑H < 5 feet

9. Inundation Duration - assessment area condition metric (skip for non -riparian wetlands)
Answer for assessment area dominant landform.
®A Evidence of short -duration inundation (< 7 consecutive days)
❑B Evidence of saturation, without evidence of inundation
❑C Evidence of long -duration inundation or very long -duration inundation (7 to 30 consecutive days or more)
10. Indicators of Deposition - assessment area condition metric (skip for non -riparian wetlands and all marshes)
Consider recent deposition only (no plant growth since deposition).
®A Sediment deposition is not excessive, but at approximately natural levels.
❑B Sediment deposition is excessive, but not overwhelming the wetland.
❑C Sediment deposition is excessive and is overwhelming the wetland.
11. Wetland Size -wetland type/wetland complex condition metric
Check a box in each column. Involves a GIS effort with field adjustment. This metric evaluates three aspects of the wetland area: the
size of the wetland type (WT), the size of the wetland complex (WC), and the size of the forested wetland (FW) (if applicable, see User
Manual). See the User Manual for boundaries of these evaluation areas. If assessment area is clear-cut, select "K" for the FW column.
WT
WC
FW (if applicable)
❑A
❑A
❑A
>- 500 acres
❑B
❑B
❑B
From 100 to < 500 acres
❑C
❑C
❑C
From 50 to < 100 acres
❑D
❑D
n
From 25 to < 50 acres
❑E
❑E
n
From 10 to < 25 acres
❑F
❑F
❑F
From 5 to < 10 acres
❑G
❑G
n
From 1 to < 5 acres
❑H
❑H
n
From 0.5 to < 1 acre
01
01
®I
From 0.1 to < 0.5 acre
❑J
❑J
❑J
From 0.01 to < 0.1 acre
❑K
❑K
n
< 0.01 acre or assessment area is clear-cut
12. Wetland Intactness - wetland type condition metric (evaluate for Pocosins only)
❑A Pocosin is the full extent (>- 90%) of its natural landscape size.
❑B Pocosin type is < 90% of the full extent of its natural landscape size.
13. Connectivity to Other Natural Areas - landscape condition metric
13a. Check appropriate box(es) (a box may be checked in each column). Involves a GIS effort with field adjustment. This metric
evaluates whether the wetland is well connected (Well) and/or loosely connected (Loosely) to the landscape patch, the contiguous
naturally vegetated area and open water (if appropriate). Boundaries are formed by four -lane roads, regularly maintained utility line
corridors the width of a four -lane road or wider, urban landscapes, maintained fields (pasture and agriculture), or open water > 300
feet wide.
Well Loosely
❑A
®A
>- 500 acres
❑B
❑B
From 100 to < 500 acres
®C
❑C
From 50 to < 100 acres
❑D
❑D
From 10 to < 50 acres
❑E
❑E
< 10 acres
❑F
❑F
Wetland type has a poor or no connection to other natural habitats
13b. Evaluate for marshes only.
❑Yes ❑No Wetland type has a surface hydrology connection to open waters/stream or tidal wetlands.
14. Edge Effect - wetland type condition metric (skip for all marshes and Estuarine Woody Wetland)
May involve a GIS effort with field adjustment. Estimate distance from wetland type boundary to artificial edges. Artificial edges include
non -forested areas >- 40 feet wide such as fields, development, roads, regularly maintained utility line corridors, and clear -cuts. Consider
the eight main points of the compass. Artificial edge occurs within 150 feet in how many directions? If the assessment area is clear cut,
select option "C."
❑A 0
®B 1 to 4
❑C 5to8
15. Vegetative Composition - assessment area condition metric (skip for all marshes and Pine Flat)
®A Vegetation is close to reference condition in species present and their proportions. Lower strata composed of appropriate
species, with exotic plants absent or sparse within the assessment area.
❑B Vegetation is different from reference condition in species diversity or proportions, but still largely composed of native species
characteristic of the wetland type. This may include communities of weedy native species that develop after clearcutting or clearing.
It also includes communities with exotics present, but not dominant, over a large portion of the expected strata.
❑C Vegetation severely altered from reference in composition, or expected species are unnaturally absent (planted stands of non -
characteristic species or at least one stratum inappropriately composed of a single species), or exotic species are dominant in at
least one stratum.
16. Vegetative Diversity - assessment area condition metric (evaluate for Non -tidal Freshwater Marsh only)
❑A Vegetation diversity is high and is composed primarily of native species (< 10% cover of exotics).
®B Vegetation diversity is low or has > 10% to 50% cover of exotics.
❑C Vegetation is dominated by exotic species (> 50 % cover of exotics).

17. Vegetative Structure — assessment area/wetland type condition metric
17a. Is vegetation present?
®Yes ❑No If Yes, continue to 17b. If No, skip to Metric 18.
17b. Evaluate percent coverage of assessment area vegetation for all marshes only. Skip to 17c for non -marsh wetlands.
❑A >_ 25% coverage of vegetation
❑B < 25% coverage of vegetation
17c. Check a box in each column for each stratum. Evaluate this portion of the metric for non -marsh wetlands. Consider
structure in airspace above the assessment area (AA) and the wetland type (WT) separately.
AA WT
T
o ®A ®A Canopy closed, or nearly closed, with natural gaps associated with natural processes
❑B ❑B Canopy present, but opened more than natural gaps
U ❑C ❑C Canopy sparse or absent
o ❑A ❑A Dense mid-story/sapling layer
❑B ®B Moderate density mid-story/sapling layer
®C ❑C Mid-story/sapling layer sparse or absent
❑A ❑A Dense shrub layer
r ❑B ®B Moderate density shrub layer
U) ®C ❑C Shrub layer sparse or absent
❑A ❑A Dense herb layer
_ ®B ®B Moderate density herb layer
❑C ❑C Herb layer sparse or absent
18. Snags — wetland type condition metric (skip for all marshes)
❑A Large snags (more than one) are visible (> 12 inches DBH, or large relative to species present and landscape stability).
®B Not A
19. Diameter Class Distribution — wetland type condition metric (skip for all marshes)
❑A Majority of canopy trees have stems > 6 inches in diameter at breast height (DBH); many large trees (> 12 inches DBH) are
present.
®B Majority of canopy trees have stems between 6 and 12 inches DBH, few are > 12 inch DBH.
❑C Majority of canopy trees are < 6 inches DBH or no trees.
20. Large Woody Debris — wetland type condition metric (skip for all marshes)
Include both natural debris and man -placed natural debris.
❑A Large logs (more than one) are visible (> 12 inches in diameter, or large relative to species present and landscape stability).
®B Not A
21. Vegetation/Open Water Dispersion — wetland type/open water condition metric (evaluate for Non -Tidal Freshwater Marsh only)
Select the figure that best describes the amount of interspersion between vegetation and open water in the growing season. Patterned
areas indicate vegetated areas, while solid white areas indicate open water.
❑A ❑B El ®D
�`� � r �._� '1 pit--��•�. �- ..
tv
22. Hydrologic Connectivity — assessment area condition metric (evaluate for riparian wetlands and Salt/Brackish Marsh only)
Examples of activities that may severely alter hydrologic connectivity include intensive ditching, fill, sedimentation, channelization, diversion,
man-made berms, beaver dams, and stream incision. Documentation required if evaluated as B, C, or D.
®A Overbank and overland flow are not severely altered in the assessment area.
❑B Overbank flow is severely altered in the assessment area.
❑C Overland flow is severely altered in the assessment area.
❑D Both overbank and overland flow are severely altered in the assessment area.
Notes

NC WAM Wetland Rating Sheet
Accompanies User Manual Version 5.0
Wetland Site Name Wetland 9 Date of Assessment August 20, 2018
Wetland Type Headwater Forest Assessor Name/Organization Kelly Thames/HDR
Notes on Field Assessment Form (Y/N) NO
Presence of regulatory considerations (Y/N) NO
Wetland is intensively managed (Y/N) NO
Assessment area is located within 50 feet of a natural tributary or other open water (Y/N) YES
Assessment area is substantially altered by beaver (Y/N) NO
Assessment area experiences overbank flooding during normal rainfall conditions (Y/N) NO
Assessment area is on a coastal island (Y/N) NO
Sub -function Rating Summar
Function
Sub -function
Metrics
Rating
Hydrology
Surface Storage and Retention
Condition
HIGH
HIGH
Sub -surface Storage and
Condition/Opportunity
NA
Retention
Condition
HIGH
Water Quality
Pathogen Change
Condition
HIGH
Habitat Physical Structure Condition HIGH
Landscape Patch Structure Condition LOW
Vegetation Composition Condition HIGH
Function Ratina Summar
Function
Condition/Opportunity
HIGH
Hydrology
Opportunity Presence (Y/N)
NO
Particulate Change
Condition
HIGH
Condition/Opportunity
NA
Opportunity Presence (Y/N)
NA
Soluble Change
Condition
MEDIUM
Condition/Opportunity
HIGH
Opportunity Presence (Y/N)
YES
Physical Change
Condition
LOW
Condition/Opportunity
LOW
Opportunity Presence (Y/N)
YES
Pollution Change
Condition
NA
Condition/Opportunity
NA
Opportunity Presence (Y/N)
NA
Habitat Physical Structure Condition HIGH
Landscape Patch Structure Condition LOW
Vegetation Composition Condition HIGH
Function Ratina Summar
Function
Metrics
Rating
Hydrology
Condition
HIGH
Water Quality
Condition
HIGH
Condition/Opportunity
HIGH
Opportunity Presence (Y/N)
YES
Habitat
Condition
HIGH
Overall Wetland Rating HIGH

NC DWO Stir -cam m Identification Form Version 4.11 ,fir 1�� + � �" k W A A-
A. Geomorphology (Subtotal = 10. 5
1° Continuity of channel bed and bank
Absent
0
vW
Moderate
CV,
Evaluator:
�T -61 L
V
s
county:
longitude:
Total Points:
Stream is at least inrermiifanr
if z19 or Perennial if 2 30'
� /s -
Stream oetermatian circle ones
Ephemeral 4 eitti t Perennial
Other Lt'1I1 'Wd
e.g. Quad Name: (h„tyf r
A. Geomorphology (Subtotal = 10. 5
1° Continuity of channel bed and bank
Absent
0
Weak
1
Moderate
CV,
Strong
3
2, Sinuosity of channel along thalweg
0
1
2
15. Sediment on plants or debris
3. In -channel structure; ex. riffle -pool, step -pool,
ripple -pool se uence
0
16. Organic debris lines or piles
2
3
4. Particle size of stream substrate
0
Yes 3
2
3
5, Activetrelict floodp{ain
0
1
2
3
6. Depositional bars or benches
0
1
2
3
7. Recent alluvial deposits
1.5
1
2
3
8. Headcuts
Q
T2
3
9. Grade control
Q
0.5
1
1.5
10. Natural valley
0
0.5
1
1 i5
11. Second or greater order channel
No :xU
Yes = 3
- artificial ditches are not rated: see discussions in manual
B. Hvdroloov [Subtotal = 1
12. Presence of Baseflow
0 1
2 3
13. Iron oxidizing bacteria
0 1
2' 3
14. Leat litter
1.5
0.5 0
15. Sediment on plants or debris
0 j 0.5
1 1.5
16. Organic debris lines or piles
0 1 0.5
1
17, Soil -based evidence of high water table?
No = 0
Yes 3
U. 1:510100V f5ubtotal = 1" e 1 ]
18. Fibrous roots in streambed
3
2 1
0
19. Rooted upland plants in streambed
3
2 1
0
20. Macro benthos (note diversity and abundanea)
0
1 2
3
21. Aquatic Mollusks
0
i 2
3
22. Fish
Q
0.5 1
1.5
23. Crayfish
0.5 1
1.5
24. Amphibians
0
0.5 1
1.5
25. Algae
0
0.5 _ 1
1.5
26. Wetland plants in streambed
FACW = 0.75; OBL = 1. Other = 0
'perennial streams may also be identified using other methods, See p. 35 of manual_
Notes:
Sketch:

NC SAM FIELD ASSESSMENT FORM Impact 16 - Intermittent Stream 13
user rvianuai version z. -i
USACE AID #: NCDWR #:
INSTRUCTIONS: Attach a sketch of the assessment area and photographs. Attach a copy of the USGS 7.5 -minute topographic quadrangle,
and circle the location of the stream reach under evaluation. If multiple stream reaches will be evaluated on the same property, identify and
number all reaches on the attached map, and include a separate form for each reach. See the NC SAM User Manual for detailed descriptions
and explanations of requested information. Record in the "Notes/Sketch" section if supplementary measurements were performed. See the
NC SAM User Manual for examples of additional measurements that may be relevant.
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
PROJECT/SITE INFORMATION:
1. Project name (if any): Piedmont Lithium
3. Applicant/owner name: Piedmont Lithium, Inc.
5. County: Gaston
2. Date of evaluation: August 20, 2018
4. Assessor name/organization: Kelly Thames/HDR
6. Nearest named water body Beaverdam Creek (HUC
7. River basin: Catawba on USGS 7.5 -minute quad: 01030102)
8. Site coordinates (decimal degrees, at lower end of assessment reach): 35.396864, -81.299077
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map): Impact 16 10. Length of assessment reach evaluated (feet): 240 ft
11. Channel depth from bed (in riffle, if present) to top of bank (feet): 1 ft ❑Unable to assess channel depth.
12. Channel width at top of bank (feet): 2-4 ft 13. Is assessment reach a swamp steam? ❑Yes ❑No
14. Feature type: ❑Perennial flow ®Intermittent flow ❑Tidal Marsh Stream
STREAM CATEGORY INFORMATION:
15. NC SAM Zone: ❑ Mountains (M) ® Piedmont (P) ❑ Inner Coastal Plain (1) ❑ Outer Coastal Plain (0)
16. Estimated geomorphic ®A` J ❑B
valley shape (skip for
Tidal Marsh Stream): (more sinuous stream, flatter valley slope) (less sinuous stream, steeper valley slope)
17. Watershed size: (skip ®Size 1 (< 0.1 mil) ❑Size 2 (0.1 to < 0.5 mit) ❑Size 3 (0.5 to < 5 mit) ❑Size 4 (>_ 5 mit)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑Section 10 water ❑Classified Trout Waters ®Water Supply Watershed (❑I ❑II ❑III ®IV ❑V)
❑Essential Fish Habitat ❑Primary Nursery Area ❑ High Quality Waters/Outstanding Resource Waters
❑Publicly owned property ❑NCDWR Riparian buffer rule in effect ❑Nutrient Sensitive Waters
❑Anadromous fish ❑303(d) List ❑CAMA Area of Environmental Concern (AEC)
❑Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
❑Designated Critical Habitat (list species)
19. Are additional stream information/supplementary measurements included in "Notes/Sketch" section or attached? ®Yes ❑No
1. Channel Water - assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
❑A Water throughout assessment reach.
®B No flow, water in pools only.
❑C No water in assessment reach.
2. Evidence of Flow Restriction - assessment reach metric
❑A At least 10% of assessment reach in -stream habitat or riffle -pool sequence is severely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impoundment on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates, debris jams,
beaver dams).
®B Not
3. Feature Pattern - assessment reach metric
❑A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
®B Not
4. Feature Longitudinal Profile - assessment reach metric
❑A Majority of assessment reach has a substantially altered stream profile (examples: channel down -cutting, existing damming, over
widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of these
disturbances).
®B Not
5. Signs of Active Instability - assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down -cutting (head -cut), active widening, and artificial hardening (such as concrete, gabion, rip -rap).
®A < 10% of channel unstable
❑B 10 to 25% of channel unstable
❑C > 25% of channel unstable

6. Streamside Area Interaction — streamside area metric Impact 16 - Intermittent Stream 13
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
®A ®A
Little or no evidence of conditions that adversely affect reference interaction
❑B ❑B
Moderate evidence of conditions (examples: berms, levees, down -cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area, leaky
or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
❑C ❑C
Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision, disruption
of flood flows through streamside area] or too much floodplain/intertidal zone access [examples: impoundments, intensive
mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a man-made feature on an
interstream divide
Water Quality Stressors — assessment reach/intertidal zone metric
Check all that apply.
❑A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
❑B Excessive sedimentation (burying of stream features or intertidal zone)
❑C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
❑D Odor (not including natural sulfide odors)
❑E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in "Notes/Sketch"
section.
®F Livestock with access to stream or intertidal zone
❑G Excessive algae in stream or intertidal zone
❑H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc)
❑I Other: (explain in "Notes/Sketch" section)
❑J Little to no stressors
8. Recent Weather — watershed metric (skip for Tidal Marsh Streams)
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a drought.
❑A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
❑B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
®C No drought conditions
9. Large or Dangerous Stream — assessment reach metric
❑Yes ®No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10. Natural In -stream Habitat Types — assessment reach metric
10a. ❑Yes ®No Degraded in -stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in -stream hardening [for example, rip -rap], recent dredging, and snagging)
(evaluate for Size 4 Coastal Plain streams only, then skip to Metric 12)
10b. Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
®A Multiple aquatic macrophytes and aquatic mosses m w ❑F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats) (D ❑G Submerged aquatic vegetation
®B Multiple sticks and/or leaf packs and/or emergent w Y ❑H Low -tide refugia (pools)
vegetation N ❑I Sand bottom
®C Multiple snags and logs (including lap trees) t m ❑J 5% vertical bank along the marsh
❑D 5% undercut banks and/or root mats and/or roots ❑K Little or no habitat
in banks extend to the normal wetted perimeter
❑E Little or no habitat
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************
11. Bedform and Substrate —assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a. ❑Yes ®No Is assessment reach in a natural sand -bed stream? (skip for Coastal Plain streams)
11 b. Bedform evaluated. Check the appropriate box(es).
®A Riffle -run section (evaluate 11c)
❑B Pool -glide section (evaluate 11 d)
❑C Natural bedform absent (skip to Metric 12, Aquatic Life)
11 c. In riffle sections, check all that occur below the normal wetted perimeter of the assessment reach — whether or not submerged. Check
at least one box in each row (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams). Not Present (NP) = absent, Rare
(R) = present but < 10%, Common (C) _ > 10-40%, Abundant (A) _ > 40-70%, Predominant (P) _ > 70%. Cumulative percentages
should not exceed 100% for each assessment reach.
NP R C A P
® ❑ ❑ ❑ ❑ Bedrock/saprolite
® ❑ ❑ ❑ ❑ Boulder (256 — 4096 mm)
® ❑ ❑ ❑ ❑ Cobble (64 — 256 mm)
❑ ❑ ® ❑ ❑ Gravel (2 — 64 mm)
❑ ❑ ❑ ❑ ® Sand (.062 — 2 mm)
❑ ❑ ❑ ® ❑ Silt/clay (< 0.062 mm)
❑ ❑ ❑ ® ❑ Detritus
® ❑ ❑ ❑ ❑ Artificial (rip -rap, concrete, etc.)
11d. ❑Yes ❑No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)

12. Aquatic Life —assessment reach metric (skip for Tidal Marsh Streams) Impact 16 - Intermittent Stream 13
12a. ®Yes ❑No Was an in -stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. ❑No Water ❑Other:
12b. ®Yes ❑No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check all that
apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to "individuals" for Size 1 and 2 streams and "taxa" for Size 3 and 4 streams.
❑ ®Adult frogs
❑ ❑Aquatic reptiles
❑ ❑Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
❑ ❑Beetles
❑ ❑Caddisfly larvae (T)
❑ ❑Asian clam (Corbicula)
❑ ❑Crustacean (isopod/amphipod/crayfish/shrimp)
❑ ❑Damselfly and dragonfly larvae
❑ ❑Dipterans
❑ ❑Mayfly larvae (E)
❑ ❑Megaloptera (alderfly, fishily, dobsonfly larvae)
❑ ❑Midges/mosquito larvae
❑ ❑Mosquito fish (Gambusia) or mud minnows (Umbra pygmaea)
❑ ❑Mussels/Clams (not Corbicula)
❑ ❑Other fish
❑ ❑Salamanders/tadpoles
❑ ❑Snails
❑ ❑Stonefly larvae (P)
❑ ❑Tipulid larvae
❑ ❑Worms/leeches
13. Streamside Area Ground Surface Condition — streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and upland runoff.
LB RB
❑A ❑A Little or no alteration to water storage capacity over a majority of the streamside area
®B ®B Moderate alteration to water storage capacity over a majority of the streamside area
El ❑C Severe alteration to water storage capacity over a majority of the streamside area (examples: ditches, fill, soil compaction,
livestock disturbance, buildings, man-made levees, drainage pipes)
14. Streamside Area Water Storage — streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
❑A ❑A Majority of streamside area with depressions able to pond water >_ 6 inches deep
❑B ❑B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
®C ®C Majority of streamside area with depressions able to pond water < 3 inches deep
15. Wetland Presence — streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the normal
wetted perimeter of assessment reach.
LB RB
❑Y ®Y Are wetlands present in the streamside area?
®N ❑N
16. Baseflow Contributors — assessment reach metric (skip for Size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
❑A Streams and/or springs (jurisdictional discharges)
❑B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
❑C Obstruction passing flow during low -flow periods within the assessment area (beaver dam, leaky dam, bottom -release dam, weir)
❑D Evidence of bank seepage or sweating (iron in water indicates seepage)
®E Stream bed or bank soil reduced (dig through deposited sediment if present)
❑F None of the above
17. Basef low Detractors — assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
❑A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
❑B Obstruction not passing flow during low -flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
❑C Urban stream (>_ 24% impervious surface for watershed)
®D Evidence that the streamside area has been modified resulting in accelerated drainage into the assessment reach
❑E Assessment reach relocated to valley edge
❑F None of the above
18. Shading — assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider "leaf -on" condition.
®A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
❑B Degraded (example: scattered trees)
❑C Stream shading is gone or largely absent

19. Buffer Width — streamside area metric (skip for Tidal Marsh Streams) Impact 16 - Intermittent Stream 13
Consider "vegetated buffer" and "wooded buffer" separately for left bank (LB) and right bank (RB) starting at the top of bank out
to the first break.
Vegetated Wooded
LB RB LB RB
®A ®A ®A ®A >_ 100 feet wide or extends to the edge of the watershed
❑B ❑B ❑B ❑B From 50 to < 100 feet wide
❑C ❑C ❑C ❑C From 30 to < 50 feet wide
❑D ❑D ❑D ❑D From 10 to < 30 feet wide
❑E ❑E ❑E ❑E < 10 feet wide or no trees
20. Buffer Structure — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
❑A ❑A Mature forest
®B ®B Non -mature woody vegetation or modified vegetation structure
❑C ❑C Herbaceous vegetation with or without a strip of trees < 10 feet wide
❑D ❑D Maintained shrubs
❑E ❑E Little or no vegetation
21. Buffer Stressors — streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but is
within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
❑A ❑A ❑A ❑A ❑A ❑A Row crops
❑B ❑B ❑B ❑B ❑B ❑B Maintained turf
❑C ❑C ❑C ❑C ❑C ❑C Pasture (no livestock)/commercial horticulture
❑D ❑D ❑D ❑D ❑D ❑D Pasture (active livestock use)
22. Stem Density — streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
❑A ❑A Medium to high stem density
®B ®B Low stem density
❑C ❑C No wooded riparian buffer or predominantly herbaceous species or bare ground
23. Continuity of Vegetated Buffer — streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10 feet wide.
LB RB
®A ®A The total length of buffer breaks is < 25 percent.
❑B ❑B The total length of buffer breaks is between 25 and 50 percent.
❑C ❑C The total length of buffer breaks is > 50 percent.
24. Vegetative Composition — streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes to
assessment reach habitat.
LB RB
❑A ❑A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native species,
with non-native invasive species absent or sparse.
®B ®B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear -cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
❑C ❑C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non -characteristic species or communities inappropriately composed of a single species or no vegetation.
25. Conductivity — assessment reach metric (skip for all Coastal Plain streams)
25a. ❑Yes ®No Was conductivity measurement recorded?
If No, select one of the following reasons. ®No Water ❑Other:
25b. Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
❑A < 46 ❑B 46 to < 67 ❑C 67 to < 79 ❑D 79 to < 230 ❑E >_ 230
Notes/Sketch:
Stream and streamside areas are accessible to livestock, therfore there is soil compaction and little to no understory, though the canopy is intact.

Draft NC SAM Stream Rating Sheet Impact 16 - Intermittent Stream 13
Accompanies User Manual Version 2.1
Stream Site Name Piedmont Lithium Date of Assessment August 20, 2018
Stream Category Pal Assessor Name/Organization Kelly Thames/HDR
Notes of Field Assessment Form (Y/N) YES
Presence of regulatory considerations (Y/N) YES
Additional stream information/supplementary measurements included (Y/N) YES
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream) Intermittent
USACE/
NCDWR
Function Class Rating Summary
All Streams
Intermittent
(1) Hydrology
HIGH
HIGH
(2) Baseflow
MEDIUM
MEDIUM
(2) Flood Flow
HIGH
HIGH
(3) Streamside Area Attenuation
HIGH
HIGH
(4) Floodplain Access
HIGH
HIGH
(4) Wooded Riparian Buffer
MEDIUM
MEDIUM
(4) Microtopography
MEDIUM
MEDIUM
(3) Stream Stability
HIGH
HIGH
(4) Channel Stability
HIGH
HIGH
(4) Sediment Transport
LOW
LOW
(4) Stream Geomorphology
HIGH
HIGH
(2) Stream/Intertidal Zone Interaction
NA
NA
(2) Longitudinal Tidal Flow
NA
NA
(2) Tidal Marsh Stream Stability
NA
NA
(3) Tidal Marsh Channel Stability
NA
NA
(3) Tidal Marsh Stream Geomorphology
NA
NA
(1) Water Quality
LOW
LOW
(2) Baseflow
MEDIUM
MEDIUM
(2) Streamside Area Vegetation
HIGH
HIGH
(3) Upland Pollutant Filtration
HIGH
HIGH
(3) Thermoregulation
HIGH
HIGH
(2) Indicators of Stressors
YES
YES
(2) Aquatic Life Tolerance
LOW
NA
(2) Intertidal Zone Filtration
NA
NA
(1) Habitat
HIGH
HIGH
(2) In -stream Habitat
MEDIUM
MEDIUM
(3) Baseflow
MEDIUM
MEDIUM
(3) Substrate
LOW
LOW
(3) Stream Stability
HIGH
HIGH
(3) In -stream Habitat
HIGH
HIGH
(2) Stream -side Habitat
HIGH
HIGH
(3) Stream -side Habitat
HIGH
HIGH
(3) Thermoregulation
HIGH
HIGH
(2) Tidal Marsh In -stream Habitat
NA
NA
(3) Flow Restriction
NA
NA
(3) Tidal Marsh Stream Stability
NA
NA
(4) Tidal Marsh Channel Stability
NA
NA
(4) Tidal Marsh Stream Geomorphology
NA
NA
(3) Tidal Marsh In -stream Habitat
NA
NA
(2) Intertidal Zone
NA
NA
Overall
HIGH
HIGH

11/6/2018
IPaC
IPaC resource list
IPaC: Explore Location
U.S. Fish & Wildlife Service
Last login September 21, 2018 06:11 AM MDT
This report is an automatically generated list of species and other resources such as critical habitat
(collectively referred to as trust resources) under the U.S. Fish and Wildlife Service's (USFWS)
jurisdiction that are known or expected to be on or near the project area referenced below. The list
may also include trust resources that occur outside of the project area, but that could potentially be
directly or indirectly affected by activities in the project area. However, determining the likelihood
and extent of effects a project may have on trust resources typically requires gathering additional
site-specific (e.g., vegetation/species surveys) and project -specific (e.g., magnitude and timing of,
proposed activities) information. 4
Below is a summary of the project information you provided and contact information for the USFWS
office(s) with jurisdiction in the defined project area. Please read the introduction to each section
that follows (Endangered Species, Migratory Birds, USFWS Facilities, and NWI Wetlands) for
additional information applicable to the trust resources addressed in that section.
Location
Gaston County, North Carolina
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Local office
Asheville Ecological Services Field Office
L [phone]
18 [phone]
160 Zillicoa Street
Asheville, NC 28801-1082
http://www.fws.gov/nc-es/es/countyfr.html
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11/6/2018 IPaC: Explore Location
Endangered species
This resource list is for informational purposes only and does not constitute an analysis of
project level impacts.
The primary information used to generate this list is the known or expected range of each species.
Additional areas of influence (AOI) for species are also considered. An AOI includes areas outside of
the species range if the species could be indirectly affected by activities in that area (e.g., placing a
dam upstream of a fish population, even if that fish does not occur at the dam site, may indirectly
impact the species by reducing or eliminating water flow downstream). Because species can move,
and site conditions can change, the species on this list are not guaranteed to be found on or near
the project area. To fully determine any potential effects to species, additional site-specific and
project -specific information is often required.
Section 7 of the Endangered Species Act requires Federal agencies to "request of the Secretary
information whether any species which is listed or proposed to be listed may be present in the area
of such proposed action" for any project that is conducted, permitted, funded, or licensed by any
Federal agency. A letter from the local office and a species list which fulfills this requirement can
only be obtained by requesting an official species list from either the Regulatory Review section in
IPaC (see directions below) or from the local field office directly.
For project evaluations that require USFWS concurrence/review, please return to the IPaC website
and request an official species list by doing the following:
1. Draw the project location and click CONTINUE.
2. Click DEFINE PROJECT.
3. Log in (if directed to do so).
4. Provide a name and description for your project.
5. Click REQUEST SPECIES LIST.
Listed species' and their critical habitats are managed by the Ecological Services Program of the U.S.
Fish and Wildlife Service (USFWS) and the fisheries division of the National Oceanic and Atmospheric
Administration (NOAA Fisheries).
Species and critical habitats under the sole responsibility of NOAA Fisheries are not shown on this
list. Please contact NOAA Fisheries for species under their jurisdiction.
1. Species listed under the Endangered Species Act are threatened or endangered; IPaC also shows
species that are candidates, or proposed, for listing. See the listing status page for more
information.
2. NOAA Fisheries, also known as the National Marine Fisheries Service (NMFS), is an office of the
National Oceanic and Atmospheric Administration within the Department of Commerce.
The following species are potentially affected by activities in this location:
Mammals
NAME STATUS
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11/6/2018
IPaC: Explore Location
Northern Long-eared Bat Myotis septentrionalis Threatened
No critical habitat has been designated for this species.
https://ecos.fws.gov/ecp/species/9045
Flowering Plants
NAME STATUS
Dwarf -flowered Heartleaf Hexastylis naniflora Threatened
No critical habitat has been designated for this species.
https://ecos.fws.gov/ecp/species/2458
Schweinitz`s Sunflower Helianthus schweinitzii Endangered
No critical habitat has been designated for this species.
https://ecos.fws.gov/ecplspecies/3849
Critical habitats
Potential effects to critical halbitat(s) in this location must be analyzed along with the endangered
species themselves.
NO) %illoe
THERE ARE NO CRITICAL HABITATS AT THIS LOCATION.
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Migratory birds
Certain birds are protected under the Migratory Bird Treaty Act! and the Bald and Golden Eagle
Protection Act2-.
Any person or organization who plans or conducts activities that may result in impacts to migratory
birds, eagles, and their habitats should follow appropriate regulations and consider implementing
appropriate conservation measures, as described below.
1. The Migratory Birds Treaty Act of 1918.
2. The Bald and Golden Eagle Protection Act of 1940.
Additional information can be found using the following links:
Birds of Conservation Concern http://www.fws.gov/birds/management/managed-species/
birds-of-conservation-concern.php
Measures for avoiding and minimizing impacts to birds
http://www.fws.gov/birds/management/project-assessment-tools-and-guidance/
conservation-measures.php
Nationwide conservation measures for birds
http://www.fws.gov/migratorybirds/pdf/management/nationwidestandardconservationmeasures.pdf
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11/6/2018
IPaC: Explore Location
THERE ARE NO MIGRATORY BIRDS OF CONSERVATION CONCERN EXPECTED TO OCCUR AT THIS LOCATION.
Tell me more about conservation measures I can implement to avoid or minimize impacts to migratory birds.
Nationwide Conservation Measures describes measures that can help avoid and minimize impacts to all birds at
any location year round. Implementation of these measures is particularly important when birds are most likely to
occur in the project area. When birds may be breeding in the area, identifying the locations of any active nests and
avoiding their destruction is a very helpful impact minimization measure. To see when birds are most likely to
occur and be breeding in your project area, view the Probability of Presence Summary. Additional measures and/or
permits may be advisable depending on the type of activity you are conducting and the type of infrastructure or
bird species present on your project site.
What does IPaC use to generate the migratory birds potentially occurring in my specified location?
The Migratory Bird Resource List is comprised of USFWS Birds of Conservation Concern (BCC) and other species
that may warrant special attention in your project location.
The migratory bird list generated for your project is derived from data provided by the Avian Knowledge Network
(AKN). The AKN data is based on a growing collection of survey, banding, and citizen science datasets and is
queried and filtered to return a list of those birds reported as occurring in the 14km grid ceII(s) which your project
intersects, and that have been identified as warranting special attention because they are a BCC species in that
area, an eagle (Eagle Act requirements may apply), or a species that has a particular vulnerability to offshore
activities or development.
Again, the Migratory Bird Resource list includes only a subset of birds that may occur in your project area. It is not
representative of all birds that may occur in your project area. To get a list of all birds potentially present in your
project area, please visit the E -bird Explore Data Tool.
�I
What does IPaC use to generate the probability of prese rice graphs for the migratory birds potentially
occurring in my specified location?
The probability of presence graphs associated with your migratory bird list are based on data provided by the
Avian Knowledge Network (AKN). This data is derived from a growing collection of survey,, banding, and citizen
science datasets .
Probability of presence data is continuously being updated as new and better information becomes available. To
learn more about how the probability of presence graphs are produced and haw to interpret them, go the
Probability of Presence Summary and then click on the "Tell me about these graphs" link.
How do I know if a bird is breeding, wintering, migrating or present year-round in my project area?
To see what part of a particular bird's range your project area falls Within (i.e. breeding, wintering, migrating or
year-round), you may refer to the following resources: The Cornell Lab of Ornithology All About Birds Bird Guide, or
(if you are unsuccessful in locating the bird of interest there), the Cornell Lab of Ornithology Neotropical Birds
guide. If a bird on your migratory bird species list has a breeding season associated with it, if that bird does occur
in your project area, there may be nests present at some point within the timeframe specified. If "Breeds
elsewhere" is indicated, then the bird likely does not breed in your project area.
What are the levels of concern for migratory birds?
Migratory birds delivered through IPaC fall into the following distinct categories of concern:
1. "BCC Rangewide" birds are Birds of Conservation Concern (BCC) that are of concern throughout their range
anywhere within the USA (including Hawaii, the Pacific Islands, Puerto Rico, and the Virgin Islands);
2. "BCC - BCR" birds are BCCs that are of concern only in particular Bird Conservation Regions (BCRs) in the
continental USA; and
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11/6/2018
IPaC: Explore Location
3. "Non -BCC - Vulnerable" birds are not BCC species in your project area, but appear on your list either because of
the Eagle Act requirements (for eagles) or (for non -eagles) potential susceptibilities in offshore areas from
certain types of development or activities (e.g. offshore energy development or longline fishing).
Although it is important to try to avoid and minimize impacts to all birds, efforts should be made, in particular, to
avoid and minimize impacts to the birds on this list, especially eagles and BCC species of rangewide concern. For
more information on conservation measures you can implement to help avoid and minimize migratory bird
impacts and requirements for eagles, please see the FAQs for these topics.
Details about birds that are potentially affected by offshore projects
For additional details about the relative occurrence and abundance of both individual bird species and groups of
bird species within your project area off the Atlantic Coast, please visit the Northeast Ocean Data Portal. The Portal
also offers data and information about other taxa besides birds that may be helpful to you in your project review.
Alternately, you may download the bird model results files underlying the portal maps through the NOAA NCCOS
Integrative Statistical Modeling and Predictive Mapping of Marine Bird Distributions and Abundance on the Atlantic
Outer Continental Shelf project webpage.
040%LS
Bird tracking data can also provide additional details about occurrence and habitat use throughout the year,
including migration. Models relying on survey data may not include this information. For additional information on
marine bird tracking data, see the Diving bird Study_ and the nanotag studies or contact Caleb Spiegel or Pam
Loring.
What if I have eagles on my list?
If your project has the potential to disturb or kill eagles, you may need to obtain a permit to avoid violating the
Eagle Act should such impacts occur.
Proper Interpretation and Use of Your Migratory Bird Report
The migratory bird list generated is not a list of all birds in your project area, only a subset of birds of priority
concern. To learn more about how your list is generated, and see options for identifying what other birds may be
in your project area, please see the FAQ "What does IPaC use to generate the migratory birds potentially occurring
in my specified location". Please be aware this report provides the "probability of presence" of birds within the 10
km grid cells) that overlap your project; not your exact project footprint. On the graphs provided, please also look
carefully at the survey effort (indicated by the black vertical bar) and for the existence of the "no data" indicator (a
red horizontal bar). A high survey effort is the key component. If the survey effort is high, then the probability of
presence scare can be viewed as more dependable. In contrast, a low survey effort bar or no data bar means a lack
of data and, therefore, a lack of certainty about presence of the species. This list is not perfect; it is simply a starting
point for identifying what birds of concern have the potential to be in your project area, when they might be there,
and if they might be breeding (which means nests might be present). The list helps you know what to look for to
confirm presence, and helps guide you in knowing when to implement conservation measures to avoid or
minimize potential impacts from your project activities, should presence be confirmed. To learn more about
conservation measures, visit the FAQ "Tell me about conservation measures I can implement to avoid or minimize
impacts to migratory birds" at the bottom of your migratory bird trust resources page.
Facilities
National Wildlife Refuge lands
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11/6/2018
IPaC: Explore Location
Any activity proposed on lands managed by the National Wildlife Refuge system must undergo a
'Compatibility Determination' conducted by the Refuge. Please contact the individual Refuges to
discuss any questions or concerns.
THERE ARE NO REFUGE LANDS AT THIS LOCATION.
Fish hatcheries
THERE ARE NO FISH HATCHERIES AT THIS LOCATION.
Wetlands in the National Wetlands inventory
Impacts to NWI wetlands and other aquatic habitats may be subject to regulation under Section 404
of the Clean Water Act, or other State/Federal statutes.
For more information please contact the Regulatory Program of the local U.S. Army Corps of
Engineers District. \1)
WETLAND INFORMATION IS NOT AVAILABLE ATTHIS TIME
This can happen when the National Wetlands Inventory (NWI) map service is unavailable, or for very
large projects that intersect many wetland areas. Try again, or visit the NWI map to view wetlands at
this location.
Data limitations
A"
The Service's objeetive of mapping wetlands and deepwater habitats is to produce reconnaissance level
information on the location, type and size of these resources. The maps are prepared from the analysis of high
altitude imagery. Wetlands are identified based on vegetation, visible hydrology and geography. A margin of error
is inherent in the use of imagery, thus, detailed on -the -ground inspection of any particular site may result in
revision of the wetland boundaries or classification established through image analysis.
The accuracy of image interpretation depends on the quality of the imagery, the experience of the image analysts,
the amount and quality of the collateral data and the amount of ground truth verification work conducted.
Metadata should be consulted to determine the date of the source imagery used and any mapping problems.
Wetlands or other mapped features may have changed since the date of the imagery or field work. There may be
occasional differences in polygon boundaries or classifications between the information depicted on the map and
the actual conditions on site.
Data exclusions
Certain wetland habitats are excluded from the National mapping program because of the limitations of aerial
imagery as the primary data source used to detect wetlands. These habitats include seagrasses or submerged
aquatic vegetation that are found in the intertidal and subtidal zones of estuaries and nearshore coastal waters.
Some deepwater reef communities (coral or tuberficid worm reefs) have also been excluded from the inventory.
These habitats, because of their depth, go undetected by aerial imagery.
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11/6/2018
Data precautions
IPaC: Explore Location
Federal, state, and local regulatory agencies with jurisdiction over wetlands may define and describe wetlands in a
different manner than that used in this inventory. There is no attempt, in either the design or products of this
inventory, to define the limits of proprietary jurisdiction of any Federal, state, or local government or to establish
the geographical scope of the regulatory programs of government agencies. Persons intending to engage in
activities involving modifications within or adjacent to wetland areas should seek the advice of appropriate federal,
state, or local agencies concerning specified agency regulatory programs and proprietary jurisdictions that may
affect such activities.
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https://ecos.fws.gov/ipac/location/MRW16CW4MNCFXC25A4ZI14VZVI/resources 7/7

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November 6, 2018
❑ Project Boundary
❑ Suffered Project Boundary
J Managed Area (MAREA)
M
1:39,352
0 0.325 065 1.3 mi
0 0.5 1 2 km
Sources: Esri, HERE, Garmn. Inrermap, inu—nt P Corp., GE6= uSGS,
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the GIS User Com pity

ENG Form 4345 Supplemental Document
Piedmont Lithium
SAW -2018-01129
Appendix D:
Block 25. Adjoining Property Owners

Piedmont Lithium Project
Block 25 - Adjoining Property Owners
Individual Permit (SAW -2018-01129)
Adjoining Parcel Ownership
Parcel #
Parcel
Property
Mailing
on Figure
Identification
Index
Deed
Deed
Current Owners
Mailing Address
Mailing City
Zip
Property Address
12
Number (PID)
Number (PIN)
Book
Page
Code
1
157896
3610-98-9877
2483
560
MILLER
910 ADERHOLDT RD
LINCOLNTON
28092
910 ADERHOLDT RD
DONALD L
2
157874
3610-58-7192
2877
673
MILLER TODD
975 HEPHZIBAH
CROUSE
28033
975 HEPHZIBAH
LEWIS
CHURCH RD
CHURCH RD
3
157877
3610-79-3295
4487
1397
KISERBRUCERUCE
210 WILL KISER RD
CROUSE
28033
210 WILL KISER RD
CLONINGER
4
159148
3610-36-1924
2541
859
LOU
910 DONTIS DRIVE
LINCOLNTON
28092
ST MARKS CHURCH RD
ROBINSON
5
159151
3610-34-4975
016E
1215
CAMPBELL
920 SAINT MARKS
CHERRYVILLE
28021
ST MARK'S CHURCH RD
KENAN
CHURCH RD
PEARSON
6
159203
3620-06-6325
4075
396
MICHAEL E
705 ADERHOLDT RD
LINCOLNTON
28092
705 ADERHOLDT RD
MAUNEY
7
159206
3620-05-6701
4431
1371
JEANETTE B
105 CENTRAL PL
SHELBY
28152
649 ADERHOLDT RD
LIFE ESTATE
8
159621
3610-52-4344
4350
802
JONES
2815 S YORK RD
GASTONIA
28052
684 WHITESIDES RD
MELISSA ANN
MAUNEY
9
159208
3620-05-5979
3466
426
RONALD
663 ADERHOLDT RD
LINCOLNTON
28092
663 ADERHOLDT RD
JAMES
HASTINGS
10
159644
3610-90-6974
1957
161
DONALD
PO BOX 38
CHIMNEY ROCK
28720
230 HASTINGS RD
BARRY
11
160762
3610-90-5504
3448
983
K & P RENTALS
PO BOX 1741
GASTONIA
28053
233 HASTINGS RD
12
157897
3620-08-1619
3691
850
RICHARD
997 CALLAWAY RD
LINCOLNTON
28092
906 ADERHOLDT RD
RONALD W
SELLERS
13
157899
3620-08-3475
4818
1386
PHILLIP
328 PINE AVE
CHERRYVILLE
28021
104 BITTERSWEET LN
WAYNE
14
157901
3620-08-4367
4455
1628
RHY LE
822 ADERHOLDT RD
LINCOLNTON
28092
822 ADERHOLDT RD
DAVID
15
157985
3610-38-7144
4487
1400
KISERBRUCERUCE
210 WILL KISER RD
CROUSE
28033
HEPHZIBAH CHURCH
RD
16
159623
3610-51-8451
520
214
WHITESIDES
1507 PINEHURST
HIGH POINT
27262
WHITESIDES RD
ELIZABETH
DR
17
160683
3610-60-7137
3900
117
BELL R LOCKE
PO BOX 481
GASTONIA
28053
WHITESIDES RD
18
160757
3519-99-5555
4820
2378
GEE KEVIN
1715 HEPHZIBAH
BESSEMER CITY
28016
1715 HEPHZIBAH
MARK
CHURCH RD
CHURCH RD
19
206528
3610-88-3383
4955
516
BENNETT
925 ADERHOLDT RD
LINCOLNTON
28092
ADERHOLDT RD
LINDA FRIDAY
Appendix D — Block 25 — Page 11

Piedmont Lithium Project
Block 25 - Adjoining Property Owners
Individual Permit (SAW -2018-01129)
Parcel #
Parcel
Property
Deed
Deed
Mailing
on Figure
Identification
Index
Current Owners
Mailing Address
Mailing City
Zip
Property Address
12
Number (PID)
Number (PIN)
Book
Page
Code
20
208719
3620-06-8405
4072
580
PEARSON
705 ADERHOLDT RD
LINCOLNTON
28092
ADERHOLDT RD
MICHAEL E
SOUTHERN
5577 FIVE KNOLLS
HEPHZIBAH CHURCH
21
211499
3610-58-4936
4191
38
GAINES LLC
DR
CHARLOTTE
28226
RD
22
218014
3519-98-1755
712
544
LINEBERGER
348 IKE LYNCH RD
DALLAS
28034
HEPHZIBAH CHURCH
FRED ERVIN
RD
23
218217
3519-79-8340
4469
1884
CRUNKLETON
170 FOREST
BESSEMER CITY
28016
170 FOREST
TIMOTHY E
DELLINGER RD
DELLINGER RD
LOEHR
150 FOREST
150 FOREST
24
218218
3519-89-2192
4923
209
CHRISTOPHER
DELLINGER RD
BESSEMER CITY
28016
DELLINGER RD
W
25
223136
3620-08-8201
1068
895
MAUNEY
1001 PHIFER RD
KINGS
28086
ADERHOLDT RD
MILDRED
MOUNTAIN
HUFFSTETLER
861 HEPHZIBAH
26
224400
3610-42-0672
4829
780
WANDA KISER
CHURCH RD
CROUSE
28033
WHITESIDES RD
27
224401
3610-43-0447
4859
1963
CARPENTER
2230 GASTON
LINCOLNTON
28092
WHITESIDES RD
DIANE K
WEBBS CHAPEL RD
28
225770
3620-00-1978
4894
570
HASTINGS
PO BOX 415
CHERRYVILLE
28021
210 HASTINGS RD
CALVIN R
29
204183
3620-01-2810
3824
564
MASON JAMES
1527 HEPHZIBAH
BESSEMER CITY
28016
1527 HEPHZIBAH
E
CH RD
CHURCH RD
MASON LENITA
30
204184
3620-02-5063
4596
510
H 1/3 &
1527 HEPHZIBAH
BESSEMER CITY
28016
1523 HEPHZIBAH
OTHERS
CHURCH RD
CHURCH RD
31
215160
3610-47-9983
4284
2163
REYNOLDS
1202 MIRROR LAKE
LINCOLNTON
28092
972 HEPHZIBAH
JEFFREY M
RD
CHURCH RD
CC BROWNING
3266 CHESTER
32
157886
3610-99-5098
2061
94
PROPERTIES
HIGHWAY
YORK
29745
ADERHOLDT RD
INC
33
157898
3620-08-2518
4424
417
RUIZ ISRAEL
902 ADERHOLDT RD
LINCOLNTON
28092
902 ADERHOLDT RD
34
159207
3620-04-9956
4326
2439
FARMER EDDIE
641 ADERHOLDT RD
LINCOLNTON
28092
641 ADERHOLDT RD
35
159211
3620-16-5952
4487
1403
KISERBRUCERUCE
210 WILL KISER RD
CROUSE
28033
ADERHOLDT RD
HASTINGS
36
207977
3620-23-4979
4113
959
FAMILY FARM
PO BOX 550282
GASTONIA
28055
611 ADERHOLDT RD
LLC
37
208720
3620-06-7617
4162
837
HALL
715 ADERHOLDT RD
LINCOLNTON
28092
715 ADERHOLDT RD
KIMBERLY M
SOUTHERN
5577 FIVE KNOLLS
38
211500
3610-69-0040
4424
1623
GAINES LLC
DR
CHARLOTTE
28226
WILL KISER RD
4344
ST MARKS
1203 ST MARKS
39
214150
3610-43-9502
1387
EVANGELICAL
CHERRYVILLE
28021
WHITESIDES RD
0
LUTH CH
CHURCH RD
Appendix D — Block 25 — Page 12

Piedmont Lithium Project
Block 25 - Adjoining Property Owners
Individual Permit (SAW -2018-01129)
Parcel #
Parcel
Property
Deed
Deed
Mailing
on Figure
Identification
Index
Current Owners
Mailing Address
Mailing City
Zip
Property Address
12
Number (PID)
Number (PIN)
Book
Page
Code
40
217859
3519-79-0545
2383
381
SUMMEY
256 FOREST
BESSEMER CITY
28016
256 FOREST
RONNIE J
DELLINGER RD
DELLINGER RD
SUMMEY
256 FOREST
FOREST DELLINGER
41
217863
3519-79-4409
4459
1341
RONNIE J
DELLINGER RD
BESSEMER CITY
28016
RD
42
221723
3610-61-6428
4701
1791
BELL R LOCKE
534 WHITESIDES RD
CROUSE
28033
WHITESIDES RD
43
223454
3610-90-1364
4789
459
HIGH JEFFREY
5010 FAIRVIEW
LINCOLNTON
28092
1631 HEPHZIBAH
H
CHURCH RD
CHURCH RD
Appendix D — Block 25 — Page 13