20190035 Ver 1_Meeting Minutes_20181108

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Meeting Minutes
Project: Piedmont Lithium
Subject: Section 404 Individual Permit Pre -Application Agency Meeting
Date: Thursday, November 08, 2018
Location: HDR Charlotte Offices (9th Floor, Henningson Conference Room); Phone Conference
Attendees: Aaalicant Team
Patrick Brindle (Piedmont Lithium, Applicant)
Kelly Thames (HDR, Environmental Permitting)
Thomas Blackwell (HDR, Environmental Permitting)
Eric Mularski (HDR, Environmental)
Mark Filardi (HDR, Groundwater)
Brad Taylor (HDR, Transportation)
Chris Scott (Marshall Miller, Mine Design)
Brittany Johns (HDR, Administrative Assistant)
By Phone:
Roll Call and Safety Minutf
Agency Representatives
David Shaeffer (USACE)
Sue Homewood (DENR - DWR)
Alan Johnson (DENR - DWR)
Olivia Munzer (NCWRC)
Zahid Kahn (DENR — Land Quality)
Todd Bowers (EPA)
Allen Ratzlaff (USFWS)
Lindsay Ferrante (SHPO)
Kelly Thames provided roll call and a Safety Minute. She provided emergency exit and AED
location information and assigned Brad Taylor responsibility of retrieving the AED, Mark Filardi
responsibility of calling 911 and herself to perform First Aid/CPR in the event of an emergency.
2. Project Introduction & bacKgrount
• Patrick Brindle, with detail, explained who Piedmont Lithium is, their background, what
they do and the role their company plays in current technology, and will play in future
technology.
• Patrick explained that the Piedmont Lithium project is in the heart of auto alley in the
Mid -Atlantic area and they are one of only five listed lithium equities. He went on to
explain that North Carolina is the number one state for lithium business [because of the
Carolina Tin-Spodumene Belt [TSB]], and as such, Gaston and Cleveland counties are
the two primary locations for exploratory drilling. Patrick also offered that the primary
sources of lithium outside the United States (US) are Chile and Argentina.
• He explained that the proposed site location is preferred because there is enough lithium
[in mineralized spodumene] to be commercially developed. There is the opportunity
[within preferred alternative] to produce 16.2 million tonnes high quality lithium oxide.
That said, the size of this project is at the right point to identify as a "Significant Project"
globally.
• Patrick went on to explain the cost-effectiveness of additional options. He mentioned that
spodumene-based [lithium] projects offer the lowest cost, while brine -based [lithium]
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projects are a little less cost-effective [and overall produce a lesser quality lithium
chemical], and finally, that China [lithium] conversion projects are the highest cost
option.
• He provided some specific cost details, and discussed where lithium -containing sub -
saline brines would come from, if that mining option were utilized.
• He also discussed the positive impact of byproducts that would be produced [from hard
rock mining, i.e. feldspar, mica] and what purposes the byproducts can be used for
today. Purposes such as low -iron glass, ceramics (or a flux for ceramic production),
marine paint, and hundreds of other every day applications for these materials.
• He then concluded with the importance of lithium in US and how vehicular transportation
has already started to shift, and will continue to shift away from internal combustion
engines.
3. Project Site Layout: Preferred Concept
Kelly began by showing the preferred alternative and preferred site layout on the screen.
a. Approximate Impacts
Currently, approximately 6,000 LF of stream impact, 2 acres of wetland impacts, and 0.5
impacts of pond impacts are estimated.
b. Mitigation
Currently, no private mitigation banks are located within the project's hydrologic unit
code [South Fork Catawba 03050102]; however, as of 11/7/18, the Division of Mitigation
Services In -Lieu Fee Program has enough credits in that HUC to cover the estimated
impacts, assuming a 1:1 ratio.
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Kelly reviewed the project in greater detail, illustrating the IP Boundary as depicted in the
preferred alternative. She explained that in regards to the IP Boundary, land option agreements
are still being finalized for access, which is why there are smaller areas within the IP Boundary
for the jurisdictional delineation and threatened and endangered species boundaries.
a. Jurisdictional Delineation
Kelly explained the jurisdictional delineations that have been completed to date;
explaining that she has already completed two site visits [with the USACE] for
verification of JD boundaries within the current JD verification area. Another JD
submission will occur once land option agreements are finalized for the remainder of the
land within the IP boundary.
b. Threatened and Endangered Species
Kelly discussed that a threatened and endangered (T&E) species survey has been
completed within a smaller boundary within the IP boundary [smaller boundary due to
land options being finalized for access].
i. To date, HDR has identified suitable habitat for dwarf -flowered heartleaf and was
able to survey this identified habitat during the appropriate flowering window. The
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survey results concluded that the species is not present. Additionally, there is no
suitable habitat for Schweinitz's sunflower, Michaux's sumac, bald eagle, or bog
turtle. There is potential roosting habitat for the northern long-eared bat, but no
hibernacula within the site. Additionally, there are no hibernacula or known
maternity roost trees within 0.5 miles of the site.
ii. These results are currently under internal QAQC and will be sent to USFWS for
comment/concurrence soon.
iii. Additional surveys will commence once land option agreements are finalized and
updates will be sent to USFWS at that time.
c. Groundwater Monitoring and Aquifer Testing
i. Mark Filardi explained that groundwater monitoring wells have been installed at
strategic locations within the site to obtain a pre -mining groundwater baseline. He
also discussed that these wells will be monitored monthly. Also discussed was
where the water table sits and how it fluctuates.
ii. It was mentioned that this area has experienced two tropical storms [Florence
and Michael] recently.
iii. An aquifer test was also completed. One pumping well and four observation wells
(two shallow and two bedrock pumping wells) have been installed on site. The
results of this aquifer test are currently being processed. In order to place
additional pumping wells, we would have to drill down 500 feet for each well.
d. State Historic Preservation Office (SHPO) Coordination
Kelly discussed that HDR initiated coordination with SHPO in April 2018. She stated that
a cultural resources firm has been retained to conduct studies on the project to
commence this month [November].
e. Department of Transportation Coordination
Kelly mentioned that HDR (Brad Taylor) has begun coordination with NCDOT.
i. The project is proposing to abandon portions of Hephzibah Church Road and
Whitesides Road for project construction and project -related vehicle
transportation purposes.
ii. Coordination with NCDOT about what exactly will they require.
iii. Kelly stated that no residents will be isolated due to the proposed road
abandonments.
5. Open Discussion
a. Draft Purpose & Need
Kelly: The template/format of the Draft Purpose and Need document is part of a larger
USACE Environmental Assessment template provided by David Shaeffer (USACE).
David: The template is typically used to write environmental assessments.
Todd: I'm on board with the Purpose and Need, but do have a few comments regarding
the Alternative Analysis when we get to it. I realize that we are still only in the draft
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process, but I have already done a bit of desktop delineation myself, and have a few
comments. Some concerns are:
• The lack of internal road crossings. Currently there are no locations where
equipment and other materials can cross streams internal to the mine layout.
This needs further investigation and will require coordination with the NCDOT [for
Hephizbah Church Road and Whitesides Road - see NCDOT coordination bullet
above].
• Wetlands on site — we need more information on what's driving the hydrology of
these wetlands.
• The proposed site layout will be impacting headwater streams, which could
completely change the hydrology on site, and may change hydrology of wetlands
— those areas may not continue to be wetlands. Furthermore, what would be the
change in downstream, offsite hydrology as well?
He also mentioned that Dave Shaeffer has a good system for mitigating (in NC, [Division
of Mitigation Services]) and that there are more drainage features than that he expected.
He stated that those [headwater] systems leading to those rivers [Beaverdam and Little
Beaverdam Creeks] will be impacted and for mitigation purposes, he will be looking at
the how those impacts will impact hydrology [on-site and offsite].
Sue: Stated she had those same concerns (as Todd had addressed).
David: Validated that studies would be necessary regarding hydrology.
Kelly: Mentioned that there are no private banks in the HUC for this project, but
currently there are credits available for the In -Lieu Fee program (Division of Mitigation
Services).
David: Addressed a statement regarding "medium and low quality" in the Purpose and
Need draft that needs to be further explained and justified by Kelly — provide
documentation to that point.
Kelly: Explained what NCSAM/NCWAM are and how it pertains to this project.
• NCSAM/NCWAM are methodologies to determine quality of streams/wetlands
and can be used for determining mitigation ratios
Olivia: Stated that it seems like there are a lot of impacts regarding waste rock areas
and asked if there may be opportunities to purchase additional land to locate waste rock
areas elsewhere and possibly change the configuration of site layout.
Kelly: Responded with a couple factors that attribute to why we want to keep it the way
it is. For example, travel times, lower costs, offsite — money and property owners willing
to sell the land, etc.
Patrick: Stated that when we look at a zero impact — we would have to triple the
acreage to create the same waste storage.
David: Can you truck it [waste] offsite somewhere else? Is it reasonable to do that?
Would moving it to another location reduce impacts? Just something to think about.
Patrick: Fair comment. With it [waste] separated offsite, other properties will have
similar [JD] features. We have to consider that there would be more [large truck] traffic
and now there is a public safety aspect [from traffic standpoint]. Theoretically, if 160,000
lbs of concentrate is produced and waste is taken offsite to other waste areas, that's
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about 80-100 tons a year, which means we've increased truck traffic on the roads by
100.
If byproducts are not sold, they are disposed.
David: How will it [byproducts] be marketed?
Patrick: The aggregate market in this area is already saturated so it would be difficult to
enter that market at this time — over time we can market that material as the project
continues.
Chris: Explained that even if we trucked them [byproducts] off or sold them, we would
still have large amounts on site because they would be produced faster than we can sell
it off.
Patrick: Surface material and segregate material from mining operations and pit
operations - we don't want to keep it there [in the pit], want to get it out of the pit and get
it out of the way [to access the lithium bearing material].
David: Is it reasonable to take these offsite or can we take that option off the table? Is
all of that disposable?
Todd: You're mining with aggregate, so some of it has to go offsite. With every time you
move the spoil material you are driving up costs, pollution, etc., it's not cost effective.
David: Asked Zahid if it's reasonable to take it off site and if they have done that in the
past.
Zahid: Said it varies and then he elaborated on how and why it would vary depending
on the project.
Patrick: If we finished operations in the largest pit, then that becomes a candidate for
placement of waste.
David: Are there large spodumene percentages in that area [referenced the area slated
for the largest waste rock area in the northwest portion of the site]?
Patrick: We do a limited amount of condemnation drilling with the purpose of not
discovering lithium [so that the area would serve waste rock area].
Chris: Volumes of those [areas referenced in two previous comments] are not that
great, not much savings for having those byproducts either.
Olivia: How does that work?
Patrick: The ore body itself appears as dykes of varying thickness and from 1 meter
thick to 22-23 meters thick. It is contained in host rock (on our site, amphibolite — mostly
the waste rock).
C
Lithium containing Host rock ("country
pegmatite dyke — =spm.,.«. ,,o rock") depicted as
starts at surface and
hlue
continues at an
angle downward
(depicted as red
color)
tip.
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Chris: Explained how to mine host rock down to get the pegmatite dykes [lithium
bearing material]. The pit shell design is shaped like an upside down wedding cake ... that
includes safety walls and berms.
David: Where is that sorted? Is it sorted within the pit?
Sue: And all the sorting is happening right on this property?
Patrick: Sorting occurs at the concentrator (on site). There are three stages of crushing,
grinding, optical sorting, a series of floating, and a stage for iron separation and
byproduct separation.
Alan Johnson: A few questions:
• Aside from this project site, is this the only site available?
• Where else in the US can you find the spodumene in the quantities you want?
David: This information [Alan's point] needs to be included in the Purpose and Need
because there are other parts of the world that offer the quantities needed for this
project, we need to understand why are we not utilizing those sites. We need justification
as to why this site is the right one and not elsewhere.
Alan: Why not Alabama or Washington, because my understanding is that "local"
means in the USA. You have to tell me why this spot, why this area up front in the P&N.
Olivia: If there can be other spots that can be just as fruitful, why not look in other areas,
instead of using this spot just because it has already been mined and surveyed?
Patrick: Time, money, interaction with population; however, if you look at the TSB there
are places to be assembled.
Olivia: What are these other parcels?
Patrick: To be direct I think part of Piedmont's strategy is to build as significant size of
landholdings as possible within the Belt.
Alan: What do you mean by only hard rock mining?
Patrick: Explained hard rock mining.
David: We need an explanation as to why it is not reasonable or practical to use a place
outside the US. You need to help us gain an understanding of why you're not looking
internationally. Why not other places? And what about cost? You're betting on cost/price
going up?
Patrick: Forecast of low to high — from low end of market: a very small forecast in
market is a large forecast for lithium — we can take a stab at that — there are a lot of
other projects in the world that would like to come into market.
Alan: I'm concerned about the site, where we mined. What are the siting criteria? Is the
DOT going to require you to replace the road?
Kelly: Currently we are not planning on rebuilding a road. There are other routes for
residents to access main roads.
Patrick: We don't know yet what DOT will require us to do.
Sue: We NEED to know because it is part of this project — we need definitive answer
from DOT.
Alan: What about discharge water?
Patrick: all internal drainage within pits will be discharged [and treated accordingly per
NPDES].
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Alan: Are there potential contaminants that will be coming out?
Todd: Regarding discharges/groundwater what is the expected reactivity for the
potential runoff — any plans there?
Patrick: We have not completed that yet, we are working with mining team to get that to
determine the answer to that question.
Chris: It seems pretty negative (negative results) right now, but no definitive results at
the moment as we are still waiting on test results.
b. Draft Alternatives Analysis
David: What is the cost comparison for importing materials vs domestic supply?
Differentiate them please.
Kelly: Siting criteria would require the hard rock mine technology because it's the least
expensive and it's a well-documented process.
Alan: Please explain hard rock technology here. Alan then went on to offer other mining
options, such as subterranean mining.
Todd (to Alan): You're talking about mountain top mining? That's a lot of mine for a
little bit of rock.
Alan: Chris explained the mining procedure that this project would be using and why
other ways are not better or safe. Mining methods need to be included as justification.
Patrick: This particular rock [mineralized spodumene] is better as a surface mine [as
the dykes begin at the surface].
Alan: We need supporting documentation as why the TSB locality is the best place to be
doing this.
David: Provide info as to why an international supply is not a better, more cost effective
option and technology — put more info in the template. Why is it not reasonable and
practical to investigate other locations and options?
Sue: You jumped [into siting within the TSB] without giving us the information on how
you got there with this site location — we need you to explain further how you determined
that this was the best site.
David: You also need to support the information regarding minimum property size for
operation for lithium hard rock mining. We need justification on why the site is this large.
Olivia: Maybe we should try a new configuration. Why is it important to have everything
the way it is, why can't we just shuffle it so there are fewer impacts?
David: Explained a bit about why the configuration is the way it is —
pit4con centrator4waste
Thomas: The current configuration also has to do with the surrounding land owners.
Chris: We don't have any drill data on that land (outside of the configuration), so we
don't know what's there.
Patrick: For the non -pit portions of the project, we can start by saying, if the belt is
defined as "this" we will exclude anything from the belt because we don't want to
eliminate the future opportunities to drill by placing tons of waste rock in potential future
drill areas.
Olivia: That would be a good explanation as to why we cannot reconfigure.
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Patrick: Preferred alternative — we have reason to believe that the areas [pit shell] in
the preferred alternative area are shallow, relatively. Other work that we've done
includes lengthy soiling samples and surveys to hone in on other potential drill
prospects. The whole of our exploration has been Gaston County — that is where we
have rights and access.
We have done road surveys to the extent that we have permission to walk on landowner
property but we cannot go further than that at this point. There are prospective targets in
Lincoln County. As you go north there are opportunities but they are more complex
(smaller land area, the Belt is narrower and therefore less likely to have large deposits).
Patrick: Once the resource was known to exist, we thought we could begin
conversations with surrounding land owners — some are interested in long-term revenue.
Thomas: Further explained why other alternatives were taken off the table because the
land was not available because the landowner was already in discussion with a
competitor.
David: Obviously your competitor is not going to sell the Albemarle mine [in reference to
this mine being an offsite alternative.
Olivia: Are you aware that the [adjacent] parcel is owned by Catawba Land
Conservancy?
Patrick: We are aware and have initiated conversation with Catawba Land
Conservancy.
David: Do we really need to go into a lot of detail because there is nothing particularly
atypical about this site [all other things being equal in Piedmont/TSB]?
Sue: Can we discuss not piecing things together so much and have more of a core
area? [in reference to an adjacent larger parcel area].
Patrick: We've been talking to Hastings Farm Trust for two years [in reference to the
parcel Sue referenced].
David: I don't think we need them to go into a lot of detail with a new site like this. This
alternative is to develop a new mine on a new site. An offsite alternative?
Kelly: If you look at the TSB there are very few large land holdings (land parcels)
remaining and it is difficult to assemble smaller parcels together. Any other parcels with
the same size land [or larger] are discussed as offsite alternatives.
Alan: Is everything within the preferred alternative is owned already?
Patrick: No, it is all option only.
David: Provided some notes to Kelly: combine siting criteria of F with C in analysis,
Criteria in G can provide some of the documentation needed in D. I will provide
comments later to Kelly. How much land do you need to get it out and what size
operation is a feasible mining operation?
Thomas: Did we make it clear in there to explain that you need to have a certain
amount of material in there in order to get the investment?
David: That's always tricky because we always try to look at it as far as costs of similar
mining operations.
Patrick: It's hard for us. We have a certain preferred alternative boundary. It has
several tons in it and with future drilling on the same property — how many acres equals
a 20 yr project life [rhetorical question, 20 years is known as standard mine life]?
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He also mentioned the quarry in distance to market.
David: That's a good driver, because one concern is always proximity to market and
because your market is the whole US, that is not a problem.
David, Kelly and Sue: Discussed desktop analysis using only NHD and NWI layers to
compare the preferred alternative to the offsite alternatives from an environmental
impact perspective.
Reached noon — several people [Mark Filardi, Brad Taylor Zahid Kahn] left the meeting.
Sue: Suggested comparing preferred alternative to offsite alternatives on an equal level.
Kelly: Explained the preferred site layout and how she came to the approximate impact
numbers using a mix of delineation and desktop analysis.
Patrick and Todd left at 12:10 PM.
Sue: In order to issue the permit I need to have the full explanation of comparison on
equal level. We only have two on-site alternatives. We have a "no impact" alternative
and still have a waste disposal issue. That's the reason there are only two (alternatives),
but any alternative is more off-site waste. Another on-site option is to combine two of the
pit shells and impact a stream [perennial stream that originates offsite] — this would
remove the stream and use that for waste disposal, but would have to take the entire
stream all the way up and around the pit. It's not the most reasonable alternative.
Chris: We don't have any drilling up there so we really don't know if it's a preferred
location for mineralized spodumene [in reference to northwest waste rock area]. What
we have now [the pit shell] is based on the drill data. We wanted to try to avoid the draw
that goes east (perennial stream that originates off site) because it is something we CAN
avoid.
David: I have concerns about only having two on-site options — it's either "no impact" or
your preferred site layout.
Chris: There are four different alternatives within the site that we can consider/present.
(Let's) assume we stay out of the delineated stream in the middle — keep waste out.
Preferred layout, no -impact, combine pit shell to impact perennial stream, and pull back
a waste area to avoid a stream.
Thomas: Explained the streams on the preferred site layout and why certain streams
were avoided.
A potentially practicable alternative is to avoid the middle stream.
Chris left the meeting at 12:30 PM.
David: Suggested it is necessary to include more than two [on-site] options.
Kelly: We will include a worse option.
David: Reviewed more comments such as: 5.2.2 offsite alternatives - please include a
map of offsite alternatives relative to each other. 5.2.1 - we need to understand why
importing raw materials is not reasonable.
Thomas: Is it also important to include the importance of lithium?
Then cost effectiveness of importing and specifically choosing the TSB was discussed.
David and Thomas agreed that there is a global demand for lithium and that the TSB
will be developed at some point anyway whether for domestic use or export.
Alan: But the primary market would be US right?
Thomas: Right.
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Olivia: FYI, there is an occurrence of seagreen darter in Beaverdam Creek downstream
of this project. There is also an undescribed crayfish in Beaverdam creek and several
aquatic mussels our aquatic biologist are interested in. Our aquatic folks would
potentially like to survey Beaverdam Creek. She is unsure of the details.
Olivia and Kelly to touch base about this further.
Kelly: There are no impacts (discharge of fill material) to Beaverdam or Little
Beaverdam Creeks.
Thomas: Said that on this site open mining was conducted in the 1940s, but we have
not seen anything that looks like old mining [shafts or pits in reference to being potential
bat habitat], that serves as potential hibernacula for northern long eared bat, but there
are definitely some old spoil areas.
Olivia: Stated that because of decline of local bats, there will likely be some kind of
restrictions tree clearing. She also was interested in talking to Piedmont Lithium about
using a waste area to construct a hibernacula during reclamation in the future.
6. SLUpb ruiwcaru caiiu i i<<ielinu
• Provide more/better justification as to why this specific area is the best option for the
project site (international vs domestic cost drivers, TSB documentation)
• Complete all necessary surveys/testing and provide necessary results.
• Include a more robust on-site alternatives discussion to include additional on-site
alternatives.
• Discuss what will happen with waste and stormwater runoff.
o Relocating the waste materials to an offsite location
o Repurposing waste materials for internal reuse
o Selling waste materials that have been or can be repurposed
• Include a (larger) map of offsite alternatives relative to each other (5.2.2)
• Justify in 5.2.1 why importing materials is not reasonable.
• Olivia and Kelly to touch base about what her aquatic biologist will want.
• Need to know requirements of NCDOT for road abandonment.
• Kelly requested that everyone send her additional comments as applicable.
• HDR is aiming to submit the IP by the end of this calendar year.
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