20190035 Ver 1_More Info Requested_20190219

ROY COOPER
Governor
MICHAEL S.REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
February 19, 2019
DWR # 20190035
Gaston County
Piedmont Lithium Inc
Attn: Mr. Patrick Brindle
5706 Dallas-Cherryville Highway
Bessemer City NC 28016
Subject: REQUEST FOR ADDITIONAL INFORMATION
Piedmont Lithium Project
Dear Mr. Brindle:
On January 4, 2019, the Division of Water Resources — Water Quality Programs (Division)
received your application dated December 27, 2018, requesting a 401 Individual Water Quality
Certification from the Division for your project. The Division has determined that your
application is incomplete and cannot be processed. The application is on -hold until all of the
following information is received:
1. If the U.S. Army Corps of Engineers requests a response to any comments received as a
result of the Public Notice, please provide the Division with a copy of your response to
the USACE. [15A NCAC 02H .0502(c)]
2. A complete review of the project cannot be conducted until the U.S. Army Corps of
Engineers has verified all stream and wetland locations for the entire project. [15A
NCAC 02H .0502(a)(7)]
3. DWR mitigation requirements cannot be determined until a site verification of
intermittent and perennial stream calls occurs. Please contact Alan Johnson at 704-235-
2200 to schedule a verification. [15A NCAC 02H .0506(h) and S.L. 2017-10]
4. Provide a site-specific detailed engineering plan, profile view, and cross-section of all
proposed impact areas. These drawings must include details regarding proposed final
contours for fill/cut areas, stream alignment in relation to pipe alignment, pipe slope,
pipe burial, dissipater pad requirements, temporary dewatering design and impacts,
adjacent sediment and erosion control measures, and plans for restoration of any
temporarily impacted areas. [15A NCAC 02H .0502(b)]
North Carolina Department of Environmental Quality I Division of Water Resources
_E �� 512 North Salisbury Street 1 1617 Mail Service Center Raleigh, North Carolina 27699-1617
�� 919.707.9000

Piedmont Lithium Inc
D W R# 20190035
Request for Additional Information
Page 2 of 3
5. Provide the results of the groundwater monitoring and modeling as mentioned in
Section 6.4.3 to document the statement "groundwater supply in the surrounding area
is not expected to increase or decrease due to activities at the proposed project site'.
[15A NCAC 02H .0506(b)(4)]
6. Clarify how stormwater runoff will be managed throughout the mine, including but not
limited to stormwater from haul roads, concentrator facility, and waste rock areas.
7. Please explain how the rock spoil rock areas have been designed to protect downstream
water quality (e.g. total height and stability, total acreages proposed to be "unstable" at
one time, etc.)
8. Provide documentation and/or a detailed technical analysis that shows that there will
be no secondary hydrological impacts to any of the retained stream features as a result
of pit development. [15A NCAC 02H .0506(b)(4)]
9. The application states that "the proposed discharge of dredge and fill material should
not cause increased chemical contamination levels within the aquatic ecosystem."
Please provide a technical basis for this statement, specifically addressing potential
changes that may occur to the material through the excavation and/or concentration
processes and whether they may increase the potential for chemical releases into the
environment from the waste rock. [15A NCAC 02H .0506(b)(4)]
Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested
information for the proper consideration of the application. Please respond in writing within 30
calendar days of receipt of this letter by sending one (1) copy of all of the above requested
information to the 401 & Buffer Permitting Branch, 1617 Mail Service Center, Raleigh, INC
27699-1617 -OR- by submitting all of the above requested information through this
link: https://edocs.deg.nc.gov/Forms/Supplemental-Information-Form (note the DWR#
requested on the link is referenced above).
If all of the requested information is not received within 30 calendar days of receipt of this
letter, the Division will be unable to approve the application and it will be returned. The return
of this project will necessitate reapplication to the Division for approval, including a complete
application package and the appropriate fee.
Please be aware that you have no authorization under the Water Quality Certification Rules for
this activity and any work done within waters of the state may be a violation of North Carolina
General Statutes and Administrative Code.

Piedmont Lithium Inc
DWR# 20190035
Request for Additional Information
Page 3 of 3
Contact Sue Homewood at 336-776-9693 or Sue. [e-mail] if you have any
questions or concerns.
Sincerely,
koafl
Karen Higgins, Supervisor
401 & Buffer Permitting Branch
cc: Kelly Thames, HDR (via email)
David Shaeffer, USACE Charlotte Regulatory Field Office (via email)
Olivia Munzer, NCWRC (via email)
Byron Hamstead, USFS (via email)
DWR MRO 401 files
DWR 401 & Buffer Permitting Unit
Filename: 20190035PiedmontLithium(Gaston)_401_IC_HOLD