20190035 Ver 1_NC WRC Comments_20190218

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
MEMORANDUM
TO: Kelly Thames
HDR, Inc.
FROM: Olivia Munzer, Western Piedmont Coordinator
Habitat Conservation
DATE: 18 February 2019
SUBJECT: Individual Permit Application for Piedmont Lithium Mine Project in Bessemer City,
Gaston County; USACE Action ID: SAW -2018-01129; DEQ Project No. 20190035.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
document. Comments are provided in accordance with provisions of the Clean Water Act of 1977 (as
amended) and Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e).
HDR, Inc., on behalf of Piedmont Lithium Inc., has submitted an Individual Permit (IP) application for
the proposed Piedmont Lithium Mine centered around 1501 Hephzibah Church Road in Bessemer City,
Gaston County, North Carolina. The approximately 971 -acre (ac) hard rock lithium mine would include
the construction of a 200 -ac open pit, a 145 -ac waste rock area, a concentrator plant site, access roads, and
applicable National Pollutant Discharge and Elimination System best management practices (BMP).
Little Beaverdam Creek, Beaverdam Creek, and their unnamed tributaries in the Catawba River basin
flow through the proposed site. The pit shell areas will impact 1,263 linear feet (If) of perennial stream
channel, 4,547.5 if of intermittent stream channel, 0.14 ac of wetlands, and 0.16 ac of ponds. Internal
access road stream crossing will impact 178 if of perennial stream channel and a stormwater BMP will
impact 55 if of perennial channel.
We have records for the dwarf -flowered heartleaf (Hexastylis naniflora; Federal Threatened, State
Threatened), bigleaf magnolia (Magnolia macrophylla; State Threatened), bog turtle (Glyptemys
muhlenbergii; Federal Threatened Due to Similarity of Appearance; State Threatened), Virginia
spiderwort (Tradescantia virginiana; State Threatened), dwarf threetooth (Triodopsis fulciden; State
Special Concern), and bald eagle (Haliaeetus leucocephalus; State Threatened), which is protected by the
federal Bald and Eagle Protection Act, in the vicinity of the site. State significantly rare species found in
the area include seagreen darter (Etheostoma thalassinum), Carolina foothills crayfish (Cambarus johni),
striate button (Mesomphix pilsbryi), glade milkvine (Matelea decipiends), and Georgia holly (Ilex
longipes). Additionally, an undescribed crayfish occurs in Beaverdam Creek downstream of the project,
Mailing Address: Habitat Conservation Division • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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USACE Action ID: SAW -2018-01129
and several state -listed aquatic mussels may occur in or downstream of the site. HDR conducted surveys
for federally -protected species and none were observed within the proposed mine site. The lack of
records from the site does not imply or confirm the absence of state -listed species. An on-site survey is
the only definitive means to determine if the proposed project would impact rare, threatened, or
endangered species. Additionally, the Eaker Farm Catawba Land Conservancy Easement occurs adjacent
to the proposed site.
We have concerns on the impacts of this project on aquatic and terrestrial wildlife resources. Based upon
the Pre -Application Agency Meeting and IP, we offer the following recommendations minimize impacts
to aquatic and terrestrial wildlife resources.
1. We recommend surveys for state -listed mussel and crayfish species within and downstream of the
site to determine if relocations are needed. Please contact W. Thomas Russ, the Foothills Aquatic
Wildlife Diversity Research Coordinator, at 828-659-3324 or [e-mail].
2. We recommend a minimum 100 -foot undisturbed buffer for perennial streams and a 50 -foot
undisturbed buffer for intermittent streams and wetlands.
3. The applicant should avoid the removal of large trees at the edges of construction corridors. Due
to the decline in bat populations, tees should not be removed during the maternity roosting season
for bats (May 15 — August 15). Also, clearing of vegetation should be avoided during the
migratory bird nesting season, roughly March to August.
4. Incorporate the following elements into erosion and sediment control plans: minimize clearing
and grading, protect waterways, phase construction for larger construction sites (>25 acres),
stabilize soils as rapidly as possible (<2 weeks), protect steep slopes, establish appropriate
perimeter controls, employ advanced settling devices, implement a certified contractors program,
and regularly inspect erosion control measures.
5. Non-native plants should be removed from the seeding schedule. Avoid using Bermudagrass,
redtop, tall fescue, and lespedeza, which are invasive and/or non-native and provide little benefit
to wildlife. Consider an alternative mix of red clover, creeping red fescue, and a grain, such as
oats, wheat, or rye. Specifically, this project would be ideal for planting native, wildflower seed
mixes that will create pollinator habitat within the reclaimed areas. Pollinators are some insects
(i.e., bees, moths, and butterflies) and birds that play an important role in the reproduction of
flowering plants, which produce many fruits and vegetables. Habitat loss, disease, and other
enviromnental changes have caused a decline in pollinators. Please contact NCWRC for a list of
suitable native plants for reclamation.
6. Water discharges from the site should be proportional to the size of the receiving stream so the
hydrology of the stream is not altered, and all discharges should comply with NPDES permit
requirements. In particular, turbidity of the discharge should be maintained at or below the
permit requirement. High water discharge rates and turbidity can negatively impact aquatic
resources within and downstream of the site. Excessive silt and sediment loads can have
numerous detrimental effects on aquatic resources including destruction of spawning habitat,
suffocation of eggs, and clogging of gills of aquatic species.
7. Existing culverts should be evaluated for their function and allowance for aquatic life and fish
passage. Generally, the culvert or pipe invert should be buried at least 1 foot below the natural
streambed (measured from the natural thalweg depth), or if culverts are less than 48 inches in
diameter, they should be buried to a depth equal to or greater than 20% of their size. If multiple
barrels are required, barrels other than the base flow barrel(s) should be placed on or near stream
bankfull or floodplain bench elevation (similar to Lyonsfield design). These should be
reconnected to floodplain benches as appropriate. This may be accomplished by utilizing sills on
the upstream and downstream ends to restrict or divert flow to the base flow barrel(s). Silled
barrels should be filled with sediment so as not to entrap wildlife or support mosquito breeding

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Piedmont Lithium Mine IP
USACE Action ID: SAW -2018-01129
conditions. Sufficient water depth should be provided in the base flow barrel(s) during low flows
to accommodate fish movement. If culverts are longer than 40-50 linear feet, alternating or
notched baffles should be installed in a manner that mimics existing stream pattern. This should
enhance aquatic life passage: 1) by depositing sediments in the barrel, 2) by maintaining channel
depth and flow regimes, and 3) by providing resting places for fish and other aquatic organisms.
In essence, base flow barrel(s) should provide a continuum of water depth and channel width
without substantial modifications of velocity.
If multiple pipes or cells are used, at least one pipe or box should be designed to remain dry
during normal flows to allow for wildlife passage.
Culverts or pipes should be situated along the existing channel alignment whenever possible to
avoid channel realignment. Widening the stream channel must be avoided. Stream channel
widening at the inlet or outlet end of structures typically decreases water velocity causing
sediment deposition that requires increased maintenance and disrupts aquatic life passage.
Riprap should not be placed in the active thalweg channel or placed in the streambed in a manner
that precludes aquatic life passage. Bioengineering boulders or structures should be
professionally designed, sized, and installed.
Sediment and erosion control measures should be installed prior to any land clearing or
construction. The use of biodegradable and wildlife -friendly sediment and erosion control
devices is strongly recommended. Silt fencing, fiber rolls and/or other products should have
loose -weave netting that is made of natural fiber materials with movable joints between the
vertical and horizontal twines. Silt fencing that has been reinforced with plastic or metal mesh
should be avoided as it impedes the movement of terrestrial wildlife species. These measures
should be routinely inspected and properly maintained. Excessive silt and sediment loads can
have numerous detrimental effects on aquatic resources including destruction of spawning
habitat, suffocation of eggs, and clogging of gills of aquatic species.
9. We recommend reclaiming the relatively shallow sediment basins as wetlands, where practicable.
Thank you for the opportunity to comment on this permit application. For questions or comments, please
contact me at [phone] or olivia.munzerkncwildlife.org.
ec: Sue Homewood, NC Division of Water Resources (NCDWR)
Alan Johnson, NCDWR
Byron Hamstead, U.S. Fish and Wildlife Service
W. Thomas Russ, NCWRC
David Shaeffer, U.S. Army Corps of Engineers