20190035 Ver 1_Piedmont Lithium Project_20181108

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Agenda
Project: Piedmont Lithium
Section 404 Individual Permit Pre -Application Agency Meeting
Subject:
Date: Thursday, November 08, 2018
Location: HDR Charlotte Offices (9'h Floor, Henningson Conference Room); Phone Conference
Attendees: Applicant Team
Patrick Brindle (Piedmont Lithium, Applicant)
Kelly,Thames (HDR, Environmental Permitting)
Eric Mularski (HDR, Environmental)
Mark Filardi (HDR, Groundwater)
Brad Taylor (HDR, Transportation)
Chris Scott (Marshall Miller, Mine Design)
Agency Representatives
David Shaeffer (USACE)
Scott Jones (USACE)
Todd Bowers (EPA)
Sue Homewood (DENR - DWR)
Alan Johnson (DENR - DWR)
James Moore (DENR — Land Quality)
Olivia Munzer (NCWRC)
Allen Ratzlaff (USFWS)
Lindsay Ferrante (SHPO)
1. Roll Call and Safety Minute = Kelly Thames
2. Project Introduction & Background — Patrick Brindle
3. Project Site Layout: Preferred Concept — Kelly Thames
a. Approximate Impacts
b. Mitigation
4. Open Discussion — Kelly Thames/David Shaeffer/All
a. Draft Purpose & Need
b. Draft Alternatives Analysis
5. Work Conducted and Ongoing — Kelly Thames
a. Land Acquisition
b. Jurisdictional Delineation
c. Threatened and Endangered Species
d. Groundwater Monitoring and Aquifer Testing
e. Department of Transportation Coordination
6. Steps Forward and Timeline — Patrick Brindle
hdrine.com
440 S Church Street, Suites 800, 900 & 1000, Charlotte, NC 28202-2075
[phone]
10 minutes
15 minutes
15 minutes
30-45 minutes
15 minutes
10 minutes

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PIEDMONT
LITHIUM
Agenda
Project: Piedmont Lithium
Subject: Section 404 Individual Permit Pre -Application Agency Meeting
Date: Thursday, November 08, 2018
Location: HDR Charlotte Offices (91h Floor, Henningson Conference Room); Phone Conference
Attendees: Applicant Team
Patrick Brindle (Piedmont Lithium, Applicant)
Thomas Blackwell (HDR, Environmental Permitting)
Kelly Thames (HDR, Environmental Permitting)
Eric Mularski (HDR, Environmental)
Mark Filardi (HDR, Groundwater)
Brad Taylor (HDR, Transportation)
Chris Scott (Marshall Miller, Mine Design)
Agency Representatives
David Shaeffer (USACE)
Scott Jones (USACE)
Todd Bowers (EPA)
Sue Homewood (DENR - DWR)
Alan Johnson (DENR - DWR)
Zahid Kahn (DENR — Land Quality)
James Moore (DENR — Land Quality)
Olivia Munzer (NCWRC)
Allen Ratzlaff (USFWS)
Lindsay Ferrante (SHPO)
1. Roll Call and Safety Minute — Kelly Thames
2. Project Introduction & Background — Patrick Brindle
3. Project Site Layout: Preferred Concept — Kelly Thames
a. Approximate Impacts
b. Mitigation
4. Work Conducted and Ongoing — Kelly Thames
a. Jurisdictional Delineation
b. Threatened and Endangered Species
c. Groundwater Monitoring and Aquifer Testing
d. SHPO Coordination
e. Department of Transportation Coordination
5. Open Discussion — Kelly Thames/David Shaeffer/All
a. Draft Purpose & Need
b. Draft Alternatives Analysis
6. Steps Forward and Timeline — Patrick Brindle
idrinc.com
440 S Church Street. Suites 800. 900 & 1000. Charlotte. NC 28202-2075
[phone]
10 minutes
15 minutes
15 minutes
15 minutes
30-45 minutes
10 minutes

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. U.S. Domestic Supply of Lithium Reserves (logistics): The alternative
would only be considered practicable and achieve project purpose if it was
located in the U.S.
B. Hard Rock Mine (technology and cost): The alternative would only be
considered practicable and achieve the overall project purpose if it relied on
hard rock mining techniques to extract mineralized spodumene containing
lithium, to convert to lithium bearing spodumene concentrate, and finally to
convert to battery grade lithium hydroxide. The conversion of lithium bearing
spodumene concentrates to battery grade lithium hydroxide from hard rock
mining has been well-documented since the 1950s, is efficient, and cost-
effective.
C. Carolina Tin-Spodumene Belt Locality (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). The TSB contains the
largest North American lithium reserves (contained in spodumene).1 The TSB
has historically provided most of the western world's lithium between the
1950s and 1980s and is estimated to be approximately 24.5 miles long, 1.8
miles in maximum width, extending southwestward from Lincolnton, North
Carolina to Gaffney, South Carolina.
D. Property Size (logistics): The alternative would only be considered
practicable and achieve the project purpose if it provided sufficient area to
construct and operate a mine to extract the minimum amount of mineralized
spodumene containing lithium to produce sufficient lithium hydroxide needed
to balance capital investment costs. In order to be practicable, a property of at
least 120 acres contained within the Carolina TSB would be required. In order
1 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 1 of 14

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to accommodate waste rock and other necessary mine features, the 120
acres would be adjacent and contiguous to a cluster of other land areas
approximately 50 acres in size or more — so that the 120 acres plus additional
land areas becomes the "core property." Ideally, the Core Property would
adequately accommodate an open pit design and wall configurations of
limited height and slope to prevent slope failure and slumping and to safely
conduct mining operations. The property size also needs to be large enough
to accommodate 50 -foot wide perimeter buffers or larger depending on local
ordinances and conditional use restrictions, sediment and erosion control,
internal access roads, and other features as required by the approved mine
design.
E. 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 land.
F. Land History (logistics and cost): The alternative would only be considered
practicable and achieve the project purpose if there was a history of previous
exploration with positive identification of mineralized spodumene within the
core property identified. According to the applicant, previous knowledge of
mineralized spodumene locations within the Carolina TSB itself helped to
immediately narrow potential mine sites and save capital exploration costs.
G. Volume of Spodumene Extracted vs. Capital Investment (costs):
Approximately 13 million tonnes or more (roughly 17 million cubic yards) of
mineralized spodumene will produce approximately 240,000 tonnes of battery
grade lithium hydroxide., According to the applicant, this volume of lithium
hydroxide is considered the minimum adequate supply of lithium to be
economically viable, attractive to long-term capital investors, and sufficient as
a domestic supply of lithium.
H. 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.
5.2 Description of alternatives
5.2.1 No action alternative: Under the no action alternative, a hard rock lithium mine
would not be constructed 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. The majority of lithium
chemicals would need to 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.
Page 2 of 14

This alternative would not satisfy the following screening criteria:
A. U.S. Domestic Supply of Lithium Reserves (logistics): The alterative would
not create a domestic supply of lithium.
C. Carolina Tin-Spodumene Belt Locality (logistics): The alternative would not
occur and would therefore not occur within the TSB.
D. Property Size (logistics): The alternative would not occur and would therefore
not provide minimum size needed to produce lithium hydroxide as a domestic
supply.
E. 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 sale the land.
G. Volume of Spodumene Extracted vs. Capital Investment (costs): This
alternative would not extract any amount of spodumene to cover capital
investment costs.
H. 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:
B. Hard Rock Mine (technology and cost): There are hard rock lithium mines
outside the U.S.
5.2.2 Off-site alternatives S 1,,p -V, '�c-p
Off-site alternative 1: Constructing a hard rock lithium mine outside the U.S.
or 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. The
Carolina Tin-Spodumene Belt contains the largest known lithium reserves within
mineralized spodumene in the U.S. Based on current known reserves, it would
not be economically feasible to locate a hard rock lithium mine in the United
Page 3 of 14

1
States outside the Carolina TSB. It is unlikely that sufficient mineralized
spodumen'e containing lithium for a domestic supply would be available outside
the TSB.
Alternatives located outside the U.S. were eliminated from consideration
because it was determined'that constructing a lithium mine outside of the
U.S., while possible, would not provide a domestic source. Alternatives
located outside the Carolina Tin-Spodumene Belt were eliminated from
consideration because the resource has to be present to be extracted.
Accordingly, off-site hard rock lithium mine sites outside the U.S. and
outside the. Carolina TSB would be unreasonable considering the overall
project purpose and the presence of the resource within the Carolina TSB.
Off-site Alternative 2: Use of 142 -Acre Parcel within Carolina TSB: A 142 -
acre parcel within the Carolina TSB was identified and considered as an
alternative site. It is of sufficient size and adjacent to a few contiguous land
parcels of 50,acres or more. Additionally, the alternative is also contiguous with
several land parcels less than 50 acres, which are owned by one owner and total
approximately 675 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 site contains mining infrastructure and it is
unlikely that many aquatic resources remain that would be subject to impacts.
However, this site is not for sale and Martin Marietta intends to continue
processing construction aggregates on the site. 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 would not be practicable for this alternative.
Page 4 of 14

Figure 1. Off-site Alternative 2
This alternative would not satisfy the following screening criteria:
E. Property Availability (logistics): The alternative is not available for purchase.
G. Volume of Spodumene Extracted vs. Capital Investment (costs): Most likely,
there are not adequate reserves of the resource remaining to cover the
capital investment costs.
This alternative would satisfy the following screening criteria:
A. U.S. Domestic Supply of Lithium Reserves (logistics): The alternative is
located within the U.S.
B. 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.
C. Carolina Tin-Spodumene Belt Locality (logistics): The alternative is located
within the Carolina TSB.
D. Property Size (logistics): The alternative is of sufficient size and surrounded
by contiguous land parcels already consolidated under one ownership.
F. Land History (logistics and cost): The alternative is a former lithium mine with
historic production records of the resource.
Page 5 of 14

H. Minimization of Environmental Impacts: This alternative would be satisfied
since there would be minimal anticipated Environmental Impacts as the site.
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. It is of
sufficient size; however, the parcel is divided by a major highway. Additionally,
the alternative is also contiguous with other land parcels less than 50 acres,
which together with the 538 -acre parcel, is owned by one owner and totals
approximately 710 acres. 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 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, which includes this landholding, 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, and
considerable land alteration would be necessary. As this site is owned by a large,
global market competitor to the applicant, it is not available for purchase as an
off-site alternative. Therefore, the combination of the unavailability of the land for
purchase, the unknown amount of resource reserves remaining, and potentially
considerable land alteration impacts, would not be practicable.
Page 6 of 14

Figure 2. Off-site Alternative 3
This alternative would not satisfy the following screening criteria:
E. Property Availability (logistics): The alternative is not available for sale and
owned by a large market competitor.
G. Volume of Spodumene Extracted vs. Capital Investment (costs): The amount
of spodumene reserves is unknown.
H. Minimization of Environmental Impacts: There would be similar environmental
impacts associated with the alternative.
This alternative would satisfy the following screening criteria:
A. U.S. Domestic Supply of Lithium Reserves (logistics): The alternative is
located within the U.S.
B. 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.
C. Carolina Tin-Spodumene Belt Locality (logistics): The alternative is located
within the Carolina TSB.
D. Property Size (logistics): The alternative is of sufficient size and surrounded
by other land areas also of sufficient size. A major highway divides access,
however.
F. Land History (logistics and cost): The alternative was, or partly was, a former
lithium mine with historic production records of the resource.
Page 7 of 14

Off-site Alternative 4: Use of 192 -Acre Parcel within Carolina TSB: A 192 -
acre parcel within the Carolina TSB was considered. It is of sufficient size, but is
not surrounded by a cluster of other land areas of sufficient size. 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 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. The alternative contains mining infrastructure and
most likely has few aquatic resources remaining that would be subject to
impacts. However, this site is not for sale as the mica resource has not likely
been depleted and operations will continue into the future as a mica mine. The
combination of the insufficient land areas surrounding the alternative,
unavailability of the land for purchase, and the lack of exploration for mineralized
spodumene result in this alternative being impracticable.
4'
Figure 3. Off-site Alternative 4
This alternative would not satisfy the following screening criteria:
D. Property Size (logistics): Although the alternative is greater than 120 acres,
there is not a cluster of other land areas approximately 50 acres in size
adjacent to the alternative.
Page 8 of 14

E. Property Availability, (logistics): The alternative is not available for purchase.
F. -Land History" (logistics and cost): The alternative is not known to contain
lithium reserves and does not have a history of exploration for lithium,.
containing -mineralized spodumene.
G. Volume of Spodumene Extracted vs. Capital Investment (costs): It is unknown
if the alternative could provide adequate mineable lithium reserves to cover
capital investments costs.
This alternative would satisfy the following screening criteria:
A. U.S. Domestic Supply of Lithium Reserves (logistics): The alternative Js
located within the U.S.
B. 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.
C. Carolina Tin-Spodumene Belt Locality (logistics):. The alternative is located
within the Carolina TSB.
H. Minimization of Environmental Impacts: There would be few environmental
impacts associated with this alternative.
5.2.3 On=site alternatives
On-site alternative "1 (applicant's preferred alternative): Piedmont Lithium Core
Property: A 120 -acre parcel within the Carolina TSB was identified by the
applicant and was 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. Upon the acquisition of
this data and knowledge of the resource presence, the applicant acquired the
120 -acre parcel, multiple adjacent parcels of 50 acres or more, and smaller in -fill
parcels to create a larger contiguous area, which,is now considered the -
applicant's Core Property of 963.5 acres, which is,the preferred alternative.
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 Core 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.
The pit shell was designed based on the data collected during the drilling
program conducted by the applicant, targeting areas of mineralization. It was
determined that approximately 13 million tonnes or more (approximately 17
million cubic yards) of. mineralized spodumene can be extracted over a 13 year
span, utilizing an approximately 200 -acre pit shell design. The waste rock areas
needed -to contain approximately 50% of pit shell waste is approximately 180
Page 9 of 14

acres. 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 Core Property, major drainages, and streams originating off site.
The 963.5 -acre Core Property is large enough to accommodate the majority of
the 200 -acre pit shell, 180 -acre waste rock areas, and the concentrator plant site.
The volume of extracted mineralized spodumene anticipated in this alternative
will be converted to approximately 240,000 tonnes (314,400 cubic yards) 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. Since
the Core Property is located within the Carolina TSB, is of adequate size to
accommodate the necessary pit shell design and attendant mine features,
contains mineralized spodumene substantiated by historic and current
exploration, can be developed as a hard rock mine, and presents the fewest
limitations regarding the screening criteria of cost, logistics, and technology, it
has been selected as the preferred alternative.,�
k
i, CO� �s
Figure 4. On-site Alternative 1 (Preferred Alternative)
Page 10 of 14

v
Figure 5. Preferred Site Layout
This alternative would satisfy the following screening criteria:
A. U.S. Domestic Supply of Lithium Reserves (logistics): The alternative is
located in the U.S.
B. 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. The technology of converting
lithium oxide spodumene concentrates to battery grade lithium hydroxide from
hard rock mining has been well-documented since the 1950s, is efficient, and
cost-effective. No retrofit of existing technology is required.
C. Carolina Tin-Spodumene Belt Locality (logistics): The alternative is
wholly contained within the Carolina TSB.
D. Property Size (logistics): The alternative is of adequate size to
accommodate the necessary size and design of the pit shell, waste rock
areas, and attendant mine features. The alternative can accommodate
specific wall configurations for pit shell and waste rock areas of limited height
and slope to prevent slope failure and slumping. The alternative is also large
enough to accommodate perimeter buffers, sediment and erosion control,
internal access roads, and other features as approved by the approved mine
design.
Page 11 of 14

E. Property Availability (logistics): The alternative is under the applicant's
control.
F. Land History (logistics and cost): The alternative has a history of previous
exploration for mineralized spodumene, which substantiates the inferred and
indicated resource amounts of the existing resource
G. Volume of Spodumene Extracted vs. Capital Investment (costs): The
alternative represents a pit shell design with estimates of mineralized
spodumene volume adequate to compensate capital investment costs while
also sufficient for a domestic supply of lithium.
H. Minimization of Environmental Impacts: The alternative would only impact
streams originating on site of medium to poor quality and minor impacts to
headwater wetlands disturbed by livestock. The FEMA floodplain, features
within the FEMA floodplain, and perennial streams originating offsite are
avoided. Buffers will be placed on remaining aquatic features.
On-site alternative 2: No Impact Alternative: This alternative consists of a pit
shell design and waste rock areas completely located in upland portions of the
Core Property while entirely avoiding impacts to Waters of the United States.
This will result in a design for the pit shell that is smaller than the preferred .
concept, which is further reduced by the required wall angles, ramp widths, and
batter angles, widths, and heights necessary for stability and safety. While 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 (a type of wall
design), which would reduce mining efficiency and increase operational costs.
Also, constraining the waste rock areas to upland areas would reduce volume
capacity of waste areas to less than 50% of waste generated, which would
necessitate higher requirements for pit backfill, potentially creating more waste
and less mineralized spodumene extracted. Essentially, this alternative is not
large enough to contain the pit shell, the waste rock areas, and the concentrator
plant entirely in uplands.
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 9.4 million
tonnes (roughly 12.3 million yards — a 29% reduction from the preferred
alternative. Furthermore, this volume of spodumene will only convert to a volume
of approximately 125,000 tonnes (163,700 cubic yards) 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
Page 12 of 14

project. Moreover, the property size is not large enough to accommodate the
necessary pit shell, waste rock areas, and concentrator plant site entirely in
uplands while also maintaining zoning and stream buffers and still produce a
sufficient amount of lithium hydroxide for continued project viability. Therefore,
this alternative is not practicable or sustainable for the project purpose and need.
W
Figure 6. On-site Alternative 2 - No Impact
This alternative would not satisfy the following screening criteria:
D. Property Size (logistics): To fit the necessary pit shell area and waste rock
area along with the concentrator plant entirely in uplands, the no impact
scenario does not work for this property size. The alternative can
accommodate specific wall configurations for pit shell and waste rock areas of
limited height and slope to prevent slope failure and slumping, but is not large
enough to also accommodate perimeter buffers, sediment and erosion
control, internal access roads, and other features as approved by the
approved mine design.
F. Volume of Spodumene Extracted vs. Capital Investment (costs): The
amount of reserves needed is present on the site; 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.
This alternative would satisfy the following screening criteria:
Page 13 of 14

r A. U.S. Domestic Supply of Lithium Reserves (logistics): The alternative is
located in the U.S.
B. Hard Rock Mine (technology and cost): The alternative creates the
opportunity to set up a hard rock mine.
C. Carolina Tin-Spodumene Belt Locality (logistics): The alternative is
wholly contained within the Carolina TSB.
E. Property Availability (logistics): The alternative has been purchased by the
applicant.
G. Land History (logistics and cost): The alternative has a history of previous
exploration for mineralized spodumene, which substantiates the inferred and
indicated resource amounts of the resource present.
H. Minimization of Environmental Impacts: This criteria would be satisfied
due to an avoidance of impacts to aquatic resources.
Page 14 of 14

CE SAW -RG -C (File Number, SAW 20'18701129)
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 Piedmont Lithium mine is centered around 1501 Hephzibah
Church Road in Bessemer City, North Carolina. 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.
c
Page 1 of 3

CE SAW -RG -C (File Number, SAW 2018-01129)
ratory
LEGEND ` ��� 'o U7
Piedmont Lihtium \ { \'• M
Mine Site (963.5 ac.)
Q USGS Quadrangles
SOURCE: USGS 7.5 minute quad ',fit _ + •! +., N ?'•- , / i�
Lmcolnton West NC 119931
' ` l
1 0 Feet 4.000 1 \ a �� ��1, V , t`\f • l i �: sL
1 inch = 4,000 feet
GAJTQN 'b=�
�. ✓. 0�
Whiteside s Road f <<4 t Hephzibah ,I 1
Church Road u_i-
s r'
�T A� r�
,
4.
tri. .� � � S �,� .i" �' I� - •I f'
NC -279
Gaston Coun Y
North Carolina !
Figure 1. Project Location
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CE SAW -RG -C (File Number, SAW 2018-01129)
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 Currently, the U.S. produces
roughly 2% of the global lithium supply and imports two-thirds of lithium needed
to meet domestic demand. Globally and domestically, the demand for lithium is
increasing; thus, a larger domestic source of lithium is needed to meet demands
in the U.S.
Spodumene (a mineral) and sub -saline brines are the main sources of lithium
used in cathodes of lithium -ion batteries. 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 from hard rock sources, lithium
must be extracted from lithium containing minerals such as spodumene through
a series of physical separation processes and chemical reactions. Crude lithium
hydroxide is then purified and crystallized into battery -grade quality lithium
hydroxide of the type which can be used in cathodes for the manufacturing of
electric car batteries.
The largest North American lithium reserves (contained in mineralized
spodumene) are found within the world-class Carolina Tin-Spodumene Belt
(TSB) located in North Carolina.4 The purpose of the project is to develop a hard
rock lithium mine in the U.S., to extract and refine mineralized spodumene to a
high quality lithium bearing spodumene concentrate, which is then converted to a
battery grade lithium hydroxide, thus providing a domestic source of lithium to
meet growing demands.
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-
reporUlithium/
3 Roskill Market Reports and Consultancy. 2018. Lithium -ion Batteries: Market Development & Raw Materials.
https://roskill.com/market-reporUlithium-ion-batteries/
4 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
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