In the first article of this two-part series, we focused on the engineering and design factors to consider when adding lithium to your mining operations. It is equally important to plan for the environmental and permitting factors that might impact your lithium project.

With shifting environmental regulations for mining operations and increased pressure from stakeholders to incorporate environmental, social, and governance (ESG) objectives, the road to supporting the domestic supply chain for critical minerals is far from straightforward. Here are three environmental areas to consider for your lithium mining project:

1. Water and mine water

• Plan for the risks to groundwater and surface water: Lithium is a mobile cation in soils, causing it to potentially leach into groundwater and reach surface water through runoff.

• Understand the impacts to water quality: Hard rock mining or brine mining of lithium can have differing impacts to mine water quality.

• Recognize the implications of emerging contaminants: Lithium is an emerging contaminant. As of early 2023, allowable contaminant levels are pending additional research and regulatory decisions.

• Be aware of drinking-water benchmarks: In collaboration with the U.S. Environmental Protection Agency (EPA), the U.S. Geological Survey (USGS) calculated a nonregulatory Health-Based Screening Level (HBSL) for drinking water of 10 micrograms per liter (µg/L) for evaluating lithium concentrations in groundwater. A second “drinking-water-only” lithium benchmark of 60 µg/L can be used when the assumed source of lithium exposure is from drinking water.

• Additional research on treatment technologies is necessary: While some of the current available soil and water treatment technologies can help with preventing or reducing lithium-impacted groundwater and surface water contaminant levels, additional research is still needed.

2. Permitting

• Conduct a siting analysis of greenfield projects: If possible, site your operations and/or plans for development on private lands. This may reduce the number of regulatory agencies with which you need to engage.

• Nail down your project definition early: If you’re halfway through the permitting process and then change your project plans, you may need to revise your baseline studies. By having a full picture of your project and design constraints for permitting from the start, you can avoid project delays during the permitting stage.

• Engage early with key stakeholders: It can be beneficial to engage early with the applicable regulators and other stakeholders. Regulators might include the Bureau of Land Management, the U.S. Forest Service, and other state environmental departments. Other stakeholders may include tribal entities and non-governmental organizations. Early discussions can help you define the applicable studies and associated scopes that will be required. Starting the conversation early will help you plan your project more efficiently and stay on schedule.

• Start baseline studies as early as you feel comfortable: As soon as you’ve determined your project footprint, you can begin baseline studies. Getting an early start on baseline studies can help you avoid scheduling issues during the permitting process.

• Assess if expansion of existing operations will impact your current permits: First, determine whether your modification requires revisiting your Environmental Assessment (EA) or Environmental Impact Statement (EIS). Triggers for modification might include a significant change in the process or additional land needs. Next, evaluate if there is a need to modify your air permit. Will expanding your operation result in an increase in emissions that exceeds your permitted capacity?

3. Environmental, social, and governance

• Understand the impacts of energy and water usage: Evaluate and understand the range of impacts to your future energy consumption and water usage. Frame this in the context of your own sustainability goals and the issues important to your stakeholders.

• Evaluate the concerns of your stakeholder groups: Think through what each of your stakeholder groups may care about and when and how you will engage and collaborate with each. This may include local communities and tribal nations.

• Account for ESG factors when making decisions: Incorporate environmental and social factors in your technology evaluation and decision-making processes (i.e., full lifecycle).

• Define the metrics and data you will use or disclose: Determine the metrics you will want to track and potentially disclose in the future beyond compliance, what data is likely to be collected and reported on your operation by third parties, and if you wish to pursue any types of independent assurance or certifications.

• Determine ongoing monitoring practices: Consider up front which ongoing monitoring practices you will employ relative to potential contamination of land and water. Assess how you can proactively share results with your stakeholders in a way that resonates.

• Understand short-term and long-term needs: Assess and develop plans for your near- and long-term talent needs, including acquisition, retention, and workforce pipeline development.

The U.S. mining industry continues to rapidly adjust to the domestic supply chain needs for lithium and other battery minerals. From mine water quality to permitting regulations to long-term ESG objectives, Barr’s experienced team can help navigate the environmental challenges for mine expansion. To learn more about our environmental and engineering solutions for the mining industry, contact us.

About the authors

Jon Minne, vice president, senior civil engineer, is a professional engineer with 30 years of experience including project management, conceptual engineering, and project planning; detailed design engineering; and construction administration. His areas of professional engineering expertise include wastewater and water pumping, piping, and treatment facility design.

Ryan Siats, vice president, senior environmental consultant, has over a decade of experience in environmental assessments, permitting, and compliance. He manages environmental reviews, permitting, and technical studies for the development, construction, and operation of new and expanding facilities.

Emily Ahachich, ESG strategic consultant, has more than 20 years of business experience—both as a consultant and from within organizations—helping clients think through ESG risks and opportunities in the context of their strategy. Her areas of focus include materiality, goal setting, and measurement; program development; and disclosures.