DWQ-2024-003826

Fact Sheet and Statement of Basis Draft
Class 5-C1 permit
UIC Permit Number UTU-37-AP-1D61E74
May 2024
A1 Lithium LLC
Green River, Utah
Figure 1. Permit Boundaries Map of A1 Lithium LLC
Location:
Moab, Utah
Operator:
A1 Lithium LLC
Facility Contact:
Greg Knox
A1 Lithium LLC
712 Proud Eagle Lane
Las Vegas, Nevada 89114
[e-mail]
1-702-759-0182
Regulatory Contact:
Porter Henze
Utah Department of Environmental Quality
Division of Water Quality
UIC Program
195 North 1950 West
Salt Lake City, UT 84116
[e-mail]
Tel. [phone]
Purpose of the Statement of Basis and Fact Sheet
The Utah Division of Water Quality (DWQ)has prepared this Fact Sheet and Statement of Basis (FSSOB) for the draft Underground Injection Control (UIC) Class V Well (Category UIC Well
5C1) for A1 Lithium LLC. Pursuant to the Utah UIC administrative rules in Utah Administrative Code R317-7 and federal regulations in Title 40 of the Code of Federal Regulations CFR)
incorporated by R317-7-1 the purpose of this FSSOB is to briefly describe the principal facts and the significant factual, legal, methodological and policy questions considered in preparing
the waiver. To meet these objectives, this FSSOB contains:
Background information on the permit process and names and telephone numbers of contacts for additional information (listed on the first page of this FSSOB above);
A description of the draft review process and public participation;
A brief description of the facility and process;
Basis for draft permit conditions
Waiver Process
Application and Review Period
InAugust of 2023Blackstone Mineralssubmitted a UIC Technical Reportfor a UIC Class 5 Spent Brine Return well (5C1 SBR). The DWQ completed its review of this application and has completed
the provisionally approved Draft Permit.
Public Participation
The waiver was prepared by the DWQ for public notice and public comment. Public comments will be accepted by the DWQ for 30 days following the first day of public notice in the local
newspaper that serves the affected community. A hearing may be held by the DWQ if public comments are substantial and the Permit requires revision based on these comments.
Description of Permitted Facility
A1 Lithium is conducting lithium and associated brine resource mining operations near Moab, Utah. Brines will be extracted from the paradox formation, specifically Clastic Zone 31 using
extraction wells. Brines will be processed using a lithium carbonate and lithium hydroxide production plant utilizing direct extraction. The spent brine that is depleted of lithium will
be pumped into the injection wells under pressure into the Paradox formation from the top of Clastic Zone 23 to the bottom of Clastic Zone 29, or from 5,660 to 6,010 feet below ground
surface.
Site Geology
The permit area is located in the Paradox Basin of the Colorado Plateau in Southwestern Utah, west of Moab Utah and near the Colorado River. The paradox basin is part of the Colorado
Plateau that is underlain by a thick sequence of evaporite salt beds of Pennsylvanian age. Alternating evaporite beds and clastic beds were deposited in a partially enclosed inland sea
as a result of cyclical recharge of the basin with ocean water. In this locality, the overall thickness of the Paradox formation is 1,700 to 1,800 feet thick.
Site Hydrology
There are no USDWS in the permit area or AOR owing to low productivity and poor water quality. Some shallow water wells and springs are used for irrigation and domestic use, but groundwater
is generally non-potable. Surficial water drains to the Colorado River.
There are two regional aquifer systems in the area, one relatively shallow aquifer system in the Mesozoic Formations and one below the Paradox formation in the Paleozoic formations.
Evaporite Beds consisting of salt generally act as confining layers that separate the aquifers. Groundwater in the target bed is composed of a brine solution with total dissolved solids
of more than 10,000 ppm owing to salt beds in these formations.
Groundwater recharge is limited owing to low rainfall and high rates of potential lake evaporation Recharge comes mainly from the north and east from the Book and Roan cliffs, and from
the La Sal Mountains in the west. No connection or recharge between the two aquifers and the Colorado River is evident.

Permit Conditions
Part I of the permit is the Authorization to Construct and Inject. Part II includes all general permit
conditions required in all UIC permit with the focus on Class V permits. Part III contains all the specific permit conditions required of all Class V SBR wells.
Construction Plan
A1 Lithium will submit well construction plans that meet the requirements of Part III (C) of this permit prior to well construction.
Standard Operating Procedures Plan
A1 Lithium has submitted injection well Operating Plan (Permit Attachment D) that meets the requirements of Part III (E) of this permit.
Monitoring, Testing and Reporting
Injectate Characterization - Each source of injectate will be analyzed for a complete suite of parameters once during the permit cycle. Additionally, any new source for injection will
be analyzed for a complete suite of parameters annually for the permit cycle. During each injection event, the source of the injectate will be analyzed for an abbreviated suite of parameters
that include those constituents of concern and those constituents that have historically been detected. The monitoring parameter list and monitoring schedule are detailed in Attachments
F of the permit, respectively.