DWQ-2024-004223

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GROUND WATER QUALITY DISCHARGE PERMIT UGW270012
STATEMENT OF BASIS
Peak Minerals Inc.
Sevier Playa Potash Project
Millard County, UT
June 2024
Introduction
The Division of Water Quality (DWQ) under the authority of the Utah Ground Water
Quality Protection Rules 1(Ground Water Rules) issues ground water discharge permits to
facilities which have a potential to discharge contaminants to ground water2. As defined
by the Ground Water Rules, such facilities include mining operations3 . The Ground Water
Rules are based on an anti-degradation strategy for ground water protection as opposed to
non-degradation; therefore, discharge of contaminants to ground water may be allowed
provided that current and future beneficial uses of the ground water are not impaired and
the other requirements of Rule 317-6-6.4.A are met4 . Following this strategy, ground
water is divided into classes based on its quality5; and higher-quality ground water is given
greater protection6 due to the greater potential for beneficial uses.
DWQ has developed permit conditions consistent with R317-6 and appropriate to the
nature of the mined materials, facility operations, maintenance, best available technology7
(BAT) and the hydrogeologic and climatic conditions of the site, to ensure that the
operation would not contaminate ground water.
Basis for Permit Issuance
Under Rule 317-6-6.4A, DWQ may issue a ground water discharge permit if:
1)The applicant demonstrates that the applicable class TDS limits, ground
water quality standards protection levels and permit limits established
under R317-6-6.4E will be met;
2)The monitoring plan, sampling and reporting requirements are adequate to
determine compliance with applicable requirements;
1 Utah Admin. Code Rule 317-6
2 https://deq.utah.gov/ProgramsServices/programs/water/groundwater/docs/2008/08Aug/GWQP_PermitInfo.pdf
3 Utah Admin Code Rule 317-6-6.1A
4 Preamble to the Ground Water Quality Protection Regulations of the State of Utah, sec. 2.1, August, 1989
5 Utah Admin. Code Rule 317-6-3
6 Utah Admin. Code Rule 317-6-4
7 Utah Admin. Code Rule 317-6-1(1.3)
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3) The applicant is using best available technology to minimize the discharge
of any pollutant; and
4) There is no impairment of present and future beneficial uses of ground
water.
Purpose

Peak Minerals Inc. (CPM) is proposing to construct potash (potassium sulfate) mining
operations and facilities on the Sevier Playa located in Millard County, Utah approximately
30 miles southwest of Delta (Figure 1). A permit was initially issued in 2019, but due to
economic conditions, construction was never started. The potash mining area will be the
entire Sevier Playa surface (approximately 26 miles long and up to 8 miles wide), with
production ponds and facilities located at the south end of the playa. The Project will be
designed to produce approximately 215,000 tons of sulfate of potash, as well as other
associated minerals, per year. The operations will be located on Bureau of Land
Management (BLM), Utah School and Institutional Trust Lands Administration (SITLA),
and private land.

In general, the mine design consists of three major components: 1) a brine extraction
system consisting of canals, trenches, and wells; 2) a recharge system consisting of canals
and trenches; and 3) a series of solar evaporation ponds. The production facilities will
include a crystallization (processing) plant, potable water treatment facility,
preconcentration ponds, production ponds, purge brine storage pond, and a tailings (waste)
storage facility (Figure 2).

Ground Water Discharge Permit UGW270012 is issued to authorize the ground water
discharge, or probable discharge, related to the potash mining operations. Construction
Permits will be required in the future to authorize the construction of individual facilities,
such as the Preconcentration Ponds, Production Ponds, Purge Brine Storage Pond, and the
Tailings Storage Area. CPM will be the operator of the potash mining facility.

New Facilities

The following new facilities will be regulated under this Permit including the associated
Best Available Technology (BAT) and Protection Levels:
• Preconcentration Ponds
• Production Ponds
• Purge Brine Storage Pound
• Tailings Storage Facilities
• Processing Facilities.

The project footprint area is approximately 124,400 acres. The Preconcentration Ponds
will occupy 6,398 acres, the Production Ponds will be 1,642 acres. The Purge Brine
Storage Pond will be 106 acres. The Tailing Storage Facility will occupy 317 acres. The
playa surface will be mined and reclaimed in successive stages. At no point in t ime will
the entire playa surface be activily mined. The process facilities will be located within one
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mile of the edge of the playa at south end of the playa. The anticipated lifespan of the
mining operation is 30 years.
BAT Performance Monitoring
Best available technology monitoring will include minimum vertical freeboard and
maximum Liner Hydraulic Conductivity. These performance standards are based on the
precedence of previous ground water discharge permits.
Minimum Vertical Freeboard. A minimum of 24 inches of vertical freeboard in
containment ponds shall be maintained to ensure containment of mining liquids.
Maximum Liner Hydraulic Conductivity. The Purge Brine Storage and the Tailings
Storage Pond will be lined with a minimum of a 24 inches of native clay with a maximum
hydraulic conductivity of 1x10-7 centimeters per second (cm/sec).
Potential Impacts to Ground Water
Potential impacts to ground water will be minimized by employing best available
technology for storage ponds and in the inherent operations of the facility. The majority of
the surface area of the brine mining operations will collect (extract) groundwater through
trenches, canals, and wells and transport the water to evaporation ponds. Any groundwater
leakage from these ponds will generally be re-collected by the extraction system and sent
back to the evaporation ponds. Groundwater in the project area will also be intrinsically
protected by the geological and hydrogeologic characteristics of the project area, as
discussed in the Geologic Description section below.
Storage ponds, such as the Purge Brine Storage Pond and the Tailings Storage Area, located
where the extraction system in less likely to intercept any groundwater leakage will have
groundwater monitoring wells installed around their perimeters. Quarterly ground water
monitoring will be implemented to assess and mitigate any discharge from these storage
ponds.
A series of groundwater monitoring wells exist throughout the project area (Stantec 2019).
The wells range in depth and will be used to assess any impacts to shallow, intermediate,
and deeper aquifers from the potash mining operations. Crystal Peak Minerals initiated
quarterly baseline sampling of these 17 existing wells in 2018.
Groundwater in the project area will also be inherently protected by the geological and
hydrogeologic characteristics of the project area, as discussed in the Geologic Description
below.
The Division of Water Quality will provide periodic onsite inspections during
construction and operation of the facilities described above. Peak Minerals will ensure
that the facility is operated in accordance with design specifications and will also ensure
that any
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early indications of facility problems will be detected early and resolved. In addition to
BAT performance monitoring, ground water quality monitoring of various aquifers in the
project area will be conducted in monitoring wells to determine if ground water quality has
been impacted by the potash mining operations.
Geologic Description
Regional. The Sevier Playa Project is situated within the Basin and Range physiographic
province of Utah, and within the Great Basin carbonate and alluvial aquifer system
(GBCAAS) as described by Heilweil and Brooks (2011). The GBCAAS is found through
western Utah and eastern Nevada covering an area of approximately 110,000 square miles.
The regional aquifer system is generally comprised of aquifers and confining units in
unconsolidated basin fill and volcanic deposits in the basins, and carbonate and other
bedrock in the mountain ranges. Most groundwater flow occurs at local and intermediate
scales, but some interbasin flow may occur under certain conditions (Heilweil and Brooks,
2011). The Sevier Playa system is the terminus of the Sevier River and is considered a
closed/terminal sedimentary basin.
The Sevier Playa system (Figure 3) is bounded on the east by the Cricket, Beaver Lake,
and San Francisco Mountains and primarily comprised of Prospect Mountain Quartzite
along the east playa margins (though other formation outcrops are observed). The playa is
bounded to the west by the Black Hills and House Range and constrained primarily by the
Notch Peak Limestone. Some volcanic flows are draped over these formations at the
southern end of the playa. Prospect Mountain Quartzite and Mutual Formation outcrops
(quartzite and shale) are also present south of the playa.
Sediments around the margin of the playa are described as alluvium/colluvium. This
sediment has accumulated at the playa margin primarily by ephemeral stream deposition
and mountain erosion (mass wasting). These coarser gravel and sand sediments also create
discontinuous higher permeability beds within the fine-grained playa sediment system
where infrequent high energy storms during historical wet periods resulted in sediments
being washed out onto the playa surface.
The shallow Sevier Playa sediments are described as very fine-grained clay interbedded
with silts and fine sands that grade to coarser grained material at the edge of the playa and
at depth. The fine-grained playa sediments (with possible volcanics) are estimated to reach
a thickness of 4,000 feet at the east edge of the playa (Case and Cook, 1979) and 560 feet
on the west edge of the playa (Wilberg 1991).
Based on drilling logs, CPM describes the typical first 100 feet (in depth) of playa system
as follows (Figure 4):
0-12 feet:Fat Clay Zone (FCZ), confining layer, no production,
12-35 feet:Marl Clay Zone (MCZ), upper production zone
35-75 feet:Siliceous Clay Zone (SCZ), lower production zone
75-80+ feet: hard dry clay, undefined thickness, no production
Similar playa sediment lithology was recorded by others (Gwynn 2006).
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The USDA Natural Resource Conservation Service Web Soil Survey
(websoilsurvey.sc.egov.usda.gov) describes the Sevier Playa soil type simply as “Playas”
with a general elevation range between 4,300 to 5,800 feet, mean annual precipitation
between 5 to 8 inches, mean annual air temperature between 48 to 51 degrees F, frost-free
period between 115 to 145 days, and a farmland classification of “not prime.”

Hydrogeology

Groundwater flow systems, such as the basins within the GBCAAS, are described to occur
at local, intermediate and regional scales (Toth 1963, Wilber 1991). Local flow is
described as recharge and discharge generally constrained by surface (topographic)
features, and is generally relatively shallow. Intermediate flow may across drainage
divides and is generally deeper than local flow. Regional flow is characterized by recharge
at the water divide (highest topography) and discharge at the bottom of the basin. Regional
flow systems are also characterized by long, inter-basin flow paths (Figure 5).

Based on potentiometric groundwater elevations , the Sevier Playa system has also been
characterized as containing three interrelated systems (Whetstone 2017). The systems
include the local-scale groundwater flow system, the “playa brine” groundwater flow
system, and the regional groundwater flow system. This characterization of the playa
system considers the evaporative surface of the playa as a discharge point for both the
“playa brine” and regional groundwater systems.

Local groundwater flow in the Sevier Playa basin has been understood to be primarily
driven by recharge from precipitation (snow) in mountains at higher altitudes, and
infiltration of the surface water (such as the Sevier River and Amasa Creek). However,
surface water use and storage by upstream users currently limits or eliminates significant
recharge from the Sevier River. The only terminus discharge mechanism in the Sevier
Playa basin for the Sevier River, as well as other local creaks and ephemeral stream, is
evaporation (Heilweil and Brooks, 2011) very similar to the Great Salt Lake system.
Therefore, while the playa surface may sporadically be considered a recharge system, it is
overwhelming a net discharge zone.

The local groundwater flow system at the surface and around the margins of the playa is
believed to be shallow and constrained by the clay confining layers observed in the CPM
borings (described above) and an upward gradient observed in the wells deeper than 40
feet that is driven by evaporation. The evaporative discharge is understood to be driven by
solar energy at the playa surface, capillary rise, and the upward hydraulic gradient. The
closed nature of the shallow, local groundwater system has resulted in brine-saturated
lacustrine deposits that represent a substantial saline resource for choride and sulfate-based
salts that are the target of the CPM mining operation (Gwynn 2006).

The intermediate flow system is primarily driven by recharge from mountain precipitation
and is interpreted to include, at least partially, the “playa brine” system described by
Whestone and ENValue (2018) and the alluvial/colluvial system at the playa margins.
Brine conditions (salt crystals, gypsum crystals, “salty” taste) have also been observed in
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the deeper basin sediments (Gwynn 2006). Some mixing of higher quality, deep regional
groundwater and lower quality local/surface and intermediate water is predicted to occur
(Garcia et al. 2015). The margins of these mixing zones, as well as the various flow
systems, are likely to vary spacially based on depth, hydraulic conductivity of the
sediment/bedrock, hydraulic gradients, fluid densities, and temperature. Discharges from
the Sevier Playa intermediate flow system are interpreted to be primarily evaporation at the
playa surface and, for deeper sediments, comingling with and discharge to the regional
groundwater system.

The regional, inter-basin flow system is principally driven by recharge to bedrock from
precipitation (primarily snow) in the adjacent mountain ranges. Limestone bedrock in the
adjacent Black Hills and House Range generally has a higher hydraulic conductivity than
the quartzite typically found in the mountains to the east of the Sevier Basin. Based on
groundwater age dating, it is estimated to take 15,000 years for deep, regional groundwater
to flow from the east margin of the Sevier Playa to the western margin (Norwest 2018a).

Whetstone and ENValue and others (Wilberg 1991) assert, based on potentiometric
groundwater elevations (measured to be at or above the playa surface) that regional
groundwater flow may discharge, in part, at the Sevier Playa surface due to evaporation.
CPM disagrees with this proposed connection of the regional aquifer to the playa surface
based on borings that encountered multiple dense clay sequences observed well below the
SCZ, suggesting the deep regional aquifer is semi-confined or confined. In either case, it
is agreed that the Sevier Playa surface is primarily a discharge (evaporation) zone under
all flow system scenarios. Based on these models, any near-surface activity on the playa
surface is considered unlikely to negatively impact water quality in underlying aquifers.

Regional groundwater flow travels beyond the Sevier Basin towards the west-northwest to
the carbonate bedrock system of the House Range (and possibly the Tule Valley) and
towards Fish Springs Flat. There is broad consensus that the eventual discharge point of
this regional aquifer system is Fish Springs located approximately 60 miles north of the
Sevier Playa (Hurlow 2014). Several other hydrographic basins within the GBCAAS
regional aquifer system also discharge at Fish Springs (Hurlow 2014, Masbruch et al.
2014).

Water discharging at Fish Springs National Wildlife Refuge (North and Middle Springs)
has been dated using various methods to be between 7,700 and 16,600 years old (Hurlow
2014). Water discharging from Table Knoll Springs located in Fish Springs Flat (south of
Fish Springs NWR) has been dated to be between 14,300 and 27,500 years old. Total
dissolved solids (TDS) concentrations measured at these springs in this area range from
approximately 1,800 to 20,000 milligrams per liter (Hurlow 2014).

Based on the distance, low hydraulic conductivity and gradient, vertical isolation from the
deep regional aquifer, timeframe of the project, groundwater velocity, average age of the
spring water, comingling of spring water with other source flows, and relatively poor
existing water quality measured at the springs, DWQ believes it is implausible that impacts
from surface activities on the Sevier Playa surface will ever be observed at Fish Springs.
7
Ground Water Quality
Ground Water Classification. Based on groundwater quality data submitted in the permit
application and groundwater classification terms established in Utah Administrative Code
(UAC) R317-6-3, groundwater at the Sevier Playa site is defined as “Class IV Saline
Ground Water”. Groundwater from existing wells located away from the playa surface is
classified (depending on depth and distance from the playa surface) as “Class IA – Pristine
Ground Water”, “Class II – Drinking Water Quality Ground Water”, or “Class III - Limited
Use Ground Water”.
As required in Part I.B.2.e of the Permit, a background monitoring program is being
completed by the Permittee to collect additional data for calculating well-specific
background ground water quality statistics and Protection Levels. After securing Director
approval of the Background Monitoring Report(s), Ground Water Protection Levels will
be calculated and established in accordance with the reopener provision in Part IV.N of the
permit.
Until sufficient data are available to calculate Ground Water Protection Levels for analytes
at each ground water monitoring well, facility compliance will be assessed using Interim
Protection Levels. Interim groundwater protection limits have been calculated for seven
representative groundwater monitoring wells and a subset of analytes using initial water
quality data (Crystal Peak Minerals 2019a, 2019b, 2019c). The Interim Protection Levels
are presented in Appendix B of the permit. Existing and proposed monitoring well location
are presented in Figure 6.
Protection Levels. In accordance with UAC R317-6-4, the various classes of groundwater
identified in the project area will be protected for use as established under rule.
Groundwater found at the Sevier Playa is defined as “Class IV Saline Ground Water”.
Protection levels for the playa groundwater are established in accordance with the criteria
in UAC R317-6-4.7 (“established to protect human health and the environment”):
a.Total dissolved solids may not exceed 1.5 times the background concentration
level.
b.In no case will the concentration of a pollutant be allowed to exceed the ground
water quality standard due to discharge. If the background concentration of a
pollutant exceeds the ground water quality standard, no statistically significant
increase will be allowed.
COMPLIANCE SCHEDULE
•Ground Water Compliance Sampling
Compliance Monitoring wells shall be installed and sampled in accordance with
R317-6-6.4.C.2 and R317-6-6.9A. The purposes of the Compliance Monitoring
Wells include (i) obtaining additional baseline data regarding the aquifers,
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hydrogeological conditions, and background water quality; and (ii) establishing
suitable points of compliance for the Permit.
Quarterly groundwater sampling will be conducted as described in the Fresh Water
Baseline Study plan (Stantec 2019).
•Non-Compliance
The Permit defines the processes and schedule required in the event that a “Probable
Out-of-Compliance” status is observed at a monitoring well (immediate resample)
and “Out-of-Compliance” status is observed (Director notification and accelerated
sampling). A contaminant assessment and corrective action process and schedule
is also described.
•Final Closure Plan. In the event that the permittee decides to discontinue its
operations at the facility the permittee shall notify the Director of such a decision
and submit a Final Closure Plan within 180 days prior to the closure of the facility.
FIGURES
Figure 1 – Site Location Map
Figure 2 – Site Features Map
Figure 3 – Site Geology Map
Figure 4 – Sevier Playa Cross-Section
Figure 5 – Conceptualized Groundwater Flow in Great Basin System
Figure 6 – Exising and Proposed Monitoring Well Locations
REFERENCES
Case, R.W. and K.L. Cook 1979. A Gravity Survey of the Sevier Lake Area, Millard
County, Utah. Utah Geology. Vol. 6, No. 1, pp. 55-76.
Crystal Peak Minerals 2019a. Sevier Playa Potash Project Ground and Surface Water
Baseline Sampling 3rd Quarter 2018 Report. February 2019.
Crystal Peak Minerals 2019b. Sevier Playa Potash Project Ground and Surface Water
Baseline Sampling 4th Quarter 2018 Report. March 2019.
Crystal Peak Minerals 2019c. Sevier Playa Potash Project Ground and Surface Water
Baseline Sampling 1st Quarter 2019 Report. May 2019.
Garcia, C.A., J.M. Huntington, S.G. Buto, M.T. Moreo, J.L. Smith, and B.J. Andraski,
April 2015. Groundwater Discharge by Evapotranspiration, Dixie Valley, West-
Central Nevada, March 2009-September 2011. Prepared by the U.S. Geological
Survey. Professional Paper 1805, Version 1.1.
Gwynn, J.W. 2006. History and Mineral Resource Characterization of Sevier Lake,
Millard County, Utah. Miscellaneous Publication 06-6, Utah Geological Survey.
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Heilweil, V. M. and L.E. Brooks (eds.) 2011. Conceptual Model of the Great Basin
Carbonate and Alluvial Aquifer System. Prepared by the U.S. Geological Survey.
Scientific Investigation Report 2010-5193.
Hurlow, H. (ed.) 2014. Hydrogeologic Studies and Groundwater Monitoring in Snake
Valley and Adjacent Hydrographic Areas, West-Central Utah and East-Central
Nevada. Utah Geological Survey, Bulletin 135.
Masbruch, M.D., P.M. Gardner and L.E. Brooks 2014. Hydrology and Numerical
Simulation of Groundwater Moverment and Heat Transport in Snake Valley and
Surrounding Areas, Juab, Millard, and Beaver Counties, Utah and White Pine and
Lincoln Counties, Nevada. Prepared by the U.S. Geological Survey. Scientific
Investigations Report 2014-5103.
Norwest Corporation, April 2018a. Crystal Peak Minerals Sevier Playa Project Water
Resources Technical Memo. Project #89-12.
Stantec Consulting Services, Inc. 2019. Water Monitoring Plan for the Sevier Playa
Potash Project. June 4, 2019.
Toth, J. 1963. A Theoretical Analysis of Groundwater Flow in Small Drainage Basins.
Journal of Geophysical Research, Vol. 68, No. 16, pp. 4795-4812.
Whetstone Associates, Inc., October 2017. Final Baseline Water Resources Technical
Report for the Sevier Playa Potash Project. Prepared for the Bureau of Land
Management, West Desert District, Fillmore Field Office.
Whetstone Associates Inc. and ENValue, October 2018. Sevier Playa Potash Project,
Resource Report: Water Resources. Prepared for Bureau of Land Management,
Fillmore Field Office. Resource Report for Sevier Playa Potash Project, Draft
Environmental Impact Statement. November 2018.
Wilberg, D. 1991. Hydrologic Reconnaisance of the Sevier Lake Area, West-Central
Utah. State of Utah Department of Natural Resources, Technical Publication No.
96.
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Sevier Playa Potash ProjectRegional Vicinity
GROUNDWATER DISCHARGEAPPLICATION
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10/25/20170 Initial Submission1/5/20181 Revised based on comments
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Statement of Basis Figure 2: Site Features Map
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Statement of Basis Figure 5: Conceptualized Groundwater Flow in Great Basin System (Heilweil
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Sources:
Project Features, Crystal Peak Minerals, 2015, 2016, 2017, 2018, 2019;
Sevier Playa Potash Project Water Resources Analysis Area,
Baseline Water Resources Technical Report for the Sevier Playa
Potash Project, Whetstone 2017;
Sevier Playa Boundary, SWCA 2015;
Roads, Millard County 2013;
Railroads, ESRI 2000;
Aerial Imagy, USDA/APFO 2016
0 5 10
Miles´1 in = 5 miles
DSGN DR APVDCHK
Sevier Playa Potash Project
Surface and Groundwater
Monitoring Network
SCALE:
DATENO.REVISION BY APVD
10/25/20170
1:318,859
Initial Submission
6/19/20181 Revised based on comments
DATE: 4/11/2019
Existing and Proposed Proposed Project Features
BLM/SITLA Lease Boundary
FIGURE 3-1
Proposed Playa Aquifer Well!.
Proposed Alluvial/Colluvial Aquifer Well!.
Proposed Bedrock Aquifer Well!.
7/18/20182 Revised based on comments
10/15/20183 Revised based on comments
Surface Water Monitoring Site"
Proposed Well Point Location!(
Proposed Water Supply Well!(
!(Existing Playa Aquifer Well
!(Existing Alluvial/Colluvial Aquifer Well
!(Existing Bedrock Aquifer Well
Sevier Playa Potash Project
Water Resources Area of Interest
2/15/20194 Revised based on comments
Proposed Water Supply
Pipeline Spurb b
Proposed Water Supply
Pipelineb b
Meteorological Station#*
Proposed Substation!.
Proposed Communication
Tower!.
Proposed Natural
Gas Pipeline
Proposed Rail Loadout Facility
Proposed Rail Spur and Access Corridor
Proposed 12.47-kV Power Line Spur!(!(!(
!(!(!(Proposed 12.47-kV Power and Communication Line
!(!(!(Proposed 12.47-kV Power Line
!(!(!(Proposed 25-kV Power Line
Proposed 69-kV Power and Communication Line!(!(!(
Proposed Sevier River Diversion Berm!
Spring!(
!(
!(
Blac k
R
o
c
k
R
d
Tie House Spring
Kaufman Spring
Access Road - Off-Lease
Statement of Basis Figure 6: Existing and Proposed Monitoring Well Locations