DWQ-2024-004222

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STATE OF UTAH
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER QUALITY
WATER QUALITY BOARD
PO BOX 144870
SALT LAKE CITY, UTAH 84114-4870

Ground Water Discharge Permit
Permit No. UGW270012

In compliance with the provisions of the Utah Water Quality Act, Title 19, Chapter 5, Utah Code
Annotated 1953, as amended, the Act,

Peak Minerals Inc.
10808 S River Front Parkway, Suite 343
Salt Lake City, Utah 84095

hereafter referred to as the Permittee, is granted a Ground Water Discharge Permit for a potash (potassium
sulfate) mining and processing operation in Millard County, Utah. The Peak Minerals operations and
facilities will be centered at approximately Latitude 38° 56’ 50.21” North, Longitude
-113° 8’ 25.75” West with facilities centered on the following tracts of land (Salt Lake Base and Meridian):

Name Township Range Section Latitude, Longitude
Preconcentration Ponds 11 West 20 South 35 39.023486, -113.068758
Production Ponds 12 West 24 South 3 38.755169, -113.184346
Purge Brine Storage Pond 12 West 24 South 5 38.748822, -113.218740
Processing Facilities 12 West 24 South 16 38.722068, -113.199777

This permit is based on representation made by the Permittee and other information contained in the
administrative record. It is the responsibility of the Permittee to read and understand all provisions of this
permit.

The facility shall be constructed and operated in accordance with conditions set forth in the permit and the
Utah Administrative Rules for Ground Water Quality Protection (UAC R317-6).

This permit shall become effective on *****.

This permit and authorization to operate shall expire at midnight ****.

___________________________________________
John Mackey, P.E.
Director
Utah Division of Water Quality

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TABLE OF CONTENTS

PART I SPECIFIC PERMIT CONDITIONS .............................................................................. 3
A. Ground Water Classification............................................................................................... 3
B. Ground Water Protection Levels ........................................................................................ 3
C. Permitted Facilities and Best Available Technology (BAT) Standard ............................... 5
D. Compliance Monitoring Requirements ............................................................................... 5
E. Non-Compliance Status ...................................................................................................... 6
F. Reporting Requirements ..................................................................................................... 8
PART II MONITORING, RECORDING AND REPORTING REQUIREMENTS ................ 10
A. Representative Sampling .................................................................................................. 10
B. Analytical Procedures ....................................................................................................... 10
C. Penalties for Tampering .................................................................................................... 10
D. Reporting of Monitoring Results ...................................................................................... 10
E. Compliance Schedules ...................................................................................................... 10
F. Additional Monitoring by the Permittee ........................................................................... 10
G. Records Contents .............................................................................................................. 10
H. Retention of Records ........................................................................................................ 11
I. Twenty-four Hour Notice of Noncompliance Reporting .................................................. 11
J. Other Noncompliance Reporting ...................................................................................... 11
K. Inspection and Entry ......................................................................................................... 11
PART III COMPLIANCE RESPONSIBILITIES ........................................................................ 12
A. Duty to Comply ................................................................................................................ 12
B. Penalties for Violations of Permit Conditions .................................................................. 12
C. Need to Halt or Reduce Activity not a Defense ................................................................ 12
D. Duty to Mitigate ................................................................................................................ 12
E. Proper Operation and Maintenance .................................................................................. 12
PART IV GENERAL REQUIREMENTS ..................................................................................... 13
A. Planned Changes ............................................................................................................... 13
B. Anticipated Noncompliance.............................................................................................. 13
C. Permit Actions .................................................................................................................. 13
D. Duty to Reapply ................................................................................................................ 13
E. Duty to Provide Information ............................................................................................. 13
F. Other Information ............................................................................................................. 13
G. Signatory Requirements .................................................................................................... 13
H. Penalties for Falsification of Reports ................................................................................ 14
I. Availability of Reports ...................................................................................................... 14
J. Property Rights ................................................................................................................. 14
K. Severability ....................................................................................................................... 14
L. Transfers ........................................................................................................................... 14
M. State Laws ......................................................................................................................... 15
N. Reopener Provision ........................................................................................................... 15

Tables Table 1 Compliance Monitoring Report Schedule

Attachments
Appendix A Combined Sampling and Analysis Plan & Quality Assurance Project
Appendix B Interim Protection Levels

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PART I SPECIFIC PERMIT CONDITIONS

A. GROUND WATER CLASSIFICATION
Based on ground water quality data submitted in the permit application and ground water
classification terms established in Utah Administrative Code (UAC) R317-6-3, ground water at the
Sevier Playa site is defined as Class IV Saline Ground Water.

Ground water from 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.

B. GROUND WATER PROTECTION LEVELS

1. Ground Water Quality Standards - The Permittee shall comply with all Ground Water
Quality Standards in R317-6-2 of the Utah Ground Water Quality Protection Rules (UAC
R317-6). The ground water around the site must comply with the applicable protection
level for each of the standards contained in R317-6-2 even though this permit does not
require monitoring for each specific chemical listed in the Rules. Therefore, the Permittee
shall not contaminate ground water by discharging compounds such as metals, leach ates,
acid, pesticides or volatile organic compounds not specified in the permit.

2. Ground Water Protection Levels

a. Class IA Ground Water - In accordance with UAC R317-6-4.2, Class IA ground water
will be protected to the maximum extent feasible from degradation due to facilities that
discharge or would probably discharge to ground water. Class IA protection levels are
established in accordance with the following criteria in UAC R317-6-4.2B:
i. Total dissolved solids may not exceed the greater of 1.25 times the background
or background plus two standard deviations.
ii. When a contaminant is not present in a detectable amount as a background
concentration, the concentration of the pollutant may not exceed the greater of
0.1 times the ground water quality standard value, or the limit of detection.
iii. When a contaminant is present in a detectable amount as a background
concentration, the concentration of the pollutant may not exceed the greater of
1.25 times the background concentration, 0.25 times the ground water quality
standard, or background plus two standard deviations; however, in no case will
the concentration of a pollutant be allowed to exceed the ground water quality
standard.

b. Class II Ground Water - In accordance with UAC R317-6-4.5, Class II ground water
will be protected for use as drinking water or other similar beneficial use with
conventional treatment prior to use. Class II protection levels are established in
accordance with the following criteria in UAC R317-6-4.5B:
i. Total dissolved solids may not exceed the greater of 1.25 times the background
value or background plus two standard deviations.
ii. When a contaminant is not present in a detectable amount as a background
concentration, the concentration of the pollutant may not exceed the greater of
0.25 times the ground water quality standard, or the limit of detection.
iii. When a contaminant is present in a detectable amount as a background
concentration, the concentration of the pollutant may not exceed the greater of

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1.25 times the background concentration, 0.25 times the ground water quality
standard, or background plus two standard deviations; however, in no case will
the concentration of a pollutant be allowed to exceed the ground water quality
standard.

c. Class III Ground Water - In accordance with UAC R317-6-4.6, Class III ground water
will be protected as a potential source of drinking water, after substantial treatment,
and as a source of water for industry and agriculture. Class III protection levels are
established in accordance with the following criteria in UAC R317-6-4.6B:
i. Total dissolved solids may not exceed the greater of 1.25 times the background
concentration level or background plus two standard deviations.
ii. When a contaminant is not present in a detectable amount as a background
concentration, the concentration of the pollutant may not exceed the greater of
0.5 times the ground water quality standard, or the limit of detection.
iii. When a contaminant is present in a detectable amount as a background
concentration, the concentration of the pollutant may not exceed the greater of
1.5 times the background concentration or 0.5 times the ground water quality
standard or background plus two standard deviations; however, in no case will
the concentration of a pollutant be allowed to exceed the ground water quality
standard. If the background concentration exceeds the ground water quality
standard no statistically significant increase will be allowed.

d. Class IV Ground Water - In accordance with UAC R317-6-4.7, protection levels for
Class IV ground water will be established to protect human health and the environment.
Class IV protection levels are established in accordance with the criteria in UAC R317-
6-4.7:
i. Total dissolved solids may not exceed 1.5 times the background concentration
level.
ii. 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.

e. Background Ground Water Quality – Background ground water quality will be
established for each well location using the methods and protocols described in the
Appendix A (Water Monitoring Plan for the Sevier Playa Potash Project, Stantec
November 2023).
i. Baseline ground water quality will be established at 16 existing and 10
proposed ground water wells located throughout the project area described in
Appendix A (Water Monitoring Plan for the Sevier Playa Potash Project,
Table 3-2, Groundwater Monitoring Locations).
ii. Additional monitoring wells installed up- and downgradient of waste storage
facilities (Purge Brine Storage Pond and Tailings Storage Area) will also
require initial baseline monitoring off all field and laboratory parameters to
establish background water quality conditions.
iii. Background water quality and Ground Water Quality Protection Levels will
be calculated using a minimum of eight (8) independent background ground
water samples from each monitoring well.

f. Interim Protection Levels (Appendix B) – Interim ground water quality limits have

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been calculated for seven (7) representative ground water monitoring wells and a
subset of analytes using initial water quality data. Until sufficient data (minimum of
eight (8) samples) are available to calculate Ground Water Protection Levels for each
analyte at each ground water monitoring well location, facility compliance will be
assessed using the Interim Protection Levels.

C. PERMITTED FACILITIES AND BEST AVAILABLE TECHNOLOGY (BAT) STANDARD

1. Authorized Construction – Facilities that discharge, or would probably discharge,
pollutants into ground water must obtain a Constructive Permit approved by a DWQ
Engineer. A detailed engineered design shall be submitted to the Director at least 30 days
prior to the beginning of construction and must include detailed site designs stamped by a
Utah Certified Professional Engineer. Facilities that may require a Construction Permit
include:

a. Sevier River Diversion Structure,
b. Recharge Canal,
c. Extraction and Recharge Trenches,
d. Preconcentration Ponds,
e. Brine Transfer Canal,
f. Production Ponds,
g. Purge Brine Storage Pond (Waste Product Area),
h. Tailings Storage Area,
i. Salt Pads, and
j. Processing Facility

2. Best Available Technology (BAT) Performance Monitoring - Best available technology
(BAT) for the facility will be a Discharge Minimization approach. BAT monitoring will
include a minimum vertical freeboard, storage pond maximum hydraulic conductivity, and
ground water quality compliance monitoring.

a. Minimum Vertical Freeboard – a minimum of 24 inches of vertical freeboard shall
be maintained to ensure total containment of the ponds.

b. Maximum Liner Hydraulic Conductivity – Storage ponds 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).

3. Spill Containment - Any of spill purge brine off the playa surface or hazardous material
that comes into contact with the ground surface or ground water that causes pollution or
has the potential to cause pollution to waters of the State shall be reported in accordance
with Part II.I.

D. COMPLIANCE MONITORING REQUIREMENTS

1. Compliance Monitoring Points

a. Compliance Wells – Monitoring wells and Well Points will serve as ground water
compliance monitoring points for the aquifers. The monitoring wells and/or well
points will be installed before ponds are put into operation.

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b. Ground Water Monitoring Plan - All water quality monitoring shall be conducted
in accordance with the ground water monitoring plan (Appendix A).

c. Protection of Monitoring Wells - All compliance monitoring wells must be
protected from damage due to surface vehicular traffic or contamination due to
surface spills. All compliance monitoring wells shall be maintained in full
operational condition for the life of this permit. Any compliance monitoring well
that becomes damaged beyond repair or is rendered unusable for any reason will
be replaced by the Permittee within 90 days or as directed by the Director.

2. Ground Water Compliance Monitoring

a. Water Level Measurements – water level measurements shall be made in each
monitoring well prior to any well purging or collection of ground water samples.
These measurements will be made from a surveyed permanent reference point
clearly demarcated on the top of the well or surface casing. Water level
measurements will be made to the nearest 0.01 foot.

b. Ground Water Quality Samples - samples of ground water from compliance
monitoring wells will be collected for laboratory analysis on a quarterly basis.

1) Analysis by Certified Laboratories - analysis of all ground water samples
shall be performed by a laboratory certified by the Utah Department of
Health.

2) Ground Water Analytical Methods - methods used to analyze ground
water samples must comply with the following:

i) Methods cited in UAC R317-6-6.3L, and
ii) Method detection limits are less than Ground Water Protection
Levels in UAC R317-6-2.

3) Analysis Parameters - the following analyses will be conducted on all
ground water samples collected:

i) Field Parameters - pH, temperature, dissolved oxygen, turbidity
and specific conductance.
ii) Laboratory Parameters – Appendix A - Combined Sampling and
Analysis Plan and Quality Assurance Project Plan (SAP/QAPP)
for the Sevier Playa Project Table 3-2 Groundwater Analytes

E. NON-COMPLIANCE STATUS

1. Probable Out-of-Compliance Status - The Permittee shall evaluate results of each ground
water sampling event to determine any exceedance of the Interim Protection Levels
(Appendix B) or Ground Water Protection Levels found in Part I.B above. Upon
determination that an Interim Protection Level or Ground Water Protection Level has been
exceeded at any downgradient compliance monitoring well, the Permittee shall:

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a. Immediately re-sample the monitoring well(s) found to be in probable out-of-
compliance status for laboratory analysis of the exceeded protection level parameter(s).
Submit the analytical results thereof, and notify the Director of the probable out -of-
compliance status within 30 days of the initial detection.

b. Upon exceedance of an Interim Protection Level (Appendix B) for two consecutive
sampling events, immediately report the results of this sampling to the Director as soon
as they are available, but not later than 30 days from each date of sampling. Site
conditions and activities will be assessed to determine potential sources of the Interim
Protection Level exceedances. If facility operations are determined to be a source or
potential source of exceedance, accelerated monthly sampling, source and contaminant
assessment and corrective action may be required by the Director.

c. Upon exceedance a Ground Water Protection Level of any one analyte listed in
Appendix A – SAP/QAPP Table 3-2 for two consecutive sampling events,
immediately implement an accelerated schedule of monthly sampling analysis,
consistent with the requirements of this permit. This monthly sampling will continue
for at least two months or until the compliance status can be determined by the
Director. Reports of the results of this sampling will be submitted to the Director as
soon as they are available, but not later than 30 days from each date of sampling.

2. Out-of-Compliance Status Based on Confirmed Exceedance of Permit Ground Water
Protection Levels

a. Out of Compliance Status shall be defined as follows:
For parameters that have been defined as detectable in the ground water
and for which protection levels have been established, out-of-compliance
shall be defined as two consecutive samples exceeding the protection
level.
b. Notification and Accelerated Monitoring - upon determination by the Permittee or
the Director, in accordance with UAC R317-6-6.17, that an out-of-compliance
status exists, the Permittee shall:

1) Verbally notify the Director of the out-of-compliance status or acknowledge
Director Notice that such a status exists within 24 hours of receipt of data, and

2) Provide written notice within 5 days of the determination, and

3) Continue an accelerated schedule of monthly ground water monitoring for
at least two months and continue monthly monitoring until the facility is
brought into compliance, or as determined by the Director.

c. Source and Contamination Assessment Study Plan - within 30 days after the
written notice to the Director required in Part II.E.2.b.2, above, the Permittee shall
submit an assessment study plan and compliance schedule for:

1) Assessment of the source or cause of the contamination, and determination
of steps necessary to correct the source.

2) Assessment of the extent of the ground water contamination and any
potential dispersion.

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3) Evaluation of potential remedial actions to restore and maintain ground
water quality, and ensure that the ground water standards will not be
exceeded at the compliance monitoring wells.

3. Out-of-Compliance Status Based Upon Failure To Maintain Best Available Technology -
In the event that BAT monitoring indicates a violation of any of the construction or
performance standards outlined in Part I.C or I.D of this permit, the Permittee shall submit
to the Director a notification and description of the violation in accordance with Part II.I of
this permit.

F. REPORTING REQUIREMENTS

1. Quarterly Ground Water Monitoring - monitoring required in Part I.D.2 above shall be
reported according to the schedule in Table 1 below, unless modified by the Director:

Table 1: Compliance Monitoring Report Schedule

Quarter Report Due Date

1st (January, February, March) April 30th
2nd (April, May, June) July 31st
3rd (July, August, September) October 31st
4th (October, November, December) January 31st

2. Water Level Measurements - water level measurements from ground water monitoring
wells will be reported as measured depth to ground water from the surveyed casing
measuring point, and ground water elevations as converted by casing measuring point
elevations.

3. Ground Water Quality Sampling - reporting will include:

a. Field Data Sheets - or copies thereof, including the field measurements, required in
Part I.D.2. above, and other pertinent field data, such as: well name/number, date and
time, names of sampling crew, type of sampling pump or bail, volume of water purged
before sampling.
b. Laboratory Analytical Reports - including date sampled, date received; and the results
of analysis for each parameter, including: value or concentration, units of
measurement, reporting limit (minimum detection limit for the examination),
analytical method, and the date of the analysis.
c. Summary of observed field conditions, groundwater depths and flow direction(s),
tabulation of current and historical laboratory analytical data, and ground water quality
trends and compliance.

4. Electronic Filing Requirements - In addition to submittal of the hard copy data, above, the
Permittee will electronically submit the required ground water monitoring data in the
electronic format specified by the Director. The data may be submitted by e-mail, compact
disc, or other approved transmittal mechanism.

5. Monitoring Well As-Built Report - For each well constructed, the Permittee shall submit
diagrams and descriptions of the final completion of the monitoring wells. T he report is
due within 60 days of the date of well completion. The report shall include:

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a. Casing: depth, diameter, and type of material.
b. Screen: length, depth interval, diameter, material type, slot size.
c. Sand Pack: depth interval, material type and grain size.
d. Annular Seals: depth interval, material type.
e. Surface Casing and Cap: depth, diameter, material type, protection measures
constructed.
f. Elevation and Well Location: ground surface elevation, elevation of water level
measuring point, latitude and longitude in hours, minutes and seconds.
g. Well construction description, well completion description, results of well pump
tests or slug tests.

6. 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. The Permittee shall
resubmit Final Closure Plans within 60 days of receipt of written notice of deficiencies
therein. Any material changes made to this plan shall require final approval of the Director.

Part II
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PART II MONITORING, RECORDING AND REPORTING REQUIREMENTS

A. REPRESENTATIVE SAMPLING
Samples taken in compliance with the monitoring requirements established under Part I shall be
representative of the monitored activity.

B. ANALYTICAL PROCEDURES
Water sample analysis must be conducted according to test procedures specified under UAC R317-
6-6.3.L, unless other test procedures have been specified in this permit.

C. PENALTIES FOR TAMPERING
The Act provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any
monitoring device or method required to be maintained under this permit shall, upon conviction,
be punished by a fine of not more than $10,000 per violation, or by imprisonment for not more than
six months per violation, or by both.

D. REPORTING OF MONITORING RESULTS
Monitoring results obtained during each reporting period specified in the permit, shall be submitted
to the Director, Utah Division of Water Quality at the following address:

State of Utah
Division of Water Quality
PO Box 144870
Salt Lake City, Utah 84114-4870
Attention: Ground Water Protection Section
or
Electronic reporting:
https://deq.utah.gov/water-quality/water-quality-electronic-submissions

E. COMPLIANCE SCHEDULES
Reports of compliance or noncompliance with, or any progress reports on interim and final
requirements contained in any Compliance Schedule of this permit shall be submitted no later than
14 days following each schedule date.

F. ADDITIONAL MONITORING BY THE PERMITTEE
If the Permittee monitors any pollutant more frequently than required by this permit, using
approved test procedures as specified in this permit, the results of this monitoring shall be included
in the calculation and reporting of the data submitted. Such increased frequency shall also be
indicated.

G. RECORDS CONTENTS
Records of monitoring information shall include:

1. The date, exact place, and time of sampling or measurements:
2. The individual(s) who performed the sampling or measurements;
3. The date(s) and time(s) analyses were performed;
4. The individual(s) who performed the analyses;
5. The analytical techniques or methods used; and,
6. The results of such analyses.

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H. RETENTION OF RECORDS
The Permittee shall retain records of all monitoring information, including all calibration and
maintenance records and copies of all reports required by this permit, and records of all data used
to complete the application for this permit, for a period of at least five years from the date of the
sample, measurement, report or application. This period may be extended by request of the Director
at any time.

I. TWENTY-FOUR HOUR NOTICE OF NONCOMPLIANCE REPORTING
1. The Permittee shall verbally report any noncompliance which may endanger public health
or the environment as soon as possible, but no later than twenty-four (24) hours from the
time the Permittee first became aware of the circumstances. The report shall be made to
the Utah Department of Environmental Quality 24-hour number, [phone], or to the
Division of Water Quality, Ground Water Protection Section at [phone], during
normal business hours (Monday through Friday 8:00 am - 5:00 pm Mountain Time).

2. A written submission shall also be provided to the Director within five (5) days of the time
that the Permittee becomes aware of the circumstances. The written submission shall
contain:

a. A description of the noncompliance and its cause;
b. The period of noncompliance, including exact dates and times;
c. The estimated time noncompliance is expected to continue if it has not been
corrected; and,
d. Steps taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance.

3. Reports shall be submitted to the addresses in Part II.D, Reporting of Monitoring Results.

J. OTHER NONCOMPLIANCE REPORTING
Instances of noncompliance not required to be reported within 24 hours, shall be reported at the
time that reports for Part II.E are submitted.

K. INSPECTION AND ENTRY
The Permittee shall allow the Director, or an authorized representative, upon the presentation of
credentials and other documents as may be required by law, to:

1. Enter upon the Permittee's premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions of the permit;

2. Have access to and copy, at reasonable times, any records that must be kept under the
conditions of this permit;

3. Inspect at reasonable times any facilities, equipment (including monitoring and control
equipment), practices, or operations regulated or required under this permit; and,

4. Sample or monitor at reasonable times, for the purpose of assuring permit compliance or
as otherwise authorized by the Act, any substances or parameters at any location.

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PART III COMPLIANCE RESPONSIBILITIES

A. DUTY TO COMPLY
The Permittee must comply with all conditions of this permit. Any permit noncompliance
constitutes a violation of the Act and is grounds for enforcement action; for permit termination,
revocation and reissuance, or modification; or for denial of a permit renewal application. The
Permittee shall give advance notice to the Director of any planned changes in the permitted facility
or activity which may result in noncompliance with permit requirements.

B. PENALTIES FOR VIOLATIONS OF PERMIT CONDITIONS
The Act provides that any person who violates a permit condition implementing provisions of the
Act is subject to a civil penalty not to exceed $10,000 per day of such violation. Any person who
willfully or negligently violates permit conditions is subject to a fine not exce eding $25,000 per
day of violation. Any person convicted under Section 19-5-115(2) of the Act a second time shall
be punished by a fine not exceeding $50,000 per day. Nothing in this permit shall be construed to
relieve the Permittee of the civil or criminal penalties for noncompliance.

C. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary
to halt or reduce the permitted activity in order to maintain complianc e with the conditions of this
permit.

D. DUTY TO MITIGATE
The Permittee shall take all reasonable steps to minimize or prevent any discharge in violation of
this permit which has a reasonable likelihood of adversely affecting human health or the
environment.

E. PROPER OPERATION AND MAINTENANCE
The Permittee shall at all times properly operate and maintain all facilities and systems of treatment
and control (and related appurtenances) which are installed or used by the Permittee to achieve
compliance with the conditions of this permit. Proper operation and maintenance also includes
adequate laboratory controls and quality assurance procedures. This provision requires the
operation of back-up or auxiliary facilities or similar systems which are installed by a Permittee
only when the operation is necessary to achieve compliance with the conditions of the permit.

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PART IV GENERAL REQUIREMENTS

A. PLANNED CHANGES
The Permittee shall give notice to the Director as soon as possible of any planned physical
alterations or additions to the permitted facility. Notice is required when the alteration or addition
could significantly change the nature of the facility or increase the quantity of pollutants discharged.

B. ANTICIPATED NONCOMPLIANCE
The Permittee shall give advance notice of any planned changes in the permitted facility or activity
which may result in noncompliance with permit requirements.

C. PERMIT ACTIONS
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request
by the Permittee for a permit modification, revocation and reissuance, or termination, or a
notification of planned changes or anticipated noncompliance, does not stay any permit condition.

D. DUTY TO REAPPLY
If the Permittee wishes to continue an activity regulated by this permit after the expiration date of
this permit, the Permittee must apply for and obtain a permit renewal or extension. The application
should be submitted at least 180 days before the expiration date of this permit.

E. DUTY TO PROVIDE INFORMATION
The Permittee shall furnish to the Director, within a reasonable time, any information which the
Director may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit, or to determine compliance with this permit. The Permittee shall also
furnish to the Director, upon request, copies of records required to be kept by this permit.

F. OTHER INFORMATION
When the Permittee becomes aware that it failed to submit any relevant facts in a permit application,
or submitted incorrect information in a permit application or any report to the Director, it shall
promptly submit such facts or information.

G. SIGNATORY REQUIREMENTS
All applications, reports or information submitted to the Director shall be signed and certified.

1. All permit applications shall be signed as follows:

a. For a corporation: by a responsible corporate officer;
b. For a partnership or sole proprietorship: by a general partner or the proprietor,
respectively.
c. For a municipality, State, Federal, or other public agency: by either a principal
executive officer or ranking elected official.

2. All reports required by the permit and other information requested by the Director shall be
signed by a person described above or by a duly authorized representative of that person.
A person is a duly authorized representative only if:

a. The authorization is made in writing by a person described above and submitted to
the Director, and,

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b. The authorization specified either an individual or a position having responsibility
for the overall operation of the regulated facility or activity, such as the position of
plant manager, operator of a well or a well field, superintendent, position of
equivalent responsibility, or an individual or position having overall responsibility
for environmental matters for the company. (A duly authorized representative may
thus be either a named individual or any individual occupying a named position.)

3. Changes to Authorization. If an authorization under Part IV.G.2 is no longer accurate
because a different individual or position has responsibility for the overall operation of the
facility, a new authorization satisfying the requirements of Part IV.G.2 must be submitted
to the Director prior to or together with any reports, information, or applications to be
signed by an authorized representative.

4. Certification. Any person signing a document under this section shall make the following
certification:

"I certify under penalty of law that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of
the person or persons who manage the system, or those persons directly responsible for
gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fine and imprisonment for
knowing violations."

H. PENALTIES FOR FALSIFICATION OF REPORTS
The Act provides that any person who knowingly makes any false statement, representation, or
certification in any record or other document submitted or required to be maintained under this
permit, including monitoring reports or reports of compliance or noncompliance shall, upon
conviction be punished by a fine of not more than $10,000 per violation, or by imprisonment for
not more than six months per violation, or by both.

I. AVAILABILITY OF REPORTS
Except for data determined to be confidential by the Permittee, all reports prepared in accordance
with the terms of this permit shall be available for public inspection at the offices of the Director.
As required by the Act, permit applications, permits, effluent data, and ground water quality data
shall not be considered confidential.

J. PROPERTY RIGHTS
The issuance of this permit does not convey any property rights of any sort, or any exclusive
privileges, nor does it authorize any injury to private property or any invasion of personal rights,
nor any infringement of federal, state or local laws or regulations.

K. SEVERABILITY
The provisions of this permit are severable, and if any provision of this permit, or the application
of any provision of this permit to any circumstance, is held invalid, the application of such provision
to other circumstances, and the remainder of this permit, shall not be affected thereby.

L. TRANSFERS
This permit may be automatically transferred to a new Permittee if:

Part IV
Permit No. UGW270012

15

1. The current Permittee notifies the Director at least 30 days in advance of the proposed
transfer date;
2. The notice includes a written agreement between the existing and new Permittee containing
a specific date for transfer of permit responsibility, coverage, and liability between them;
and,
3. The Director does not notify the existing Permittee and the proposed new Permittee of his
or her intent to modify, or revoke and reissue the permit. If this notice is not received, the
transfer is effective on the date specified in the agreement mentioned in Paragraph 2 above.

M. STATE LAWS
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve
the Permittee from any responsibilities, liabilities, penalties established pursuant to any applicable
state law or regulation under authority preserved by Section 19-5-115 of the Act.

N. REOPENER PROVISION
This permit may be reopened and modified (following proper administrative procedures) to include
the appropriate limitations and compliance schedule, if necessary, if one or more of the following
events occurs:

1. If new ground water standards are adopted by the Board, the permit may be
reopened and modified to extend the terms of the permit or to include pollutants
covered by new standards. The Permittee may apply for a variance under the
conditions outlined in R317-6-6.4.D.
2. If alternative compliance mechanisms are required.
3. If subsequent ground water monitoring data reveals the background water quality
values in Part I.B are not accurate.

Attachments
Permit No. UGW270012

APPENDIX A

Combined Sampling and Analysis Plan & Quality Assurance Project
Plan

(Stantec, November 2023)

COMBINED SAMPLING AND ANALYSIS PLAN &
QUALITY ASSURANCE PROJECT PLAN
PEAK MINERALS
SEVIER PLAYA POTASH PROJECT

10808 South River Front Parkway, Suite 343
South Jordan, Utah 84095

November 2023
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
i
CONTENTS
1.0 INTRODUCTION .............................................................................................................................. 1-1
1.1 Background ................................................................................................................................. 1-1
1.2 Objectives of This SAP/QAPP ..................................................................................................... 1-2
1.3 Area of Interest ............................................................................................................................ 1-3
1.4 Sampling Area Location ............................................................................................................. 1-3
1.5 Responsible Agency ................................................................................................................... 1-3
1.6 Project Organization ................................................................................................................... 1-3
2.0 BACKGROUND .................................................................................................................... 2-1
2.1 Sampling Area Description ........................................................................................................ 2-1
2.2 Operational History ..................................................................................................................... 2-1
2.3 Previous Investigations ................................................................................................................ 2-4
2.3.1 Surface Water ........................................................................................................ 2-5
2.3.2 Groundwater .......................................................................................................... 2-5
2.4 Scoping Meeting ......................................................................................................................... 2-7
2.5 Geological/Meteorological Information .................................................................................. 2-7
2.5.1 Geology .................................................................................................................. 2-7
2.5.2 Meteorology ........................................................................................................... 2-7
2.6 Impact on Human Health and/or the Environment ................................................................ 2-8
3.0 PROJECT AND DATA QUALITY OBJECTIVES ....................................................................... 3-1
3.1 Project Task and Problem Definition ......................................................................................... 3-1
3.2 Data Quality Objectives ............................................................................................................. 3-7
3.2.1 Problem Statement ................................................................................................ 3-7
3.2.2 Study Goals ............................................................................................................. 3-8
3.2.3 Information Inputs .................................................................................................. 3-9
3.2.4 Study Boundaries ................................................................................................... 3-9
3.2.5 Approach to Data Analytics .............................................................................. 3-10
3.2.6 Performance or Acceptance Criteria ............................................................... 3-11
3.2.7 Selected Sampling Design .................................................................................. 3-11
3.3 Measurement Quality Objectives ........................................................................................... 3-11
3.3.1 Precision ................................................................................................................ 3-13
3.3.2 Accuracy .............................................................................................................. 3-14
3.3.3 Representativeness .............................................................................................. 3-15
3.3.4 Completeness ...................................................................................................... 3-16
3.3.5 Comparability ...................................................................................................... 3-17
3.3.6 Sensitivity ............................................................................................................... 3-17
3.4 Data Review and Validation ................................................................................................... 3-18
3.4.1 Response Actions ................................................................................................. 3-19
3.4.2 Reconciliation with User Requirements ............................................................. 3-19
3.5 Data Management ................................................................................................................... 3-19
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
ii
3.5.1 Statistical Data Analysis ....................................................................................... 3-20
3.5.2 Data Management Process ............................................................................... 3-20
3.5.3 Data Reporting .................................................................................................... 3-21
3.6 Assessment Oversight................................................................................................................ 3-21
4.0 SAMPLING DESIGN AND RATIONALE ................................................................................. 4-1
4.1 Groundwater ............................................................................................................................... 4-1
4.1.1 Existing Wells ........................................................................................................... 4-7
4.1.2 Proposed Wells ....................................................................................................... 4-8
4.1.3 Springs ................................................................................................................... 4-12
4.2 Surface Water ............................................................................................................................ 4-13
5.0 REQUESTS FOR ANALYSES ................................................................................................... 5-1
5.1 Analysis Narrative ........................................................................................................................ 5-1
5.1.1 Surface Water ........................................................................................................ 5-1
5.1.2 Groundwater .......................................................................................................... 5-2
5.2 Analytical Laboratory ................................................................................................................. 5-3
6.0 FIELD METHODS AND PROCEDURES ................................................................................... 6-1
6.1 Monitoring Frequency ................................................................................................................. 6-1
6.2 Field Equipment ........................................................................................................................... 6-1
6.2.1 List of Equipment .................................................................................................... 6-1
6.2.2 Calibration of Field Equipment ............................................................................ 6-3
6.3 Surface Water Sampling ............................................................................................................. 6-3
6.3.1 Surface Water Quality Sample Collection .......................................................... 6-3
6.3.2 Surface Water Flow Measurement ...................................................................... 6-4
6.4 Groundwater Sampling .............................................................................................................. 6-5
6.4.1 Groundwater Level Measurement ...................................................................... 6-5
6.4.2 Groundwater Quality Sampling ........................................................................... 6-6
6.4.3 Spring Sampling ................................................................................................... 6-12
6.5 Decontamination Procedures ................................................................................................. 6-12
7.0 SAMPLE CONTAINERS, PRESERVATION, PACKAGING, AND SHIPPING ........................... 7-1
7.1 Water Sample Containers .......................................................................................................... 7-1
7.2 Packaging and Shipping ............................................................................................................ 7-1
8.0 DISPOSAL OF RESIDUAL MATERIALS ................................................................................... 8-1
9.0 SAMPLE DOCUMENTATION ................................................................................................. 9-1
9.1 Field Documentation .................................................................................................................. 9-1
9.1.1 Field Logbooks ....................................................................................................... 9-1
9.1.2 Photographs ........................................................................................................... 9-2
9.2 Sample Labeling .......................................................................................................................... 9-2
9.3 Sample Chain-Of-Custody Forms .............................................................................................. 9-3
10.0 QUALITY CONTROL .......................................................................................................... 10-1
10.1 Field Quality Control .............................................................................................................. 10-1
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
iii
10.1.1 Blind Duplicates .................................................................................................... 10-1
10.1.2 Equipment Blanks ................................................................................................. 10-1
10.1.3 Field Blanks ............................................................................................................ 10-2
10.1.4 Temperature Blanks ............................................................................................. 10-2
10.2 Laboratory Quality Control Samples ................................................................................... 10-2
10.2.1 Method Blank ....................................................................................................... 10-2
10.2.2 Laboratory Duplicate .......................................................................................... 10-2
10.2.3 Laboratory Control Sample ................................................................................ 10-3
10.2.4 MS/MSD Duplicates ............................................................................................. 10-3
11.0 FIELD VARIANCES ............................................................................................................ 11-1
12.0 FIELD HEALTH AND SAFETY PROCEDURES ...................................................................... 12-1
13.0 REFERENCES ..................................................................................................................... 13-1
TABLES
Table 1-1. Distribution List ........................................................................................................................... 1-5
Table 3-1. Surface Water Analytes ........................................................................................................... 3-3
Table 3-2. Groundwater Analytes ............................................................................................................ 3-5
Table 3-3. Data Quality Indicators Measurement Performance Criteria .......................................... 3-12
Table 4-1. Baseline Groundwater Monitoring Sites ................................................................................ 4-3
Table 6-1. Equipment List ........................................................................................................................... 6-2
FIGURES
Figure 1-1. Project Personnel Organization Chart
Figure 2-1. Regional Vicinity
Figure 2-2. Project Area
Figure 4-1. Surface and Groundwater Monitoring Network
Figure 4-2. Typical Well Monitoring Section
APPENDICES
Appendix A. Water Quality Criteria
Appendix B. Laboratory QA/QC Program
Appendix C. Standard Operating Procedures
Appendix D. Field Equipment Specifications
Appendix E. Field Forms
Appendix F. Chain-of-Custody Forms
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
iv
ABBREVIATIONS
µg/l Micrograms per liter
AMSL above mean sea level
ASTM American Society of Testing Materials
BLM U.S. Bureau of Land Management
BTOC below top of casing
CCVs Continuing Calibration Verification Standards
CDFM Corehole Dynamic Flowmeter
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
cfs cubic feet per second
CoC Chain of Custody
DO dissolved oxygen
DQI Data Quality Indicators
DQO Data Quality Objectives
EPA U.S. Environmental Protection Agency
ft foot/feet
HSU Hydrostratigraphic unit
ICV Initial calibration value
ITRC Interstate Technology and Regulatory Council
K2SO4 Potassium sulfate
LCS laboratory control sample
LCSD Laboratory Control Sample Duplicates
LMS Laboratory matrix spike
LMSD Laboratory Matrix Spike Duplicates
MDL method (or minimum) detection limit
mg/l milligrams per liter
ml milliliter
MQO Measurement Quality Objectives
MS matrix spikes
MS/MSD matrix spike/matrix spike duplicate
MTM Monitoring Task Manager
NELAP National Environmental Accreditation Program
NTU Nephelometric Turbidity Units
Pace Pace Laboratories, formerly ESC Lab Sciences
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
v
Peak Minerals Peak Minerals Inc. (DBA “Peak Minerals”)
PM Project Manager
PQL practical quantitation limit
Project Sevier Playa Potash Project
PSI pounds per square inch
PVC polyvinyl chloride
QA/QC quality assurance and quality control
QAO Quality Assurance Officer
QC quality control
QCS quality control summary
RCRA Resource Conservation and Recovery Act
RPD relative percent difference
SAP Sampling Analysis Plan
SAP/QAPP Sampling and Analysis Plan/Quality Assurance Project Plan
SC Specific conductance
SITLA State of Utah School and Institutional Trust Lands Administration
SOP Sulfate of potash
SW southwest
TDS total dissolved solids
TSS total suspended solids
UAC Utah Administrative Code
UDWQ Utah Division of Water Quality
WPSA Waste Product Storage Area

Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
1-1
1.0 INTRODUCTION
1.1 Background
Peak Minerals Inc. (Peak Minerals) is proposing to construct and operate the Sevier Playa Potash
Project (Project) on federal, state, and private lands in Millard County, Utah. Peak Minerals is proposing
to construct and operate the Sevier Playa Potash Project (Sevier Playa Project, or Project) that would
be designed during Phase 1 to produce an average annual production of approximately 215,000
short United States (U.S) tons per year (tons/yr) of potash in the form of sulfate of potash (SOP, or
potassium sulfate [K2SO4]), as well as other associated mineral products. The Project’s life would be
approximately 25 years during Phase 1, with more production time and value obtained during Phase
2 activities. The Processing Facility would also produce solid magnesium chloride (MgCl2) in the form
of Bischofite flakes (2,200,000 short tons) of and liquid de-sulfatedMgCl2 brine (4,412,500 short tons)
after the production ponds have matured over the Phase 1 life of mine (LoM). Peak Minerals controls
through agreement the right to develop and operate potassium mineral leases on approximately
118,000 acres of land administered by the Bureau of Land Management (BLM), and controls through
agreement potash mineral leases on an additional approximately 6,400 acres of state lands
administered by the Utah School and Institutional Trust Lands Administration.
In general, the on-lease mining design for the Project would consist of the following three major
features: 1) a brine extraction system consisting of canals and trenches; 2) a recharge system
consisting of canals and trenches; and 3) a series of evaporation ponds consisting of
preconcentration and production ponds. The brines extracted from below the surface of the Sevier
Playa would be concentrated by solar evaporation in a series of Preconcentration Ponds. The brines
would be further evaporated and the potassium-rich salts precipitated in the Production Ponds would
be harvested and transported to an on-lease Processing Facility. The salts would be processed at the
Processing Facility to produce saleable SOP, as well as other associated mineral products.
Infrastructure to support the Project would include 1) access roads; 2) communication towers; 3)
power and communications lines; and 4) Water Supply Facilities. These components will all be located
on off-lease lands.
The Utah Division of Water Quality (“UDWQ”), as the regulatory agency with jurisdiction over
groundwater within the state, requires that a baseline assessment of the groundwater resources in the
area be prepared as part of an anticipated Groundwater Discharge Permit application. Further, the
federal lease held by Peak Minerals contains two Special Stipulations that require monitoring of
surface and groundwater in the vicinity of the Project (BLM 2011).
Special Stipulation 8 of the federal leases states:
“The Lessee at his expense, will be responsible to replace any water resources (that contain in a
base line analysis of <10,000 mg/1 TDS), that are lost or adversely affected (quality or quantity) by
their mining operations. If replacement is required, the lessee shall replace the sources with an
alternate source in the same quantity and quality to maintain existing uses. The lessee/operator
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
1-2
shall obtain sufficient base line data and monitoring in order to establish parameters to show
whether water resources are affected.”
Special Stipulation 13 of the federal leases states:
“Sufficient base line data shall be established prior to conducting any surface disturbing activity
which shall be determined necessary by the AO [Authorized Officer]. In order to accomplish this,
the lessee shall submit for review and approval by the AO a plan to analyze ground and surface
water interactions as part of any operations or exploration on the leases. The plan shall be
submitted prior to or concurrent with a Mining or Exploration plan, under 43 CFR 3592.1. The plan
shall include, but not be limited to the following items, and shall describe how the lessee proposes
to; (1) develop sufficient baseline groundwater information to document existing hydrogeology
associated with Sevier Lake basin fill and underlying carbonates, encompassing a reasonable
area of potential resources, springs, and the alluvial and bedrock aquifers. This shall include items
such as the location, size, and depth of any hole that would encounter water and/or brine as well
as any information that would be collected on each hole. (2) Determine the potential impacts to
existing water right holders, wells, wetlands, and surface and groundwater throughout their
operations. Water chemistry (including stable isotopes as necessary), estimated flow and water
quantity (water balance) shall be addressed. (3) Monitor the actual impacts to groundwater
resources throughout and surrounding the operation including but not limited to changes in
meteoric precipitation and springs, wells (base conditions, water levels, and chemistry conditions
prior to construction and monitoring after construction), wetlands, and ditches. Wells, wetlands,
and springs (at sites determined to be relevant based upon the groundwater study that would be
conducted prior to development) shall be monitored during operations in order to minimize
potential impacts to groundwater resources by allowing an early identification. Further, the plan
shall contain sufficient detail to allow it to be independently assessed and include such things as
the type of groundwater model that would be used (and/or other methods of analysis), phasing
of the analysis and proposed iterative studies. The plan shall also contain a list of people and their
qualifications to accomplish the work and a list of deliverables with a timing schedule. The lessee
shall be responsible for any cost incurred for the plan and the accomplishing of the work.”
1.2 Objectives of This SAP/QAPP
The purpose of this Sampling and Analysis Plan/Quality Assurance Project Plan (“SAP/QAPP”) is to
present methods for collecting and validating the above-required data. This SAP/QAPP provides a
description of the procedures for collecting surface and groundwater data to supplement data
collected to date; to better assess the seasonal fluctuations within the hydrologic regime; to monitor
wells, springs, and streams; and to ensure a valid data set that can be used to evaluate potential
future impacts from the proposed Project. The collection of meteorological data at the site is
discussed in the associated Water Monitoring Plan (Norwest 2019).
At the request of BLM, this plan was prepared in general accordance with guidance provided by the
U.S. Environmental Protection Agency (“EPA”) (2002 and 2012) for the preparation of Quality
Assurance Project Plans and Sampling and Analysis Plans, respectively. To avoid duplication, the
Sampling and Analysis Plan and the Quality Assurance Project Plan have been combined in this
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
1-3
document, which was organized using the template prepared by the EPA (2012). The use of this
template and guidance should not be construed as implying the Project falls under the umbrella of
the Resource Conservation and Recovery Act (“RCRA”) or the Comprehensive Environmental
Response, Compensation, and Liability Act (“CERCLA”).
1.3 Area of Interest
The area of interest associated with this SAP/QAPP consists of the Sevier Playa and adjacent areas
located in Millard County, Utah. A map showing the area of interest, together with additional
information regarding the playa and adjacent areas, is presented in Section 2.1 of this document.
1.4 Sampling Area Location
The Sevier Playa is a terminal basin located at the downstream end of the Sevier River in west-central
Utah. As a salt-encrusted and occasionally-flooded area, the playa is not in current use. Areas
adjacent to the playa are currently used as rangeland and wildlife habitat.
1.5 Responsible Agency
Monitoring activities conducted under this SAP/QAPP will be performed by or under contract to Peak
Minerals. The resulting data will be submitted to UDWQ and BLM for review to ensure that Peak Minerals
is in compliance with the requirements of the state groundwater discharge permit and the federal
lease Special Stipulations, respectively.
1.6 Project Organization
The SAP/QAPP organizational chart is presented in Figure 1-1, with the responsibilities of key Project
personnel presented below. Contact information for these individuals is presented in Table 1-1. Some
team members may be responsible for more than one position.
As significant changes to duties or personnel occur, Peak Minerals will document and append such
changes to this SAP/QAPP within 60 days of the change(s) and notify UDWQ and BLM. Where changes
do not reflect an alteration in the overall scope of the activities or a change of requirements, such
changes will be incorporated into the next required SAP/QAPP revision.
UDWQ Lead Engineer: This individual will be the primary UDWQ contact for issues related to
compliance of the Project to the UDWQ Groundwater Discharge Permit. He will review this SAP/QAPP
and will be responsible for determining compliance of the SAP/QAPP with state regulatory
requirements. He will also review future monitoring data and audit monitoring activities.
BLM Authorized Officer: The Authorized Officer will be the primary BLM contact responsible for ensuring
proper implementation of the SAP/QAPP. They will review this SAP/QAPP, audit monitoring activities,
and assess the adequacy of the resulting data for meeting the requirements of the federal lease
Special Stipulations.
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
1-4
Peak Minerals Project Manager: The Peak Minerals Project Manager (“PM”) will provide overall
direction to task managers and monitoring personnel necessary to accomplish the objectives of the
SAP/QAPP, including development and completion of the technical work scope; coordination and
execution of the scope, schedule, and budget requirements; reporting on the status of monitoring
activities; assuring that staff with appropriate technical qualifications are utilized during
implementation of the SAP/QAPP; and serving as primary liaison between Peak Minerals and the
affected agencies (UDWQ and BLM).
Monitoring Task Manager: The Monitoring Task Manager (“MTM”) is responsible for conducting and/or
oversight of field activities associated with implementation of the SAP/QAPP. Specific MTM
responsibilities include:
• Conduct or oversee installation of monitoring wells, downhole testing, and sample collection
activities and ensure that work performed by the analytical laboratories is conducted in
accordance with accepted protocols;
• Ensure that all field and data management personnel have reviewed the SAP/QAPP, are
properly trained in procedures discussed in this document, and follow established policies and
procedures;
• Review and validate testing and analytical results to ensure that the results fulfill the data
quality objectives (“DQOs”) established in the SAP/QAPP; and
• Direct or prepare annual reports in which data collection activities are summarized and the
resulting data are presented.

Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
1-5
Figure 1-1. Project Personnel Organization Chart

Table 1-1. Distribution List
Position Agency Contact Information
BLM Authorized Officer BLM Phone: [phone]
UDWQ Lead Engineer UDWQ Phone: [phone]
PM Project Manager Peak Minerals Phone: [phone]
PM Quality Assurance
Officer Peak Minerals Phone: [phone]
Monitoring Task Manager Johnston-Leigh Phone: [phone]
Project Reviewer Stantec Phone: [phone]
Pace Laboratory Manager Pace Laboratories Phone: [phone]
UDWQ
Oversight Engineer
BLM
Authorized Officer
PM
Project Manager
Monitoring
Task Manager
PM Quality Assurance
Officer
Project Reviewer
AWAL Laboratory
Manager
Pace
Laboratory Manager
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
1-6
Peak Minerals Quality Assurance Officer: The Quality Assurance Officer (“QAO”) will oversee
implementation of the SAP/QAPP and ensure that all analytical data generated thereby are
validated according to appropriate procedures. Specific responsibilities of the QAO include:
• Provide independent QA oversight during implementation of the SAP/QAPP;
• Review logbooks, chain-of-custody forms, and laboratory analytical reports to determine if
data meet the requirements of the SAP/QAPP;
• Maintain an accurate and complete database of all analytical and other data generated
during implementation of the SAP/QAPP;
• Assess analytical data to determine if the data meet appropriate measurement quality
objectives (“MQOs”);
• Report data quality issues, quality control (“QC”) concerns, and data non-conformance to
established standards to the PM and DM;
• Periodically review the groundwater and surface water sampling program, analytical results,
and data validation procedures for conformance to protocols and standards established in
the SAP/QAPP; and
• Specify corrective actions to be taken in the event of QC failures or non-conformance to
protocols and standards specified in the SAP/QAPP.
Project Reviewer: The Project Reviewer will provide oversight of technical and quality assurance efforts
during implementation of the SAP/QAPP. They will also assist in the preparation of future updates to
the SAP/QAPP as needed.
Laboratory Manager: The laboratories that may work on this Project are Pace Lab Sciences, formerly
ESC Labs. The laboratory manager will be responsible for ensuring that all quality assurance/quality
control procedures are implemented in accordance with in-house plans and this SAP/QAPP. They will
also serve as the primary point of contact between Peak Minerals, its contractors, and the laboratory
if questions arise during the data validation process.

Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
2-1
2.0 BACKGROUND
2.1 Sampling Area Description
The Sevier Playa is located in west-central Utah approximately 140 miles southwest of Salt Lake City
and about midway between the towns of Delta (30 miles to the northeast) and Milford (25 miles to
the south-southeast) (Figures 2-1 and 2-2). The playa is approximately 26 miles long by an average of
8 miles wide and covers approximately 130,000 acres at an average elevation of about 4,514 feet
above mean sea level. The center of the playa is located at about latitude 38.921o North, longitude
113.134o West.
The area of interest associated with this SAP/QAPP is shown in Figure 4-1. This area extends generally
three to four miles beyond the lease area on the west, south, and east sides of the playa, with the
western boundary of the area extending into the foothills of the House Range and Black Hills, the
eastern boundary extending to the ridge of the Cricket Mountains, and the southern boundary
extending to the foothills of the San Francisco Range. On the north, the area of interest extends north
of US Highway 6/50 and northeast to Conks Dam. This area is considered sufficient to monitor the
potential hydrologic impacts of the Project, as further explained in the companion Water Monitoring
Plan (Peak Minerals, 2023).
2.2 Operational History
According to Brebner et al. (2018), a prior developer of the Sevier Playa assembled a lease position
in 1978 that encompassed the entire surface of the Sevier Playa, including the current Project area.
This company carried out significant site activities through 1990 focused on resource characterization
and measurement of climatic conditions. These leases were eventually relinquished back to the
resource owners.
Peak Minerals was granted potash leases from SITLA in 2008 and installed wells in the southern portion
of the playa to monitor and confirm brine chemistry. Peak Minerals also controls development rights
to federal potassium leases from BLM by competitive bid in 2011. Since then, Peak Minerals has
focused its efforts on further evaluation of the mineral potential of the playa and obtaining the permits
necessary to begin extraction of the playa’s resources. This has included drilling of more than 400
boreholes and the installation and testing of over 90 wells. The wells and borings have concentrated
on conditions within the upper 100 feet of the playa surface, but several boreholes have also been
completed to depths up to 500 feet below ground surface to evaluate the stratigraphy of the playa.

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Disclaimer: This document has been prepared based on information provided by others as cited in the Notes section. Stantec has not verified the accuracy and/or completeness of this information and shall not be responsible for any errors
or omissions which may be incorporated herein as a result. Stantec assumes no responsibility for data supplied in electronic format, and the recipient accepts full responsibility for verifying the accuracy and completeness of the data.
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1. Coordinate System: NAD 1983 UTM Zone 12N
2. Data Sources: Peak Minerals Inc.
3. Background: Sources: Esri, USGS, NOAA
(At original document size of 8.5x11)
1 in = 25 Miles
0 12.5 25
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Drawn by JT on 2023-09-20
TR by BT on 2023-09-20
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Peak Minerals Inc.
Sevier Playa Project
SAP and QAPP
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2-1
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Lake
Playa
JUAB COUNTY
MILLARD COUNTY
BEAVER COUNTY
MILLARD COUNTY
Disclaimer: This document has been prepared based on information provided by others as cited in the Notes section. Stantec has not verified the accuracy and/or completeness of this information and shall not be responsible for any errors or omissions which may be incorporated herein as a result. Stantec assumes
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Client/Project
Figure No.
Project Location
Title
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Legend
Sevier Playa Boundary
BLM and SITLA Lease Boundary
Notes
1. Coordinate System: NAD 1983 UTM Zone 12N
2. Data Sources: Peak Minerals Inc.
3. Background: Utah Geospatial Resource Center, Esri, HERE, Garmin,
SafeGraph, FAO, METI/NASA, USGS, Bureau of Land Management, EPA,
NPS, Esri, CGIAR, USGS, Sources: Esri, Garmin, USGS, NPS
(At original document size of 11x17)
1 in = 10 Miles
0 5 10
Miles
Drawn by JT on 2023-09-20
TR by BT on 2023-09-20
IR by SM on 2023-09-20
Millard County, UT
182923537
Peak Minerals Inc.
Sevier Playa Project
SAP and QAPP
Project Area
2-2
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
2-4
2.3 Previous Investigations
Peak Minerals began monitoring groundwater beneath and adjacent to the Sevier Playa in 2011 with
the installation of a monitoring well network, refurbishment of existing wells, performance of hydrologic
testing, and monitoring of groundwater levels and water quality. This effort was expanded in 2012 to
include monitoring of discharge and water quality in the Sevier River.
Whetstone (2017) prepared a summary of publicly available and site-specific data for the playa
available through 2013 as well as select data through 2015. Norwest Corporation subsequently
prepared a Technical Memorandum (Norwest 2018b) summarizing additional data collected from
2014 thru 2016 that were not included in the Whetstone (2017) report. These data provide a good
basic understanding of surface and groundwater quality and quantity in the area of the playa.
The State of Utah classifies surface and groundwater in UAC Title R317 based on quality and intended
use. As noted in R317-6, groundwater in the state is classified as follows:
• Class I – Includes Class IA (Pristine), Class IB (Irreplaceable), and Class IC (Ecologically
Important) groundwater. Groundwater is categorized as Class IA if the Total Dissolved Solids
(“TDS”) concentration is less than 500 milligrams per liter (mg/l) and no contaminant
concentration exceeds the standards provided in Appendix A of this plan. Class IB and Class
IC groundwater are classified based on use rather than quality.
• Class II – Groundwater of a quality sufficient for human consumption. The TDS concentration
of this water is between 500 and 3,000 mg/l, and no constituent concentration may exceed
the standards provided in Appendix A of this plan.
• Class III – Limited Use groundwater. This classification is reserved for groundwater with a TDS
concentration between 3,000 and 10,000 mg/l or where the concentration of one or more of
the contaminants listed in Appendix A exceeds the associated standard.
• Class IV – Saline groundwater. The TDS concentration of this class of groundwater is greater
than 10,000 mg/l.
UAC Title R317-2 classifies surface water based on location and Beneficial Use. According to R317-2-
13.6, the Sevier River from the Sevier Playa upstream to Gunnison Bend Reservoir (located about 27
miles northeast of the northern end of the Sevier Playa) is classified for protection of the following uses:
• Class 2B – Infrequent primary contact for recreation as well as secondary contact recreation
where there is a low likelihood of ingestion of water or a low degree of bodily contact with the
water (such as wading, hunting, and fishing);
• Class 3C – Non-game fisheries and aquatic life, including the necessary organisms in their food
chain; and
• Class 4 – Agricultural uses including irrigation of crops and stock watering.
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
2-5
Appendix A provides a list of the water-quality standards for these classifications of surface water as
contained in UAC Title R317-2-14.
The data from Whetstone (2017) and Norwest (2018b) provide an understanding of the quality and
quantity of surface and groundwater in and around the playa. From these data, the state
classification and condition of waters in and around the playa can be identified. Based on the data
collected to date, surface and groundwater resources within and adjacent to the Sevier Playa can
be summarized as follows:
2.3.1 Surface Water
• Under current water use conditions, the majority of the Sevier River flow is diverted upstream
from the playa for various beneficial uses. As a result, flows in the lower Sevier River toward the
playa are infrequent and consist primarily of irrigation return flows. Infrequent flooding occurs,
generally resulting from snowmelt during high precipitation years.
• Runoff from the ephemeral watersheds surrounding the playa is typically lost to infiltration and
evaporation as it flows downstream toward the playa. Only during high-intensity precipitation
or substantial snowmelt events does runoff reach the playa from these ephemeral watersheds.
• During high flow years, the flow in the Sevier River below Conks Dam (located about 22 miles
northeast of the northern end of the Sevier Playa) occasionally exceeds channel capacity.
During normal years, the Sevier River is typically dry below Conks Dam except for a 6-mile
reach above Crafts Lake which, based on mapping by the U.S. Geological Survey, flows
perennially.
• During years when surface flow exists within the lower Sevier River, the quality of this surface
water is relatively poor, with TDS concentrations often exceeding 3,000 mg/l. This water tends
to be a well-buffered sodium-chloride type. The highest TDS concentrations typically occur in
late fall and winter (October through March) with occasional secondary peaks in April or May.
The TDS concentration of the river water is typically greater than the surface water agricultural
standard (Class 4) of 1,200 mg/l at monitoring points closest to the playa.
• Water in the lower Sevier River sporadically exceeds state surface water quality standards
listed in UAC Title R317-2 for cadmium, lead, mercury, selenium, silver, zinc, and pH.
2.3.2 Groundwater
• Groundwater within the area of interest occurs in three hydrostratigraphic units: the playa
groundwater system, the alluvial/colluvial groundwater system, and the regional bedrock
groundwater system.
• The playa groundwater system occurs in playa sediments that consist generally of very fine-
grained clays with local, discontinuous interbeds of silts, sands, and gravel that extend laterally
into the playa sediments from the mountain ranges on both sides of the playa. The production
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
2-6
zone for the Project is generally considered to be the upper 90 to 95 feet of playa sediments.
Below this depth, the playa sediments are typically hard and dry.
• The alluvial/colluvial groundwater system occurs in sediments on slopes adjacent to the playa.
These sediments consist of interbedded sand, silt, and clay of variable composition and
thickness. The alluvial/colluvial sediments often interbed with the playa sediments near the
edges of the playa.
• The regional bedrock groundwater system occurs in the Prospect Mountain Quartzite in the
Cricket Mountains east of the playa, the Notch Peak Limestone in the House Range/Black Hills
west of the playa, and either the Prospect Mountain Quartzite or Mutual Formation on the
south. Structurally, the playa formed in a depression created by down-dropped faulting where
the sediments collected.
• Groundwater quality in the aquifers within the area of interest ranges from Class I near the
ridges of the adjacent mountains to Class IV adjacent to and within the playa groundwater
system.
• Within the regional bedrock system, groundwater flows beneath the playa generally from east
to west in the area of interest. Within the alluvial/colluvial system, groundwater recharges the
regional bedrock system and flows toward to the playa.
• Whetstone (2017) and Norwest (2018b) interpreted differently the extent to which
alluvial/colluvial groundwater on the west side of the playa flows toward the playa and the
degree of interaction between the playa and regional bedrock groundwater systems. It is
anticipated that data collected under the SAP/QAPP will assist in better defining these
systems.
• Well testing has determined that groundwater flow velocities within the area of interest are
relatively high in the regional bedrock system, moderate in the alluvial/ colluvial strata, and
very low in the clayey playa deposits.
• The groundwater chemistry of the regional bedrock system varies depending on the
formation, ranging from a sodium-chloride water type to a calcium-bicarbonate to calcium-
chloride water type. Whetstone (2017) pointed out that groundwater in the regional bedrock
system meets state Class I water quality standards in the area of interest.
• Alluvial/colluvial aquifers in the area of interest have groundwater chemistry of a sodium-
chloride to a sodium-sulfate water type. Groundwater samples for the unconsolidated
deposits typically meet numerical groundwater standards listed in Appendix A, with the
exceptions of parameters for fluoride, arsenic, and pH. These waters are generally categorized
as Class III waters.
• Groundwater within the playa sediments is a sodium-chloride water type. Due to TDS
concentrations above 10,000 mg/l, these waters are categorized as Class IV under the state
standards.
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
2-7
2.4 Scoping Meeting
Multiple meetings have been held between Peak Minerals and BLM as well as Peak Minerals and
UDWQ to discuss the scope and content of this SAP/QAPP. As a result of those discussions, Norwest
(2017) submitted a 50% Framework Water Monitoring Plan to BLM on November 10, 2017. That
document consisted of a draft Sampling and Analysis Plan as well as a Quality Assurance Project Plan.
BLM and its contractors (ENValue and Whetstone Associates) provided comments on that plan on
June 25, 2019.
Peak Minerals then held a meeting with BLM on April 17, 2018, to further discuss the scope of the
document that would be needed to meet the requirements of the federal lease Special Stipulations.
Dan Hall, of UDWQ, attended a portion of the meeting to discuss UDWQ’s position on the scope that
they require. This SAP/QAPP addresses that combined scope. BLM and its contractors approved the
SAP/QAPP on June 25, 2019.
2.5 Geological/Meteorological Information
2.5.1 Geology
A good summary of the geology of the area of interest is provided by Whetstone (2017). As indicated
therein, the Sevier Playa is located in an east-dipping structural graben between the House Range
and Cricket Mountains. Little is known of the playa sediments below a depth of 975 feet (the greatest
depth to which a borehole has been drilled from the playa surface). However, based on data
collected from a gravity survey of the area, Case and Cook (1979) estimated that up to 4,600 feet of
“alluvium and/or volcanics” may exist beneath the east edge of the playa.
The Sevier Playa is a terminal hydrologic basin, having no exterior drainage. Given this condition,
mineral-rich brine exists within the playa sediments. This brine consists of the mineral salts that exist
naturally in the playa groundwater. The playa sediments that contain the brine are composed
primarily of clay and marl (carbonate-rich clay).
Consistent with borehole logs from Gwynn (2006) and Wilberg (1991), discontinuous stringers of coarse
alluvial/colluvial sediments have been found to extend laterally into the playa sediments. These
alluvial/colluvial deposits generally grade from coarser grained to finer grained with interbedded
distance into the playa.
Cambrian to Ordovician-age limestone, dolomite, and quartzite underlie the area of interest (Hintze
and Davis 2003). The shallowest of these bedrock layers consist of the Notch Peak Formation, which
crops out in the House Range west of the playa, and the Prospect Mountain Quartzite, which crops
out in the Cricket Mountains east of playa.
2.5.2 Meteorology
The climate of the area of interest is semi-arid. Data downloaded from the Western Regional Climate
Center indicate that the average annual precipitation at Delta, Utah is 7.89 inches, with an average
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
2-8
annual maximum temperature of 65.7oF and an average annual minimum temperature of 34.5oF. At
Milford, Utah, the average annual precipitation is reported to be 9.03 inches, with an average annual
maximum temperature of 65.5oF and an average annual minimum temperature of 33.3oF. In both
cases, March, April, May, and October are typically the wettest months while June and July are
typically the driest months.
2.6 Impact on Human Health and/or the Environment
Given the remoteness of the Project area, the lack of anthropological beneficial use of potentially
impacted surface and groundwater in the area of interest (other than for the future production of
minerals under the Project), and the innocuous nature of the minerals that will be produced, no
impacts to human health are anticipated from operation of the Project. However, impacts to the
environment may occur if TDS concentrations in surface or groundwater are elevated by Project
operations above levels that are considered safe for wildlife and agricultural (i.e., stock watering)
purposes.
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
3-1
3.0 PROJECT AND DATA QUALITY OBJECTIVES
3.1 Project Task and Problem Definition
The intent of this SAP/QAPP is to collect the necessary data to meet the requirements of a
Groundwater Discharge Permit from UDWQ and the requirements of federal lease Special Stipulations
8 and 13. UDWQ rules require an assessment of groundwater quality in the uppermost aquifer that
may be impacted by a project. UDWQ personnel have determined that aquifer to be the
alluvial/colluvial groundwater system at the edge of the playa. The BLM stipulations require that
monitoring be conducted not only in the alluvial/colluvial groundwater system but also in the regional
bedrock groundwater system.
Peak Minerals understands that, under Special Stipulation 8, it will be responsible to replace any water
resources (with baseline TDS concentrations of less than 10,000 mg/l) that are lost or adversely
affected (in quantity or quality) by Project operations (see Section 1.1). The determination of whether
a water resource has been “adversely affected” would be made through statistical comparisons of
data collected during the baseline period with that collected during the Project operational period,
as further described herein. Thus, once the baseline database is established and accepted by BLM,
that database will be used to assess the data collected during operational monitoring and to
evaluate potential Project-related impacts to surface and groundwater resources within the area of
interest.
Peak Minerals also understands that the baseline data will be compared to operational monitoring
data to determine compliance with state regulations through both direct standards comparison and
trend analysis. If Project-caused impacts are determined to have occurred, Peak Minerals will work
with the UDWQ and BLM to develop acceptable processes to reduce impacts and replace impacted
water sources as appropriate.
Based on the above, the purposes of the SAP/QAPP are to:
• Collect baseline surface and groundwater data within the area of interest;
• Develop a valid set of water quality and quantity data under natural, pre-Project conditions;
• Monitor water sources within the area of interest during operation of the Project to document
future water quality and quantity conditions; and
• Develop a valid data set that will allow a determination to be made of whether or not
operation of the Project results in changes to the quality or quantity of water in surface
resources or in the alluvial/colluvial or regional bedrock groundwater systems that require
future mitigation actions.
To date, work associated with the Project has focused on resource evaluation and environmental
monitoring. No site development or full-scale mineral production has occurred. Thus, this SAP/QAPP
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
3-2
will result in the collection of baseline data to supplement existing data and gain a better
understanding of spatial and temporal variations in surface and groundwater quality and quantity
within the area of interest.
As noted in Section 2.3, surface water within the area of interest is categorized under UDWQ
regulations as Beneficial Use Class 2B, Class 3C, and Class 4. Therefore, constituents of potential
concern in surface water within the area of interest include pH and the metals and inorganic
constituents that are regulated under Title R317-2. These analytes are listed in Table 3-1. Hexavalent
chromium and biochemical oxygen demand are not included in this table due to holding time
restrictions that cannot be met because of site remoteness. Additional parameters that are not
regulated under the Utah surface-water regulations have been added to Table 3-1, including total
suspended solids, specific conductance, various forms of alkalinity, and major cations and anions.
Concentrations of these additional analytes will be used by Peak Minerals to assist in data
interpretation and validation, as discussed in Sections 3.3 and 3.5. During the baseline monitoring
period, surface-water samples will be analyzed for the list of constituents presented in Table 3-1.
As also indicated in Section 2.3, groundwater in the area of interest is categorized as Class IA, II, III,
and IV water, depending on its location. Therefore, constituents of potential concern in groundwater
within the area of interest include pH as well as the metals and inorganic constituents that are
regulated under UAC Title R317-6. These analytes are presented in Table 3-2. As is the case with surface
water, additional analytes that are not regulated under the Utah groundwater regulations have been
added to Table 3-2 to assist in data interpretation and validation, as discussed in Sections 3.3 and 3.5.
During the baseline monitoring period, groundwater samples will be analyzed for the list of constituents
presented in Table 3-2.
The focus of this SAP/QAPP is the collection of baseline hydrologic data. During the Project operational
period, the focus of monitoring will shift to determining whether hydrologic impacts have occurred in
the area of interest as a result of Project activities. If experience indicates that future changes to the
SAP/QAPP are appropriate for the Project operational period, Peak Minerals will recommend
modifications to the SAP/QAPP. For instance, if certain parameters have not been detected during
the baseline monitoring period and nothing about Project operations suggests that these analytes
may be affected by future operations, Peak Minerals may request that these parameters be dropped
from the analytical lists contained in Tables 3-1 and 3-2. Such recommendations would be submitted
to BLM and UDWQ for approval as part of an annual report (see Section 3.5.3) before implementing
any changes.

Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
3-3
Table 3-1. Surface Water Analytes
Parameter Basis
Lowest
Standard
Class 2B,
3C, 4
Analysis
Method
Method
Detection
Limit
Practical
Quantification
Limit
Required
Preservative
Minimum
Sample
Volume
pH (su) -- 6.5–9.0 su Field 0.1 su 0.1 su Field
(none) 15 ml
Specific
Conductance
(µmhos/cm)
Dissolved -- Field 10
umhos/cm
10
umhos/cm
Field
(none) 15 ml
Total Suspended
Solids (TSS) (mg/l) Total -- 2540 D-2011 0.35 mg/l 2.5 mg/l None
250 ml TDS (measured)
(mg/l) Dissolved 2540 C-2011 2.82 mg/l 10 mg/l Cool to 4oC
TDS (calculated) -- --
Cation-Anion
Balance -- --
Alkalinity, total
(as mg/l CaCO3) Dissolved -- 2320 B-2011 2.71 mg/l 20 mg/l Cool to 4oC
60 ml
Alkalinity, carbonate
(as mg/l CaCO3) Dissolved -- 2320 B-2011 2.71 mg/l 20 mg/l Cool to 4oC
Alkalinity,
bicarbonate
(as mg/l CaCO3)
Dissolved -- 2320 B-2011 2.71 mg/l 20 mg/l Cool to 4oC
Alkalinity, hydroxide
(as mg/l CaCO3) Dissolved -- 2320 B-2011 2.71 mg/l 20 mg/l Cool to 4oC
Chloride (mg/l) Dissolved -- 9056A 0.0519 mg/l 1 mg/l Cool to 4oC
50 ml Fluoride Maximum 1.4–2.4 mg/l 9056A 0.0099 mg/l 0.1 mg/l Cool to 4oC
Sulfate (mg/l) Dissolved -- 9056A 0.0774 mg/l 5 mg/l Cool to 4oC
Nitrate+Nitrite as
nitrogen (mg/l) Dissolved -- 353.2 0.0197 mg/l 0.1 mg/l Cool to 4oC 20 ml
Phosphorous (mg/l) Dissolved -- 365.4 0.035 mg/l 0.1 mg/l H2SO4
50 ml
Aluminum (mg/l) Dissolved 0.75 mg/l 6020B 0.00515
mg/l 0.1 mg/l HNO3
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
3-4
Parameter Basis
Lowest
Standard
Class 2B,
3C, 4
Analysis
Method
Method
Detection
Limit
Practical
Quantification
Limit
Required
Preservative
Minimum
Sample
Volume
Arsenic (mg/l) Dissolved 0.1 mg/l 6010B 0.0065 mg/l 0.01 mg/l HNO3
Barium (mg/l) Dissolved -- 6010B 0.0017 mg/l 0.005 mg/l HNO3
Beryllium (mg/l) Dissolved -- 6010B 0.0007 mg/l 0.002 mg/l HNO3
Boron (mg/l) Dissolved 0.75 mg/l 6010B 0.0126 mg/l 0.2 mg/l HNO3
Cadmium (mg/l) Dissolved 0.008 mg/l (a) 6020B 0.00016
mg/l 0.001 mg/l HNO3
Calcium (mg/l) Dissolved -- 6010B 0.0463 mg/l 1 mg/l HNO3
Chromium, Total Dissolved 1.773 mg/l (a) 6010B 0.0014 mg/l 0.01 mg/l HNO3
Copper (mg/l) Dissolved 0.050 mg/l (a) 6020B 0.00052
mg/l 0.005 mg/l HNO3/l
Iron (mg/l) Dissolved 1.0 mg/l 6010B 0.0141 mg/l 0.1 mg/l HNO3
Lead (mg/l) Dissolved 0.011 mg/l 6020B 0.00024
mg/l 0.002 mg/l HNO3
Magnesium (mg/l) Dissolved -- 6010B 0.0111 mg/l 1 mg/l HNO3
Mercury (ug/l) Dissolved 0.012 ug/l 1631E 0. 0002 ug/l 0.0005 ug/l HCl
Potassium (mg/l) Dissolved -- 6010B 0.1024 mg/l 1 mg/l HNO3
Selenium (mg/l) Dissolved 0.0046 mg/l 6020B 0.00038
mg/l 0.002 mg/l HNO3
Silver (mg/l) Dissolved 0.035 mg/l (a) 6020B 0.00031
mg/l 0.002 mg/l HNO3
Sodium (mg/l) Dissolved -- 6010B 0.0985 mg/l 1 mg/l HNO3
(a) Standard is a function of hardness.
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
3-5
Table 3-2. Groundwater Analytes
Parameter Basis
Lowest
Standard
Class 1,
2, 3, or 4
Analysis
Method
Method
Detection
Limit
Practical
Quantification
Limit
Required
Preservative
Minimum
Sample
Volume
pH (su) -- 6.5–8.5
su Field 0.1 su 0.1 su Field
(none) 15 ml
Specific Conductance
(µmhos/cm) Dissolved -- Field 10
umhos/cm
10
umhos/cm
Field
(none) 15 ml
TDS (measured) (mg/l) Dissolved -- 2540 C-
2011 2.82 mg/l 10 mg/l Cool to
4oC
250 ml TDS (calculated) -- --
Cation-Anion Balance -- --
Cyanide (free) (mg/l) Dissolved 0.2 mg/l 4500CN E-
2011 0.0018 mg/l 0.005 mg/l NaOH
60 ml
Alkalinity, total (as mg/l CaCO3) Dissolved -- 2320 B-2011 2.71 mg/l 20 mg/l Cool to
4oC
Alkalinity, carbonate
(as mg/l CaCO3) Dissolved -- 2320 B-2011 2.71 mg/l 20 mg/l Cool to
4oC
Alkalinity, bicarbonate
(as mg/l CaCO3) Dissolved -- 2320 B-2011 2.71 mg/l 20 mg/l Cool to
4oC
Alkalinity, hydroxide
(as mg/l CaCO3) Dissolved -- 2320 B-2011 2.71 mg/l 20 mg/l Cool to
4oC
Chloride (mg/l) Dissolved -- 9056A 0.0519 mg/l 1 mg/l Cool to
4oC
50 ml Fluoride (mg/l) Dissolved 4.0 mg/l 9056A 0.0099 mg/l 0.1 mg/l Cool to
4oC
Sulfate (mg/l) Dissolved -- 9056A 0.0774 mg/l 5 mg/l Cool to
4oC
Nitrate+Nitrite as nitrogen (mg/l) Dissolved 10.0
mg/l 353.2 0.0197 mg/l 0.1 mg/l Cool to
4oC 20 ml
Phosphorous (mg/l) Dissolved -- 365.4 0.035 mg/l 0.1 mg/l H2SO4
50 ml
Aluminum (mg/l) Dissolved -- 6010B 0.035 mg/l 0.2 mg/l HNO3
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
3-6
Parameter Basis
Lowest
Standard
Class 1,
2, 3, or 4
Analysis
Method
Method
Detection
Limit
Practical
Quantification
Limit
Required
Preservative
Minimum
Sample
Volume
Antimony (mg/l) Dissolved 0.006
mg/l 6020B 0.000754
mg/l 0.002 mg/l HNO3
Arsenic (mg/l) Dissolved 0.05
mg/l 6010B 0.0065 mg/l 0.01 mg/l HNO3
Barium (mg/l) Dissolved 2.0 mg/l 6010B 0.0017 mg/l 0.005 mg/l HNO3
Beryllium (mg/l) Dissolved 0.004
mg/l 6010B 0.0007 mg/l 0.002 mg/l HNO3
Cadmium (mg/l) Dissolved 0.005
mg/l 6010B 0.0007 mg/l 0.002 mg/l HNO3
Calcium (mg/l) Dissolved -- 6010B 0.0463 mg/l 1 mg/l HNO3
Chromium (mg/l) Total 0.231
mg/l 6010B 0.0014 mg/l 0.01 mg/l HNO3
Copper (mg/l) Dissolved 1.3 mg/l 6010B 0.0053 mg/l 0.01 mg/l HNO3
Iron (mg/l) Dissolved -- 6010B 0.0141 mg/l 0.1 mg/l HNO3
Lead (mg/l) Dissolved 0.015
mg/l 6010B 0.0019 mg/l 0.005 mg/l HNO3
Magnesium (mg/l) Dissolved -- 6010B 0.0111 mg/l 1 mg/l HNO3
Mercury (mg/l) Dissolved 0.002
mg/l 7470A 0.000049
mg/l 0.0002 mg/l HNO3
Potassium (mg/l) Dissolved -- 6010B 0.1024 mg/l 1 mg/l HNO3
Selenium (mg/l) Dissolved 0.05
mg/l 6010B 0.0074 mg/l 0.01 mg/l HNO3
Silver (mg/l) Dissolved 0.1 mg/l 6010B 0.0028 mg/l 0.005 mg/l HNO3
Sodium (mg/l) Dissolved -- 6010B 0.0985 mg/l 1 mg/l HNO3
Thallium (mg/l) Dissolved 0.002
mg/l 6020B 0.00019 mg/l 0.002 mg/l HNO3
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
3-7
Parameter Basis
Lowest
Standard
Class 1,
2, 3, or 4
Analysis
Method
Method
Detection
Limit
Practical
Quantification
Limit
Required
Preservative
Minimum
Sample
Volume
Uranium (mg/l) Dissolved 0.030
mg/l 6020B 0.00033 mg/l 0.001 mg/l HNO3
Zinc (mg/l) Dissolved 5.0 mg/l 6010B 0.0059 g/l 0.05 mg/l HNO3
Following the collection and validation of baseline data, the purposes of hydrologic monitoring during
the operational period will be to:
• Monitor hydrologic resources within the area of interest including, but not limited to, changes
in surface water, meteoric precipitation, groundwater, wetlands, and ditches.
• Determine the impacts, if any, to existing water right holders, wetlands, surface water, and
groundwater as a result of Project operations.
3.2 Data Quality Objectives
EPA guidance identifies seven elements that should be addressed when developing DQOs for a
project (EPA 2006). These elements consist of the following:
1. State the problem
2. Identify the goals of the study
3. Identify information inputs
4. Define the boundaries of the study
5. Develop the analytic approach
6. Specify performance or acceptance criteria
7. Develop the plan for obtaining data
These elements are described in more detail below.
3.2.1 Problem Statement
In order to comply with the requirements of UDWQ and BLM, Peak Minerals will determine baseline
surface and groundwater conditions (quantity and quality) within the area of interest. These data will
be necessary to determine whether or not operation of the Project is in compliance with a future
UDWQ Groundwater Discharge Permit and Special Stipulations 8 and 13 of the federal lease.
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The conceptual hydrologic model of the area of interest is described generally in Section 2.3 of this
document. In summary, this model consists of the following:
• Surface water within the area of interest is regulated by the State of Utah for infrequent
contact recreational use, non-game fisheries and aquatic life, and agricultural use.
• Much of the surface water in the Sevier River upstream from the Sevier Playa is beneficially
used before it reaches the playa, except during periods of above-normal precipitation.
• No substantial surface runoff occurs to the playa from adjacent slopes due to the ephemeral
nature of those watersheds.
• The beneficial use of groundwater within the area of interest is regulated by the State of Utah
as a function of the baseline quality of that groundwater.
• Groundwater within the area of interest occurs in playa sediments, alluvial/colluvial sediments,
and bedrock. The classification of this groundwater, under rules promulgated by UDWQ, varies
substantially within the area of interest due primarily to a wide range of natural TDS
concentrations.
• The degree of interaction between the groundwater systems within the area of interest is not
fully defined.
The planning team, decision makers, and data users associated with this effort are presented in
Section 1.4. Peak Minerals has committed the necessary resources to implement this SAP/QAPP in a
manner that satisfies the data needs of the Project as well as the appropriate governmental agencies
(primarily UDWQ and BLM). Peak Minerals desires to begin data collection under this SAP/QAPP as
soon as practical following approval of the SAP/QAPP.
3.2.2 Study Goals
Study questions and alternative actions help establish study goals. The key study questions associated
with the SAP/QAPP are:
• What spatial and temporal variability naturally exists in the quality and quantity of surface and
ground water within the area of interest?
• What is the degree of interaction between the playa groundwater system, the
alluvial/colluvial groundwater system, and the regional bedrock groundwater system within
the area of interest?
Two alternative actions exist to address these study questions:
• Monitor the quality and quantity of surface and groundwater within the area of interest to
provide data that, when combined with historic information, will result in a better
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understanding of seasonal variations in and the degree of interaction between hydrologic
systems in the vicinity of the proposed Project, or
• Take no action.
The no-action alternative will not address either of the study questions. Therefore, the decision
statement and goal of the SAP/QAPP is to develop a valid set of surface and groundwater quality
and quantity data under natural, pre-Project conditions. These data will then be evaluated, along
with historic Peak Minerals and publicly available data from the area of interest, to define baseline
conditions and to provide a better understanding of the degree to which groundwater systems
interact within the area of interest. These data will also be used during the operational period to
determine whether or not operation of the Project has impacted local water resources to the extent
that mitigation actions are needed.
3.2.3 Information Inputs
A substantial amount of hydrologic, geologic, and other environmental and resource data has been
collected within the area of interest. These data have been generated from investigations conducted
by public entities (most notably the U.S. Geological Survey), by Peak Minerals, and by prior
investigators of the mineral reserves associated with the Sevier Playa.
This historic database has resulted in the formulation of a conceptual model of surface and
groundwater conditions within the area of interest. These historic data will be reviewed to validate
their usefulness. Historic data that are determined to be valid will be used in future decision-making.
Historic data that are determined to not be valid will be appropriately flagged.
The historic database is not sufficient to fully address the study questions contained in Section 3.2.2.
Additional surface and groundwater quality and quantity data will be required to properly address
those study questions. Tables 3-1 and 3-2 provide a list of the parameters that will be monitored on a
routine basis during the baseline data-collection period. The methods that will be used to collect the
routine data and address the study questions are outlined in Sections 4 through 6 of this SAP/QAPP.
As indicated previously in this SAP/QAPP, the baseline data will serve as a point of comparison to
determine if operation of the Project has adversely impacted surface and groundwater resources
within the area of interest. The action levels against which the baseline data will be compared are
detailed in federal lease Special Stipulations 8 and 13 and in the Groundwater Quality Discharge
Permit that will be issued by UDWQ.
3.2.4 Study Boundaries
The spatial boundary in which the SAP/QAPP will be implemented is defined as the area of interest
shown in Figure 4-1. A description of the extent of these boundaries is provided in Section 2.1.
The goal of monitoring during the baseline data-collection period will be to develop a statistically-
valid database that adequately describes pre-Project hydrologic conditions. To that end, data will
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be collected quarterly during the baseline period to assess seasonal variations in hydrologic
conditions within the area of interest.
It is currently anticipated that Project construction will begin in Spring of 2024. Since baseline
monitoring under this Plan recommenced in September 2018 and continued through June 2020, this
allowed monitoring during eight quarterly events prior to the temporary shutdown. Since the
recommencement of the monitoring in July 2023, there have been three additional quarterly sampling
events prior to the start of construction. The U.S. Environmental Protection Agency (2009) recommends
that a minimum of eight to ten independent baseline observations be collected before running most
statistical tests. Thus, the period of baseline data collection period has adequately met this
requirement.
Thus, it is concluded that enough data will be available to assess baseline conditions. Monitoring of
water resources within the area of interest during the operation period of the Project will be defined
following a review of the baseline data.
Locations within the area of interest that will be monitored are discussed in Section 4. Sampling units
from which data will be collected consist of the Sevier River and monitoring wells completed in the
playa, alluvial/colluvial, and regional bedrock groundwater systems. A limited number of samples
have also been collected from springs in the general vicinity of the playa and may be collected from
those sources in the future. Future decisions regarding the need for impact mitigation, if any, will be
made based on data collected from the location(s) of impact.
Three practical constraints exist with respect to implementation of the SAP/QAPP: (1) weather
conditions (e.g., freezing temperatures, difficult or unsafe site access, etc.), (2) access permission from
private landowners in the case of certain springs that may be monitored, and (3) vandalism of
monitoring locations. If conditions are such that collection of data from a specific location during a
particular sampling event is not feasible, these conditions will be documented and provided to UDWQ
and BLM.
3.2.5 Approach to Data Analytics
Analyses of environmental data often assume that the data follow a normal distribution. While this
may be the case for water quality and quantity data collected from the area of interest during the
baseline period, it is inappropriate to make that assumption prior to the generation of additional data.
Following the collection of baseline data, all data will be subject to the data validation process
discussed in Section 3.4. All valid data that are collected under this SAP/QAPP will be evaluated to
provide a set of statistics that are appropriate to the data distribution. For this evaluation, the data will
be grouped by individual monitoring point as well as within sampling units (e.g., all wells completed in
the alluvial/colluvial groundwater system, all samples collected from the Sevier River, etc.).
It is currently anticipated that the data will be evaluated using ProUCL (found at
https://www.epa.gov/land-research/proucl-software), a statistical data-evaluation software
package developed by the EPA, or another appropriate data evaluation package. ProUCL
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calculates basic statistics (e.g., means, median, standard deviation, etc.) as well as statistical intervals,
single and two sample hypothesis tests, analysis of variance, regression, trend evaluation, outlier, and
goodness-of-fit tests. It also provides graphical analyses, including probability plots, histograms, box
plots, and line/trend plots.
Data collected during the operational period will be compared with the baseline data to determine
if Project operations have impacted water resources within the area of interest. It is currently
anticipated that these comparisons will be made using ProUCL and an approach that is applicable
to the data statistical distribution. Comparisons will be made against the applicable UDWQ surface
and groundwater quality standards and the federal lease TDS concentration limitation of <10,000
mg/l. If impacts are determined to have occurred, then Peak Minerals will take appropriate action in
consultation with UDWQ or BLM, depending on the standard or limitation against which the impact
has been determined.
3.2.6 Performance or Acceptance Criteria
All data collected during the baseline and operational periods will undergo review and validation, as
indicated in Section 3.4. All valid data collected during the baseline and operational periods will be
accepted. Data that are not considered valid will be appropriately flagged.
3.2.7 Selected Sampling Design
Sampling under this SAP/QAPP will be performed as indicated in Sections 4 through 6. The sampling
design was selected to provide additional baseline data as well as data to determine whether or not
future impacts, if any, occur to water resources within the area of interest due to operation of the
Project.
3.3 Measurement Quality Objectives
MQOs are used to determine the viability and usability of field and laboratory data. MQOs are defined
by the criteria established for the following data quality indicators (“DQIs”):
1. Precision
2. Accuracy
3. Representativeness
4. Completeness
5. Comparability
6. Sensitivity
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MQOs represent the “acceptance criteria” for the DQI attributes and are set based on the equipment
used in field sampling and laboratory analyses. These DQIs and their associated acceptance goals
are summarized in Table 3-3 and discussed below.
Table 3-3. Data Quality Indicators Measurement Performance Criteria
Data Quality Indicator Method Quality Indicator Quality Control Sample and/or Activity
EPA Methods 9056 Cations/Anions and 6010B Metals
Accuracy Spiked result is >75% and <125% of
spiked amount in field sample matrix Matrix spike/matrix spike duplicates
Bias Quantitation within warning limits Field duplicates, matrix spike/matrix spike
duplicates
Precision 20% RPD using EPA methods 9056
and 6010B
Field duplicates, matrix spike/matrix spike
duplicates
Sensitivity MDL and RDL for all methods Laboratory analytical analyses
Representativeness Statistical evaluation design
Laboratory provision of field preservative
vials, chain of custody documentation, meet
laboratory holding times, and ensure proper
shipping procedures
Comparability N/A Adhere to SOPs and use same laboratory
Completeness 95% or higher completeness Compare total numbered of samples with
valid results to number of samples collected
Reproducibility
Ensure proper sampling depth,
sample stabilization before
collection, proper sample handling,
and meeting sample holding time
requirements
Obtaining representative samples that
ensure aquifer waters are sampled.
Validity N/A Verify WMP procedures were followed,
validate that DQI were met using MQO.
TDS Method 2540 C-2011
Accuracy Spiked result is >75% and <125% of
spiked amount in field sample matrix Matrix spike/matrix spike duplicates
Bias Quantitation within warning limits Shewhart control charts of analytical data
Precision 5% RPD using EPA method 2540 C-
2011
Field duplicates, matrix spike/matrix spike
duplicates
Sensitivity MDL and PQL for all methods Laboratory analytical analyses
Representativeness Statistical evaluation design
Laboratory provision of field preservative
vials, chain of custody documentation, meet
laboratory hold times, and ensure proper
shipping procedures
Comparability N/A Adhere to SOPs and use same laboratory
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Data Quality Indicator Method Quality Indicator Quality Control Sample and/or Activity
Completeness 95% or higher completeness Compare total number of samples with valid
results to number of samples collected
Reproducibility
Ensure proper sampling depth,
sample stabilization before
collection, proper sample handling,
and meeting sample holding time
requirements
Obtain representative samples that ensure
aquifer waters are sampled.
Validity N/A Verify QAPP procedures were followed,
validate that DQI were met using MQO.
3.3.1 Precision
Precision is a measure of the degree to which a set of observations or measurements of the same
property, obtained under similar conditions, conform internally. This indicator is used to evaluate the
variability related to sample collection and handling as well as laboratory sample handling and
analysis procedures.
Precision will be determined by analyzing field, laboratory, and matrix spike/matrix spike duplicate
(“MS/MSD”) samples. A field (or “blind”) duplicate is a sample collected in the field from the same
location and matrix at the same time as the original using the same sample collection and handling
procedures. A laboratory duplicate is a laboratory split of a submitted field sample but labeled with
a different sample number.
Blind duplicates will be collected in the field at a rate of 10 percent of the total number of samples
collected (or portion thereof) from each matrix (i.e., surface water or groundwater).
The precision of the field and analytical data will be determined by calculating the relative percent
difference between the value reported for the original sample and the value reported for the
duplicate sample as follows:
RPD = │(𝐶𝐶2−𝐶𝐶1) 𝑥𝑥 100%│((𝐶𝐶2+𝐶𝐶1)/2)
Where:
RPD = relative percent difference
C1 = analyte concentration in the original sample; and
C2 = analyte concentration in the sample duplicate.
The precision MQO goal for the SAP/QAPP is to obtain duplicate data that demonstrate a Relative
Percent Difference (“RPD”) of 20% or less for LCSDs and an RPD of 30% or less for LMSDs. The MQO goal
for field duplicate data is an RPD of less than 25% for samples with a TDS concentration of less than or
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equal to 3,000 mg/L and an RPD of less than 35% for samples with a TDS concentration of greater than
3,000 mg/L. This TDS limit was selected to be equivalent to the UDWQ Class I/Class II standard.
The smaller the RPD between the original and duplicate samples the higher precision, accuracy, and
lower the bias. Trend charts documenting the LCSD and LMSD sample results included in Quality
Control Summary of each Pace report will be used to identify results over time that are outside the
precision MQO goals outlined above.
Results outside these limits may be qualified as “estimated.”
It should be noted that RPDs outside of the above ranges often occur when dealing with low
concentrations that are near the method detection limit, particularly when the TDS concentration is
high (as will often be the case for this project). Thus, professional judgement will be exercised when
designating a result as “estimated” based on the precisions MQO.
3.3.2 Accuracy
Accuracy is the degree to which a measurement agrees with the actual value. Accuracy will be
evaluated by having the laboratory spike a field sample with a known amount of a chemical
compound. After analysis for the spike is completed, the accuracy of the laboratory measurement
will be expressed as a percent recovery as shown by the following equation:
Percent Recovery = (𝐶𝐶2−𝐶𝐶1) 𝑥𝑥 100%𝐶𝐶𝐶𝐶
Where:
C0 = amount of analyte added to the sample matrix;
C1 = amount of analyte present in the un-spiked sample matrix (equal to zero
for the standard matrix); and
C2 = amount of spiked material recovered in the analysis.
The amount of an analyte spiked into a field sample matrix is specified by the laboratory quality
control program. For data evaluation purposes, the accuracy MQO of this SAP/QAPP is to obtain
percent recovery data that are:
• Greater than 75 percent and less than 125 percent of the original concentration for
groundwater and surface water.
Results outside of these limits would be qualified as “estimated.”
Sampling accuracy will also be assessed by evaluating the results obtained by the collection and
analysis of equipment blanks (see Section 10.1.2). The presence of analytes in deionized equipment-
blank water from improper decontamination procedures will be determined and corrected
immediately.
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Accuracy is also affected by bias, which is a persistent misrepresentation of a measurement that
causes either positive (high) or negative (low) error. Bias may originate from sources such as chronic
sample interference, calibration errors, and response factor shifts. The 95 percent upper confidence
level baseline analytical results for select analytes will serve as target levels for bias determination.
Warning limits will initially be calculated by using the target value + 2 standard deviations.
The bias MQO for the SAP/QAPP are:
• Field water quality meter calibration within 5 percent of the calibration standard;
• Quantitation within warning limits; and
• Warning limits breached < 5 percent of the time.
Non-compliance with the above MQOs will require qualification of the data. Non-compliance may
also result in repair or replacement of the field instrumentation and/or additional analyses of the water
samples to determine the source of the shift above or below warning limits.
3.3.3 Representativeness
Representativeness is the degree to which data accurately and precisely represent the population.
Representativeness is usually considered a qualitative term that does not lend itself to direct
measurement. However, including it in the MQO is meant to re-enforce the goal of confirming that
measurements are made and physical samples are collected in a manner that appropriately reflects
actual conditions. This is addressed primarily in the sample design through the selection of sampling
sites and procedures that reflect the SAP/QAPP goals and environment being sampled. For instance,
under the low-flow well sampling method, the intake for each low-flow pump will be located within
the screen interval determined by field testing to be the dominant inflow zone (see Section 6.4.2.1).
Furthermore, the procedure of purging until the field parameters stabilize presumably ensures that
fluid samples are representative of the aquifer waters. Similarly, for the no-purge (in-situ equipment)
groundwater sampling method, the sample bottles will be located within a zone that has been
evaluated by down-well flow measurements to indicate that the waters within the casing interval
occupied by the in-situ sampling equipment are representative of the waters within the aquifer (see
Section 6.4.2.2).
Representativeness is ensured in the laboratory through (1) the proper handling and storage of
samples and (2) analysis within the specified holding times so that the material analyzed reflects the
material collected as accurately as possible. Sample integrity can then be documented with the
following procedures:
• Laboratory preparation of field preservation vials;
• Proper sample handling (i.e., chain of custody); and
• Evaluating holding times and condition of samples on arrival at the laboratory.
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Proper procedures will minimize the potential for alterations of the samples and ensure that samples
received by the laboratory are representative of those at the site.
3.3.4 Completeness
Field completeness is a measure of the amount of data collected compared to the amount needed
to ensure that the uncertainty or error associated with the measurement is within acceptable limits.
Analytical completeness will be assessed by comparing the total number of analytical results to the
number of samples collected.
Completeness is determined by:
C = 𝑃𝑃1 𝑥𝑥 100%𝑃𝑃𝐶𝐶
Where:
C = completeness (%)
P0 = total number of samples planned, and
P1 = number of actual data points.
The completeness MQO for the SAP/QAPP is 95 percent or higher completeness.
The completeness of the analyses will also be checked by calculating the total dissolved solids
content as a sum of the individual constituents (after mathematically converting alkalinity [as CaCO3]
to carbonate and bicarbonate) and comparing this value to the laboratory-measured TDS
concentration. The ionic charge balance error will also be calculated by comparing the molar-
equivalent concentrations of the major cations (primarily calcium, magnesium, potassium, and
sodium) with the molar-equivalent concentrations of the major anions (primarily alkalinity, chloride,
and sulfate). These calculations will be performed using dissolved constituents only. The MOQ goals
for these calculated values are:
• Calculated TDS concentration within +20% of the measured TDS concentration.
• Total cation molar-equivalent concentration within +10% of the total anion molar-equivalent
concentration.
Hem (1985) notes that the accuracy of the above comparisons can be problematic in water with
high dissolved solids contents (such as will likely occur with many of the samples that will be collected
under this SAP/QAPP). However, Hem (1985) also indicates that these comparisons tend to be
relatively consistent at individual locations, even if they fall outside of typical ranges. Therefore, values
outside of the above MQO goals will be flagged so the end user may interpret the results accordingly.
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3.3.5 Comparability
Comparability is a qualitative measure of the confidence with which one data set can be compared
to another. It is currently anticipated that samples for the same analytes will be analyzed by the same
laboratory throughout implementation of this SAP/QAPP. The field methods to collect the samples
during baseline evaluation will be same as those used for long-term operational monitoring. The field
personnel will use and follow prescribed standard operating procedures. Each of these factors will
minimize comparability issues.
Comparability is a qualitative assessment and is addressed primarily in sampling design through use
of comparable sampling procedures and through accurate resampling of stations over time. In the
laboratory, comparability is ensured through the use of comparable analytical procedures and
ensuring that analysts are trained in the proper application of the procedures. Within-study
comparability will be assessed through analytical performance (i.e., quality control samples) as
discussed in the laboratory QA/QC manual (Appendix B).
As indicated in Section 5.1, both laboratories performing analyses of samples collected under this
SAP/QAPP are certified by the State of Utah and accredited through the National Environmental
Laboratory Accreditation Program. Compliance with the standards established by these agencies
provides an additional comparability check on the laboratory data.
3.3.6 Sensitivity
Sensitivity is the capability of a test method or instrument to discriminate between measurement
responses representing different levels (e.g., concentrations) of a variable of interest. Sensitivity is
addressed primarily through the selection of appropriate analytical methods, equipment, and
instrumentation. The methods selected for this study were chosen to provide the sensitivity required to
provide a comparison of the data with potentially applicable regulatory standards. This is a
quantitative assessment and is monitored through instrument calibration and calibration verification
samples as well as the analysis of procedural blanks with each analytical batch.
The sensitivity of laboratory analyses is a function of the method (or minimum) detection limit (“MDL”)
and the practical quantitation limit (“PQL”). The MDL represents the minimum concentration of an
analyte that can be measured above the instrument background noise. Thus, when detection limits
are used as reporting limits, the laboratory is indicating that the analyte is not present at or above the
value given. It may be present at a lower concentration but cannot be "seen" by the instrument.
The PQL is the minimum concentration of an analyte that can be measured within specified limits of
precision and accuracy. This limit is determined by the laboratory based on interference that is
naturally present in the sample (e.g., high salinity may require dilution of the sample which may affect
the ability of the laboratory to accurately determine the magnitude of analytes that are present in
low concentration).
The sensitivity MQO goals for the SAP/QAPP are as follows (except as affected by high salinity which
may constrain laboratory procedures):
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• PQLs less than the applicable regulatory standard summarized in Tables 3-1 and 3-2.
• PQLs less than or equal to 10 times the associated MDL for analytes without a regulatory
standard.
3.4 Data Review and Validation
The analytical laboratory will be responsible to review each data package prior to release for
validation. At a minimum, the following reviews must be performed by the laboratory:
• Peer review of the data by a qualified analyst;
• Review of the reported data and deviations by a technical supervisor or data coordinator;
and
• QA officer review of 10% of the data.
Field teams will note any field-related quality problems in the logbook. QA reports will be provided to
the Monitoring Task Manager (“MTM”) whenever field quality problems are encountered. In addition,
a third-party entity under contract to Peak Minerals will review all field and laboratory data and
validate those data. This review will involve the following:
• Sample holding times to ensure that they meet applicable requirements;
• Initial and continuing calibration of field instrumentation;
• Results of field blank analyses;
• Results of duplicate analyses;
• Sample handling and storage procedures; and
• Completeness of field documentation.
Data validation is performed to assess the degree to which sampling and analytical methods have
generated consistent, reliable, and accurate data. Section 3.3 and Table 4 present the criteria for
deciding the degree to which the data have met predetermined measurement quality objectives.
Data that do not meet MQOs will be flagged. Results that are less than the reporting limits but exceed
the method detection limits will be qualified as estimates and used in calculations as a detected
value. All corrections, notions, and flagged comments will be added to the project database.
Data validation reports will be provided to the MTM by the Quality Assurance Officer (“QAO”). These
reports will include a discussion of any significant quality problems that were observed and their effect
on the use of the data. Quality issues identified by the field team, laboratory, and data validation
specialist will be incorporated into the data evaluation report(s) submitted to the PM, UDWQ, and
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BLM. If significant problems are encountered, the MTM will report these issues along with the results of
the necessary response actions to the PM, UDWQ, and BLM.
3.4.1 Response Actions
Response actions will be implemented on a case-by-case basis to correct quality problems. All
personnel involved in the implementation of the SAP/QAPP are responsible for discovering QA
problems or deficiencies in their areas of responsibility. Any such deficiencies will be reported to the
Quality Assurance Officer as soon as possible after discovery. The QAO will report the issue to the PM
and will have authority to stop sampling work until the issue is corrected. The PM, in consultation with
the Peak Minerals Quality Assurance Officer, will prepare QA response actions in cooperation with
personnel in the area where the deficiency was found.
The corrective action process has two components that must be addressed: (1) resolve the immediate
problem and (2) prevent future occurrences of the problem. It is the responsibility of the PM to ensure
that both components are addressed, and to finalize the action necessary to achieve resolution.
Results of the following QA activities may also initiate corrective actions:
• Performance audits;
• Systems audits; and
• Failure to adhere to the approved SAP/QAPP.
3.4.2 Reconciliation with User Requirements
The DQIs listed in Section 3.3 will be evaluated at the end of each sampling event. The potential need
for adjustments or corrective action to keep measurement systems in control will be evaluated and
discussed with the BLM and UDWQ, as necessary.
Data validation reports prepared by Peak Minerals will include an evaluation of the usability of the
data. Precision, accuracy, representativeness, completeness, and comparability will be evaluated
and compared with the project DQOs by the MTM, in consultation with the QAO and PM, as each
data set is received. At the completion of each year, an annual assessment of data usability and
compliance with the DQOs will be conducted and documented in the annual report.
3.5 Data Management
Data from both the surface water and groundwater monitoring efforts will be used to describe the
water resources in the area of interest. Using ProUCL or other appropriate statistical evaluation
packages, the data will be evaluated for confidence intervals, the presence of outliers, determination
of appropriate distributions for statistical analysis, and preparation of summary statistics and
evaluation of non-detect data. The data will also be plotted graphically (e.g., time series plots,
histograms, box-whisker plots, etc.) and using tri-linear diagrams of water quality as needed to support
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data interpretation. These values and graphs will then be used as a comparison with future data to
determine if impacts have occurred.
3.5.1 Statistical Data Analysis
Groundwater chemistry can vary with time under non-equilibrium groundwater conditions if the flow
field is altered. Reversals of the flow direction near a well could cause abrupt changes in the water
chemistry (Fetter 1980). Therefore, a primary purpose of the groundwater sampling program is to
detect statistically significant changes in groundwater chemistry from baseline conditions following
construction and start-up of Project operations.
Analyses of groundwater samples for major cation and anions provide a framework for early
detection in changes to local groundwater chemistry that may be associated with Project operations.
In groundwater, dissolved solids are generally either positively charged ions (cations) or negatively
charged ions (anions), and the charges should balance (cation/anion balance). Stable groundwater
is characterized by dominant cations and anions, but changes to groundwater flow patterns may
alter the concentrations of those constituents, resulting in changes to the cation/anion balance or
water type.
Statistical evaluations of baseline vs. operational datasets will be performed as outlined in Section
3.2.5. The precise methods that will be used in these comparative analyses will be determined once
the baseline data have been collected, reviewed, and validated and their statistical distribution(s)
has been determined.
It is currently anticipated that data will be summarized using measures of central tendency and
dispersion including mean, minimum, maximum, standard deviation, and statistical intervals (i.e.,
confidence limits and tolerance limits) complimented by histograms/box plots to graphically present
the distribution of study parameters. To test the equality or significance of the difference in repeated
measurements (analytical results), the parametric analysis of variance or the non-parametric method
of Friedman’s (1939) test can be used. Parametric tests assume data are normally distributed. When
the data are not normally distributed, an alternative non-parametric test should be used.
3.5.2 Data Management Process
Peak Minerals will incorporate the collected laboratory and field data into a relational database that
allows the data to be queried (e.g., by location, analytical results, constituent of concern, sample
medium, sample depth, etc.). If appropriate, the database, which will include both field and
laboratory data, will be linked to an electronic site map. It is currently anticipated that laboratory data
will be transferred to Peak Minerals electronically, thereby minimizing the potential for data entry
errors. Selection of the software and preparation of the database will be conducted following the
start of baseline sampling.
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3.5.3 Data Reporting
Following receipt of analytical reports from the laboratories for each sampling round, a third-party
entity under contract to Peak Minerals will validate the data as outlined in Section 3.4. Copies of the
validated data will be provided electronically to BLM and UDWQ within 45 days of receiving all data
associated with a sampling event. Each data submittal will include a statistical evaluation of the data
as outlined above. If this evaluation indicates that Project operations have adversely impacted water
resources, the quarterly data submittal will include recommendations for impact verification and/or
mitigation.
Peak Minerals will prepare annual reports detailing the results of the surface and groundwater
monitoring completed for the prior year. Copies of these reports will be provided electronically to
UDWQ and BLM before the end of the first quarter of the following year. The annual reports will include
tabulated field and laboratory results. These annual data and all previous monitoring data will be
included in the database for documentary and comparative purposes and can be supplied to UDWQ
or BLM, if required.
Data interpretation may include appropriate plots of iso-concentration contours for selected
constituents, graphs that show concentrations of selected parameters over time, comparisons to
relevant water quality standards, updated surface and groundwater analytical tables, summary
statistics, and a description of data validation. Report appendices will include copies of pertinent field
notes, laboratory analytical results, QC data, data validation, summary statistics, well records, well
testing data, water level data, field water quality measurements, and other field measurements such
as transducer data and rating curves, as applicable. Given the probable voluminous nature of the
laboratory analytical reports, these will be provided only in electronic format.
Also, the reports will include recommended steps for optimization of sampling and analysis efforts
(when applicable) and a discussion on any identified impacts to surface or groundwater resources. If
exceedances of standards or significant changes in conditions identified during the year suggest that
Project operations are affecting local water resources, specific actions taken or anticipated following
such exceedances will be summarized and recommendations for further activities will be provided.
These may include additional sampling, review of sampling protocols, changes to the operational
monitoring plan, or other recommendations to mitigate observed negative impacts to water
resources.
3.6 Assessment Oversight
The Peak Minerals Quality Assurance Officer will oversee implementation of the SAP/QAPP and ensure
that all analytical data generated thereby are validated according to appropriate procedures.
Specific responsibilities of the Quality Assurance Officer include:
• Provide independent QA oversight during implementation of the SAP/QAPP;
• Review logbooks, chain-of-custody forms, and laboratory analytical reports to determine if
data meet the requirements of the SAP/QAPP;
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
3-22
• Maintain an accurate and complete database of all analytical and other data generated
during implementation of the SAP/QAPP;
• Assess analytical data to determine if the data meet appropriate MQOs;
• Report data quality issues, quality control concerns, and data non-conformance to
established standards to the Peak Minerals project manager;
• Periodically review the sampling program, analytical results, and data validation procedures
for conformance to protocols and standards established in the SAP/QAPP; and
• Specify corrective actions to be taken in the event of QC failures or non-conformance to
protocols and standards specified in the SAP/QAPP and follow up to ensure that those
corrective actions are implemented.
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4-1
4.0 SAMPLING DESIGN AND RATIONALE
As noted in Section 3.1, one of the primary purposes of the SAP/QAPP is to collect sufficient, validated
baseline surface and groundwater data to define natural, pre-Project conditions and to allow future
determinations to be made of whether or not operation of the Project results in changes to the quality
or quantity of surface or groundwater within the area of interest. To accomplish this, selected surface
water locations together with existing and new wells will be monitored.
4.1 Groundwater
In developing the proposed SAP/QAPP groundwater monitoring network, existing wells in the area
were evaluated for their adequacy to provide acceptable data. An assessment was also made of
the need to drill and complete new monitoring wells to provide additional information. Based on this
evaluation, it is proposed that 32 wells (18 existing and 14 proposed) be used to assess baseline
groundwater conditions under this SAP/QAPP. The selected existing and new wells to be included in
the monitoring network represent the regional bedrock, alluvial/colluvial, and playa groundwater
systems within the area of interest.
Groundwater monitoring efforts will consist of measuring groundwater levels and collecting
groundwater quality samples at each of the wells listed in Table 4-1 and shown on Figure 4-1. Sampling
of groundwater issuing from springs is discussed in Section 4.1.3 of this document. Sample collection
dates will be selected to represent seasonal variations in groundwater conditions. The wells to be
monitored are described below.

Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
4-3
Table 4-1. Baseline Groundwater Monitoring Sites
Well ID Ownership
Latitude
(NAD83)
Decimal
Degree
Longitude
(NAD83)
Decimal
Degree
Casing
Elevation
(ft AMSL)
Total
Depth
(ft BTOC)
Diameter
(inch)
Screen
(ft BTOC)
Screen
Length
(ft)
Depth to
Sample
Intake
(ft BTOC)
Measuring
Point Stick
Up (ft)
Boring
Construction
Log
Single Well
Drawdown
Test
Max Flow
and
Drawdown
(SW)
Suitable for Low Purge Suitable
for No
Purge Yes/No Why
Playa Wells (Existing)
SN2-11-400-4 Peak Minerals 38.7835250 -113.174497 4,527.38 497 4 497-347 150 406-411 Yes No N/A Yes Previous Field
Data Yes
Machine Gun USGS 38.8361191 -113.2298862 4,531.54 102 2 100-95 5 101-104 Yes No N/A Yes Yes, Purge
Record Yes
Headlight Gap USGS 38.8296586 -113.1341471 4,549.94 207 2 210-207 3 207-210 Yes No N/A Yes Purge Record Yes
Provo Peak Minerals 38.8291203 -113.1274863 4,575.75 460 4 460-260 200 270-276 Yes Yes 1 GPM 67' Yes Drawdown Test Yes
Playa Wells (Proposed)
Proposed Playa
Perimeter West Peak Minerals 38.9070000 -113.204567 - - 4 - - - - - - - - -
Proposed Tailings
North Peak Minerals 38.756441 -113.231382 - - 4 - - - - - - - - -
Proposed Playa
Perimeter South Peak Minerals 38.726343 -113.192944 - - 4 - - - - - - - - -
Proposed Playa
Perimeter South 2 Peak Minerals 38.723402 -113.191879 - - 4 - - - - - - - - -
Alluvial Colluvial Wells (Existing)
257 Cutoff Peak Minerals 39.1405648 -112.9426389 4,552.84 60 4 60-45 15 50-56 Yes Yes 1.75 GPM
22.80' Yes Drawdown Test Yes
Bonneville Peak Minerals 38.8279350 -113.1010343 4,772.15 315 4 310-210 100 215-221 Yes Yes 0.53 GPM
97.77' Questionable Drawdown Test Yes
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
4-4
Well ID Ownership
Latitude
(NAD83)
Decimal
Degree
Longitude
(NAD83)
Decimal
Degree
Casing
Elevation
(ft AMSL)
Total
Depth
(ft BTOC)
Diameter
(inch)
Screen
(ft BTOC)
Screen
Length
(ft)
Depth to
Sample
Intake
(ft BTOC)
Measuring
Point Stick
Up (ft)
Boring
Construction
Log
Single Well
Drawdown
Test
Max Flow
and
Drawdown
(SW)
Suitable for Low Purge Suitable
for No
Purge Yes/No Why
Crystal Peak
Road USGS 38.7040571 ‐113.2856608 4,623.94 195 2 195-177 18 185-188 Yes No NA Yes High Turbidity Yes
Guzzler Peak Minerals 38.9605644 ‐113.0213739 4,966.81 425 4 425-325 100 385-389 Yes Yes 4 GPM 18' Yes Drawdown Test Yes
Miller Canyon
Reservoir Peak Minerals 39.0332852 ‐113.2365813 4,699.22 315 4 315-245 70 272-278 Yes Yes 10 GPM 7' Yes Drawdown Test Yes
Mudhole BLM 39.1305575 ‐112.8943545 4,559.56 503 8 338-365 27 370-373 No Yes 37 GPM 7.8' Yes Drawdown Test Yes
Alluvial/Colluvial Wells (Proposed)
UDOT2
Replacement Peak Minerals 39.1700167 -113.0271333 - - 4 - - - - - - - - -
Proposed A/C
West Peak Minerals 38.9186167 -113.224933 - - 4 - - - - - - - - -
Proposed Tailings
West Peak Minerals 38.7232486 -113.250747 - - 4 - - - - - - - - -
Proposed Tailings
North Peak Minerals 38.762242 -113.244973 - - 4 - - - - - - - - -

Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
4-5
Well ID Ownership
Latitude
(NAD83)
Decimal
Degree
Longitude
(NAD83)
Decimal
Degree
Casing
Elevation
(ft AMSL)
Total
Depth
(ft BTOC)
Diameter
(inch)
Screen
(ft BTOC)
Screen
Length
(ft)
Depth to
Sample
Intake
(ft BTOC)
Boring
Construction
Log
Single Well
Drawdown
Test
Max Flow
and
Drawdown
(SW)
Suitable for Low Purge Suitable
for No
Purge Yes/No Why
Bedrock Wells (Existing)
Black Hills BLM 38.8356642 ‐113.2488075 4,638.12 560 6 ? ? 540-543 No Yes 18 GPM 19' Yes Drawdown Test Yes
Coyote Peak Minerals 38.8550295 ‐113.2637821 4,784.27 765 5 760-560 200 705-711 Yes Yes 55 GPM 40' Yes Drawdown Test Yes
Lakeview BLM 38.7175450 ‐113.1909711 4,590.11 532 6
125-70
and 500-
420
80 94-100 Yes Yes 26 GPM 2' Yes Drawdown Test Yes
Monument Point Peak Minerals 38.8115229 ‐113.0825462 4,891.3 1215 5 1210-
1030 180 1155-
1161 Yes Yes 54 GPM 96' Yes Drawdown Test Yes
Nighthawk Peak Minerals 39.0284436 ‐113.2573385 4,804.36 780 5 780-580 200 608-614 Yes Yes 45 GPM 74' Yes Drawdown Test Yes
North Cricket Peak Minerals 38.9987550 ‐112.9872956 5,083.78 780 5 780-580 200 661-667 Yes Yes 36 GPM 3' Yes Drawdown Test Yes
Bedrock Wells (Proposed)
Proposed
Bedrock West Peak Minerals 38.9129333 -113.255050 - - 4 - - - - - - - - -
Proposed
Bedrock Tailings Peak Minerals 38.748624 -113.250783 - - 4 - - - - - - - - -
Water Supply 1 Peak Minerals 38.6861005 -113.2194244 - - 8 - - - - - - - - -
Water Supply 2 Peak Minerals 38.6857800 -113.1761975 - - 8 - - - - - - - - -
Water Supply 3 Peak Minerals 38.6850996 -113.1557851 - - 8 - - - - - - - - -
Water Supply 4 Peak Minerals 38.6895652 -113.1334771 - - 8 - - - - - - - - -
Springs from Which Samples Were Previously Collected
Anderson Spring BLM 39.101146 -112.982398 - - - - - - - - - - - -
Rocky Knoll
Spring BLM 39.172633 -112.896757 - - - - - - - - - - - -
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Well ID Ownership
Latitude
(NAD83)
Decimal
Degree
Longitude
(NAD83)
Decimal
Degree
Casing
Elevation
(ft AMSL)
Total
Depth
(ft BTOC)
Diameter
(inch)
Screen
(ft BTOC)
Screen
Length
(ft)
Depth to
Sample
Intake
(ft BTOC)
Boring
Construction
Log
Single Well
Drawdown
Test
Max Flow
and
Drawdown
(SW)
Suitable for Low Purge Suitable
for No
Purge Yes/No Why
Coyote Spring Rasmuson 38.683521 -112.877867 - - - - - - - - - - - -
South Coyote
Spring BLM 38.674192 -112.871611 - - - - - - - - - - - -
Sevier River
Below Conks
Dam N/A 39.278949 -112.683078 - - - - - - - - - - - -
257 Cutoff Road N/A 39.142512 -112.956173 - - - - - - - - - - - -
Notes: 1. AMSL = above mean sea level
2. BTOC = below top of casing
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
4-7
4.1.1 Existing Wells
In selecting the initial monitoring points from existing wells to be included in the monitoring network,
prior sampling data were reviewed. In reviewing field logs associated with prior well sampling in the
general area of the Project, it was apparent that some of the wells may have yielded unreliable data
(e.g., field water-quality measurements that did not stabilize during well purging and/or the well being
pumped dry during purging). Therefore, it was decided that existing wells used for baseline and
operational groundwater monitoring should meet the following criteria where feasible:
• The well construction details are known including screen intervals;
• The well can be purged using EPA (2017) low-flow purging methods, resulting in (1) no more
than 0.3 foot of drawdown during purging (or stabilized drawdown if greater than 0.3 foot)
and (2) static water levels that are above the screen interval at the time of sampling; and
• The well diameter can accommodate sampling system equipment and provide a sufficient
volume of water to allow for the analysis of original and duplicate samples.
Based on these criteria, the 18 existing wells were initially chosen for the SAP/QAPP groundwater well
monitoring network (see Table 4-1 and Figure 4-1). Four of the existing wells to be monitored under the
SAP/QAPP are located within or at the perimeter of the Sevier Playa (Playa Wells). These consist of:
• SN2-11-400-4,
• Provo Well,
• Headlight Gap Well, and
• Machine Gun Well.
These wells were selected as representative of the elevation and quality of groundwater in the playa
groundwater system both at depth and along the edge of the playa.
The following six existing wells were selected to monitor the alluvial/colluvial groundwater system:
• 257 Cutoff Well as an indicator of groundwater near the point at which the Sevier River flows
into the playa;
• Guzzler Well, Mudhole Well, and Bonneville Well as indicators of groundwater upgradient from
the playa; and
• Crystal Peak Road Well and Miller Canyon Reservoir Well as being potentially downgradient
from the playa.
These wells were selected as representative of the elevation and quality of the alluvial/colluvial
groundwater system adjacent to the playa.
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
4-8
The following six existing wells completed in the regional bedrock groundwater system are included
in the SAP/QAPP:
• Coyote Well, Nighthawk Well, and Black Hills Well on the west (downgradient) side of the
playa;
• Monument Point Well and North Cricket Well on the east (upgradient) side of the playa; and
• Lakeview Well on the south (upgradient) side of playa.
These wells were selected as representative of the elevation and quality of the regional bedrock
groundwater system near the playa.
The data from these wells will aid in developing a representative baseline dataset and provide means
to evaluate potential changes to these zones, if any, following the onset of Project operations.
Concerns have been raised that several of the wells proposed for monitoring are older wells
completed with steel casing that may influence the quality of groundwater obtained from those wells.
Specifically, the Black Hills, Lakeview, and Mudhole wells were completed with steel casing. Peak
Minerals acknowledges this concern. Summarizing the work of others, Llopis (1991) stated that
groundwater samples collected from steel-cased wells tend to contain elevated concentrations of
cadmium, chromium, copper, iron, manganese, and zinc. Of these constituents, cadmium,
chromium, and copper are included on the groundwater analytical list provided in Table 3-2.
However, proper well purging and sampling should minimize those influences. Furthermore, under
passive sampling, the samplers are to be located within well sections that, in theory, are representative
of the aquifer groundwater. Salinity is of greater concern at this time than individual metallic ions and
the effect of the slightly elevated metal concentrations will be minimal relative to the concentrations
of TDS and the primary parameters that comprise TDS. Therefore, given the concern, care will be taken
during evaluations of baseline metals data collected from wells that are cased with steel to determine
if such data should be flagged due to potential interaction with the casing.
Peak Minerals drilled and installed two single-level water monitoring wells (Playa South 1 and Playa
South 2) to supplement data obtained from the playa groundwater system near the Dike Access Well.
The two new wells will be installed along a line perpendicular to the edge of the playa toward the
proposed water-supply wells to assess the influence of long-term pumping of the water supply wells
on the playa groundwater system, if any, and potential movement of brines toward the water supply
wells. These wells will consist of 4-inch diameter screen and casing.
4.1.2 Proposed Wells
In addition to the existing wells, 14 wells (including the Project water supply wells) will be drilled and
completed by Peak Minerals to add to the monitoring well network (see Table 4-1 and Figure 4-1).
Figure 4-2 presents the typical completion detail for these wells. These wells will be drilled using reverse
rotary and/or sonic drilling methods. Efforts will be made to drill these holes with air; however, if
borehole stability becomes an issue, a combination of air and foam will be used to maintain the hole.
Final depths of these wells will be determined based on field geology at the time of drilling.
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
4-9
One new replacement well is proposed on the north end of the playa to replace the UDOT-2 well.
Three new wells are proposed to provide additional information along the west side of the playa
between Coyote well to the south and Nighthawk well to the north. Four new wells are proposed to
monitor potential changes to groundwater levels and chemistry, if any, due to activities in the Tailings
Management Area. Two new wells will be drilled to supply water to the processing facility. The
remaining two new wells are proposed along the south end of the playa to monitor potential water
level and quality changes resulting from water supply pumping (see Figure 4-1).
These monitoring wells are proposed to be single well completions and will consist of an 9-7/8-inch
diameter borehole completed with 4-inch diameter threaded polyvinyl chloride (“PVC”) casing. For
wells shallower than 300 feet, the casings will be Schedule 40 PVC. For wells deeper than 300 feet,
casings will consist of Schedule 80 PVC. Centralizers will be used to center the casings within the
borehole.
Well construction for single monitoring wells (shown in Figure 4-2) will consist of a 4-inch diameter
casing with an end cap on a section of blank casing that extends at least 5 feet below the screen, a
section of well screen, and a section of blank casing extending to a point at least 1 foot above the
ground surface with a slip-on cap. Graded sand will be installed as a filter pack in the completion
zone surrounding the lower solid casing and well screen to a level at least 5 feet above the top of the
screen. Bentonite grout will be tremied into the annular space from the top of the filter pack to 5 feet
below the ground surface and cement grout will be placed from the top of the bentonite to the
ground surface. A steel protective casing with a locking lid will be installed over the PVC casing,
extending at least 3 feet into the cement grout and 2 feet above ground surface. The PVC casing
and cap will be adjusted/cut to fit below the top of the steel protective casing before the steel casing
is set.
In addition, Peak Minerals will install well points around the perimeter of the Tailings Management Area
(“TMA”) as noted on Figure 4-1. These well points will be installed using direct-push methods to depths
that extend at least 10 feet into the marl clay zone that serves as the uppermost aquifer in the playa
sediments. The purpose of these well points will be to monitor the elevation and quality of groundwater
immediately adjacent to the TMA.
Using 3.25-inch hollow push rods, each well point will be completed with 2-inch diameter threaded
PVC casing, with 5 feet of PVC screen at the bottom of the casing string. Graded sand will be installed
as a filter pack in the annular space between the borehole wall and the casing string, with the
remainder of this space completed as indicated above.
Following drilling and completion, each new monitoring well and well point will be developed by
surging, bailing, and/or pumping to ensure that water sampled from the wells in the future is
representative of the adjacent natural groundwater. Development of the wells and well points will be
conducted for 6 hours or until the water retrieved is visually clear and has stabilized with respect to
pH, temperature, and specific conductance.
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
4-11
4.1.2.1 Proposed West Wells
The proposed Bedrock West, Alluvial/Colluvial West, and Playa Perimeter wells will be installed on the
west side of the area of interest as shown on Figure 4-1.
The Playa Perimeter West well will be installed near the margin of the playa basin. It will be a single-
level well completion designed to monitor playa perimeter conditions.
These wells are proposed to be downgradient wells completed in the three aquifers: the Bedrock West
well in the regional bedrock groundwater system, the Alluvial/Colluvial West well in the
alluvial/colluvial groundwater system, and the Playa Perimeter well in the playa groundwater system.
These wells will be used for water level monitoring and groundwater quality sampling.
4.1.2.2 Proposed Waste Product Storage Facility Wells
The future location of the WPSA is shown on Figure 4-1. Several investigators with the U.S. Geological
Survey, of which Gardner et al. (2011) is just one example, have shown that groundwater in the
regional bedrock aquifer flows to the west-northwest beneath the Sevier Playa. Assuming similar flow
directions in the alluvial/colluvial groundwater system at the future TMA, wells will be installed to
monitor areas downgradient from that area. The Tailings North and Tailings West wells will be
completed in alluvial/colluvial sediments, the Tailings North Playa well will be completed in the Marl
Clay Zone of the playa sediments, and the Tailings Bedrock well will be completed in the regional
bedrock groundwater system. These new monitoring wells will be used to assess groundwater
conditions in the vicinity of the TMA.
These wells will be monitored to detect potential water levels changes, potential movement of the
high concentration brines, and potential changes to the groundwater chemistry of the area, if any,
in response to tailings and purge brine storage. These wells will be completed in the same manner as
the single-level completion wells discussed above.
4.1.2.3 Proposed Water Supply Wells
Peak Minerals plans to drill and install two water supply wells into the regional bedrock aquifer on BLM
and SITLA land, approximately 5.5 miles south of the proposed processing facility area (see Figure 4-
1). Information regarding the geology at the site of the proposed water supply wells is available from
a 750-foot-deep test hole (CWTW-1) that was completed by Peak Minerals to assess potential water
quality and sustainable discharge rates (CH2M Hill, 2012). It is currently anticipated that these wells will
not be drilled until after the start of facility construction. The drilling program is planned to be phased,
with one well being drilled in year 1 and the other wells drilled at later dates as water demand
increases. Six months prior to the anticipated start date, the final work plan for well drilling and
installation, including planned construction details, will be prepared and submitted to BLM and UDWQ
under separate cover.
These two wells, when completed, will also be used to monitor the groundwater quality of the bedrock
aquifer. Since the wells will be producing on a regular basis, the water produced will be representative
of the water within the aquifer. Therefore, a sampling port/tap will be installed on the water line from
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
4-12
the well(s) to the processing facility to collect samples from the wells during operation. Additionally,
the water levels will be monitored in each production well to assess the impact of pumping from the
adjacent wells.
Additionally, two monitoring wells would be installed south and east of the water supply wells to
monitoring the upgradient affects. Well PM-20-SBRWS would be located south of the water supply
wells to assess the drawdown toward the south. Well PM-20-EBRWS would be installed near the rail
loadout to assess the drawdown from the water supply wells to the east.
4.1.2.5 Proposed Well Points
Peak Minerals plans to install single-level well points around the perimeter of the TMA to supplement
data obtained from the remainder of the groundwater monitoring network in that area. The well
points will be monitored primarily for water levels and specific conductance to determine whether
leakage is occurring from the TMA. As 2-inch dimeter well points, these wells can also be sampled for
a broader suite of analytes if deemed necessary.
Proposed UDOT Well Replacement
An existing well, known as UDOT-2 and located north of the playa northeast of the intersection of
Hwy 6/50 and the 257 Cutoff Road, has partially filled with sediment, making sampling difficult and
data interpretation problematic. A replacement well (PM-20-NAC) would be installed at the
intersection of Hwy 6/50 and the 257 Cutoff Road to monitor groundwater conditions in the
alluvial/colluvial sediments upgradient from the playa. This well would be a single-level completion
consisting of four-inch diameter screen and casing.
4.1.3 Springs
Four springs shown on Figure 4-1 may be monitored during the baseline and Project operational
periods. These springs consist of Rocky Knoll and Anderson Springs to the north and the Coyote and
South Coyote Springs to the south.
Anderson Spring is a groundwater seep that exists in the bottom of the Sevier River channel near the
river’s terminus into the playa. There was no discernable flow at this location during a prior attempt to
sample Anderson Spring. During periods when the Sevier River flows at that location, Anderson Spring
will not be accessible for sampling.
Phreatophytes have invaded the area of Rocky Knoll Spring, which currently exists as a slight seep
with no observable flow. This spring maybe sampled if sufficient water is available.
Coyote and South Coyote Springs are in in an adjacent basin southeast of the playa. Coyote Spring
is currently piped to a location where flow measurements can be collected using a bucket and
stopwatch. No such arrangement exists at South Spring. Peak Minerals has collected one sample from
Coyote Spring. Although a hydrogeologic connection between these springs and the playa is unlikely,
they may be monitored during the baseline and/or operational periods to provide a general
indication of near-surface groundwater in that area.
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
4-13
A fence has been installed around Rocky Knoll Spring, generally precluding its use by wildlife or
livestock. The remaining springs are currently used by wildlife and for stock watering. If monitored,
indications of recent wildlife or livestock usage of the springs at the time of sampling will be noted in
the field logbook. Since flow measurements may mobilize sediments and cause disturbances in the
water, any water quality samples collected from the springs will be done before measuring the flow.
If monitored, flow data and water quality samples will be collected from the springs following
procedures outlined in Section 4.2.
4.2 Surface Water
The purpose of surface water monitoring will be to document the quality and quantity of surface
inflows to the playa. This will be accomplished using the surface water sampling points on the Sevier
River shown on Figure 4-1. The samples will be collected below Conks Dam and at the 257 Cutoff
Road. Data collected from below Conks Dam will provide information concerning the quality and
quantity of water that is released to the lower Sevier River. Data collected from the 257 Cutoff Road
site will allow an assessment of the quantity and quality of water that flows onto the playa.
Flow data and water quality samples will be collected from the surface water sampling locations
during the baseline sampling period. Sample collection dates will be selected to represent seasonal
variations in flow and water quality. Discharge measurements will be collected using methods outlined
in Section 6.3.2. Surface water quality samples will be collected as indicated in Section 6.3.1.
It is likely that the depth of surface flow at the time of each monitoring event will be variable, ranging
from dry channels to fast moving water. Safety will be a primary concern when conducting monitoring
activities at surface water stations. Any safety-driven deviations from the standard monitoring
methods outlined in Section 6 (e.g., swift water that may preclude access to the center of the channel
for flow measurements and sample collection) will be noted in the field logbooks.
Combined Sampling and Analysis Plan & Quality Assurance Protection Plan, November 2023
5-1
5.0 REQUESTS FOR ANALYSES
5.1 Analysis Narrative
Field samples collected during the implementation of this SAP/QAPP will be analyzed for the
constituents listed in Tables 3-1 and 3-2. These tables also indicate the analytical methods that will be
used by the laboratory. Clean sample containers of appropriate volumes will be obtained from the
analytical laboratory. If preservatives other than ice are required, these preservatives will be supplied
by the laboratory.
Analyses for the constituents listed in Tables 3-1 and 3-2 will be performed by Pace Lab Sciences
(“Pace”) in Mt. Juliet, Tennessee. Additional samples from each well will be sent to American West
Analytical Laboratory (“AWAL”) for analyses using a proprietary “brine protocol” method. Due to the
high brine concentrations, standard methods for determination of specific gravity can be inconsistent.
Therefore, AWAL has developed a proprietary method to generate these values. As these are not
used for water quality assessments, they are not discussed further.
Pace is accredited through the National Environmental Laboratory Accreditation Program (NELAP)
and is certified in Utah (No. 6157585858) to analyze samples for wastewater, drinking water, RCRA,
USTs, and air quality. AWAL is also accredited through NELAP and is certified in Utah (A2LA Cert No.
3236.01). AWAL will analyze the high concentration brine samples using their proprietary methods.
Samples for laboratory analyses will be collected in laboratory-supplied containers immediately
following field analyses and filtering. Laboratory analyses are detailed on Tables 3-1 and 3-2.
Analytical methods were selected to achieve method detection limits that are no greater than the
applicable standard and will consist of the following:
5.1.1 Surface Water
• Specific conductance, temperature, dissolved oxygen, turbidity, and pH via field
measurement;
• TDS: field filtration with no added preservatives and a holding time of 7 days (AWWA Standard
Method 2540 C-2011);
• Alkalinity: field filtration with no added preservative and a holding time of 14 days (AWWA
Standard Method 2320 B-2011);
• Major anions: field filtration with no added preservatives and a holding time of 28 days (EPA
Method 9056A);
• Major cations and metals by ICP-OES: field filtration with HNO3 added as a preservative and a
holding time of 180 days (EPA Method 6010B);
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• Metals by ICP-MS: field filtration with HNO3 added as a preservative and a holding time of 180
days (EPA Method 6020B);
• Mercury: field filtration with HCl added as a preservative and a holding time of 90 days (EPA
Method 1631E);
• Nitrate+Nitrite: field filtration with no added preservatives and a holding time of 28 days for
nitrate+nitrite (EPA Method 353.2); and
• Phosphorous (total): field filtration with H2SO4 added as a preservative and a holding time of
28 days (EPA Method 365.4).
5.1.2 Groundwater
As noted in Section 6.4.2, groundwater samples will be collected using two methods: in-situ sampling
(“ISS”) methods and low-flow purge methods. All groundwater samples will be analyzed for dissolved
oxygen (DO), specific conductance, temperature, turbidity, and pH in the field. Groundwater
samples collected using ISS and low-flow purge methods will be field filtered, preserved, and analyzed
as follows:
• TDS: field filtration with no added preservatives and a holding time of 7 days (AWWA Standard
Method 2540 C-2011).
• Alkalinity: field filtration with no added preservative and a holding time of 14 days (AWWA
Standard Method 2320 B-2011).
• Major anions: field filtration with no added preservatives and a holding time of 28 days (EPA
Method 9056A).
• Major cations and metals by ICP-OES: field filtration with HNO3 added as a preservative and a
holding time of 180 days (EPA Method 6010B).
• Metals by ICP-MS: field filtration with HNO3 added as a preservative and a holding time of 180
days (EPA Method 6020B).
• Cyanide: NaOH added as a preservative, chilled, and analyzed within 14 days (AWWA
Standard Method 4500-CN E).
• Mercury: field filtration with HNO3 added as a preservative and a holding time of 28 days (EPA
Method 7470A).
• Nitrate+Nitrite: field filtration with no added preservatives and a holding time of 28 days for
nitrate+nitrite (EPA Method 353.2).
• Phosphorous (total): field filtration with H2SO4 added as a preservative and a holding time of
28 days (EPA Methods 365.4).
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• Specific gravity: no filtration, no added preservative, and no cooling of sample (Brine Protocol,
AWAL).
With the exception of the proprietary “brine protocol” performed by AWAL for analyzing specific
gravity, all analyses will be performed using EPA-approved analytical methods. It is currently
anticipated that standard turn-around times will be requested for all analytical results. The collection
of field QC samples (i.e., blanks, duplicates, and splits) is discussed in Section 10. These samples will be
analyzed in the same manner as all other field samples.
UDWQ rules indicate that the standards for the class of water need to be adjusted based on hardness
of the waters (R317-2-14, Utah DEQ May 1, 2018). The majority of the waters occurring in the lower
Sevier drainage have a hardness of 400 mg/l or more, based on both the data in the Whetstone (2017)
report and the 2016 water quality data collected by UDWQ in the general project area. After adjusting
for the hardness, the metals standards increase from the values shown in the Utah Groundwater
Protection Standards to the following:
• Cadmium – >400mg/l hardness, 1-hour acute value 0.008 mg/l.
• Chromium III – >400 mg/l hardness, 1-hour acute value 1.773 mg/l.
• Copper – >400 mg/l hardness, 1-hour acute value 0.050 mg/l.
• Lead – >400 mg/l hardness, 1-hour acute value 0.281 mg/l.
• Silver – >400 mg/l hardness, 1-hour acute value 0.035 mg/l.
The laboratory MDL for these metals meet the adjusted values based on water hardness. The
aluminum standard, footnote six of Table 2.14.2 in R317-2-14, Utah DEQ May 1, 2018, indicates that, for
sites with pH over seven and hardness over 50, the standard to be used is 0.75 mg/l. Thus, the 0.1 mg/l
reporting limit is also sufficient for aluminum. Additionally, antimony will be analyzed by Pace to meet
the 0.006 mg/l standard for Utah groundwater.
Mercury analyses for surface waters are scheduled to be analyzed by Pace to meet the UDWQ
standard of 1.2E-5 mg/l. It is anticipated that the naturally high salinity of many of the water samples
collected under this SAP/QAPP will cause analytical interference. In those cases, it is typical for the
laboratory to dilute the sample, thereby resulting in a higher practical quantitation limit. Pending
sample interference due to high salinity, the reporting limit will be 0.5 nanograms per liter or 5.0E-7
mg/l. If sample interference occurs, the reporting limit will be raised.
5.2 Analytical Laboratory
As noted in Section 5.1, analyses for the constituents listed in Tables 3-1 and 3-2 will be performed by
Pace. Pace has an internal QA program that has been approved by the National Environmental
Laboratory Accredited Program and the State of Utah. A copy of this QA program is provided in
Appendix B. Peak Minerals understands and agrees to the MQOs that are presented in the Pace QA
program and that will be used by Pace for this project.
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6.0 FIELD METHODS AND PROCEDURES
The purposes of the SAP/QAPP, outlined in Section 3.1, will be accomplished through the collection of
surface and groundwater samples from the locations shown on Figure 4-1. This chapter presents a
discussion of the field sampling methods and procedures that will be used to accomplish the goals of
the SAP/QAPP. Information regarding sample tracking and shipping is provided in Section 7.
Sampling methods used during implementation of the SAP/QAPP will adhere to the sampling,
analytical, and data QA/QC procedures outlined herein. These procedures accord with the UDWQ
Water Quality Assessment Guidance (UDWQ, 2010) and UDWQ's field procedures described in the
DWQ Monitoring Plan Manual (UDWQ, 2006). All samples will be collected and properly preserved so
that they are delivered to the laboratory and tested within the holding times required by the
applicable EPA analytical method. Personnel involved in sampling will wear clean, disposable gloves
that are donned prior to the collection of each sample, thereby minimizing the potential for cross-
contamination between samples.
Sampling and field data collection will occur as detailed in the Standard Operating Procedures
(“SOPs”) provided in Appendix C. Summaries of those procedures are presented below. The following
summaries are presented to be consistent with EPA guidance for the preparation of the SAP/QAPP
documents. Where conflicts exist between the following summaries and the SOPs, the SOPs will
govern.
6.1 Monitoring Frequency
Monitoring of surface and groundwater under this SAP/QAPP will be conducted quarterly to assess
seasonal variations in hydrologic conditions within the area of interest. Once this initial baseline validity
assessment is complete, a report will be prepared and submitted to UDWQ and BLM to present a
summary of data collected and justify the valid baseline data set. On-going monitoring throughout
the life of the Project will then be used to evaluate potential impacts, if any, from Project operations
and to assess conditions for reclamation and closure of the site. Based on the data collected, the
report may include recommendations on adjustments to the SAP/QAPP regarding the sampling points
and analyte list to better monitor the potential impacts from future Project operations.
6.2 Field Equipment
6.2.1 List of Equipment
Equipment that will be used in the field during the collection of surface and groundwater samples is
listed in Table 6-1. Some of the field instrumentation may be combined into a single piece of
equipment (e.g., through the use of multi-parameter instrument). Manufacturer’s information on the
recommended equipment described in Table 6-1 is included in Appendix D. Portions of field
equipment that will contact the water to be sampled will be rinsed in distilled water prior to use at the
next sample location, thereby minimizing the potential for cross contamination.
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Table 6-1. Equipment List
Field Equipment Manufacture Specification
Water Level Monitoring
Solinst 101 P7 Laser marked 1/100-foot
increments PVDF tape
https://www.solinst.com/products/level-measurement-
devices/water-level-meters.php
Solinst Levelogger Edge 3001
conductivity, water level and
temperature
https://www.solinst.com/products/dataloggers-and-
telemetry/3001-levelogger-series/levelogger-edge/datasheet/
Solinst Barologger Edge absolute
pressure, W Data Wizard https://www.solinst.com/products/data/3001.pdf
Surface Water Flow
USGS Top Setting Wading Rod, 0.2, 0.6
and 0.8 depth settings http://rickly.com/usgs-topset-wading-rod-1-2m/
USGS Type AA Current Meter, Price-
type http://rickly.com/usgs-type-aa-current-meter/
Groundwater Sampling
Snap Sampler, QED Environmental
Systems, Inc. https://www.snapsampler.com/
Geotech 1.66x36" Bladder Pumps http://www.geotechenv.com/pdf/ground_water_sampling_equip
ment/geotech_bladder_pumps.pdf
Geotech BP Controller 300/500 PSI http://www.geotechenv.com/pdf/ground_water_sampling_equip
ment/bp_controller.pdf
Groundwater/Surface Water Field Meter
YSI EXO Multimeter Platform https://www.ysi.com/EXO-HH
YSI EXO1 Multiparameter Sonde,
SC/Temp, pH, DO, Turbidity https://www.ysi.com/EXO1?EXO1-Water-Quality-Sonde-89
YSI EXO1 Flow Cell https://www.ysi.com/Accessory/id-599080/EXO1-and-ProDSS-Flow-
Cell
Geotech Portable Turbidity Meter
(option 2)
http://www.geotechenv.com/pdf/water_quality/geotech_turbidit
y_meter.pdf
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6.2.2 Calibration of Field Equipment
All instruments and equipment used during sampling and analysis will be operated, calibrated, and
maintained in accordance with the manufacturers’ recommendations, as well as criteria set forth in
the applicable analytical methodology references. Documentation of all routine and special
maintenance and calibration information will be maintained in a logbook and will be available for
review by authorized agency representatives upon request.
Most field equipment used during site monitoring is factory calibrated. Equipment that is not factory
calibrated will be calibrated each day prior to collecting field data. Calibration and operation of all
equipment used for collection of samples and field parameters will conform to the respective
manufacturer’s specifications. Instrument calibrations and calibration checks will be recorded daily
in a logbook and on Forms B and C of Appendix E.
The YSI meter listed in Table 6-1 measures several different water parameters. The calibration of this
instrument will be performed as follows:
• Calibration of the pH meter will be performed to pH standards (4, 7, or 10 standard units)
bracketing the actual field measured value with a post-calibration check using an alternate
pH standard to ensure that the meter is reading within 5% of the standard.
• The specific conductance meter will be calibrated to one of four standards (1,413, 4,000,
6,000, or 10,000 microSiemens per centimeter [µS/cm]) with a post-calibration check using an
alternate salinity standard to ensure that the meter is reading within 5% of the standard.
• Dissolved oxygen will be calibrated using the barometric pressure method outlined by the
manufacturer.
• The turbidity meter will be calibrated to 0.02, 20, 100, and 800 NTU. Turbidity measurements will
be made using a separate turbidimeter and not the flow-through cell used for groundwater
sampling.
6.3 Surface Water Sampling
The collection of samples from the Sevier River will start at the downstream-most location and progress
upstream. The river conditions and field parameters will be logged on the Surface Water Sample Form
C in Appendix E. Flow measurements within the channel will likely mobilize sediments and cause
disturbances in the water; therefore, river water quality samples will be collected before flow
measurements.
6.3.1 Surface Water Quality Sample Collection
Surface-water samples will be collected from the locations shown in Figure 4-1. The samples will be
taken from flowing, not stagnant water. Sample collection bottles will be labeled and transported to
the river edge in a sample caddy and remain sealed until the water sample is collected. Depending
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on site conditions, samples will be collected by use of a sampling pole or by wading into the river. The
samples will be collected upstream of the sampling pole location or wading personnel to avoid
disturbance of the sampled water. Samples will be collected directly into sample bottles to which no
preservatives have been added. In this case, the sample collection bottle will be rinsed a minimum of
three times with river water before collecting the sample.
Sample bottles that contain an added preservative will be filled from a rinsed bottle that does not
contain a preservative, thereby avoiding the loss of the preservative. These bottles will be filled at least
to the neck of the bottle, but not overflowing, before capping.
All surface-water samples will be considered grab samples. Sample collection bottles will be immersed
mouth down below the water surface to approximately one-third the depth of the stream flow if the
flow depth is sufficient. With the lid removed, the bottle will be pulled up through the water column at
a rate that would fill the bottle from a vertical section of the stream, the purpose being to collect
water from different depths in the stream. If the flow depth is insufficient to submerge the bottle, care
will be taken to avoid the introduction of bottom sediment into the sample during collection. The
sample cap will then be replaced, and the sample bottle placed in the sample caddy.
Samples requiring analyses of dissolved constituents (as noted in Table 3-1) will be field filtered using a
0.45-micron filter to remove larger particles that have been entrained in the water sample. A clean,
unused filter will be used for each filtered sample collected. The filtered water samples will be
transferred from the filter directly into the appropriate sample containers with a preservative (if
required) and processed for shipment to the laboratory. When transferring samples, care will be taken
not to touch the filter to the sample container.
Field parameters for temperature, pH, specific conductance, turbidity, and dissolved oxygen will be
collected in the flowing water and recorded. Surface water samples will be chilled and processed for
shipment to the laboratory. Sample management and custody will be performed following
procedures in Section 7.
6.3.2 Surface Water Flow Measurement
Streamflow measurements will be collected using a current meter or other appropriate method
approved by the U.S. Geological Survey (Buchanan and Somers, 1969). Once sufficient data are
available, rating curves will be developed for each channel location, thereby allowing stage-gauge
readings to provide future estimates of flow based on the rating curve. Flow and cross-section data
will be collected to represent those periods when flow stage varies between high and low to aid in
developing a more accurate rating curve for each stream station.
Absolute pressure transducers will be installed at each surface-water sample location shown on Figure
4-1 to determine the stage at these stations during periods when samplers are not in the field. In both
cases, a pressure transducer will be placed inside a section of vertical PVC casing secured to a
vertical T-post and staff gage. These transducers will be programmed to collect water levels at a
minimum of once per hour.
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During each sampling event, the river stage will be recorded from the staff gauge at each station
and data from the pressure transducers will be downloaded. Flow measurements will be recorded on
the Surface Water Sample Form C in Appendix E. The transducer level readings will be adjusted for
barometric pressure changes and compared with the manual stage readings to ensure appropriate
correlation.
The pressure transducer readings and staff gauge heights described above will be used to develop
rating curves. These curves will be used to estimate the river flow without having to physically measure
the channel area and flow velocity at the time of each stage reading. The rating curves will be
developed from a log-log plot of stage and discharge data (Kennedy, 1984), which generates a
straight-line equation in the following form:
Q = P(G–e)b
Where: Q = discharge (cfs)
P = the intercept equal to Q when (G-e) is equal to 1.0
G = the river stage (feet)
e = a constant that, when subtracted from G, would result in a
straight line on a log-log plot of Q vs. (G-e); the default value of
“e” is zero and is adjusted if initial log-log plot shows curvature
b = the slope of linear trend line on log-log plot
The rating curve will be considered accurate over the range of manually measured flows if the
correlation coefficients (R2) of the rating curve is greater than 0.8. The rating curves will allow the
generation of daily flow records at both gauging stations for duration of the Project.
6.4 Groundwater Sampling
6.4.1 Groundwater Level Measurement
The wells identified in Table 4-1 will be used to monitor groundwater levels in the bedrock,
alluvial/colluvial, and playa groundwater systems. These data will consist of manual water level
measurements during sampling events to monitor trends in groundwater levels during baseline and
operational periods.
Manual water level measurements will be collected using electronic water-level indicators, with the
probe tape marked in 0.01-foot increments. All wells will be sounded for depth to water from the top
of casing prior to purging. Field water-level indicators will be calibrated according to manufacturer's
recommendations before each field sampling event. Field meter probes will be decontaminated
before and after use at each well by rinsing with distilled water.
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In addition to manual water-level measurements, pressure transducers will be installed in bedrock
wells Black Hills, Coyote, Monument Point, Nighthawk and North Cricket and alluvial/colluvial wells
Mudhole to the north of the playa and Lakeview on the south end of the playa. Data will be collected
from these pressure transducers at a minimum rate of twice each day. The purpose of the pressure
transducer measurements is to identify regional daily trends in water levels over time.
When analyzing barometric data, it is important to keep in mind that storm events commonly reduce
total atmospheric pressure by about 1.7% from pre-existing high-pressure conditions. 1.7% converts to
approximately 0.6 feet or 0.2 meters of water level equivalent barometric fluctuation.
The Solinst Levelogger (20 PSI) series of water level dataloggers that will be used measure absolute
pressure. Thus, when in water, they measure the total head of water plus the barometric pressure. The
general rule is to use one Barologger for an area that has a radius of 20 miles. One Barologger will be
placed near Nighthawk well and used to correct data collected from the pressure transducers
installed on the north half of the playa. A second Barologger will be installed at Monument Point well
and used to correct data collected from pressure transducers installed on the south half of the playa.
The algorithms programmed into the Barologger are strictly for use in air, making this instrument
extremely accurate. The barometric data are then used, along with software Data Wizard, to
compensate the Levelogger data and provide true water level readings. To increase the accuracy
of barometric compensation data, the Barologgers and pressure transducers will be programmed
with the same recording times.
Each transducer will be checked annually to verify its accuracy. This procedure will include raising the
transducer to the top of the water surface while monitoring the pressure/head reading. When it
measures zero, the cable will be marked. The transducer will then be lowered to depths of 5, 25, and
100 feet below the water surface and the pressure/head readings will be recorded. If these readings
match the actual values, within the accuracy of the transducer, the transducer will be deemed
acceptable and will continue in service. If not, the transducer will be replaced and returned for
calibration and service.
Data from the transducers will be downloaded during each field sampling event. These data will be
stored on a USB flash drive and then transferred to the central database for review, data verification,
and analysis.
6.4.2 Groundwater Quality Sampling
It is currently anticipated that samples will be collected from the monitoring wells using low-flow purge
and sampling methods or passive sampling methods as discussed further below. In either case, down-
well flow testing will be conducted prior to the initial sampling round in order to select a representative
depth from which samples will be collected from the wells.
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6.4.2.1 Down-Well Flow Testing
Low flow and passive groundwater sampling methods are not recommended for wells with long
screens unless the project team has a good understanding of the zones of inflow to the screen
segments. Therefore, prior to use of these proposed sampling protocols, down-well flow tests were
conducted, thereby determining the flow zones within the monitoring wells. The testing also assisted
in understanding the relationship of groundwater flow between zones within the same groundwater
system and provided information regarding interaction between groundwater systems within the area
of interest.
Down-well flow testing was conducted in selected wells by Colog of Lakewood Colorado between
the dates of June 4-22, 2018. The following wells were tested:
• Playa well SN2-11-400-4.
• Alluvial/colluvial wells 257 Cutoff, Bonneville, Crystal Peak Road, Guzzler, Lakeview, Headlight
Gap, Machine Gun, Miller Canyon Reservoir, Mudhole and Provo.
• Bedrock wells Black Hills, Coyote, Monument Point, Nighthawk and North Cricket.
These 16 wells were logged to evaluate the vertical distribution of flow into and out of the wells for the
purpose of locating sampling equipment in the wells. The screen interval showing the highest inflow
of water will be the zone from which samples will be collected during each sampling event.
Each well was video logged first to determine the location of the well screen. In a few cases, the well
screen interval determined by video logging did not match the well driller’s log. Table 3-1 will be
updated for accurate screen intervals once this evaluation is complete.
The down-well flow testing method involves fluid-column conductivity logging over time after the in-
situ fluid column has been replaced with environmentally safe deionized water. Finite difference
modeling routines are used to determine zones where formation water is entering the well and to
calculate aquifer permeability. Zones of in-flow, no-flow or very low flows are calculated throughout
the well screen interval. Table 4-1 will be updated upon completion of the down-well flow testing with
the sampling depth selected for each well. Published field studies demonstrate that the technique
has achieved better low-flow resolution than that reported with other flow measurement techniques
(Vernon et al., 1993, reported in EPA CLU-IN, accessed 2018).
Well SN2-11-400-4, located within the playa, was flow tested using a Corehole Dynamic Flowmeter
(CDFM) because the equipment used to test the other wells could not be deployed to the playa
surface. Data collection with a CDFM is based on Faraday's Law of Induction: voltage induced by a
conductor moving at right angles through a magnetic field is directly proportional to the velocity of
the moving conductor. Although the CDFM results are not as detailed and specific as the method
used by Colog, interval(s) of higher flow into the well were still identified and will be used to set the
sampling equipment depth and update Table 4-1.
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At this time, Peak Minerals does not anticipate re-testing the wells unless there are noted obstructions
in the wells within the sampling intervals that are suspected to potentially change the in-flow depth
interval.
6.4.2.2 In-Situ Sampling Method
Peak Minerals plans to use the In-situ Sampling (“ISS”) method for collecting groundwater quality
samples in wells greater than 2-inch diameter, excluding wells equipped with dedicated submersible
pumps (Black Hills, Lakeview, and Mudhole wells). Because the ISS sample volume in a 2-inch diameter
well is insufficient to collect a duplicate of the full analytical suite shown on Table 3-2, low-flow
sampling will be used in 2-inch diameter wells and is described in the subsequent section.
The wells that comprise the SAP/QAPP groundwater monitoring network vary in depth, diameter, and
lithology surrounding the screen intervals. Review of previous sampling purge logs shows
inconsistencies in purge procedures, apparently in response to individual well characteristics. Most
notable are the numbers of wells that go dry when attempting a standard three-well volume purge.
Studies conducted in the 1990s demonstrated that purging of multiple well volumes of groundwater
was not necessary to collect representative samples of the groundwater (Powell and Puls 1993;
Barcelona et al. 1994; Puls and Barcelona 1996). These studies and others ushered in the low-flow
purging method as a replacement to the multiple volumes purging. Robin and Gillham (1987) and
Powell and Puls (1993) continued their investigations into low-flow purging and demonstrated that no
purging was required as long as the sample device was set in the well screen at a depth where
adequate well water exchange was occurring naturally (determined for this project through down-
well flow testing). Puls and Barcelona (1996) indicate that passive sample collection may be more
appropriate for obtaining a representative sample in low-permeability and fractured flow formations
than standard sampling protocols.
Recent testing and verification of ISS devices can be found in numerous documents including Britt
(2006), Interstate Technology and Regulatory Council (ITRC) (2007), Parsons (2005), Parker and
Mulherin (2007), and the current American Society of Testing Materials (“ASTM”) Standard Guide for
Selection of Passive Techniques for Sampling Groundwater Monitoring Wells [ASTM D7929-14] (ASTM,
2014). The benefit of an ISS device is that the sampler is left in the well to equilibrate with the flow
through the well screen, which minimizes the alteration of the groundwater sample through purging.
This removes some of the sources of variability in water quality data due to differences in sampling
personnel, sampling procedures, and equipment (EPA, 2005; Britt et al. 2010).
ASTM D7929-14 states that ISS sampling methods should consider sampler design, ability of the sampler
to collect the target contaminants, well construction (including well diameter, screen, and filter pack
length), vertical and horizontal flow patterns within the well, and the constituents of concern. Passive
ISS samplers are particularly well suited for conditions where active sampling methods can be
problematic, such as those demonstrated in the purge logs from prior well sampling activities in the
area of interest (CH2M, 2013). These conditions can include low-yield formations, where excessive
drawdown is unavoidable even at low flow rates or where low-turbidity samples are needed but
cannot be obtained using other sampling methods, such as with a bailer or a pump (ASTM D7929-14).
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The ITRC (2007) encourage the appropriate use of passive sampler technologies in new groundwater
monitoring programs and as a replacement for existing high-volume purge sampling systems. The
benefits stated by the ITRC (2007) include the following:
• Relatively easy to use;
• Reduces field-sampling variability, resulting in more reproducible data;
• Decreases field labor and project management costs for long-term monitoring;
• Allows rapid field sample collection;
• Allows sampling of the same interval in the well;
• Practical for use where access is difficult or where discretion is desirable;
• Can be deployed in series to provide a vertical chemical profile;
• Can be deployed in most wells; and
• Has no depth limit.
ISS sampling imparts the least degree of differential influence of any of these factors from one
sampling event to the next through elimination of variations in sampling procedures and sample
handling. Using an ISS system, the focus shifts from the sampling process to interpretation of time-series
data. The ISS system will be a dedicated system to reduce field sampling variability but can be
removed temporarily to allow use of the well for other purposes. If, for any reason, the ISS system is not
functioning correctly in any of the wells, the backup sampling method would be low-flow purge (EPA,
2017).
For the ISS method, Peak Minerals proposes to use the Snap Sampler® ISS sampling method. With this
system, sample bottles are suspended on a cable at an appropriate depth within the well screen
(determined from the down-well flow testing described in Section 6.4.2.1) and allowed to set for a
minimum of one week prior to sampling. A minimum of 460 ml of groundwater is required for the
analyte list shown on Table 3-2. In 4-inch diameter wells and larger, 2,100 ml of groundwater can be
collected using a total of six Snap Sampler bottles. Therefore, sufficient water will be available to allow
the collection of the original sample as well as a duplicate or MS/MSD sample from any 4-inch
diameter well or larger.
At the time of sampling, the lids on the bottles are triggered closed, thereby sealing the sample. The
cable is then withdrawn and the sample bottles are removed to the ground surface. An appropriate
volume of unfiltered groundwater will be transferred into a separate container for field testing of pH
and specific conductance. Aliquots of groundwater will be field filtered through a 0.45-micron
disposable filter into appropriate laboratory supplied containers. Laboratory supplied preservative will
be added to the appropriate sample containers.
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Following sample collection, the Snap Sampler bottles will be cleaned using a bristle brush and
Liquinox™ or an equivalent non-phosphate detergent, then rinsed with tap water and distilled water.
The bottles will be drip-dried (under a paper towel or other cover to preclude dust impacts), after
which they will be placed back onto the cable and lowered back into the well. The bottles will be
dedicated to an individual well. A standard operating procedure is included in Appendix C.
The sample ID, sample date and time, field parameters, required analyses and sample volume will be
recorded on the Groundwater Sample Log Form B (Appendix E). The sample management and
shipping will be processed in accordance with the procedures in Section 7.
6.4.2.3 Low-Flow Sampling Method
Low flow purge methods will be used in 2-inch diameter wells including Machine Gun, Crystal Peak
Road and Headlight Gap and BLM wells with previously installed submersible pumps (i.e., Black Hills,
Lakeview, and Mudhole). Low-flow sampling methods will generally follow procedures recommended
by the EPA (2017).
The low-flow wells identified above were down-well flow tested and sample depths will be presented
on Table 4-1. Peak Minerals acknowledges that EPA (2017) recommends that the low flow procedure
is preferentially applicable to wells with a well screen length no more than 10 feet and a static water
level above the well screen. However, the EPA recommendation assumed that the dominant
groundwater inflow interval to a well was not known. Furthermore, Kaminski (2010) recommends that
the purge location should relate to the saturated thickness of the monitored zone and preferential
pathways rather than an arbitrary screen length (Kaminski 2010).
Low flow purging will be performed using Geotech bladder pumps capable of installation in 2-inch
diameter casing and larger. These bladder pumps can operate at depths up to 1,000 feet with true
low flow capability for less agitation. Bladder pumps will be installed in accordance with the
manufacturer’s instructions and are planned to be a dedicated installation for each well. The pumps
will be controlled by the Geotech 300 PSI Controller with accurate microprocessor-controlled
fill/discharge timers to sustain low flow sampling techniques. The 300 PSI controller can operate the
pumps to sampling depths of 690 feet. The depth at which the pumps are installed will be identified
on Table 4-1 (determined by the down-well testing described in Section 6.4.2.1), with samples
collected from the primary zone of groundwater flow through the well screen.
Tubing from the pump will be connected to a flow-through cell in which dissolved oxygen, specific
conductance, temperature, and pH will be monitored until these parameters stabilize for three
consecutive readings taken at 5-minute intervals. Turbidity measurements will be collected from water
diverted at a bypass valve installed before the flow through cell. The water samples for turbidity will
be collected in separate sample cells and analyzed using a turbidimeter. Stable water quality
parameter measurements indicate representative sampling is obtainable. Stabilization will be
considered complete when the following is achieved (EPA 2017):
• Dissolved Oxygen (DO): +10 percent for values > 0.5 mg/L; if three values are < 0.5 mg/L the
water is considered stabilized.
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6-11
• pH: + 0.1 unit.
• Specific Conductance (SC): +3 percent.
• Temperature: +3 percent.
• Turbidity: +10% for values greater than 5 NTU; if three turbidity values are less than 5 NTU,
consider the values as stabilized.
There is some concern over the stabilization of field parameters based on previous sampling logs. If
field parameters do not stabilize even with adjustments to purge rates, and/or the drawdown in the
well is surpassing the preferred quantity of 0.3 feet, field personnel will document the lack of
stabilization and stop the purge process after the stabilization of DO, pH, temperature, and SC. Further,
once the required purge volume is obtained (as discussed below), the purge process will not extend
past ½ hour. If such steps are taken, they will be noted in the field log and the data will be
appropriately qualified.
The discharge from the flow-through cell will be directed to a 5-gallon bucket to determine the total
volume purged (including that which is collected for turbidity measurements). During pumping, the
flow rate will be monitored using a 250-ml graduated cylinder while drawdown in the well is measured.
The goal is to purge the well at a rate that produces less than 0.3 foot of drawdown. The final purge
volume must be greater than the stabilized drawdown volume plus the pump’s tubing volume.
Once the field parameters stabilize and the minimum total volume of purge water has been verified
by the amount of water collected in the bucket, the water will be sampled. The tubing will be
disconnected from the flow-through cell and each bottle will be filled from that tubing.
Samples intended to provide concentrations of dissolved constituents (Table 3-2) will be field filtered
using a 0.45-micron filter to remove larger particles that have been entrained in the water sample. A
clean, unused filter will be used for each filtered sample collected. Groundwater samples will be
transferred from the filter directly into the appropriate sample containers with a preservative and
stored on ice until they are processed for shipment to the laboratory. When transferring samples, care
will be taken not to touch the filter to the sample container.
Sample containers will be supplied by the analytical laboratory. Commercially available pre-cleaned
jars will be used, and the laboratory will be responsible for maintaining a record of certification from
the suppliers. Preservatives (if needed) would be added to the sample bottles before filling to reduce
the time the sample is handled and open to the atmosphere.
The sample ID, sample date and time, field parameters, required analyses and sample volume will be
recorded on the Groundwater Sample Log Form B (Appendix E). The sample management and
shipping will be processed in accordance with the procedures in Section 7.
At wells where a duplicate sample is to be collected, all bottles designated for a particular analysis
for both sample designations will be filled sequentially before bottles for another analysis are filled. In
the filling sequence for duplicate samples, bottles with the two different sample designations will
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alternate. Groundwater samples will be transferred directly into the appropriate sample containers
with preservative, if required, chilled if appropriate, and processed for shipment to the laboratory.
6.4.3 Spring Sampling
If springs are monitored in the future, flow measurements will be collected if feasible and the spring
water will be sampled if present. Given the intermittent nature of the springs as well as landowner
accessibility issues, spring monitoring locations may change as more information becomes available.
If the flow is too low to allow the use of a current meter to measure the discharge rate, the flow velocity
will be estimated using the float method or other approach recommended by Buchanan and Somers
(1969).
In order to avoid potential disturbances caused by flow measurement, water quality samples will be
collected from the springs before measuring the flow. Field measurements of temperature, pH, SC,
turbidity, and DO will be collected and recorded during each sampling event. The spring samples
and field measurements will be logged on the Surface Water Sample Form C (Appendix E). Sample
management and shipping would follow procedures in Section 7. The samples will be analyzed for
the constituents listed above in Table 3-1.
6.5 Decontamination Procedures
Sampling equipment that comes into contact with water at another source will be decontaminated
in accordance with SOP 2 in Appendix C. Disposable equipment intended for one-time use will not
be decontaminated but will be packaged for appropriate disposal.
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7.0 SAMPLE CONTAINERS, PRESERVATION, PACKAGING,
AND SHIPPING
7.1 Water Sample Containers
The number and type of sample containers are listed in Tables 3-1 and 3-2. The containers will be pre-
cleaned and preservatives, if required, will be added to the containers in the field. All samples will
be chilled to 4°C +2oC immediately upon collection and labeling except for brine protocol sample
which will remain at room temperature. Additional information regarding sample preservation and
analysis is provided in Sections 5.1.1 (surface water) and 5.1.2 (groundwater).
7.2 Packaging and Shipping
All sample bottles associated with each location will be placed in a sealable plastic bag for shipment
to the laboratory. Glass sample bottles will be individually placed inside a protective bubble wrap
container to minimize the potential for breakage during shipment. All sample containers will be
placed inside a sealable 5-mil plastic bag that is placed inside a strong-outside shipping container
(e.g., a cooler). Ice will be added to the cooler and empty space in the cooler will be filled with
bubble wrap if necessary to prevent movement and breakage of the sample containers during
shipment.
A properly completed chain-of-custody form for the samples in the cooler will be placed inside a
separate plastic bag, sealed, and taped to the inside lid of the cooler. Security seals will be signed
and placed over the lip of the cooler lid. This seal with be secured to the lid with packing tape. The
cooler will be shipped directly to Pace via an overnight service.
The sample for the brine protocol analysis will not be iced. Rather, it will remain at ambient
temperature during transport and hand delivery to AWAL.
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8.0 DISPOSAL OF RESIDUAL MATERIALS
In the process of collecting environmental samples, the sampling team will generate different types
of waste that may include the following:
• Used sampling gloves,
• Disposable sampling equipment,
• Decontamination fluids,
• Purged groundwater and excess groundwater collected for sample container filling.
Used sampling gloves and disposable equipment will be placed in a municipal refuse dumpster. These
wastes are not considered hazardous and can be sent to a municipal landfill.
Decontamination fluids that will be generated in the sampling event will consist of tap water
containing a non-phosphate detergent, distilled or deionized water, and residual (innocuous)
contaminants. The volume and concentration of the decontamination fluid will be sufficiently low to
allow disposal at the site or sampling area and will, therefore, be poured onto the ground.
Purged groundwater will be disposed by pouring onto the ground adjacent to the sampled well.

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9.0 SAMPLE DOCUMENTATION
9.1 Field Documentation
Field documentation serves as the primary foundation for all field data that will be used to evaluate
conditions within the area of interest. Care will be taken to ensure that all field documentation is
accurate, legible, and written in indelible black or blue ink. No pencils or erasures will be used.
Incorrect entries in field books, logs, or on forms that need to be corrected will be crossed out with
one line, initialed, and dated. Skipped pages or blank sections at the end of a page will be crossed
out with an "X" covering the entire page or blank section; "No Further Entries," initials, and date will be
written by the person crossing out the section or page. The responsible field team member will write
his/her signature, date, and time after the day's last entry.
9.1.1 Field Logbooks
The field logbook will be a bound, weatherproof book with numbered pages and will serve primarily
as a summary of the activities carried out during the fieldwork. The logbook will be signed by the field
personnel at the end of the daily entry. All entries will be made in indelible black or blue ink. The field
forms (Appendix E, Forms A through C), will contain the documentation for sampling activities and will
be referenced in the logbook each day, including an indication of which form(s) were used.
Field logbooks will document the following:
• Date;
• Time of important events;
• Purpose and objective of field work;
• Health and safety issues;
• Personnel and subcontractors on job site and time spent on the site;
• Summary of what was completed/performed;
• Type of sampling equipment used;
• Field instrument readings and calibration;
• Field observations and details related to analysis or integrity of samples (e.g., weather
conditions, noticeable odors, colors, etc.);
• Preliminary sample descriptions (e.g., clear or turbid water);
• Sample preservation;
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• Lot numbers of the sample containers, sample identification numbers and any explanatory
codes, and chain-of-custody form numbers;
• Shipping arrangements (overnight air bill number);
• Name(s) of recipient laboratory(ies);
• Problems encountered and corrective action taken;
• Deviations from the sampling plan and reason for the deviations; and
• List of forms completed (i.e., Forms A through C).
Electronic field logs (i.e., using a tablet or laptop computer) may also be used to capture the above
information.
9.1.2 Photographs
Photographs will be taken of the sample locations and at other areas of interest to document
conditions during each sampling event. Documentation of a photograph is crucial to verify that it
represents an existing situation. The following information concerning photographs will be noted in the
logbook:
• Date, time, and location photograph was taken - in format mm/dd/yyyy – hh:mm;
• Weather conditions;
• Description of photograph;
• Reasons photograph was taken;
• Sequential number of the photograph; and
• Orientation direction when the photograph was taken.
After the photos are downloaded, the information recorded in the field logbook will be summarized
in captions in the digital photo log.
9.2 Sample Labeling
All sample containers will be labeled (pre-printed by laboratory or sampling team) using waterproof
labels and ink with the following information written on the labels:
• Client or project name;
• Sample identification number;
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• Date and time of collection - in format mm/dd/yyyy – hh:mm;
• Requested analysis; and
• Container type and type of preservation used (chemicals added).
Field information concerning water samples will be listed on the appropriate forms contained in
Appendix E.
9.3 Sample Chain-Of-Custody Forms
Chain-of-custody (“CoC”) is a mechanism employed to ensure that samples shipped from the field
and data resulting from laboratory analysis are credible and defensible. CoC begins at the time and
point of sample collection. Documentation of sample possession and CoC is provided using sample
labels and CoC forms.
All sample shipments for analyses will be accompanied by a chain-of-custody form. A copy of the
form is found in Appendix F. Form(s) will be completed and sent with the samples for each laboratory
and each shipment (i.e., each day). If multiple coolers are sent to a single laboratory on a single day,
form(s) will be completed and sent with the samples for each cooler.
Information listed on the CoC includes:
• Sample ID;
• Project name, location, and number;
• Sampling dates and times;
• Name of sampling technician(s);
• Media being tested for each sample;
• Number of containers per sample;
• Signature of person relinquishing and receiving custody;
• Requested analyses for each sample; and
• Special requirements/comments for project or analysis.
The CoC form will identify the contents of each shipment and maintain the custodial integrity of the
samples. Generally, a sample is considered to be in someone's custody if it is either in someone’s
physical possession, in someone's view, locked up, or kept in a secured area that is restricted to
authorized personnel. Until the samples are shipped, the custody of the samples will be the
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responsibility of the sampling team leader. The sampling team leader or designee will sign the chain-
of-custody form in the “relinquished by” box and note date, time, and air bill number.
The field person relinquishing the samples will keep one copy of each CoC form and send the
remaining copies with the samples. As noted in Section 7.2, the CoC form will be sealed in a
waterproof plastic bag and taped to the inside lid of the shipping container (cooler).

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10.0 QUALITY CONTROL
Quality assurance and quality control (“QA/QC”) are critical components of every monitoring
program. QA/QC requirements for Peak Minerals’ monitoring activities are intended to ensure that
data collected meet the project and data quality objectives discussed in Section 3. Quality assurance
planning helps ensure that the Project DQOs are met. Quality control samples ensure that procedures
and actions are conducted correctly.
10.1 Field Quality Control
QC samples to be collected in the field are briefly described below.
10.1.1 Blind Duplicates
A blind duplicate sample is a duplicate of an original sample collected at the same time and location
as the original sample. Blind duplicate water samples are collected in immediate succession, using
identical sampling techniques, and treated in an identical manner during storage, transportation, and
analysis. The sample containers are assigned a unique identification number in the field such that they
cannot be identified as duplicates by laboratory personnel (i.e., the samples are submitted “blind”).
When collecting blind duplicate water samples, bottles representing the original sample and the blind
duplicate, with the two different sample identification numbers, will alternate in the filling sequence.
Bottles for one type of analysis will be filled before bottles for the next analysis are filled. Duplicate
samples will be preserved, packaged, and sealed in the same manner as other samples of the same
matrix.
Blind duplicate sample results are used to assess precision of the overall sample collection and analysis
process, as noted in Section 3.3.1. Blind duplicate surface and groundwater samples will be collected
at a minimum frequency of one duplicate for every 10 regular samples, or portion thereof, with at
least one duplicate for each matrix (i.e., surface water and groundwater).
10.1.2 Equipment Blanks
Equipment blanks are used to demonstrate that dedicated sampling equipment is adequately clean,
if a certificate is not available to demonstrate cleanliness. Equipment blanks will be collected by
placing the dedicated sampling equipment in deionized or distilled water, allowing the water to
contact the internal portions of the equipment, and collecting samples into the appropriate sample
containers. This will be done for the groundwater sampling equipment listed in Table 6-1 if certificates
of cleanliness are not available form the manufacturers of that equipment. These blanks will be
analyzed for all laboratory analyses listed in Table 3-2. Analyses in accordance with Table 3-1 will not
be necessary since dedicated sampling equipment will not be used during the collection of surface
water samples. Equipment blanks for dedicated equipment will be collected at a rate of one sample
for every ten sets of similar dedicated equipment (i.e., bailers and sample tubing) or portions thereof.
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10.1.3 Field Blanks
Field blanks will be collected to evaluate whether contaminants have been introduced into the
samples during sampling due to contamination from sample containers or from environmental
conditions (e.g., dust). Field blank samples will be obtained by pouring deionized water into a
sampling container at the sampling point, leaving the lid off during sampling at that location. The field
blanks that are collected will be analyzed for metals.
One field blank will be collected each time a blind duplicate sample is collected. The field blanks will
be preserved, packaged, and sealed in the manner described for the environmental samples. A
separate sample number will be assigned to each field blank sample, and it will be submitted blind
to the laboratory.
10.1.4 Temperature Blanks
For each sample container that is shipped or transported on ice to an analytical laboratory, a 40-ml
or larger glass or polyethylene container will be included that is marked “temperature blank.” This
blank will contain deionized or distilled water and will be used by the laboratory to check the
temperature of samples upon receipt.
10.2 Laboratory Quality Control Samples
QC data are necessary to determine precision and accuracy and to demonstrate the absence of
interferences and/or contamination of laboratory glassware and reagents. Each type of laboratory-
based QC sample will be analyzed, at a rate of 5% or one per batch (a batch is a group of up to 20
samples analyzed together), whichever is more frequent.
10.2.1 Method Blank
A method blank is a sample generated in the laboratory consisting of reagent-grade water that is
taken through the entire sample preparation and analysis with the field samples. It is used to monitor
for contamination that may be introduced into the samples during processing within the laboratory.
Evaluation criteria are provided in the source methods and in the laboratory QA manuals provided in
Appendix B.
10.2.2 Laboratory Duplicate
A laboratory duplicate consists of an aliquot of a field sample that is taken from the same container
as the initial field sample and prepared and analyzed with the field sample. Laboratory duplicates
are used to monitor the precision (in terms of RPD) of the analytical process. In conjunction with field
duplicates, the sampling precision can then be inferred. Criteria for laboratory duplicates are
provided in the source methods and in the laboratory QA manuals provided in Appendix B.
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10.2.3 Laboratory Control Sample
A laboratory control sample (“LCS”) consists of a laboratory-generated sample that contains the
analytes of interest at known concentrations. It may be prepared by the laboratory or purchased
from an outside source. The LCS is taken through the same preparation and analytical procedures as
the field samples. Analyte recoveries indicate the accuracy of the analytical system. LCSs and matrix
spikes (“MS”) together allow the overall accuracy of the sampling and analytical process to be
determined. Criteria for LCS evaluation are provided in the source methods and in the laboratory QA
manuals provided in Appendix B.
10.2.4 MS/MSD Duplicates
MS/MSDs are used to assess the effect of the sample matrix on analyte recovery. Both the MS and the
MSD consist of an aliquot of a field sample to which the laboratory adds a known concentration of
the analyte(s) of interest. An unspiked aliquot is also analyzed, and the percent recovery for the spiked
sample is calculated.
The sample(s) chosen for MS/MSDs should be representative of the sample matrix but should not
contain excessive concentrations of analytes or interfering substances. MS/MSDs will be analyzed at
a frequency of one MS/MSD per 20 or fewer samples for each matrix and each sampling event.
Analysis of MS/MSDs requires collection of a sufficient volume of sample to accommodate the number
of aliquots to be analyzed. The laboratory will be informed of the number of MS/MSD samples to be
collected to ensure that a sufficient number of samples contained are filled for the analyses. The
laboratory will also be alerted as to which sample is to be used for MS/MSD analysis by a notation on
the sample container label and the chain-of-custody record or packing list.
When collecting water samples that will be the subject of MS/MSD analyses, bottles for each type of
analysis will alternate in the filling sequence. Bottles for one type of analysis will be filled before bottles
for the next analysis are filled. Control limits for MS/MSDs are provided in the source methods and in
the laboratory quality assurance manuals provided in Appendix B.
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11.0 FIELD VARIANCES
As conditions in the field may vary, it may become necessary to implement minor modifications to
sampling as presented in this plan. When possible, the QA Officer will be notified, and a verbal
approval will be obtained before implementing the changes. Modifications to the approved plan will
be documented in the sampling project report.
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12.0 FIELD HEALTH AND SAFETY PROCEDURES
All field activities associated with the SAP/QAPP will be performed in accordance with the most recent
edition of the Peak Minerals Site Safety Plan.

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13.0 REFERENCES
Barcelona, M.J., H.A. Wehrmann, and M.D. Varljen, 1994. "Reproducible Well-Purging Procedures and
VOC Stabilization Criteria for Ground-Water Sampling." Groundwater. Volume 32, No. 1, pp.12–
22.
BLM. 2011. Potassium Lease. Issued to Peak Minerals Inc. by United States Department of the Interior,
Bureau of Land Management. June 1, 2011.
Brebner, J., A. Lefaivre, D. Bairos, C. Laxer, L.D. Henchel, R. Reinke, and S. Ennis. 2018. NI 43-101
Technical Report Summarizing the Feasibility Study for the Sevier Playa Potash Project, Millard
County, Utah. Project report prepared for Crystal Peak Minerals Inc. by Novopro Projects Inc.
and Norwest Corporation. Montreal, QC, Canada.
Britt, S.L. 2006. Differential recoveries during VOC sampling: low-flow, the snap sampler, and remedial
decision-making. In Proceedings of the Fifth International Conference on Remediation of
Chlorinated and Recalcitrant Compounds, Monterey, California, May 22–25, 2006.
Britt, S.L., B.L. Parker, and J.A. Cherry. 2010. A New Downhole Passive Sampling System to Avoid Bias
and Error from Groundwater Sample Handling. Environmental Science and Technology
44(13):4917–4923.
Buchanan, T.J., and W.P. Somers. 1969. Discharge Measurements at Gaging Stations. Chapter A in
Techniques of Water-Resources Investigations of the United States Geological Survey: Book 3
– Applications of Hydraulics. Reston, Virginia.
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.
CH2M HILL (CH2M). 2012. Technical Memorandum, Results of Clean Water Test Hole. July 3, 2012.
CH2M HILL. 2013. Draft-Final Sevier Playa Basin Conceptual Model Report. December.
Dunn, O.J. 1964. Multiple comparisons using rank 1 sums. Technometrics 6(3):241–252.
Department of Water Quality. 2010. Water Quality Assessment Guidance. Utah Division of Water
Quality Department of Environmental Quality. October 7, 2010.
Fetter, C.W. 1980. Applied Hydrogeology. Columbus, Ohio: Charles E. Merrill Publishing Co.
Friedman, M. 1939. A correction: The use of ranks to avoid the assumption of normality implicit in the
analysis of variance. Journal of the American Statistical Association 34 (205):109.
doi:10.2307/2279169.
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Gardner, P.M., M.D. Masbruch, R.W. Plume, and S.G. Buto. 2011. Regional Potentiometric-Surface Map
of the Great Basin Carbonate and Alluvial Aquifer System in Snake Valley and Surrounding
Areas, Juab, Millard, and Beaver Counties, Utah, and White Pine and Lincoln Counties,
Nevada. U.S. Geological Survey Scientific Investigations Map 3193. Reston, Virginia.
Gwynn, J.W. 2006. History and Mineral Resource Characterization of Sevier Lake, Millard County, Utah.
Utah Geological Survey Miscellaneous Publication 06-6. Salt Lake City, Utah.
Hem, J.D. 1985. Study and Interpretation of the Chemical Characteristics of Natural Water. U.S.
Geological Survey Water-Supply Paper 2254. Reston, Virginia.
Hintze, L.F. and F.D. Davis. 2003. Geology of Millard County, Utah. Utah Geological Survey Bulletin 133.
Salt Lake City, Utah.
Interstate Technology and Regulatory Council (ITRC). 2007. Protocol for use of five passive samplers to
sample for a variety of contaminants in groundwater. Interstate Technology and Regulatory
Council. Document DSP5.
Kaminski, D. 2010, Low-Flow Groundwater Sampling: An Update on proper Application and Use.
PowerPoint, QED 2010.
Kennedy, E.J., 1984. Techniques of Water-Resources Investigations of the United States Geological
Survey.
Book 3 - Applications of Hydraulics; Chapter A10 - Discharge Ratings at Gauging Stations.
Llopis, J.L. 1991. The Effects of Well Casing Material on Ground Water-Quality. EPA/540/4-91/005. U.S.
Environmental Protection Agency Office of Research and Development. Washington, D.C.
Norwest Corporation. 2017. 50% Framework Water Monitoring Plan, Sampling and Analysis Plan,
Quality Assurance Project Plan: Crystal Peak Minerals Sevier Playa Potash Project. Project
report prepared for Crystal Peak Minerals. Salt Lake City, Utah.
Norwest Corporation. 2018a. Water Monitoring Plan for the Sevier Playa Potash Project. Project report
prepared for Crystal Peak Minerals. Salt Lake City, Utah.
Norwest Corporation. 2018b. Crystal Peak Minerals (Peak Minerals) Sevier Playa Project Water
Resources Technical Memorandum. Project report prepared for Crystal Peak Minerals. Salt
Lake City, Utah.
Parker, L., and N. Mulherin. 2007. Evaluation of the Snap Sampler for Sampling Groundwater Monitoring
Wells for VOCs and Explosives. U.S. Army Corps of Engineers, ERDC/CRREL TR-07-14, 68p.
Parsons. 2005. Final results report for the demonstration of no-purge groundwater sampling devices at
former McClellan Air Force Base, California; U.S. Army Corps of Engineers/Air Force Center for
Environmental Excellence/Air Force Real Property Agency.
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Powell, R.M., and R.W. Puls. 1993. Passive sampling of groundwater monitoring wells without purging:
Multilevel well chemistry and tracer disappearance. Journal of Contaminant Hydrology 12:51–77.
Puls, R.W., and M.J. Barcelona. 1996. Low-Flow (Minimal Drawdown) Ground-Water Sampling
Procedures. Washington, D.C.: U.S. Environmental Protection Agency.
Robin, M.J.L., and R.W. Gillham. 1987. Field evaluation of well purging procedures. Groundwater
Monitoring & Remediation 7:85–93.
U.S. Environmental Protection Agency. 2002. Guidance for Quality Assurance Project Plans. EPA
QA/G-5. Office of Environmental Information. EPA/240/R-02/009. Washington, D.C.
U.S. Environmental Protection Agency. 2005. Intergovernmental Data Quality Task Force, Uniform
Federal Policy for Quality Assurance Project Plans; Evaluating, Assessing, and Documenting
Environmental Data Collection and Use Programs; Part 1: UFPQAPP Manual. EPA: EPA-505-B-
04-900A and DoD: DTIC ADA 427785. Available at: https://www.epa.gov/sites/production/
files/documents/ufp_qapp_v1_0305.pdf.
U.S. Environmental Protection Agency. 2006. Guidance on Systematic Planning Using the Data Quality
Objectives Process. EPA QA/G-4. Office of Environmental Information. EPA/240/B-06/001.
Washington, D.C.
U.S. Environmental Protection Agency. 2009. Statistical Guidance of Groundwater Monitoring Data at
RCRA Facilities: Unified Guidance. EPA 530-R-09-007. Washington, D.C.
U.S. Environmental Protection Agency. 2012. Sampling and Analysis Plan Guidance and Template:
Version 3, Brownfields Assessment Projects. R9QA/008.1. San Francisco, California.
U.S. Environmental Protection Agency. 2017. Low Stress (Low Flow) Purging and Sampling Procedure
for the Collection of Groundwater Samples from Monitoring Wells. EQASOP-GW4. Originally
published July 30, 1996. Quality Assurance Unit, Region 1. North Chelmsford, Massachusetts.
Whetstone Associates. 2017. Final Baseline Water Resources Technical Report for the Sevier Playa
Potash Project. Project report prepared for U.S. Bureau of Land Management. Document
4169C.171004. Gunnison, Colorado.
Wilberg, D.E. 1991. Hydrologic Reconnaissance of the Sevier Lake Area, West-Central Utah. Technical
Publication No. 96. Utah Department of Natural Resources. Salt Lake City, Utah.

Attachments
Permit No. UGW270012

APPENDIX B

INTERIM PROTECTION LEVELS

Well Gr
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W
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Headlight Gap (HLG)4 109,350 10,995 0.091 0.217 <0.05 <0.100 <0.100 185 <0.100 <0.0002
SN2-11-400-4 (SN2)4 103,575 8,959 0.125 <0.250 <0.05 <0.100 <0.100 176 <0.100 <0.0002
257 Cutoff (257)4 120,300 25,463 0.135 0.292 <0.05 <0.100 <0.100 479 <0.100 <0.0002
Miller Canyon Reservoir (MCR)3 1,670 395 0.178 0.043 <0.001 <0.002 <0.002 195 <0.002 <0.0002
Lakeview (LKV)2 917 256 0.028 0.042 <0.001 0.003 <0.002 13 0.007 <0.0002
North Cricket (NCT)2 657 57 0.009 0.106 <0.001 <0.002 <0.002 6 <0.002 <0.0002
Coyote (CYT)2 650 145 0.032 0.050 <0.001 <0.002 <0.002 14 <0.002 <0.0002
1 -
APPENDIX B - INTERIM PROTECTION LEVELS1
Crystal Peak Minerals - Sevier Playa Projects
Concentrations in milligrams per liter (mg/L)
Ground Water Discharge Permit No. UGW270012
Interim Protection Levels for reported (detected) chemicals calculated as 1.25 times the average background value for Class II
groundwater or 1.5 times the background for Class III and IV. Interim limits for non-detects set to typical reported detection limits. Where
both non-detects and measured concentrations are reported, the average background is calculated using the reported concentrations and
the detection limit values.