DERR-2024-009839

July 10, 2024

Utah Department of Environmental Quality,
Division of Environmental Response and RemediaƟon (DERR)
Comments to the Final OU-1 Baseline Ecological Risk Assessment Report US Magnesium LLC Site,
Rowley, Utah, May 2024
General Comments:
1.Page 3 to Page 12 (v3 clean), ExecuƟve Summary: Overall, please review this secƟon of the
report for spelling and grammar errors and correct them as necessary.
2.Following SecƟon 7.2.3.3, the secƟon numbering has been compromised and the subsequent
secƟons are numbered incorrectly. The DERR recommends correc Ɵng the secƟon numbering
and confirming that the Contents SecƟon correlates to correcƟons.
Specific Comments:
3.Page 7 (v3 clean), ExecuƟve Summary, BERA Findings for Birds, LOE 3.: The sentences included
in the secƟon for LOE #3 read somewhat contradictory to one another. The DERR recommends
reviewing this secƟon for clarity and either rewording the findings or separaƟng the last
sentence in the secƟon.
4.Page 91 and 92 (v3 clean), Uncertain COPECs Not QuanƟtaƟvely Evaluated, Lack of Screening
Levels: This secƟon lists the number of consƟtuents that lack benchmarks for soil, sediment,
and surface water. The numbers listed for each media type do not appear to equal the totals
that are listed in bullet points for each secƟon. The DERR recommends confirming the correct
totals and adjusƟng accordingly.
5.Page 98 (vs clean), Conclusions, second to last paragraph, second sentence: Please correct the
sentence to read, “ContaminaƟon of PRIs 1 and 3 remain in place under the cap at the Site, and
confirmaƟon sampling of the cap has not been performed.”