DWQ-2024-007637

Demonstration Plant Considerations
The Utah Division of Water Quality (DWQ) has determined the Great Salt Lake Lithium Project Demonstration Plant Application to be complete. However, additional items should be considered
during the Demonstration Plant's operation. Please address the following items to ensure DWQ has the information needed to evaluate the Final Plant.
DWQ cannot ascertain the accuracy of the analyses of diluted samples without the full QA/QC report for independent validation. Moving forward, analytical reports from all analyses, whether
internal or external laboratories, should be provided as a level 4 data package (or equivalent, that includes all method-specified QA/QC sample results) for independent validation of
reported results. Reported data packages should be complete, including all QC test results described in the method, and analyses should be sufficiently sensitive to support the quantitation
of all key constituents (as detailed in Utah Admin. Code R317-16 (3)(c)(i)), including trace metals and other toxic pollutants so far as possible. 
Regarding the addition of groundwater to the effluent stream: What are the volumes of RO treated water, RO reject water, and raw groundwater in the effluent? Is the addition of RO reject
water accounted for in the characterization of effluent? 
Buffer additions: please provide data in anticipation of using both sodium hydroxide & calcium carbonate.
“Because the Demonstration Plant would be operated for a limited period, no foreign materials (for example, descalers or equipment cleaning operations) would be added to the process
equipment and the intake and outlet infrastructure.” However, the maintenance of the operation will be necessary at full scale. Therefore, DWQ encourages you to pilot the maintenance,
such as cleaning, so that it can be addressed and accounted for Certification. Ensure that your monitoring plan incorporates capture of this effluent.
Regarding the unreported parameters: bicarbonate, carbonate, TSS, temperature, and pH, please provide reasonable responses justifying their absence or an interpretation of the missing
values.
If you have any further questions about the above items, please contact Benjamin Holcomb, Standards & Technical Service Section Manager. Thank you for your efforts to protect water quality.

DWQ-2024-003333