DAQ-2024-010861

1

DAQC-984-24
Site ID 10571 (B4)

MEMORANDUM

TO: STACK TEST FILE – KENNECOTT UTAH COPPER – Bingham Canyon Mine

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Connor Kijowski, Environmental Scientist

DATE: October 7, 2024

SUBJECT: Source: In-Pit Crusher (M3/M4) and Transfer Point Baghouses (C6/C8)
Location: Kennecott Bingham Canyon Mine
Contact: Sean Daly: 801-913-4456
Tester: Alliance Source Testing: 352-663-7568
Site ID #: 10571
Permit/AO #: DAQE-AN105710047-21, dated May 10, 2021
Subject: Review of pretest protocol dated September 12, 2024
On September 17, 2024, Utah Division of Air Quality (DAQ) received a protocol for testing of the In-Pit
Crusher Baghouse (M3/M4) and the Transfer Point Baghouse (C6/C8) at Bingham Canyon Mine, Salt
Lake County, Utah. Testing will be performed on October 15-17, 2024, to determine compliance with the
emission limits found in Condition II.B.1.a of the Approval Order (AO) DAQE-AN105710047-21, dated
May 10, 2021.

PROTOCOL CONDITIONS:

1. Method 1 used to determine sample traverses: OK
2. Method 2 used to determine stack gas velocity and volumetric flow rate: OK
3. Method 3/3A used to determine dry molecular weight of the effluent gas stream: OK
4. Method 4 used to determine moisture content: OK
5. Method 201A used to determine PM10 and PM2.5 emissions: OK
6. Method 202 used to determine condensable PM10 and PM2.5 emissions: OK
DEVIATIONS: No deviations were noted.

CONCLUSION: The protocol appears to be acceptable.

2

RECOMMENDATION: Note that the AO lists controlled drop points C6/C7 and C7/C8.
Conveyor 7 was removed from service, and as such, controlled drop
point C6/C7 was removed from service and C7/C8 was renamed at the
source to C6/C8 and is subject to the limits in II.B.1.a of the AO for
controlled drop point C7/C8.

The appropriate tests methods were verified by the source via email and
an updated pretest protocol can be viewed in the attachments. The
methods proposed in the pretest protocol are sufficient to determine
emissions from the In-Pit Crusher Baghouse (M3/M4) and the Transfer
Point Baghouse (C6/C8). It is recommended that the pretest protocol be
determined as acceptable.

ATTACHMENTS: Kennecott Utah Copper verification email, Updated Kennecott Utah
Copper test notification and Alliance Source Testing pretest protocol.
Connor Kijowski <[e-mail]>
Mine Stack Test Protocol
4 messages
Bellard, Andrew (RTKC) <[e-mail]>Fri, Oct 4, 2024 at 1:05 PM
To: "[e-mail]" <[e-mail]>
Cc: "Daly, Sean 3 (RTKC)" <[e-mail]>, Charles Horton <[e-mail]>, Delaine Spangler
<[e-mail]>
Hi Connor,

I made those changes to the protocol and they are attached here. Let me know if that works for you or if we need to
change anything else.

Thanks,

Andrew (Andy) Bellard
Advisor, Environment
Rio Tinto Kennecott
4700 Daybreak Parkway, South Jordan, Utah 84009, USA
M [phone] W [phone]
This email is confidential and contains personal data. It may also be privileged. If you are not the intended recipient, please notify the sender
immediately and delete this message from your system without first printing or copying it Rio Tinto’s Data Privacy Standard applies to all personal
data contained in this email (including any attachments).

AST-2024-4469 RTK BCM PM Compliance Testing SSTP_F.pdf
381K
Connor Kijowski <[e-mail]>Fri, Oct 4, 2024 at 2:58 PM
To: "Bellard, Andrew (RTKC)" <[e-mail]>
Cc: "Daly, Sean 3 (RTKC)" <[e-mail]>, Charles Horton <[e-mail]>, Delaine Spangler
<[e-mail]>
Hi Andrew,
Thanks for the response. Can you also include PM2.5 under Table 2-1 for Method 201a? Once that's included, we should
be good to go.
Thanks,
Connor
[Quoted text hidden]
10/7/24, 8:38 AM State of Utah Mail - Mine Stack Test Protocol
https://mail.google.com/mail/u/0/?ik=0e8810739b&view=pt&search=all&permthid=thread-f:1812011369413127677&simpl=msg-f:18120113694131276…1/4
You don't often get email from [e-mail]. Learn why this is important
--
Connor Kijowski
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
Bellard, Andrew (RTKC) <[e-mail]>Mon, Oct 7, 2024 at 8:34 AM
To: Connor Kijowski <[e-mail]>
Cc: "Daly, Sean 3 (RTKC)" <[e-mail]>, Charles Horton <[e-mail]>, Delaine Spangler
<[e-mail]>
Here you are, changes made.

Thanks,
Andy

From: Connor Kijowski <[e-mail]>
Sent: Friday, October 4, 2024 2:59 PM
To: Bellard, Andrew (RTKC) <[e-mail]>
Cc: Daly, Sean 3 (RTKC) <[e-mail]>; Charles Horton <[e-mail]>; Delaine
Spangler <[e-mail]>
Subject: [External] Re: Mine Stack Test Protocol

Hi Andrew,

Thanks for the response. Can you also include PM2.5 under Table 2-1 for Method 201a? Once that's included, we should
be good to go.

Thanks,
Connor

On Fri, Oct 4, 2024 at 1:05 PM Bellard, Andrew (RTKC) <[e-mail]> wrote:
Hi Connor,

I made those changes to the protocol and they are attached here. Let me know if that works for you or if we need to
change anything else.
10/7/24, 8:38 AM State of Utah Mail - Mine Stack Test Protocol
https://mail.google.com/mail/u/0/?ik=0e8810739b&view=pt&search=all&permthid=thread-f:1812011369413127677&simpl=msg-f:18120113694131276…2/4

Thanks,

Andrew (Andy) Bellard
Advisor, Environment
Rio Tinto Kennecott
4700 Daybreak Parkway, South Jordan, Utah 84009, USA
M [phone] W [phone]
This email is confidential and contains personal data. It may also be privileged. If you are not the intended recipient, please notify the sender
immediately and delete this message from your system without first printing or copying it Rio Tinto’s Data Privacy Standard applies to all personal
data contained in this email (including any attachments).

--
Connor Kijowski
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov

AST-2024-4469 RTK BCM PM Compliance Testing SSTP_F.pdf
380K
Connor Kijowski <[e-mail]>Mon, Oct 7, 2024 at 8:34 AM
To: "Bellard, Andrew (RTKC)" <[e-mail]>
Cc: "Daly, Sean 3 (RTKC)" <[e-mail]>, Charles Horton <[e-mail]>, Delaine Spangler
<[e-mail]>
Great, thanks. I appreciate your assistance.
[Quoted text hidden]
--
10/7/24, 8:38 AM State of Utah Mail - Mine Stack Test Protocol
https://mail.google.com/mail/u/0/?ik=0e8810739b&view=pt&search=all&permthid=thread-f:1812011369413127677&simpl=msg-f:18120113694131276…3/4
Connor Kijowski
Environmental Scientist | Minor Source Compliance
M: [phone]
airquality.utah.gov
10/7/24, 8:38 AM State of Utah Mail - Mine Stack Test Protocol
https://mail.google.com/mail/u/0/?ik=0e8810739b&view=pt&search=all&permthid=thread-f:1812011369413127677&simpl=msg-f:18120113694131276…4/4

Site Specific Test Plan
Rio Tinto Kennecott
4700 Daybreak Parkway
South Jordan, Utah 84009
Sources to be Tested: In-Pit Crusher Baghouse (M3-M4)
& Transfer Point Baghouse (C6/C8) Proposed Test Dates: October 15 & 17, 2024
Project No. AST-2024-4469

Prepared By
Alliance Technical Group, LLC 3683 W 2270 S, Suite E West Valley City, UT 84120
Site Specific Test Plan
Test Program Summary
AST-2024-4469 RTK – Bingham Canyon Mine Page i

Regulatory Information
Permit No. DAQE-AN105710047-21

Source Information
Source Name Source ID Target Parameters
In-Pit Crusher Baghouse M3-M4 PM2.5, PM10, CPM
Transfer Point Baghouse C6/C8 PM10, CPM
Contact Information
Test Location Test Company Analytical Laboratory
Rio Tinto Kennecott Bingham Canyon Mine Salt Lake County, UT
Sean Daly [e-mail] [phone]
Jenny Esker
[e-mail] [phone]
Alliance Technical Group, LLC 3683 W 2270 S, Suite E West Valley City, UT 84120
Project Manager Charles Horton [e-mail]
[phone]
Field Team Leader Mitchell Manwaring [e-mail]
[phone] (subject to change)
QA/QC Manager Kathleen Shonk
[e-mail] [phone]
Test Plan/Report Coordinator
Delaine Spangler
[e-mail]
Alliance Source Testing, LLC 5530 Marshall Street Arvada, CO 80002 Eric Grosjean [e-mail] [phone]
Site Specific Test Plan
Table of Contents
AST-2024-4469 RTK – Bingham Canyon Mine Page ii

TABLE OF CONTENTS
1.0 Introduction ................................................................................................................................................... 1-1
1.1 Process/Control System Descriptions ............................................................................................................ 1-1
1.2 Project Team ................................................................................................................................................. 1-1
1.3 Safety Requirements ..................................................................................................................................... 1-1
2.0 Summary of Test Program ............................................................................................................................ 2-1
2.1 General Description ...................................................................................................................................... 2-1
2.2 Process/Control System Parameters to be Monitored and Recorded.............................................................. 2-1
2.3 Proposed Test Schedule ................................................................................................................................ 2-1
2.4 Emission Limits ............................................................................................................................................ 2-2
2.5 Test Report.................................................................................................................................................... 2-3
3.0 Testing Methodology .................................................................................................................................... 3-1
3.1 U.S. EPA Reference Test Methods 1 and 2 – Sampling/Traverse Points and Volumetric Flow Rate ............ 3-1
3.2 U.S. EPA Reference Test Method 3/3A – Oxygen/Carbon Dioxide .............................................................. 3-1
3.3 U.S. EPA Reference Test Method 4 – Moisture Content ............................................................................... 3-2
3.4 U.S. EPA Reference Test Methods 201A and 202 – PM <10 microns .......................................................... 3-2
3.5 Quality Assurance/Quality Control – U.S. EPA Reference Test Method 3/3A .............................................. 3-2
4.0 Quality Assurance Program .......................................................................................................................... 4-1
4.1 Equipment ..................................................................................................................................................... 4-1
4.2 Field Sampling .............................................................................................................................................. 4-2
4.3 Analytical Laboratory ................................................................................................................................... 4-2
LIST OF TABLES
Table 1-1: Project Team ............................................................................................................................................. 1-1
Table 2-1: Program Outline and Tentative Test Schedule ........................................................................................... 2-2
Table 2-2: Emission Limits ........................................................................................................................................ 2-2
Table 3-1: Source Testing Methodology..................................................................................................................... 3-1
Site Specific Test Plan
Introduction
AST-2024-4469 RTK – Bingham Canyon Mine Page 1-1

1.0 Introduction
Alliance Technical Group, LLC (Alliance) was retained by Rio Tinto Kennecott (RTK) to conduct compliance
testing at the Bingham Canyon Mine (BCM) located in Salt Lake County, Utah. Portions of the facility are subject
to provisions of the Utah Department of Environmental Quality, Division of Air Quality (UDAQ) Approval Order
(AO) DAQE-AN105710047-21. Testing will be conducted to determine the emission rates of particulate matter less
than 10 microns (PM10) and condensable particulate matter (CPM) at the exhausts of the In-Pit Crusher Baghouse
(M3-M4) and the Transfer Point Baghouse (C6/C8). CPM emissions will be collected for inventory purposes only
and shall not be used for compliance demonstration.
This site-specific test plan (SSTP) has been prepared to address the notification and testing requirements of the
UDAQ permit.
1.1 Process/Control System Descriptions
The Bingham Copper Mine is an open-pit mine located approximately four (4) miles southwest of Copperton, Utah.
Copper ore extracted from the mine is loaded into haul trucks. The trucks are unloaded by dumping into a hopper
system. The ore drops into a gyratory crusher which crushes the ore. The unloading and crushing operation takes
place in the mine pit. Dust from the crushing operation is controlled by the in-pit crusher baghouse. Ore is then
transferred from crusher to concentrator by conveyor belt, which includes transfer point C6/C8. All exhaust air and
particulate emissions from each transfer drop points are routed through their respective baghouse before being
vented to the atmosphere. The minimum gas flow for C6/C8 is 3,168 dry standard cubic feet (dscfm).
1.2 Project Team
Personnel planned to be involved in this project are identified in the following table.
Table 1-1: Project Team

RTK Personnel Sean Daly
Jenny Esker
Regulatory Agency UDAQ
Alliance Personnel Mitchell Manwaring
other field personnel assigned at time of testing event
1.3 Safety Requirements
Testing personnel will undergo site-specific safety training for all applicable areas upon arrival at the site. Alliance
personnel will have current OSHA or MSHA safety training and be equipped with hard hats, safety glasses with side
shields, steel-toed safety shoes, hearing protection, fire resistant clothing, and fall protection (including shock
corded lanyards and full-body harnesses). Alliance personnel will conduct themselves in a manner consistent with
Client and Alliance’s safety policies.
A Job Safety Analysis (JSA) will be completed daily by the Alliance Field Team Leader.
Site Specific Test Plan
Summary of Test Programs
AST-2024-4469 RTK – Bingham Canyon Mine Page 2-1

2.0 Summary of Test Program
To satisfy the requirements of the UDAQ permit, the facility will conduct a performance test program to determine
the compliance status of the M3-M4 and C6/C8 baghouses.
2.1 General Description
All testing will be performed in accordance with specifications stipulated in U.S. EPA Reference Test Methods 1, 2,
3/3A, 4, 201A and 202. Table 2-1 presents an outline and tentative schedule for the emissions testing program. The
following is a summary of the test objectives.

• Testing will be performed to demonstrate compliance with the UDAQ permit.
• Emissions testing will be conducted on the exhaust of M3-M4 and C6/C8 baghouses.
• Performance testing will be conducted at no less than 90% of the production rate achieved to date.
• Each of the three (3) test runs will be approximately 60 minutes in duration for each source.
• CPM emissions will be collected for inventory purposes only and shall not be used for compliance
demonstration.
• If the stack gas temperature is less than 85°F at the time of testing, total particulate matter will be measured
using U.S. EPA Reference Test Method 17 or modified U.S. EPA Reference Test Method 5 with an
unheated sample system.
2.2 Process/Control System Parameters to be Monitored and Recorded
Plant personnel will collect operational and parametric data at least once every 15 minutes during the testing. The
following list identifies the measurements, observations and records that will be collected during the testing
program:

• Production rate – tons/hr
2.3 Proposed Test Schedule
Table 2-1 presents an outline and tentative schedule for the emissions testing program.
Site Specific Test Plan
Summary of Test Programs
AST-2024-4469 RTK – Bingham Canyon Mine Page 2-2

Table 2-1: Program Outline and Tentative Test Schedule

Testing Location Parameter US EPA Method No. of Runs Run Duration Est. Onsite Time
DAY 1 – October 14, 2024
Equipment Setup on M3-M4 6 hr
DAY 2 – October 15, 2021

In-Pit Crusher
Baghouse (M3-M4)
VFR 1-2
3

60 min

10 hr
O2/CO2 3/3A
BWS 4
Filterable PM2.5 PM10
201A
Condensable PM 202
DAY 3 – October 16, 2024
Equipment Setup on C6/C8 6 hr
DAY 4 – October 17, 2024

Transfer Point Baghouse (C6/C8)
VFR 1-2
3

60 min

10 hr
O2/CO2 3/3A
BWS 4
Filterable PM10 201A
Condensable PM 202
DAY 5 – October 18, 2024
Contingency Day (if needed)
2.4 Emission Limits
Emission limits for each pollutant are below. Table 2-2: Emission Limits

Source Pollutant Citation
PM10 – 1.77 lb/hr;
Permit
In-Pit Crusher Baghouse 0.016 g/dscf
M3-M4 PM2.5 – 0.78 lb/hr; 0.007 g/dscf
Transfer Point Baghouse PM10 – 0.19 lb/hr;
C6/C8 0.007 g/dscf
Site Specific Test Plan
Summary of Test Programs
AST-2024-4469 RTK – Bingham Canyon Mine Page 2-3

2.5 Test Report
The final test report must be submitted within 60 days of the completion of the performance test and will include the
following information.
• Introduction – Brief discussion of project scope of work and activities.
• Results and Discussion – A summary of test results and process/control system operational data with
comparison to regulatory requirements or vendor guarantees along with a description of process conditions
and/or testing deviations that may have affected the testing results.
• Methodology – A description of the sampling and analytical methodologies.
• Sample Calculations – Example calculations for each target parameter.
• Field Data – Copies of actual handwritten or electronic field data sheets.
• Laboratory Data – Copies of laboratory report(s) and chain of custody(s).
• Quality Control Data – Copies of all instrument calibration data and/or calibration gas certificates.
• Process Operating/Control System Data – Process operating and control system data (as provided by RTK)
to support the test results.
Site Specific Test Plan
Testing Methodology
AST-2024-4469 RTK – Bingham Canyon Mine Page 3-1

3.0 Testing Methodology
This section provides a description of the sampling and analytical procedures for each test method that will be
employed during the test program. All equipment, procedures and quality assurance measures necessary for the
completion of the test program meet or exceed the specifications of each relevant test method. The emission testing
program will be conducted in accordance with the test methods listed in Table 3-1.
Table 3-1: Source Testing Methodology

Parameter U.S. EPA Reference Test Methods
Notes/Remarks
Volumetric Flow Rate 1 & 2 Full Velocity Traverses
Oxygen / Carbon Dioxide 3/3A Integrated Bag / Instrumental Analysis
Moisture Content 4 Gravimetric Analysis
Filterable Particulate Matter less than 10 Microns 201A Constant Rate Sampling
Condensable Particulate Matter 202 Constant Rate Sampling
All stack diameters, depths, widths, upstream and downstream disturbance distances and nipple lengths will be
measured on site with an EPA Method 1 verification measurement provided by the Field Team Leader. These
measurements will be included in the test report.
3.1 U.S. EPA Reference Test Methods 1 and 2 – Sampling/Traverse Points and Volumetric Flow Rate
The sampling location and number of traverse (sampling) points will be selected in accordance with U.S. EPA
Reference Test Method 1. To determine the minimum number of traverse points, the upstream and downstream
distances will be equated into equivalent diameters and compared to Figure 1-1 (for isokinetic sampling) and/or
Figure 1-2 (measuring velocity alone) in U.S. EPA Reference Test Method 1.
Full velocity traverses will be conducted in accordance with U.S. EPA Reference Test Method 2 to determine the
average stack gas velocity pressure, static pressure and temperature. The velocity and static pressure measurement
system will consist of a pitot tube and inclined manometer. The stack gas temperature will be measured with a K-
type thermocouple and pyrometer.
Stack gas velocity pressure and temperature readings will be recorded during each test run. The data collected will
be utilized to calculate the volumetric flow rate in accordance with U.S. EPA Reference Test Method 2.
3.2 U.S. EPA Reference Test Method 3/3A – Oxygen/Carbon Dioxide
The oxygen (O2) and carbon dioxide (CO2) testing will be conducted in accordance with U.S. EPA Reference Test
Method 3/3A. One (1) integrated Tedlar bag sample will be collected during each test run. The bags will be
collected from the positive pressure side of the sample pump and conditioner. They will be collected through a
manifold with a restriction (either rotameter or critical orifice) to ensure even filling throughout the course of the
run. Samples will be concurrent with the test runs. The bag samples will be analyzed on site with a gas analyzer.
The remaining stack gas constituent will be assumed to be nitrogen for the stack gas molecular weight
determination. The quality control measures are described in Section 3.5.
Site Specific Test Plan
Testing Methodology
AST-2024-4469 RTK – Bingham Canyon Mine Page 3-2

3.3 U.S. EPA Reference Test Method 4 – Moisture Content
The stack gas moisture content will be determined in accordance with U.S. EPA Reference Test Method 4. The gas
conditioning train will consist of a series of chilled impingers. Prior to testing, each impinger will be filled with a
known quantity of water or silica gel. Each impinger will be analyzed gravimetrically before and after each test run
on the same analytical balance to determine the amount of moisture condensed.
3.4 U.S. EPA Reference Test Methods 201A and 202 – PM <10 microns
The PM10 testing will be conducted in accordance with U.S. EPA Reference Test Methods 201A and 202. The
complete sampling system will consist of a stainless-steel nozzle, PM10 in-stack cyclone, in-stack filter holder, pre-
weighed quartz filter, heated glass-lined probe extension, un-weighed Teflon filter, gas conditioning train, pump and
calibrated dry gas meter. The gas conditioning train will consist of a coiled condenser and four (4) chilled
impingers. The first and second impingers will be initially empty, the third will contain 100 mL of de-ionized water
and the last impinger will contain 200-300 grams of silica gel. The un-weighed 90 mm Teflon filter will be placed
between the second and third impinger. The probe liner heating system will be maintained at a temperature of 248
±25°F, and the impinger temperature will be maintained at 68°F or less throughout testing. The temperature of the
Teflon filter will be maintained greater than 65°F but less than or equal to 85°F.
Following the completion of each test run, the sampling train will be leak checked at a vacuum pressure greater than
or equal to the highest vacuum pressure observed during the run. The nitrogen purge will be omitted due to minimal
condensate collected in the dry impingers. After the leak check the impinger contents will be measured for moisture
gain. If condensate will be collected in the first dry impinger, then the front-half of the sample train (the nozzle,
probe, and heated pre-weighed filter) and the coil condenser will be removed, and a glass bubbler will be connected
to the first impinger. If needed, de-ionized ultra-filtered (DIUF) water will be added to the first impinger to raise the
water level above the bubbler. Zero nitrogen will be connected to the bubbler, and a 60-minute purge at 14 liters per
minute will be conducted. After the completion of the nitrogen purge the impinger contents will be measured for
moisture gain.
The pre-weighed quartz filter will be carefully removed and placed in container 1. The front half of the filter holder
and back-half of the PM10 cyclone will be rinsed six (6) times with acetone to remove any adhering particulate
matter, and these rinses will be recovered in container 2. All containers will be sealed, labeled and liquid levels
marked for transport to the identified laboratory for filterable particulate matter analysis.
The contents of impingers 1 and 2 will be recovered in container CPM Cont. #1. The back half of the filterable PM
filter holder, probe extension, coil condenser, impingers 1 and 2 and all connecting glassware will be rinsed with
DIUF water and then rinsed with acetone, followed by hexane. The water rinses will be added to container CPM
Cont. #1 while the solvent rinses will be recovered in container CPM Cont. #2. The Teflon filter will be removed
from the filter holder and placed in container CPM Cont. #3. The front half of the condensable PM filter holder will
be rinsed with DIUF water and then with acetone, followed by hexane. The water rinse will be added to container
CPM Cont. #1 while the solvent rinses will be added to container CPM Cont. #2. All containers will be sealed,
labeled and liquid levels marked for transport to the identified laboratory for condensable particulate matter analysis.
3.5 Quality Assurance/Quality Control – U.S. EPA Reference Test Method 3/3A
Cylinder calibration gases will meet EPA Protocol 1 (+/- 2%) standards. Copies of all calibration gas certificates
will be included in the Quality Assurance/Quality Control Appendix of the report.
Site Specific Test Plan
Testing Methodology
AST-2024-4469 RTK – Bingham Canyon Mine Page 3-3

Low Level gas will be introduced directly to the analyzer. After adjusting the analyzer to the Low-Level gas
concentration and once the analyzer reading is stable, the analyzer value will be recorded. This process will be
repeated for the High-Level gas. For the Calibration Error Test, Low, Mid, and High-Level calibration gases will be
sequentially introduced directly to the analyzer. The Calibration Error for each gas must be within 2.0 percent of the
Calibration Span or 0.5% absolute difference.
A Data Acquisition System with battery backup will be used to record the instrument response in one (1) minute
averages. The data will be continuously stored as a *.CSV file in Excel format on the hard drive of a computer. At
the completion of testing, the data will also be saved to the Alliance server. All data will be reviewed by the Field
Team Leader before leaving the facility. Once arriving at Alliance’s office, all written and electronic data will be
relinquished to the report coordinator and then a final review will be performed by the Project Manager.
Site Specific Test Plan
Quality Assurance Program
AST-2024-4469 RTK – Bingham Canyon Mine Page 4-4

4.0 Quality Assurance Program
Alliance follows the procedures outlined in the Quality Assurance/Quality Control Management Plan to ensure the
continuous production of useful and valid data throughout the course of this test program. The QC checks and
procedures described in this section represent an integral part of the overall sampling and analytical scheme.
Adherence to prescribed procedures is quite often the most applicable QC check.
4.1 Equipment
Field test equipment is assigned a unique, permanent identification number. Prior to mobilizing for the test
program, equipment is inspected before being packed to detect equipment problems prior to arriving on site. This
minimizes lost time on the job site due to equipment failure. Occasional equipment failure in the field is
unavoidable despite the most rigorous inspection and maintenance procedures. Therefore, replacements for critical
equipment or components are brought to the job site. Equipment returning from the field is inspected before it is
returned to storage. During the course of these inspections, items are cleaned, repaired, reconditioned and
recalibrated where necessary.
Calibrations are conducted in a manner, and at a frequency, which meets or exceeds U.S. EPA specifications. The
calibration procedures outlined in the U.S. EPA Methods, and those recommended within the Quality Assurance
Handbook for Air Pollution Measurement Systems: Volume III (EPA-600/R-94/038c, September 1994) are utilized.
When these methods are inapplicable, methods such as those prescribed by the American Society for Testing and
Materials (ASTM) or other nationally recognized agency may be used. Data obtained during calibrations is checked
for completeness and accuracy. Copies of calibration forms are included in the report.

The following sections elaborate on the calibration procedures followed by Alliance for these items of equipment.

• Dry Gas Meter and Orifice. A full meter calibration using critical orifices as the calibration standard is
conducted at least semi-annually, more frequently if required. The meter calibration procedure determines
the meter correction factor (Y) and the meter’s orifice pressure differential (ΔH@). Alliance uses approved
Alternative Method 009 as a post-test calibration check to ensure that the correction factor has not changed
more than 5% since the last full meter calibration. This check is performed after each test series.
• Pitot Tubes and Manometers. Type-S pitot tubes that meet the geometric criteria required by U.S. EPA
Reference Test Method 2 are assigned a coefficient of 0.84 unless a specific coefficient has been
determined from a wind tunnel calibration. If a specific coefficient from a wind tunnel calibration has been
obtained that coefficient will be used in lieu of 0.84. Standard pitot tubes that meet the geometric criteria
required by U.S. EPA Reference Test Method 2 are assigned a coefficient of 0.99. Any pitot tubes not
meeting the appropriate geometric criteria are discarded and replaced. Manometers are verified to be level
and zeroed prior to each test run and do not require further calibration.
• Temperature Measuring Devices. All thermocouple sensors mounted in Dry Gas Meter Consoles are
calibrated semi-annually with a NIST-traceable thermocouple calibrator (temperature simulator) and
verified during field use using a second NIST-traceable meter. NIST-traceable thermocouple calibrators
are calibrated annually by an outside laboratory.
• Nozzles. Nozzles are measured three (3) times prior to initiating sampling with a caliper. The maximum
difference between any two (2) dimensions is 0.004 in.
• Digital Calipers. Calipers are calibrated annually by Alliance by using gage blocks that are calibrated
annually by an outside laboratory.
Site Specific Test Plan
Quality Assurance Program
AST-2024-4469 RTK – Bingham Canyon Mine Page 4-2

• Barometer. The barometric pressure is obtained from a nationally recognized agency or a calibrated
barometer. Calibrated barometers are checked prior to each field trip against a mercury barometer. The
barometer is acceptable if the values agree within ± 2 percent absolute. Barometers not meeting this
requirement are adjusted or taken out of service.
• Balances and Weights. Balances are calibrated annually by an outside laboratory. A functional check is
conducted on the balance each day it is use in the field using a calibration weight. Weights are re-certified
every two (2) years by an outside laboratory or internally. If conducted internally, they are weighed on a
NIST traceable balance. If the weight does not meet the expected criteria, they are replaced.
• Other Equipment. A mass flow controller calibration is conducted on each Environics system annually
following the procedures in the Manufacturer’s Operation manual. A methane/ethane penetration factor
check is conducted on the total hydrocarbon analyzers equipped with non-methane cutters every six (6)
months following the procedures in 40 CFR 60, Subpart JJJJ. Other equipment such as probes, umbilical
lines, cold boxes, etc. are routinely maintained and inspected to ensure that they are in good working order.
They are repaired or replaced as needed.
4.2 Field Sampling
Field sampling will be done in accordance with the Standard Operating Procedures (SOP) for the applicable test
method(s). General QC measures for the test program include:
• Cleaned glassware and sample train components will be sealed until assembly.
• Sample trains will be leak checked before and after each test run.
• Appropriate probe, filter and impinger temperatures will be maintained.
• The sampling port will be sealed to prevent air from leaking from the port.
• Dry gas meter, ΔP, ΔH, temperature and pump vacuum data will be recorded during each sample point.
• An isokinetic sampling rate of 90-110% will be maintained, as applicable.
• All raw data will be maintained in organized manner.
• All raw data will be reviewed on a daily basis for completeness and acceptability.
4.3 Analytical Laboratory
Analytical laboratory selection for sample analyses is based on the capabilities, certifications and accreditations that
the laboratory possesses. An approved analytical laboratory subcontractor list is maintained with a copy of the
certificate and analyte list as evidence of compliance. Alliance assumes responsibility to the client for the
subcontractor’s work. Alliance maintains a verifiable copy of the results with chain of custody documentation.