DAQ-2024-011233

1

DAQC-1073-24
Site ID 10346 (B4)

MEMORANDUM

TO: STACK TEST FILE – KENNECOTT UTAH COPPER – Smelter

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Paul Morris, Environmental Scientist

DATE: October 21, 2024

SUBJECT: Sources: Combined Heat and Power Unit (REF CHP)
Contact: Sean Daly: 801-204-2563
Location: Kennecott Utah Copper Smelter, 12000 West 2100 South,
Magna, Salt Lake County, Utah
Test Contractor: Alliance Technical Group, LLC
FRS ID #: UT0000004903500030
Permit/AO#: Title V Operating Permit 350003004 dated September 18, 2020
Date of Last Revision: September 27, 2022
Subject: Review of Stack Test Protocols dated October 10, 2024
On October 11, 2024, Utah Division of Air Quality (DAQ) received a protocol for testing of the
Kennecott Utah Copper REF CHP in Magna, Utah. Testing will be performed November 11-12, 2024, to
determine compliance with Title V Operating Permit, Conditions II.B.48.a, II.B.48.b, II.B.48.c, and
II.B.48.d.

PROTOCOL CONDITIONS:

1. RM 1 used to determine sample velocity traverses: OK
2. RM 2 used to determine stack gas velocity and volumetric flow rate: OK
3. RM 3A used to determine dry molecular weight of the gas stream: OK
4. RM 7E used to determine NOx emissions: OK
5. RM 10 used to determine CO emissions: OK
DEVIATIONS: No deviations were noted.

CONCLUSION: The protocols appear to be acceptable.

RECOMMENDATION: Send attached protocol review and test date confirmation notice.

6 , 3
Mr. Bryce Bird, Director
Department of Environmental Quality
Division of Air Quality
P.O. Box 144820
Salt Lake City, Utah 84114-4820
October 10,2024
Attention: Mr. Paul Morris
Rio'l'into Kennecoti Uiah Copper, LL,3
4700 Daybreak Parkway
South Jordan, UT 84009
T 801-569-7667
DEPANTMENT OF
ENVIHONMENTAT OI..IAIITV
Vqil d et\ uersol
ocl I I n24
DrvrsroN oF AtR (uAtrw
Subject:Kennecott Utah Cooper Refinery
Title V Permit 3500030004
Approval Order DAQE-AN0l 03460058-20
Stack Test Protocol: Combined Heat and Power Unit
Dear Mr. Bird:
Kennecott Utah Copper, LLC is hereby submitting the attached testing protocol for the Combined Heat
and Power Unit (REF CHP). The compliance test has been scheduled for November 11-12,2024, and
delivery of the attached protocol provides at least 30 days' notice in advance of testing.
The testing is required by the Title V Operating Permit 3500030004 and Approval Order No. DAQE-
4N103460058-20.
Should you have any questions or need further information, please contact me or Sean Daly at 801-204-
2563.
Sincerely,
Dustin Morris
Manager, Refinery & Rail
Attachment (1): Testing Protocol
RioTinto KennecoH Utah Copper, 1LC.4700 Daybreak Parkway, South Jordan, Utah 84009
Allarc
U-iAH DFPARTMFNI OF
ENVI RONI'JE NTAL QUALITY
Site Specific Test Plan
Rio Tinto Kennecott
4700 Daybreak Parkway
South Jordan, UT 84095
Source to be Tested: REFCHP
Proposed Test Dates: November 1 2 & 13,2024
Project No. AST-2024-45 50
Prepared By
Alliance Technical Group, LLC
3683 W 2270 S, Suite E,
West Valley City, UT 84120
t]IVISION OF AIR OUALITY
FAliatrce Site Specific Tesr Plan
Test program Summary
Begulatory Information
Permit Nos.
Regulatory Cilation
Source Information
DAQE-AN0103460058-20
Title V 3500030004
40 CFR 60, Subpart KKKK
Source Name
Power Unit
Contact Information
Source ID
REFCTIP
Target Parameters
NOx, CO
Test Location Test Company
Rio Tinto Kennecott Alliance Technical Group, LLC
2500 South 9180 West 3683 W 2270 S, Suite E
Magna, UT 84044 West Valley City, UT 84120
Jenny Esker Project [e-mail] Charles Horton
[phone] [e-mail]
(3s2) 663-7s68
Sean [e-mail] Field Team Leader(801)204-2563 Ryanlyons
[e-mail]
(708) 214-48s0
(subject to change)
QA/QC Manager
Kathleen Shonk
katie. shonk@alliancetg. com
(8r2) 4s2-478s
Test Plan/Report Coordinator
Delaine Spangler
delaine.spangler@alliancetg. com
AST-2024-4s50 RTK - Magna, UT Page i
+rE.AliatpE)Sile Specific Test Plan
Tahle o{ Contcnts
TABLE OF CONTENTS
l.l Process/Control System Descriptions. .................... l-l
2.0 Summary of Test Program ................2-l
2.2 Process/Control System Parameters to be Monitored and Recorded...... ...........2-l
3.1 U.S. EPA Reference Test Method 3A - Oxygen/Carbon Dioxide........ ............ 3-l
3.2 U.S. EPA Reference Test Method 7E -Nitogen Oxides ............ 3-l
3.3 U.S. EPA Reference Test Method l0 - Carbon Monoxide.... ..... 3-l
3.4 U.S. EPA Reference Test Method 19 - Volumetric Flow Rate ............. ...........3-2
3.5 U.S. EPA Reference Test Method 205 - Gas Dilution System Certification. ........................3-2
3.6 Quality Assurance/Quality Control - U.S. EPA Reference Test Methods 3A,78 and 10.......... ................3-2
LIST OF TABLES
Table 2-l: Program Outline and Tentative Test Schedu1e................... .....2-2
AST-2024-4550 RTK - Magna, UT Page ii
Allarpe Site Specrfic Test Plan
Introduction
1.0 Introduction
Alliance Technical Group, LLC (Alliance) was retained by Rio Tinto Kennecott (RTK) to conduct compliance
testing at the Refinery located in Magna, 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-
AN0103460058-20 and the Title V Operating Permit 3500030004. Testing will be conducted to determine the
emission rates of nitrogen oxides (NOx) and carbon monoxide (CO) from the exhaust of REFCFIP - Power Unit at
three (3) operating conditions: furbine-only, duct burners-only, and combined-cycle. The turbine-only condition is
subject to 40 CFR 60, Subpart KKKK per Title V permit condition II.8.48.e.
This site-specific test plan (SSTP) has been prepared to address the notification and testing requirements of the Title
V and UDAQ permits.
l.l Process/ControlSystemDescriptions
REFCT{P - Power Unit description: The unit consists of a Solar Taurus 70 turbine generator and TEG firing duct
burners. In March 2014, the original duct bumer was removed, and a redesigned duct burner was installed at the
Ct{P. With the installation of the redesigned duct bumer, the total heat input capaciry for the combined heat and
power system is 110.3 million British thermalunits per hour (MMBut/hr). The unit is designed to operate in one of
three modes: Combined-Cycle, Turbine-Only, and Duct Bumer-Only. All testing will be conducted at 90Yo or
greater ofthe production capacify ofthe unit.
1.2 Project Team
Personnel planned to be involved in this project are identified in the following table.
Table 1-1: Project Team
1.3 Safety Requirements
Testing personnel will undergo site-specific safery training for all applicable areas upon arrival at the site. Alliance
personnel will have current OSHA or MSFIA safety training and be equipped with hard hats, safefy glasses with side
shields, steel-toed safety shoes, hearing protection, fire resistant ctothing, 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 safery policies.
A Job Safefy Analysis (JSA) will be completed daily by the Alliance Field Team Leader.
RTK Personnel Sean Daly
Jenny Esker
Regulatory Agency UDAQ
Alliance Personnel Ryan Lyons
other field personnel assigned at time of testing event
AST-2024-4550 RTK - Magna, UT Page l-l
Allatpe
Site Specific Test Plan
Summarv of Test Prosrams
2.0 Summary of Test Program
To satisfy the requirements of the UDAQ and Title V permits, the facility will conduct a performance test program
to determine the compliance status of REFCHP.
2.1 General Description
All testing will be performed in accordance with specifications stipulated in U.S. EPA Reference Test Methods 3A,
78, 10, and 19. 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 t DAQ and Title V permits.
Emissions testing will be conducted on the exhaust of REFCFIP.
Performance testing will be conducted at no less than 90 percent of the maximum production achieved in
the previous three years.
Sampling runs will be conducted during three (3) operating conditions: turbine-only, duct burners-only, and
combined-cycle. Run times will be 60-minutes in duration for the combined cycle condition and the duct
burners-only conditions and 20-minutes in duration for the turbine-only condition.
NOx and oxygen (O2) emissions will be measured during all three operating conditions. CO measurements
are required for the combined-cycle and duct bumer testing. Concurrent stack gas velocity, 02, carbon
dioxide (COz), and moisture measurements will be collected for the determination of volumetric flow and
mass emission rates for the combined-cycle and duct bumer conditions.
2,2 Process/Control System Parameters to be Monitored and Recorded
Plant personnel will collect operational and parametric data at Ieast once every 15 minutes during the testing. The
following list identifies the measurements, observations and records that will be collected during the testing
program:
a
a
a
a
a
a
a
a
a
a
a
Feed water flow; klb,tr
Duct Bumer Gas FIow, ACFH
Steam Flow, klbsftr
Steam Pressure, psig
Turbine Gas Flow, lbftr
Generator Output, kW
Turbine Inlet Air Temp, oF
Turbine Air Inlet Filter, dP (psi)
2.3 Proposed Test Schedule
Table 2-l presents an outline and tentative schedule for the emissions testing program.
AST-2024-45s0 RTK - Magna, UT Page 2-l
Allatpe
Table 2-l: Program Outline and Tentative Test Schedule
2.4 Emission Limits
Emission limits for each pollutant are below
Table 2-2: Emission Limits
Site Specific Test Plan
Testing Location Parameter US EPA Method No. ofRuns Run Duration Est. Onsite
Time
DAY 1 -November 11,2024
Equipment Setup & Pretest QA/QC Checks 6hr
DAY 2 -November 12,2024
REFCFIP _
Combined Cycle
Oz I COz 3A
3 60 min l0 hr
NOx 7E
CO l0
VFR t9
DAY 3 -November 13,2024
REFCHP - Turbine
Only
Oz I COz 3A
J 20 min
8hr
NOx 7E
REFCHP - Duct
Bumer Only
Oz I COz ]A
J 60 min
NOx 7E
CO l0
VFR t9
DAY4-November 14,2024
Contingency Day (if needed)
Source Pollutent Citetion
REFCHP - Combined Heat & Power Unit
NOx - 5.96 lb,41r Permit (Condition II.B.48.a)
CO - 6.43 lb/hr Permit (Condition II.B.48.b)
REFCFIP - Turbine Only NOx-25 ppm @15%Oz Permit (Condition II.B.48.d)
REFCHP - Duct Bumers Onlv
NOx - 7.491bftv;54 ppm @15% Oz
Permit (Condition II.B.4 8.e)
CO - 2.5 lb/hr
AST-2024-4550 RTK - Magna, UT Page 2-2
,aAlianoe
Site Specific Test Plan
Summant of Tesl Prosram.c
2.5 Test Report
The fural test report must be submitted within 60 days of the completion of the performance test and will include the
fo llowing information.
o Introduction -Brief discussion of project scope of work and activities.
o 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.
o Methodologlt - A description of the sampling and analytical methodologies.
t Sample Calculations - Example calculations for each target parameter.
o Field Dala - Copies of actual handwritten or electronic field data sheets.
o Quality Control Data - Copies of all instrument calibration data and/or calibration gas certificates.. Process Operating/Control System Datq - Process operating and control system data (as provided by RTK)
to support the test results.
AST-2024-4550 RTK - Magna, UT Page2-3
Site SpecSfic Test PlanNlrr,E
,,,,,.,,",,"0",.o
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 qualily 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- l.
Table 3-l: Source Testing Methodology
All stack diameters, depths, widths, upstream and downstream disturbance distances and nipple lengths will be
measured on site with an EPA Method I verification measurement provided by the Field Team Leader. These
measurements will be included in the test report.
3.1 U.S. EPA Reference Test Method 3A - Oxygen/Carbon Dioxide
The oxygen (Oz) and carbon dioxide (CO2) testing will be conducted in accordance with U.S. EPA Reference Test
Method 3A. Data will be collected online and reported in one-minute averages. The sampling system will consist
of a stainless steel probe, Teflon sample line(s), gas conditioning system and the identified gas analyzer. The gas
conditioning system will be a non-contact condenser used to remove moisture from the stack gas. If an unheated
Teflon sample line is used, then a portable non-contact condenser will be placed in the system directly after the
probe. Otherwise, a heated Teflon sample line will be used. The quality control measures are described in Section
3.6.
3.2 U.S. EPA Reference Test Method 7E - Nitrogen Oxides
The nitrogen oxides (NOx) testing will be conducted in accordance with U.S. EPA Reference Test Method 7E. Data
will be collected online and reported in one-minute averages. The sampling system will consist of a stainless steel
probe, Teflon sample line(s), gas conditioning system and the identified gas analyzer. The gas conditioning system
will be a non-contact condenser used to remove moisture from the stack gas. If an unheated Teflon sample hne is
used, then a portable non-contact condenser will be placed in the system directly after the probe. Otherwise, a
heated Teflon sample line will be used. The qualify control measures are described rr Section 3.6.
3.3 U.S. EPA Reference Test Method l0 - Carbon Monoxide
The carbon monoxide (CO) testing will be conducted in accordance with U.S. EPA Reference Test Method 10.
Data will be collected online and reported in one-minute averages. The sampling system will consist of a stainless
steel probe, Teflon sample line(s), gas conditioning system, and the identified gas analyzer. The gas conditioning
system will be a non-contact condenser used to remove moisture from the gas. If an unheated Teflon sample line is
used, then a portable non-contact condenser will be placed in the system directly after the probe. Otherwise, a
heated Teflon sample line will be used. The quality control measures are described in Section 3.6.
Parameter U.S. EPA Reference
Test Methods Notes/Remarks
Oxygen / Carbon Dioxide 3A Instrumental Analysis
Nitrogen Oxides ,7E Instrumental Analysis
Carbon Monoxide l0 Instrumental Analysis
Volumetric Flow Rate 19 Fuel Factors/Heat lnputs
Gas Dilution System Certifrcation 205
AsT-2024-4550 RTK - Magna, UT Page 3-l
AllalEg sitespecincrestptan
3.4 U.S. EPA Reference Test Method 19 - Volumetric Flow Rate
The gas volumetric flow rate will be determined in accordance with U.S. EPA Reference Test Method l9 using the
measured oKygen concentration, the published fuel factor, a calibrated gas meter and the fuel heating value.
3.5 U.S. EPA Reference Test Method 205 - Gas Dilution System Certification
A calibration gas dilution system field check will be conducted in accordance with U.S. EPA Reference Method
205. An initial three (3) point calibration will be conducted, using individual Protocol I gases, on the analyzer used
to complete the dilution system field check. Multiple dilution rates and total gas flow rates will be utilized to force
the dilution system to perform two dilutions on each mass flow controller. The diluted calibration gases will be sent
directly to the analyzer, and the analyzer response will be recorded in an electronic field data sheet. A mid-level
supply gas, with a cylinder concentration within l0% of one of the gas divider settings described above, will be
introduced directly to the analyzer, and the analyzer response recorded in an electronic field data sheet. The
cylinder concentration and the analyzer response must agree withn 2%. These steps will be repeated three (3)
times. The average analyzer response must agree within2Yo of the predicted gas concentration. No single injection
shall differ more than 2%o from the average instrument response for that dilution.
3.6 Quality Assurance/Quality Control - U.S. EPA Reference Test Methods 3A, 7E and l0
Cylinder calibration gases will meet EPA Protocol I (+l- 2%) standards. Copies of all calibration gas certificates
will be included in the Quality Assurance/Quality Control Appendix of the report.
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 ppmvlo/o absolute difference.
High or Mid-Level gas (whichever is closer to the stack gas concentration) will be introduced at the probe and the
time required for the analyzer reading to reach 95 percent or 0.5 ppm/% (whichever was less restrictive) of the gas
concentration will be recorded. The analyzer reading will be observed until it reaches a stable value, and this value
will be recorded. Next, Low-Level gas will be inhoduced at the probe and the time required for the analyzer reading
to decrease to a value within 5.0 percent or 0.5 ppm/% (whichever was less restrictive) will be recorded. If the Low-
Level gas is zero gas, the acceptable response must be 5.0 percent of the upscale gas concenhation or 0.5 ppm/%
(whichever was less restrictive). The analyzer reading will be observed until it reaches a stable value, and this value
will be recorded. The measurement system response time and initial system bias will be determined from these data.
The System Bias for each gas must be within 5.0 percent of the Calibration Span or 0.5 ppmv/o% absolute difference.
High or Mid-Level gas (whichever is closer to the stack gas concenhation) will be introduced at the probe. After the
analyzer response is stable, the value will be recorded. Next, Low-Level gas will be introduced at the probe, and the
analyzer value will be recorded once it reaches a stable response. The System Bias for each gas must be within 5.0
percent of the Calibration Span or 0.5 ppmv/7o absolute difference or the data is invalidated, and the Calibration
Error Test and System Bias must be repeated.
The Drift between pre- and post-run System Bias must be within 3 percent of the Calibration Span or 0.5 ppmv/%
absolute difference or the Calibration Error Test and System Bias must be repeated.
AST-2024-4550 RTK - Magna, UT Page 3-2
Allatpe Site Specfic Test Plan
Teslins Methodoloer
To determine the number of sampling points, a gas stratification check will be conducted prior to initiating testing.
The pollutant concentrations will be measured at twelve haverse points (as described in Method 1) or three points
(16.7, 50.0 and 83.3 percent of the measurement line). Each traverse point will be sampled for a minimum of twice
the system response time.
If the pollutant concentration at each traverse point do not differ more than 5%o or 0.5 ppml}.3% (whichever is less
restrictive) of the average pollutant concentration, then single point sampling will be conducted during the test runs.
If the pollutant concentration does not meet these specihcations but differs less than l0% or 1.0 ppm/0.5% from the
average concentration, then three (3) point sampling will be conducted (stacks less than 7.8 feet in diameter - 16.7,
50.0 and 83.3 percent of the measurement line; stacks greater than 7.8 feet in diameter - 0.4, 1.0, and 2.0 meters
from the stack wall). If the pollutant concentration differs by more than l0% or 1.0 ppm/0.5o/o from the average
concentration, then sampling will be conducted at a minimum of twelve (12) traverse points. Copies of stratification
check data will be included in the Quality Assurance/Quality Control Appendix of the report.
An NOu - NO converter check will be performed on the analyzer prior to initiating testing or at the completion of
testing. An approximately 50 ppm nitrogen dioxide cylinder gas will be introduced directly to the NOx analyzer and
the instrument response will be recorded in an electronic data sheet. The instrument response must be within +/- l0
percent of the cylinder concentration.
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 aniving at Alliance's office, all written and electronic data will be
relinquished to the report coordinator and then a fural review will be performed by the Project Manager.
AsT-2024-4550 RTK - Magna, UT Page 3-3
Allanoe
Site Specfic Test Plan
Quality Assurance P rogram
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 aniving 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
retumed 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 specihcations. 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-94i038c, 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 requred. The meter calibration procedure determines
the meter correction factor (Y) and the meter's orifice pressure differential (AH@) 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 tumel 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 NlST-traceable thermocouple calibrator (temperature simulator) and
verified during field use using a second NlST-traceable meter. NlST-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.
AST-2024-4550 RTK - Magna, UT Page 4-l
AIlatpe
Site Specirtc Test Plan
O ual ity Assurance Prosram
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 rwo (2) years by an outside laboratory or intemally. 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:
o 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, AP, AH, temperature and pump vacuum data will be recorded during each sample point.
o An isokinetic sampling rate of 90-110% will be maintained, as applicable.
. All raw data will be maintained in organized manner.
o All raw data will be reviewed on a daily basis for completeness and acceptability.
AST-2024-4ss0 RTK - Magna, UT Page 4-2