DAQ-2024-011493

1

DAQC-1131-24
Site ID 10346 (B4)

MEMORANDUM

TO: STACK TEST FILE – KENNECOTT UTAH COPPER – Main Stack

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Paul Morris, Environmental Scientist

DATE: November 8, 2024

SUBJECT: Sources: Main Stack (SME011)
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 30, 2024

On November 7, 2024, Utah Division of Air Quality (DAQ) received a protocol for testing of the
Kennecott Utah Copper SME011 in Magna, Utah. Testing will be performed December 3, 2024, to
determine compliance with Title V Operating Permit, Conditions II.B.24.a and II.B.24.f.

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 201A used to determine PM emissions: OK
5. RM 202 used to determine CPM emissions: OK

DEVIATIONS: No deviations were noted.

CONCLUSION: The protocols appear to be acceptable.

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

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Mr. Bryce Bird, Director
Department of Environmental Quality
Division of Air Quality
P.O. Box t448zo
Salt Lake City, Utah 84u4-482o
October go,2c24
UTAH DEPARTMENT
ENVIRONMENTAL QUALITY
N0\/ - 1 2|?{
DIVISION OF AIR QUALlTY
Attention:
Subject:
Mr. Joseph Randolph
Stack Test Protocols - Kennecott Utah Copper (Smelter
Facility). Main Stack PMro and .P!&.. (SME ou)o Acid Plant Tail Gas (SME oub)
Dear Mr. Bird:
Kennecott Utah Copper, LLC is hereby submitting the attached testing protocols for
the Main Stack PM,o and PMz.s compliance test (SMEorr). The compliance testing is
scheduled to be performed the week of December 03, zoz4 and delivery of the
attached protocol provides at least 3o days' notice in advance oftesting.
The Main Stack is required by the Utah State Approval Order No. DAQE-
ANrog46oo6o-zr and Title V Operating Permit No. 35ooo3ooo4.
Should you have any questions or need further information regarding these events,
please contact me or Sean Daly at 801-204-2565.
Sincerely,
Manager
Refinery and Rail
Attachment
Allare
Site Specific Test Plan
Rio Tinto Kennecott
4700 Daybreak Parkway
South Jordan, UT 84095
Source to be Tested: Main Stack SME0I1
Proposed Test Date: December 3,2024
Project No. AST-2024-5083
Prepared By
Alliance Technical Group, LLC
3683 W 2270 S, Suite E
West Valley City, UT 84120
UlAH DEPARTMENT OF
ENVI RONIIE NTAL OUALITY
DIVISION OF AIR OUALITY
Afiarrce Site Specific Tesl Plan
Test Program Summary
Resulatorv Information
Permit Nos.
Source Information
DAQE-AN103460061-22
Title V Operating Permit 3500030004
Source Name
Smelter Main Stack
Contact Information
Source ID
SMEOI I
Target Parameters
PMIO, PM2.5, CPM
Test Location Test Company Analytical Laboratory
Kennecott Utah Copper, LLC Alliance Technical Group, LLC Alliance Technical Group, LLC
4700 Daybreak Parkway 3683 W 2270 S, Suite E 5530 Marshall Street
South Jordan, UT 84009 West Valley City, UT 84120 Arvada, CO 80002
Eric Grosjean
Jenny Esker Project Manager [e-mail]@riotinto.com Charles Horton (303) 420-5g4g
[phone] [e-mail]
(3s2) 663-7s68
Sean Daly
[e-mail] Field Team Leader
[phone] Charles Horton
charles.horton@alliancetg. com
(3s2) 663-7s68
(subject to change)
QA/QC Manager
Kathleen Shonk
katie. shonk@al liancetg. com
(812) 4s2-478s
Test Plan/Report Coordinator
Delaine Spangler
delaine. spangler@alliancetg. com
AST-204-5083 RTK - Magna, UT Page i
Alialpe Sile Spectrtc Test Plan
Table of Contents
TABLE OF CONTENTS
1.1 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 Methods I and2 - Sampling/Traverse Points and Volumehic Flow Rate........3-l
3.2 U.S. EPA Reference Test Method 3l3A- Oxygen/Carbon Dioxide... .............. 3-l
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 < l0 Microns IPM <2.5 Microns........ ................3-2
3.5 Quality Assurance/Quality Control - U.S. EPA Reference Test Method 3/3A ............ ......... 3-3
LIST OF TABLES
Table 2-l: Program Outline and Tentative Test Schedu1e................... ......2-l
Table 3-2: Sample Location Summar ............ 3-l
AST-204-5083 RTK - Magna, UT Page ii
d.AIiarpe Site Specfic Test Plan
Introduction
1.0 Introduction
Alliance Technical Group, LLC (Alliance) was retained by Rio Tinto Kennecott (RTK) to conduct compliance
testing at the Smelter facility located in Magna, Utah. The facility operates under the Utah Department of
Environmental Quality, Division of Air Quality (UDAQ) Approval Order (AO) DAQE-AN103460061-22 and the
Title V Operating Permit No. 350030004. Testing will be conducted to determine the emission rates of particulate
matter less than l0 microns (PMl0), particulate matter less than2.5 microns (PM2.5) and condensable particulate
matter (CPM) from the Main Stack designated as SME0I l.
This site-specific test plan (SSTP) has been prepared to address the notification and testing requirements of the
UDAQ and Title V permits.
1.1 Process/ControlSystemDescriptions
The smelter facility refines, and processes copper slurry concentrates for the production of copper anodes. Gases
from the acid plant, secondary gas system, rotary dryer, powerhouse superheater and the Foster Wheeler boiler,
matte grinding plant, anode area, and hydrometallurgical plant are ducted through a variety of environmental
controls to the smelter Main Stack SMEOI I and vented to the atmosphere.
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 safety training for all applicable areas upon arrival at the site. Alliance
personnel will have current OSHA or MSHA safety haining 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 hamesses). 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.
AST-204-5083
RTK Personnel Sean Daly
Regulatory Agency UDAQ
Alliance Personnel Charles Horton
other field personnel assigned at time of testing event
RTK - Magna, UT Page l-l
Allatpe Site Specrfic Test Plan
Summary of Tesl Programs
2.0 Summary of Test Program
To satisfu the requirements of the UDAQ and Title V permits, the facility will conduct a performance test program
to determine the compliance status of SME0I l.
2.1 General Description
All testing will be performed in accordance with specifications stipulated in U.S. EPA Reference Test Methods l, 2,
313A,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.
r Testing will be performed to demonstrate compliance with the UDAQ and Title V permits.
r Emissions testing will be conducted on the exhaust of SMEOl l.
o Performance testing will be conducted at the maximum normal operation load for the source.
. Each of the three (3) test runs will be approximately 60 minutes in duration.
2.2 Process/Control System Parameters to be Monitored and Recorded
Plant personnel will collect operational and parametric data at least once every l5 minutes during the testing. The
following list identifies the measurements, observations and records that will be collected during the testing
program:
o Production / Throughput
2.3 Proposed Test Schedule
Table 2- l presents an outline and tentative schedule for the emissions testing program.
Table 2-l: Program Outline and Tentative Test Schedule
Testing
Location Parameter US EPA Method No. ofRuns Run
Duration
Est.Onsite
Time
DAY l-December2,2024
Equipment Setup & Pretest QA/QC Checks 6hr
DAY2-December3,2024
SMEOI I
VFR t-2
J 60 min l0 hr
Ozl COz 3l3A
BWS 4
PMIO/PM2.5/CPM 201A I 202
DAY3-December4,2024
Contingency Day (if necessary)
AST-204-5083 RTK - Magna. UT Page 2-l
Aliatpe
Site Specrfic Test Plan
Summary ofTesl Programs
2.4 Emission Limits
Emission limits for each pollutant are below.
Table 2-2: Emission Limits
Source Pollutant Citation
SMEOI I
PMl0 - 89.5 lb/hr (filterable)
Permit
PM2.5 - 85.0 lb/hr (filterable)
PM2.5 - 434lbllff (filterable + condensable)
PMl0 - 439lbhr (filterable + condensable)
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.
o Introduction - Brief discussion of project scope of work and activities.
t 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 Methodology - A description of the sampling and analytical methodologies.
. Sample Calculations - Example calculations for each target parameter.
o Field Dala - Copies of actual handwritten or electronic field data sheets.
o Laboratory Data - Copies of laboratory report(s) and chain of custody(s).
o Quality Control Data - Copies of all instmment 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.
AST-204-5083 RTK - Magna, UT Page 2-2
Afiatpe Site Specirtc Test Plan
Tesling Methodology
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- l.
Table 3-1: Source Testing Methodology
All stack diameters, depths, widths, upstream and downstream disturbance distances and nipple lengths will be
measured on site with a verification measurement provided by the Field Team Leader.
Table 3-2: Sample Location Summary
3.1 U.S. EPA Reference Test Methods I 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 l. To determine the minimum number of traverse points, the upstream and downstream
distances will be equated into equivalent diameters and compared to Figure l-l in U.S. EPA Reference Test Method
l.
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 volumehic flow rate in accordance with U.S. EPA Reference Test Method 2.
3.2 U.S. EPA Reference Test Method 3/34 - Oxygen/Carbon Dioxide
The oxygen (Oz) 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
Parameter U.S. EPA Reference
Test Methods Notes/Remarks
Volumetric Flow Rate t&2 Full Velocity Traverses
Oxygen/Carbon Dioxide 313A htegrated Bag i Instrumental Analysis
Moisture Content 4 Gravimetric Analysis
PM < l0 microns / PM < 2.5 microns 20tA I 202 Constant Rate Sampling
Source Identification Diameter (inches)Port Location to Nearest Disturbance Sample Points
Main Stack - SMEOI I 288 Up, 10 D, Down > l0 D l2 points
AST-204-5083 RTK - Magna, UT Page 3-l
Aliatpe Site Specrfic Test Plan
Testing Methodology
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.
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 hain 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 20lA and 202 - PM < l0 Microns/PM < 2.5 Microns
The PM2.5 and PMl0 testing will be conducted in accordance with U.S. EPA Reference Test Methods 20lA and
202. T\e complete sampling system will consist of a stainless-steel nozzle, PMl0 and PM2.5 in-stack cyclones, 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 (DI) 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 impingers. 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 65oF but less than or equal
to 85oF.
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. If condensate is 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 fnst 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 l4 liters per minute will be conducted. After the completion of the nitrogen
purge the impinger contents will be measured for moisture gain. The nitrogen purge will be omitted if minimal
condensate collected in the dry impingers.
The pre-weighed quartz filter will be carefully removed and placed in container I . The front half of the filter holder
and back-half of the PM2.5 cyclone will be rinsed six (6) times with acetone to remove any adhering particulate
matter, and these rinses will be recovered in container 2. T\e back-half of the PMl0 cyclone, front half of the PM2 5
cyclone and the connecting stainless-steel tubing will be rinsed six (6) times with acetone, and these rinses will be
recovered in container 3. All containers will be sealed, labeled and liquid levels marked for transport to the
identihed laboratory for filterable particulate matter analysis.
The contents of impingers I and2 will be recovered in container CPM Cont. #1. The back half of the filterable PM
filter holder, probe extension, coil condenser, impingers I 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. #l 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
AST-204-5083 RTK - Magna, UT Page 3-2
,#Aliatpe Site Specirtc Test Plan
Testine Methodolom
CPM Cont. #l while the solvent rinses will be added to container CPM Cont. #2. All containers will be sealed,
labeled and liquid levels marked for hansport 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 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 inkoduced 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 (l) 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.
AST-204-5083 RTK - Magna, UT Page 3-3
AIiarpe Site Spectfrc Test Plan
Quality Assurance Program
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
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 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.
o 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 (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%o since the last full meter calibration. This check is performed after each test series.
r 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 coeffrcient will be used in lieu of 0.84. Standard pitot tubes that meet the geomekic 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.
r 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-haceable thermocouple calibrators
are calibrated annually by an outside laboratory.
o Nozzles. Nozzles are measured tkee (3) times prior to initiating sampling with a caliper. The maximum
difference between any two (2) dimensions is 0.004 in.
. Disital Calipers. Calipers are calibrated annually by Alliance by using gage blocks that are calibrated
annually by an outside laboratory.
AST-204-5083 RTK - Magna, UT Page 4-l
It'i,llAliatpe Site Specific Test Plan
Quality Assurance Program
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 intemally. If conducted intemally, 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.
o Sample trains will be leak checked before and after each test run.
. Appropriate probe, filter and impinger temperatures will be maintained.
r 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-l l0% will be maintained, as applicable.
o 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 subconhactor 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.
AST-204-5083 RTK - Magna, UT Page 4-2