DAQ-2025-001852

1

DAQC-327-25
Site ID 11977 (B4)

MEMORANDUM

TO: STACK TEST FILE – TRANS-JORDAN LANDFILL GENERATION FACILITY

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Paul Morris, Environmental Scientist

DATE: March 28, 2025

SUBJECT: Source: Enclosed Flare
Location: 10473 South Bacchus Highway, South Jordan, Salt Lake County, Utah
Contact: Jason Turville: 801 569-8994
Tester: Alliance Technical Group, LLC
FRS ID #: UT0000004903500535
Permit #: Title V Permit 3500535004, dated July 21, 2020
Date of Last Revision: January 12, 2023
Subject: Review of Pretest Protocol received March 27, 2025

On March 27, 2025 (email), Utah Division of Air Quality (DAQ) received a protocol for testing of the
enclosed flare operating at the Trans-Jordan Landfill Generation Facility located at 10473 South Bacchus
Highway, South Jordan, Salt Lake County, Utah. Testing will be performed on April 28, 2025, to
determine compliance with the VOC emission limits found in 40 CFR Part 60 Subpart OOO.

PROTOCOL CONDITIONS:

1. Method 1 used to determine appropriate sample velocity traverses: OK
2. Method 2 used to determine stack gas velocities and volumetric flow rates: OK
3. Method 3C use to determine dry molecular weight of the stack gases: OK
4. Method 4 used to determine moisture content of stack gases: OK
5. Method 25C used to determine non-methane VOC emissions: OK

DEVIATIONS: No deviations were noted.

CONCLUSION: The stack test protocol is acceptable.

RECOMMENDATION: Send protocol review and test date confirmation notice.

ATTACHMENTS: Stack test protocol received March 27, 2025.

6 3

Site Specific Test Plan

Trans-Jordan Landfill
10473 South Baccus Hwy.
South Jordan, UT 84009

Source to be Tested: Enclosed Flare
Proposed Test Date: April 28, 2025

Project No. AST-2025-1819

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-2025-1819 Trans-Jordan – South Jordan, UT Page i

Regulatory Information

Permit Nos. DAQE-AN119770013-24
Title V 3500535004
Regulatory Citation NSPS Subpart OOO 62.16714 and 62.16718

Source Information

Source Name Target Parameter
Flare / Enclosed Combustor Flare
(Inlet and Outlet) NMVOC

Contact Information

Test Location Test Company Analytical Laboratory
Trans-Jordan Landfill
10473 South Baccus Hwy.
South Jordan, UT 84009

Facility Contact
Jason Turville
[e-mail]
[phone]

Amit Nair
Kleinfelder
849 W Levoy Dr., Suite 200
Taylorsville, UT 84123
[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
Alan Jensen
[e-mail]
[phone]
(subject to change)

QA/QC Manager
Kathleen Shonk
[e-mail]
[phone]

Test Plan/Report Coordinator
Delaine Spangler
[e-mail]
Atmospheric Analysis & Consulting, Inc.
2225 Sperry Avenue
Ventura, CA 93003
John Yokoyama
[e-mail]
[phone]

Site Specific Test Plan
Table of Contents

AST-2025-1819 Trans-Jordan – South Jordan, UT 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 .................................................................................................................................................. 2-2
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 3C – Oxygen/Carbon Dioxide/Methane/Nitrogen ................................ 3-1
3.3 U.S. EPA Reference Test Method 4 – Moisture Content ............................................................................ 3-2
3.4 U.S. EPA Reference Test Method 25C – Non-Methane Volatile Organic Compounds in Landfill Gases . 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 ........................................................................................ 2-1
Table 2-2: Emission Limits ...................................................................................................................................... 2-2
Table 3-1: Source Testing Methodology .................................................................................................................. 3-1

Site Specific Test Plan
Introduction

AST-2025-1819 Trans-Jordan – South Jordan, UT Page 1-1

1.0 Introduction
Alliance Technical Group, LLC (Alliance) was retained by Trans-Jordan Landfill (Trans-Jordan) to conduct
compliance testing at the South Jordan, Utah facility. Portions of the facility are subject to provisions of the New
Source Performance Standard (NSPS) Subpart OOO 62.16714 and 62.16718 and the Utah Department of
Environmental Quality, Division of Air Quality (UDAQ) DAQE-AN119770013-24 and Title V 3500535004.
Testing will be conducted to determine the emission rates of non-methane volatile organic compounds (NMVOC)
from the inlet and the outlet of the Enclosed Combustor Flare (Flare) to determine the NMVOC control efficiency
(CE).

This site-specific test plan (SSTP) has been prepared to address the notification and testing requirements of the
UDAQ permit and the NSPS.
1.1 Process/Control System Descriptions
The combustor sampling location consists of a vertical, round stack with two orthogonal sampling ports located at
least two diameters downstream and one-half diameter upstream of the nearest flow disturbances. Gas sampling will
be performed at a single point in the stack.
1.2 Project Team
Personnel planned to be involved in this project are identified in the following table.

Table 1-1: Project Team

Trans-Jordan Personnel Jason Turville
Regulatory Agency UDAQ
Alliance Personnel Alan Jensen
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-2025-1819 Trans-Jordan – South Jordan, UT Page 2-1

2.0 Summary of Test Program
To satisfy the requirements of the UDAQ permit and the NSPS, the facility will conduct a performance test program
to determine the compliance status of the Flare.
2.1 General Description
All testing will be performed in accordance with specifications stipulated in U.S. EPA Reference Test Methods 1, 2,
3C, 4, and 25C. 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 permit and NSPS Subpart OOO 62.16714
and 62.16718.
 Emissions testing will be conducted on the inlet and outlet of the Flare.
 If the outlet results meet the concentration emissions limit, then compliance will be demonstrated using the
outlet results only; if not then the CE results will be used to demonstrate compliance.
 Each of the three (3) test runs will be approximately 60 minutes in duration per location.
 NMVOC concentrations will be reported on an as hexane basis.
 Simultaneous testing will be performed at the flare inlet and outlet to determine NMVOC CE.
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:

 Operating Temperature, °F
2.3 Proposed Test Schedule
Table 2-1 presents an outline and tentative schedule for the emissions testing program.

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 – April 28, 2025
Equipment Setup & Pretest QA/QC Checks
8 hr Enclosed Combustor
Flare
VFR 1-2
3 60 minutes
(per location)
O2/CO2 3C
BWS 4
NMVOC 25C
DAY 2 – April 29, 2025
Contingency Day (if needed)

Site Specific Test Plan
Summary of Test Programs

AST-2025-1819 Trans-Jordan – South Jordan, UT Page 2-2

2.4 Emission Limits
Emission limits for each pollutant are below.

Table 2-2: Emission Limits

Source Pollutant Citation
Flare
NMVOC – ≥98% CE
OR
NMVOC – 20 ppmvd @3 % O2
NSPS Subpart OOO 62.16714 and
62.16718
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. In addition to the final test report, the test results must be entered into the U.S. EPA
Electronic Reporting Tool (ERT) for submittal via CEDRI.
 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
Trans-Jordan) to support the test results.

Site Specific Test Plan
Testing Methodology

AST-2025-1819 Trans-Jordan – South Jordan, UT 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 3C Inlet – Summa Can
Moisture Content 4 Gravimetric Analysis
Non-Methane Volatile Organic Compounds 25C Summa Can

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 3C – Oxygen/Carbon Dioxide/Methane/Nitrogen
The inlet carbon dioxide (CO2), oxygen (O2), methane (CH4) and nitrogen (N2) testing will be conducted in accordance
with U.S. EPA Reference Test Method 3C. The sampling system will consist of a stainless steel sample probe, Teflon
sample line(s), rotameter and stainless steel sample canister. The rotameter will ensure the gas will be sampled at a
constant rate.

Following the completion of each test run, the sample tank will be removed and the vacuum pressure will be
measured to ensure a valid sample will be collected. Each sample canister will be clearly identified and sealed for
transport to the identified lab for analysis.

Site Specific Test Plan
Testing Methodology

AST-2025-1819 Trans-Jordan – South Jordan, UT 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 Method 25C – Non-Methane Volatile Organic Compounds in Landfill
Gases
The non-methane volatile organic compounds (NMVOC) testing will be conducted in accordance with U.S. EPA
Reference Method 25C. A sample of the landfill gas will be extracted using an evacuated cylinder or an evacuated
stainless-steel canister. Each sample will be withdrawn at a constant flow rate through a calibrated flow-controlling
orifice and into an evacuated stainless-steel canister. Following sampling, the canisters will be sealed and shipped to
the identified laboratory. The NMVOC content of the gas will be determined by injecting a portion of the gas into a
gas chromatographic column to separate the NMVOC from carbon monoxide (CO), carbon dioxide (CO2), and
methane (CH4). The NMVOC will be oxidized to CO2, reduced to CH4 and measured by a flame ionization detector
(FID).

Site Specific Test Plan
Quality Assurance Program

AST-2025-1819 Trans-Jordan – South Jordan, UT Page 4-1

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-2025-1819 Trans-Jordan – South Jordan, UT 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.