DAQ-2025-002486

1

DAQC-443-25
Site ID 10346 (B4)

MEMORANDUM

TO: STACK TEST FILE – KENNECOTT UTAH COPPER, LLC

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Paul Morris, Environmental Scientist

DATE: May 9, 2025

SUBJECT: Sources: Cathode Wash (REF 004) and Anode Scrap Wash (REF 005)
Contact: Sean Daly: 801-204-2563
Location: Kennecott Utah Copper, 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: February 5, 2025
Subject: Review of Stack Test Protocols dated May 6, 2025

On May 8, 2025, Utah Division of Air Quality (DAQ) received a protocol for testing of the Kennecott
Utah Copper, LLC REF 004 and REF 005 in Magna, Utah. Testing will be performed June 10-11, 2025,
to determine compliance with Title V Operating Permit, Conditions II.B.36.a and II.B.37.a.

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 4 used to determine BWS emissions: OK
4. RM 8 used to determine H2SO4 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
RioTinto
Date
6 May 2025
Rio Tinto Kennecott Utah Copper, LLC
4700 Daybreak Parkway
South Jordan, UT 84009 USA
Tel: [phone]
Mr. Bryce Bird, Director
Department of Environmental Quality
Division of Air Quality
P.O. Box 144820
Salt Lake City, Utah 84114-4820
Attn: Paul Morris
Dear Mr. Bird:
RE: Stack Test Protocol
Cathode Wash (REF004) and Anode Scrap Wash (REF005)
Title V Operating Permit No. 3500030004
Kennecott Utah Copper - Refinery Facility
Kennecott Utah Copper LLC (Kennecott) is hereby submitting the attached
protocol for the Cathode Wash (REF004) and Anode Scrap Wash (REF005)
compliance tests. The tests are scheduled forthe week of June 1Oth, 2025. The
test is required by the Utah State Approval Order No. DAQE-AN0l03460058-20
and Title V Operating Permit No. 3500030004, and as required, delivery of the
attached protocol provides at least 30 days' notice in advance of testing.
Should you have any questions or need further information regarding the event,
please contact me or Sean Daly at 801-204-2563.
Yours sincerely,
1/l/t
Matt Tobey
Manager, Smelter and Refinery
EM,nONilETTT^L OIJ^IJIY
[lAY - I 2025
Rio Tinto Kenne@tt Utah Copper, LLC 4700 Daybreak Parkway, South Jordan, UT 84009
AIlare
Site Specific Test Plan
Rio'l-into Kennecott
4700 Daybreak Parkway
South Jordan. UT 84095
Source to be'fested: REF004
Prcrposed'l'est [)ate: June 1 1. 2025
Project No. AST-2025 -2432-002
I)repared By
Alliance'['echnical Group, LLC
3683 W 2270 S, Suite E
Wcst Valley City. tJ1- 84120
tlrnu OqPnRI'Mt.Iil OF
r+--_---l
li-tr,ro De f,vered
in,ulSloNoFAlRot,AL
E NVI RONN4ENTAL QUALITY
pulErrpc)
TECIINICAL GNOUP Site Specific Test Plan
Test Program Summary
Resulatorv lnformation
Permit Nos. DAQE-AN0103460058-20
Title V 3500030004
Source Information
Source Name
Cathode Wash
Contact Information
Source ID
REFOO4
Target Parameter
HzSOa
Tesl Location Test Company Analytical Laboratory
Rio Tinto Kennecott Alliance Technical Group, LLC Alliance Technical Group, LLC
2500 South 91 80 West 3683 W 2270 S, Suite E 5530 Marshall Street
Magna, UT 84044 West Valley City, UT 84120 Arvada, CO 80002
Cory Manshack
Jenny Esker Project Manager [e-mail]@riotinto.com Charles Horton [phone]
(801 ) 569-6494 [e-mail]
(3s2) 663-7s68
Sean Daly
[e-mail] Field Team Leader(801)204-2563 Ryan Lyons
ryan. [e-mail]
(708) 214-48s0
(subject to change)
QA/QC Manager
Kathleen Shonk
[e-mail]
(812) 4s2-478s
Test Plan /Report Coordinator
Delaine Spangler
[e-mail]
AS t-2025-2432-002 RTK - Magna, UT Page i
puIATEE)
Site Specifc Test Plan
Table of ContentsTf CIINICAL GROUP
TABLE OF CONTENTS
l.l Process/Control System Descriptions.. ................ I - I
2.0 Summary of Test Program ............ l-l
2.2 Process/Control System Parameters to be Monitored and Recorded............... ..................... l-l
3.1 U.S. EPA Reference Test Methods 1 and2l2G - Sampling/Traverse Points and Volumetric Flow Rate ..3-l
3.2 U.S. EPA Alternative Test Method ALT-153 - Molecular Weight ................3-l
3.3 U.S. EPA Reference Test Method 4 - Moisture Content......... .......................3-2
3.4 U.S. EPA Reference Test Method 8 - Sulfuric Acid Mist ........3-2
3.5 Quality Assurance/Quality Control - U.S. EPA Reference Method ALT-153 .....................3-2
LIST OF TABLES
Table 2-l: Program Outline and Tentative Test Schedule ...................... l-1
AST-2025-2432-002 RTK - Magna, UT Page ii
AI
ITCIINICAI GROI.i P
rta Site Specrfic Test Plan
lntroduction
1.0 Introduction
Alliance Technical Group, LL,C (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-
ANO103460058-20 and the Title V Operating Permit 3500030004. Testing will be conducted as outlined in Table
l-l below.
Table l-l: Test Matrix
This site-specific test plan (SSTP) has been prepared to address the notification and testing requirements of the
facility Title V and UDAQ permits.
1.1 Process/Control System Descriptions
REF004 - Cathode Wash description: Cathodes are transported from the "tankhouse" by transfer cars to the
Machine and Product Control (MPC) building where they are washed. Acid mist produced is collected through
local hooding and passed through demister pads.
1.2 Project Team
Personnel planned to be involved in this project are identified in the following table.
Table l-2: 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 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.
RTK Personnel Sean Daly
Jenny Esker
Regulatory Agency UDAQ
Alliance Personnel Ryan Lyons
other field personnel assigned at time oftesting event
AST-202s-2432-002 RTK - Magna, UT Page I -l
pilr6rpe
lEa_rtt'.ilcAl G n () ll t,Site Spectfc Test Plan
Summary o/Test Programs
2.0 Summary of Test Program
To satisfo the requirements of the UDAQ and Title V permits, the facility will conduct a performance test program
to determine the compliance status of the REF004 - Cathode Wash.
2.1 General Description
Alltesting will be performed in accordance with specifications stipulated in U.S. EPA Reference Test Methods 1,2,
2G, Alt-153,4, and 8 i GD-008. Table 2-l 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 and Title V permits.
Emissions testing will be conducted on the exhaust of REF004 Cathode Wash.
Performance testing will be conducted at no less than 90 percent of the maximum production achieved in
the previous three years. However, the operation is a batch process where operations are demonstrated by
unit status. Applicable production data forthe test will be monitored and included with testing results.
Each of the three (3) test runs will be approximately 60 minutes in duration.
Emission Measurement Center Guideline Document 008 (EMC GD-008) will be followed for REF004 due
to the cyclonic nature ofthe exhausts.
2.2 Process/Control System Parameters to be Monitored and Recorded
Plant personnel will collect operational and parametric dataal 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:
Production rate - lb/trr
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
a
a
a
a
a
DAY I -June 11,2025
REF004 - Cathode
Wash
Alt-t 53
DAY2-lune12,2025
Contingency Day (if needed)
AST-2025-2432-002 RTK * Magna, UT Page 1-l
pulhrpEr
TECIINICAL GROUT'Site Specifc Test Plan
Summary of Test Programs
2.4 Emission Limits
Emission limits for each pollutant are below.
Table 2-2: Emission Limits
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
fol lowi ng information.
e Introduclior - Brief discussion of project scope of work and activities.
o Resuhs 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.
c Methodologt - 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.
t Laboralory Data - Copies oflaboratory report(s) and chain ofcustody(s).
c Quality Control Data - Copies of all instrument calibration data and/or calibration gas certificates.
c Process Operating/Conlrol System Dala - Process operating and control system data (as provided by RTK)
to support the test results.
HzSO+ - 0.0008 grldscf; 0.12lblhr
AST-2025-2432-002 RTK - Magna, UT Page 1-2
AII t_c ll I'l I cA t, G tl()ll tr
rla Sire Specrfic T'est Plan
Testine Methodolopy
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
completionofthetestprogranrmeetorexceedthespecificationsofeachrelevanttestmethod. Theemissiontesting
program will be conducted in accordance with the test methods listed in Table 3-1.
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 Methods I and 2/2G - 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 velocify 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.
Full velocity traverses will be conducted in accordance with U.S. EPA Reference Test Method 2G to determine the
average stack gas velocity pressure, static pressure and temperature using a two-dimensional (2-D) probe. 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.
The Oz and CO: concentration from REF004 are assumed to be ambient for volumetric flow rate calculations.
3.2 U.S. EPA Alternative Test Method ALT-I53 - Molecular Weight
The molecular weight testing will be conducted in accordance with U.S. EPA Alternative Test Method ALT-153.
One (l) integrated Tedlar bag sample will be collected during each test run. 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.
t &212G Full Velocity Traverses
ALT-I53 Integrated Bag / Instrumental Analysis
Gravimetric Analysis
Sulfuric Acid Mist
AST-2025-2432-002 RTK - Magna, UT Page 3-l
t6
f.l Irl,rr Sire Specifc 7e.st Plan
7'est ing lvle thodo logy
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 nroistttre condensed.
3.4 U.S. EPA Reference Test Method 8 - Sulfuric Acid Mist
The sulfuric acid mist testing will be conducted in accordance with Ll.S. EPA Reference l'est Method 8. The
cornplete sampling system will consist of a glass noz,z,le, heated glass-lined probe, un-heated quartz filter, gas
conditioning train, pump and calibrated dry gas rneter. The gas conditioning train will consist of one (l) chilled
impinger containing 100 mL of 80o/o isopropyl alcohol (lPA), additional impingers for moisture as needed and a
final inrpinger containing 200-300 grams of silica gel. The probe liner heating system will be maintained at 120 +
l4"C (248 t25'F), and the impinger temperature will be nraintained at20"C (68'F) or less throughout testing. The
un-heated quartz filter will be used between the outlet of the first impinger and the inlet of the second impinger.
Following the completion of each test run, the sampling train will be leak checked at vacuum pressure greater than
or equal to the highest vacuum pressure observed during the run and the contents of the impingers will be measured
for moisture gain. The contents of the first impinger will be collected in container l. The probe, nozzle, fiont of
half of the filter holder and first inrpinger will be rinsed with 80% lPA. These rinses and the un-heated filter will be
added to container l. All samples will be sealed, labeled and liquid levels marked for transport to the identified
laboratory for analysis. The laboratory will use ion chronratography (lC) to analyze the samples in accordance with
ALT-133. This is a modification from the current U.S. EPA Reference'fest Methodology, which requires titrations.
lC is more reliable and accurate than titrations.
3.5 Quality Assurance/Quality Control - U.S. EPA Reference Method ALT-I 53
EPI l'rotocol I Calibration Gases
Cylinder calibration gases will meet EPA Protocol I (+l- 2%) standards. Copies of all calibration gas certificates
will be found in the Quality Assurance/Quality Control Appendix of the final test report.
Direct ('alibration & Calibration lirror Test
[,ow-Level gas will be collected in a Tedlar bag and introduced to the instrument. After adjusting the analyzer to the
Low-Level gas concentration and once the analyz.er reading is stable, the analyzer value will be recorded. This
process will be repeated for the High-Level gas. For the C'alibration Error Test, l,ow, Mid, and High-Level
calibration gases will be sequentially collected in a Tedlar bag and introduced to the instrument. All values are to be
within 2.0 percent of the Calibration Span.
System Bias and Response'l'ime
High or Mid-Level gas (whichever is closer to the stack gas concentration) rvill be collected in a Tedlar bag and
introduced to the instrument and the time required for thc analyzer reading to reach 95 percent or 0.5%o (whichever
was less restrictive) of the gas concentration will be recorcled. 1'he analyzer reading will be observed until it reaches
a stable value as defined in ALT-153 Section 4.-5, and this value will be recorded. Next, l,ow-Level gas will be
collected in a Tedlar bag and introduced to the instrument and the time required for the analyzer reading to decrease
to a value within 5.0 percent or 0.5% (whichever was less restrictive) will be recorded. If the t,ow-Level gas is zero
gas, the response must meet 0.5%o or 5.0 percent of the upscale gas concentration (whichever was less restrictive).
The analyzer reading will be observed until it reaches a stable value as defined in Al,T-153 Section 4.5, and this
AST-2025-2432-002 RTK - Magna. LJ-l I'age 3-2
o CAL ROr_'Site Specifc Test Plan
Testing Methodology
value will be recorded. The initial system bias will be determined from these data. The System Bias must be within
5.0 percent of the Calibration Span.
Post Tesl System Bias Checl<s
High or Mid-Level gas (whichever was closer to the stack gtts conaentration) will be collected in a Tedlar bag and
introduced to the instrument. After the analyzer response is stable, the value will be recorded. Next, Low Level gas
will be collected in a Tedlar bag and introduced to the instrument, and the analyzer value recorded once it reaches a
stableresponse. TheSystemBiasmustbewithin5.0percentoftheCalibrationSpanor0.5o/oabsolutedifferenceor
the data will be invalidated, and the Calibration Error Test and System Bias will be repeated.
Post Test Drifl Checl<s
Drift berween pre- and post-run System Bias will be within 3 percent of the Calibration Span. If the drift exceeds 3
percent, the Calibration Error Test and System Bias will be repeated.
Data Collection
After instrument calibration, each sample bag will be introduced to the appropriate analyzer according to the
procedures in ALT-153 Section 4.1. The analysis will be continued until the following criteria is met, at which point
the concentrations will be recorded:
YICO2
. Differ by no more than 0.3% when COz is greater than 4.0o/o, or,
r Differ by no more thut 0.2o/o when COz is less than 4.0%o.
o/oOz
Differ by no more than 0.3% when Oz is less than 15.0%, or,
Differ by no more than 0.2oh when Ou is greater than 15.0%.
At the completion of testing, the data will 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.
a
a
AS'l-2025-2432-002 RTK - Magna, UT Page 3-3
(t I r I'l | (Il ( ) ii I'l
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 sanrpling and analytical schenre.
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 problerrrs 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. 'l'herefore, replacements for critical
equiprlent or conlponents are brought to the job site. Equipment retuming fronr 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. T'he
calibration procedures outlined in the U.S. EPA Methods, and those recornnrended within the Quality Assurance
Handbook for Air Pollution Measurement Systems: Volume Ill (EPA-600/R-94/038c, September 1994) are utilized.
When these nrethods are inapplicable, methods such as those prescribed by the American Society for'l'esting and
Materials (ASTM) or other nationally recognized agency may be used. Data obtained during calibrations is checked
for conrpleteness and accuracy. Copies of calibration forms are included in the report.
The following sections elaborateon the calibration procedures followed by Alliance forthese 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 conection factor (Y) and the nreter'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 perfonned after each test series.
r Pitot l-ubes and Manometers. Type-S pitot tubes that nleet the geometric criteria required by U.S. EPA
Refcrence l'est 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 frorn a wind tunnel calibration has been
obtained that coefficient will be used in lieu of 0.84. Standard pitot tubes that nreet the geornetric criteria
required by U.S. EPA Reference Test Method 2 are assigned a coefficierrt of 0.99. Any pitot tubes not
nreeting the appropriate geometric criteria are discarded and replaced. Manonreters 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 nrounted in Dry Gas Meter Consoles are
calibrated senri-annually with a NIST-traceable thermocouplc calibrator (temperature simulator) and
verifled during field use using a second NIST-traceable meter. NISI-traceable thermocouple calibrators
are calibrated annually by an outside laboratory.
. Nozzles. Nozzles are measured three (3) times prior to initiating sarnpling with a caliper. The maximum
difference between any two (2) dinrensions is 0.004 in.
. Disital Calipers. Calipers are calibrated annually by Alliance by using gage blocks that are calibrated
annually by an outside laboratory.
Site Specrfic Tesr Plan
Q ual ity Assurance Progranr
AST-202s-2432-OO2 R'l'K - Magna. [.)'l Page 4-l
I I ('lii'.ll()r"''l GI1() II Site Specrfc'l.e.rr Plan
Q ual i t1, A s surance P ro g ra nt
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 Weishts. Balances are calibrated annually by an outside laboratory. A functional check is
conducted on the balance each day it is used in the field using a calibration weight. Weights are re-certified
every two (2) years by an outside laboratory or internally. 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.
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 tenlperatures will be maintained.
. The sampling port will be sealed to prevent air from leaking from the port.
. Dry gas meter, AP, AH, temperature and purnp 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 an organized manner.
o 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.
AS'I -2025-2432-002 ttl K Magna. LJ'f Page 4-2
Allare
Site Specific Test Plan
Rio'l'into Kennccott
4700 Daybreak Parkway
South .lordan. tjl- 84095
Source to be'l'ested: Il.EF005
I)roposed'l'est Date: June 10, 2025
Proiect No. AS'l'-2025 -2432-001
I'}repared By
Alliance'l'echnical GroLrp, LLC
3683 W 2270 S. Suite E
Wcst Valley City. LJ'f 84120
put6rrce
Tf CIINICAL GROTJP Site Specific Test Plan
Test Program Swnmary
Regulatorv Information
Permit Nos. DAQE-AN0103460058-20
Title V 3500030004
Source Information
Source Name
Anode Scrap Washing
Contact Information
Source ID
REFOO5
Target Parameter
HzSOr
Test Location Test Company Analytical Laboratory
Rio Tinto Kennecott Alliance Technical Group, LLC Alliance Technical Group, LLC
2500 South 9180 West 3683 w 2270 S, Suite E 5530 Marshall Street
Magna, UT 84044 West Valley City, UT 84120 Awada, CO 80002
Cory Manshack
Jenny Esker Project Manager [e-mail]@riotinto.com Charles Horton [phone]
[phone] [e-mail]
(3s2) 663-7s68
Sean [e-mail] Field Team Leader
[phone] Ryan Lyons
ryan.lyons@all iancetg.com
(708) 2144850
(subject to change)
QA/QC Manager
Kathleen Shonk
[e-mail]
(812) 4s2-478s
Test Plar/Report Coordinator
Delaine Spangler
[e-mail]
AST-202s-2432-00 I RTK - Magna, UT Page i
pllt6rpe
Sire Specifc Test Plan
Table of ContentsTECIINICAL. GROTJP
TABLE OF CONTENTS
l.l Process/Control System Descriptions.. ................ l-l
2.0 Summary of Test Program ............ l-l
2.2 Process/Control System Parameters to be Monitored and Recorded............... ..................... l-l
3.1 U.S. EPA Reference Test Methods 1 and2l2G - Sampling/Traverse Points and Volumetric Flow Rate..3-1
3.2 U.S. EPA Alternative Test Method ALT-153 - Molecular Weight ................3-1
3.3 U.S. EPA Reference Test Method 4 - Moisture Content......... ....................... 3-2
3.4 U.S. EPA Reference Test Method 8 - Sulfuric Acid Mist ........3-2
3.5 Quality Assurance/Quality Control - U.S. EPA Reference Method ALT'153 .....................3-2
LIST OF TABLES
Table 2-l : Program Outline and Tentative Test Schedule ...................... I - I
AST-2025-2432-00 I RTK - Magna, UT Page ii
AllErrEE)
IfCIINICAI (i n () U l,Site Spectfic Test Plan
lntroduclion
1.0 lntroduction
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-
ANo103460058-20 and the Title V Operating Permit 3500030004. Testing will be conducted as outlined in Table
l-l below.
Table l-l: Test Matrix
This site-specific test plan (SSTP) has been prepared to address the notification and testing requirements of the
facility Title V and UDAQ permits.
l.l Process/ControlSystemDescriptions
REF005 - Anode Scrap Washing description: Spent anodes are transported from the "tankhouse" by automatic
guided vehicles (AGV) to the machine and product control building (MPC) where they are washed. Acid mist
produced is collected through local hooding and passed through demister pads.
1.2 Project Team
Personnel planned to be involved in this project are identified in the following table.
Table l-2: 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 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.
RTK Personnel Sean Daly
Jenny Esker
Regulatory Agency UDAQ
Alliance Personnel Ryan Lyons
other field personnel assigned at time of testing evenl
AST-2025-2432-00 I RTK - Magna, UT Page l-l
pilt6rpe
TECHNICAL GROUP Site Specific Test Plan
Summary ofTest Programs
2.0 Summary of Test Program
To satisft the requirements of the UDAQ and Title V permits, the facility will conduct a performance test program
to determine the compliance status of the REF005 - Anode Scrap Washing.
2.1 General Description
All testing will be performed in accordance with specifications stipulated in U.S. EPA Reference Test Methods l, 2,
2G, Alt-153,4, and 8 / GD-008. Table 2-l 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 and Title V permits.
Emissions testing will be conducted on the exhaust of REF005 - Anode Scrap Washing.
Performance testing will be conducted at no less than 90 percent of the maximum production achieved in
the previous three years.
Each of the three (3) test runs will be approximately 60 minutes in duration.
Emission Measurement Center Guideline Document 008 (EMC GD-008) will be followed for REF005 due
to the cyclonic nature ofthe exhausts.
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:
Production rate - lbftrr
2.3 Proposed Test Schedule
Table2-l presents an outline and tentative schedule for the emissions testing program.
Table 2-l: Program Outline and Tentative Test Schedule
a
a
a
a
a
DAY I - June9,2025
Equipment Setup & Pretest QA/QC Checks
DAY 2 - June 10,2025 -
REF 005 / Anode
Scrap Wash
Alt- 153
AST-2025-2432-00 I RTK - Magna, UT Page l-l
I[(]t.1tJtcAL GnO[]tr Site Specific Test Plan
Sunmary of Test Programs
2.4 Emission Limits
Emission limits for each pollutant are below.
Table 2-22 Emission Limits
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
fol lowing 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.
Methodologt - 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 oflaboratory report(s) and chain ofcustody(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.
a
a
a
a
a
a
HzSO+ - 0.0008 grldscf; 0.02 lb/hr
AST-2025-2432-001 RTK - Magna, UT Page l-2
pill6rrrcE)
rfollNtonL Gn()UP Sire Specifc Tesr Plan
Testing Methodologt-
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-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 Methods I and 2l2G - Sampling/TrAverse Points and Volumetric Flow Rate
'l'he 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.
Full velocity traverses will be conducted in accordance with U.S. EPA Reference Test Method 2G to determine the
average stack gas velocity pressure, static pressure and temperature using a two-dimensional (2-D) probe. 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.
'l'he O: and COz concentration from REF005 are assumed to be ambient for volumetric flow rate calculations.
3.2 U.S. EPA Alternative Test Method ALT-I53 - Molecular Weight
'Ihe molecular weight testing will be conducted in accordance with U.S. EPA Alternative Test Method ALT-153.
One (l) integrated Tedlar bag sample will be collected during each test run. 1'he 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.
Volumetric Flow Rate I &212G Full Velocity Traverses
Integrated Bag / Instrumental AnalysisMolecular Weight ALT-I53
Moisture Content
Sulfuric Acid Mist Isokinetic Sampling
AST-202.5-2412-00 t R-IK - Magna, UT Page 3-l
pur6rpe
Site SpeciJic Test l'lon
Te s t i ng Itle t ho do I oR t'lii.Jl(:Al al Ii ( ) | '
3.3 tl.S. EPA Reference Test Method 4 - Moisture Content
The stack gas moisture content will be deterrnined in accordance with U.S. EPA Reference Test Method 4. The gas
conditioning train will consist of a series of chilled irnpingers. Prior to testing, each impinger will be filled with a
knownquantityofwaterorsilicagel. Eachimpingerwill beanalyzedgravimetricallybeforeandaftereachtestrun
on the same analytical balance to determine the amount of'moisture condensed.
3,4 U.S. EPA Reference Test Method 8 - Sulfuric Acid Mist
The sulfuric acid mist testing will be conducted in accordance with U.S. EPA Reference Test Method 8. The
complete sampling system will consist ol a glass nozzle, heated glass-lined probe, un-heated quartz filter, gas
conditioning train, pump and calibrated dry gas rneter. The gas conditioning train will consist of one (l) chilled
impinger containing 100 mL of 80% isopropyl alcohol (lPA), additional impingers for moisture as needed and a
final impinger containing 200-300 grams of silica gel. The probe liner heating system will be maintained at 120 +
l4"C(248+25"F),andtheimpingertemperaturewill bemaintainedat20oC(68'F)orlessthroughouttesting.'l'he
un-heated quartz filter will be used between the outlet of the first impinger and the inlet of the second impinger.
Following the completion of each test run, the sampling train will be leak checked at vacuum pressure greater than
or equal to the highest vacuum pressure observed during the run and the contents of the impingers will be measured
for moisture gain. The contents of the first impinger will be collected in container L The probe, nozzle, front of
half of the filter holder and first impinger will be rinsed with 80% lPA. 'l'hese rinses and the un-heated filter will be
added to container l. All samples will be sealed, labeled and liquid levels marked for transport to the identified
laboratory for analysis. The laboratory will use ion chromatography (lC) to analyze the samples in accordance with
ALT-133. This is a modification from the current I.-1.S. EPA Reference Test Methodology, which requires titrations.
IC is more reliable and accurate than titrations.
3.5 Quality Assurance/Quality Control - U.S. EPA Reference Method ALT-153
I:,PA Protocol I ('alibralion Gases
Cylinder calibration gases will meet EPA Protocol I (+l- 2o/o) standards. Copies of all calibration gas certificates
will be found in the Quality Assurance/Quality Control Appendix of the final test report.
Direct Calibration & Calibration llrror 7'e.sl
Low-Level gas will be collected in a Tedlar bag and introduced to the instrument. After adjusting the analyzer to the
Low-Level gas concentration and once the analyz.er reading is stable, the analyzer value will be recorded. This
process will be repeated for the High-Level gas. For the Calibration Error Test, t,ow, Mid, and High-Level
calibration gases wilI be sequentially collected in a 'l'edlar bag and introduced to the instrument. All values are to be
within 2.0 percent of the Calibration Span.
Systent l]ias and Response 'l'ime
High or Mid-Level gas (whichever is closer to the stack gas concentration) will be collected in a Tedlar bag and
introduced to the instrument and the time required lbr the analyzer reading to reach 95 percent or 0.5%o (whichever
was less restrictive) of the gas concentration will be recorded. The analyzer reading will be observed until it reaches
a stable value as defined in AL'l'-153 Section 4.-5, and this value will be recorded. Next, Low-Level gas will be
collected in a Tedlar bag and introduced to the instrunrent and the time required for the analyzer reading to decrease
to a value within 5.0 percent or 0.5oh (whichcver was less restrictive) will be recorded. lf the t,ow-Level gas is zero
gas, the response must meet 0.5oh or 5.0 percent of the upscale gas concentration (whichever was less restrictive).
T'he analyzer reading will be observed until it reaches a stable value as defined in Al,T-153 Section 4.5, and this
AS'f-2025-2432-00 I R'l'K Magna. IJT Pagc 3-2
pul6rnoE)
rlI i',ll/ll(r rl
value will be recorded. The initial system bias will be determined from these data. 'fhe System Bias must be within
-5.0 percent of the Calibration Span.
l'}ost'fest Systcm llias ('hecks
High or Mid-Level gas (whichever was closer to the stack gas concentration) will be collected in a Tedlar bag and
introduced to the instrument. After the analyzer response is stable, the value will be recorded. Next, Low Level gas
will be collected in a Tedlar bag and introduced to the instrument, and the analyzer value recorded once it reaches a
stable response. 'lhe System Bias must be within 5.0 percent of the Calibration Span or0.5Yo absolute difference or
the data will be invalidated, and the Calibration Error Test and System Bias will be repeated.
Post Test Drift ('hecks
Drift between pre- and post-run System Bias will be within 3 percent of the Calibration Span. If the drift exceeds 3
percent, the Calibration Error'l'est and System Bias will be repeated.
Data Colleclion
After instrument calibration, each sample bag will
procedures in A1,1'-153 Section 4.1. The analysis will
the concentrations will be recorded:
o/oCOt
. Differ by no more than 0.3oh when COu is greater than 4.0o/o, or,
o Differ by no more lhan 0.2%o when COz is less than 4.0%o.
o/oOz
. Differ by no more than 0.3%o when Or is less than 15.0%o, or,
o Differ by no more than 0.2o/o when Oz is greater than 15.0o/o.
At the completion of testing, the data will 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.
\ite Specific Test Plan
Te s r i ng lrle t hod o I ogy,
be introduced to the appropriate analyzer according to the
be continued until the following criteria is met, at which point
ASl'-2025-2432-00 I RTK Magna, UT Page 3-3
put6rpe
r,ll lJl(': A l (rllf Site Specrf c Test Plon
() ua I i t)' A s s urance P rogrant
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 k) detect equipment problems prior to arriving on site. T'his
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 retuming 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: Volunre lll (llPA-600iR-94/038c, September 1994) are utilized.
When these nrethods 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 (Y1 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 lneet 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. lf 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 'l'est Method 2 are assigned a coefficient of 0.99. Any pitot tubes not
meeting the appropriate geometric criteria are discardcd and replaced. Manometers are verified to be level
and zeroed prior to each test run and do not require further calibration.
r Tenrperature Measurinq Devices. All thermocouple sensors nrounted in Dry Gas Meter Consoles are
calibrated semi-annually with a NIST-traceable therrnocouple calibrator (temperature simulator) and
verified during field use using a second NIS'l-traceable nreter. 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 maxrmum
difference between any two (2) dinrensions is 0.004 in.
Disital Calipers. Calipers are calibrated annually by Alliance by using gage blocks that are calibrated
annually by an outside Iaboratory.
ASl'-2025-2432-00 I RTK Magna, [J'l Page 4- I
pul6rpe
:litll l(),r1 l,r I
4.2
Barometer. The barometric pressure is obtained fronr 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 ofservice.
Balances and Weights. Balances are calibrated annually by an outside laboratory. A tunctional check is
conducted on the balance each day it is used in the field using a calibration weight. Weights are re-certified
every two (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 systerr 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, urnbilical
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.
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.
r The sampling port will be sealed to prevent air from leaking from the port.
. Dry gas meter, AP, AH, temperature and pump vacuum datawill be recorded during each sarnple point.
o An isokinetic sampling rate of 90- I I 0% will be maintained, as applicable.
. All raw data will be maintained in an organized manner.
o All raw data will be reviewed on a daily basis for completeness and acceptability.
4.3 Analytical Laboratory
Analytical laboratory selection for sarmple 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 eviderrce of compliance. Alliance assumes responsibility to the clicnt for the
subcontractor's work. Alliance maintains a verifiable copy of the results with chain of custody docunrentation.
Sirc ,\pet'i./ic Test ['lun
QuaIit1,1ssutturce Progrant
T@
OF AIR QT'ALITY
AS1.-2025-2432-00 l RTK Magna, Ll'l I>agc 4-2