DAQ-2025-002614

1

DAQC-505-25
Site ID 10346 (B5)

MEMORANDUM

TO: CEM FILE – KENNECOTT UTAH COPPER

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Rob Leishman, Environmental Scientist

DATE: May 22, 2025

SUBJECT: Source: Smelter Main Stack (SME011)
Acid Plant Tail Gas (SME011b)
Contact: Sean Daly – 801-204-2563
Jenny Esker – 801-569-6494
Location: Kennecott Smelter, Magna, UT
Test Contractor: Alliance Technical Group
FRS ID#: UT0000004903500030
Permit/AO#: Title V operating permit 35003004 dated September 18, 2020
Last Revised February 25, 2025
Approval Order (AO) DAQE-AN103460063-24 dated
October 29, 2024
Subject: Review of RA/PST Protocol dated May 6, 2025

On May 8, 2025, Utah Division of Air Quality (DAQ) received a protocol by email for a RA/PST
(relative accuracy/performance specification test) of the Smelter Main Stack and Acid Plant Tail Gas in
Magna, Utah. Testing will be performed on June 24-25, 2025, to determine the relative accuracy of the
O2, CO2, NOX, and SO2 monitoring systems.

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 4 used to determine moisture content: OK
5. RM 6C used to determine SO2 emissions: OK
6. RM 7E used to determine NOX concentrations of emissions: OK
7. RM 205 used to validate gas dilution systems for field instrument calibration: OK

1 8 2
2

DEVIATIONS: None noted.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: Send attached protocol review and test date confirmation notice.
RioTinto
Date
6 May 2025
Rio Tinto Kennecott Utah Copper, LLC
4700 Daybreak Parkway
South Jordan, UT 84009
Tel: +l 801 569 6331
Mr. Bryce Bird, Director
Department of Environmental Quality
Division of Air Quality
P.O. Box 144820
Salt Lake City, Utah 84114-4820
Attn: Rob Leishman
Dear Mr. Bird:
RE: Relative Accuracy Test Audit (RATA) Protocol
Main Stack VFR, SO2, and NOx and Tail Gas SO2
Title V Operating Permit No. 3500030004
Kennecott Utah Copper - Smelter Facility
Kennecott Utah Copper LLC (Kennecott) is hereby submitting the attached
protocols for the Main Stack (SME 01 1) and Tail Gas (SME01 1b) Main Stack will
be testing sulfur dioxide (SOz), nitrogen oxides (NOx), and volumetric flow rate
RATA to be conducted on the Main Stack continuous emissions monitoring system
(CEMS). Tail Gas will be testing sulfur dioxide (So2). The RATA is scheduled for
June 24 and 25 2025. The RATA is required by the Utah State Approval Order No.
DAQE-AN103460061-22 and Title V Operating Permit No. 3500030004, and as
required, delivery of the attached protocol provides at least 45 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,
Matt Tobey
Manager, Smelter and Refinery
DEPAHTMENT OF
ENVIRONMENTA OUATITY
MAY - I 2025
Rio Tinto Kenne@tt Utah Copper, LLC 4700 Daybreak Parkway, South Jordan, UT 84009
Allare
Site Specific Test Plan
I{io l'into Ke'nnecott
4700 Daybreak Parkway
Soulh Jordan. LIT 84095
Source to be'l-ested: Main Stack SMIiOl
Proposed'['est [)ate: June 24, 2025
Project No. A S1'-2025-2434-001
Prcparcd By
Alliancc'T'echnical Group, LLC
3683 W 2270 S, Suite E,
West Vallcy City, LJT 84120
pul6rrpE)
Tf CIINICAL GNOL-JP Sire Specific Test Plan
Test Program Summary
Regulatory Information
Permil Nos.
Regulatory Citation
Source Information
DAQE-ANr 03460061-22
Title V Operating Permit 3500030004
40 CFR 60, Appendix B, PS 2 and 6
Source Name
Smelter Main Stack
Contact Information
Source ID
SMEOI I
Target Parameters
VFR, SO:, NOX
Test Localion
Kennecott Utah Copper, LLC
4700 Daybreak Parkway
South Jordan, UT 84009
Jenny Esker
[e-mail]
(80r) 569-6494
Sean Daly
sean.daly3 @riotinto. com
(801) 204-2s63
Test Company
Alliance Technical Group, LLC
3683 W 2270 S, Suite E
West Valley City, UT 84120
Project Manager
Charles Horton
[e-mail]
(3s2) 663-7s68
Field Team Leader
Ryan Lyons
[e-mail]
(708) 214-48s0
(subject to change)
QA/QC Manager
Kathleen Shonk
katie.shonk@all iancetg.com
(812) 4s2-478s
Test Plan/Report Coordinator
Delaine Spangler
delaine.spangler@al I iancetg.com
AST-202s-2434-00 l RTK - Magna, UT Page i
i | ( lll'Jl()n I (iti () | l'Site Specrfic Tesr Plan
Table ofContents
TABLE OF CONTENTS
I . I Process/Control System Descriptions.. ................ I - I
2.0 Summary of Test Program ............2-l
2.2 Process/Control System Parameters to be Monitored and Recorded ................. ................... 2-1
3.1 U.S. EPA Reference Test Methods I and 2 - Sampling/Traverse Points and Volumetric Flow Rate ........ 3-l
3.2 U.S. EPA Reference Test Method 3^A - Oxygen/Carbon Dioxide ..................3-2
3.3 U.S. EPA Reference Test Method 4 - Moisture Content......... .......................3-2
3.4 U.S. EPA Reference Test Method 6C - Sulfur Dioxide......... .........................3-2
3.5 U.S. EPA Reference Test Method 7E - Nitrogen Oxides .........3-2
3.6 U.S. EPA Reference Test Method 205 - Gas Dilution System Cerlification. .......................3-2
3.7 Quality Assurance/Quality Control - U.S. EPA Reference Test Methods 3,A, 6C and 7E......................... 3-3
LIST OF TABLES
Table 2-l: Program Outline and Tentative Test Schedule ......................2-l
Table?-2'. Relative Accuracy Requirements and Limits ........................2-2
Table 3-2: Sample Location Summar .......3-1
ASl'-2025-2434-00 I R'IK - Magna, LJ-l'Page ii
All6lEE)rrc!NtCAt G R () llt'Site Specific Test Plan
lntroduclion
1.0 Introduction
Alliance Technical Group, LLC (AIliance) was retained by Rio Tinto Kennecott (RTK) to conduct performance
specification (PS) testing at the Smelter facility located in Magna, Utah. Portions of the facility are subject to
provisions of the 40 CFR 60, Appendix B, PS 2 and 6, the Utah Department of Environmental Quality, Division of
Air Qualiry (UDAQ) Approval Order (AO) DAQE-ANI03460061-22 and the Title V Operating Permit No.
350030004. Testing will include conducting a relative accuracy test audit (RATA) to determine the relative
accuracy (RA) of the continuous emissions monitoring system (CEMS) and continuous emissions rate monitoring
system (CERMS), as outlined in Table l-l below.
Table l-l: Test Matrix
Main Stack (SMEOl l)
Sulfur Dioxide (SOz),
Nitrogen Oxides (NOx)
Volumetric Flow Rate (VFR)
This site-specific test plan (SSTP) has been prepared to address the notification and testing requirements of the
UDAQ and Title V permits and 40 CFR 60, Appendix B, PS 2 and 6.
l.t 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 CEMS Descriptions
Parameter:
Make:
Model:
Serial No.
Span:
Nitrosen Oxides
NOx
Thermo Scientific
42iQLS
12127413438
0-100 / 0-r0,000
43iQ
12127413439
0-r00 / 0-10,000
43iQ
121274t3439
0-r00 / 0-r0,000
Flow
Primary
Cemtek/KVB-Enertec
Flow 100
00 t9
0-l" H:o
Sulfur Dioxide
SO:- Low SOz- High
Thermo Scientific Thermo Scientific
1.3 Project Team
Personnel planned to be involved in this project are identified in the following table
Table l-2: ProjectTeam
RTK Personnel Sean Daly
Jenny Esker
Regulatory Agency UDAQ
Alliance Personnel Ryan Lyons
other field personnel assigned at time of testing event
AST-2025-2434-00 I RTK - Magna, UT Page l-l
pill6rrpE)
TECIINICAI GROTJP Site Specific Test Plan
Inrroduction
1.4 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.
AST-2025-2434-00 r RTK - Magna, UT Page 1-2
pur6rpe
TECHNICAL GROUP Site Specific Test Plan
Sunmary ofTest Programs
2.0 Summary of Test Program
To satisf, the requirements of the UDAQ and Title V permits and 40 CFR 60, Appendix B, PS 2 and 6, the facility
will conduct a performance test program to determine the compliance status of the SMEO I I .
2.1 General Description
All testing will be performed in accordance with specifications stipulated in U.S. EPA Reference Test Methods 1,2,
3A, 4, 6C and 7E. Table 2-l presents an outline and tentative schedule for the emissions testing program. The
following is a summary of the test objectives.
o Testing will be performed to demonstrate compliance with the UDAQ and Title V permits and 40 CFR 60,
Appendix B, PS 2 and 6.
Emissions testing will be conducted on the exhaust of SME0I l.
Performance testing will be conducted at greater than 50Yo operating load.
Each of the 9-12 RATA test runs will be 2l minutes in duration.
Each of the 3-4 test runs for moisture content will be 60 minutes in duration.
The CEMS times are reported in Mountain Standard Time (year-round); prior to sampling the RM data
logger will be synched to CEMS time.
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:
CEMS Data
CERMS Data
2.3 Proposed Test Schedule
Table 2-1 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
a
a
DAY I - June23,2025
Equipment Setup & Pretest QA/QC Checks
DAY 2 - 1une24,2025
2l min
AST-2025-2434-00 I RTK - Magna, UT Page 2-l
put6rpe
TECHNICAL GROUP Site Specifc Test Plan
Swnmary ofTest Programs
2.4 Emission Limits
Emission limits for each pollutant are below.
Table 2-2: Relative Accuracy Requirements and Limits
60, Appendix B, PS 6
<20 % (RM) or <10 % (AS)2l I lb/hr (3-hour average)60, Appendix B, PS 2
35 lb/hr (annual)60, Appendix B, PS 2<20 % (RM) or <10 % (AS)
*sME0lloperatesunderseveral emissionlimitsofvariousaveragingperiodsforSO2andNOx. Annualaveragesarepresentedinthistablefor
reference.
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 ofproject scope ofwork 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.
t Methodologt - A description of the sampling and analytical methodologies.
o Sample Calculalions - Example calculations for each target parameter.
o Field Data - Copies of actual handwritten or electronic field data sheets.
o Quality Control Data - Copies of all instrument calibration data and/or calibration gas certificates.
o Process Operating/Control System Data - Process operating and control system data (as provided by RTK)
to support the test results.
AST-2025-2434-00 I RTK - Magra, UT Page2-2
AllErlEE)
It(,ltl.Jlon (l Il () ll t)
Site Spectf c Tesr Plon
Testing 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 3-1.
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 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 (for isokinetic sampling) and/or
Figure l-2 (measuring velocity alone) in U.S. EPA Reference Test Method L
Full velocity traverses will be conducted in accordance with U.S. E,PA 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.
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 for comparison to the continuous emission rate monitoring system
Full Velocity TraversesVolumetric Flow Rate
Instrumental AnalysisOxygen / Carbon Dioxide
Moisture Content Cravimetric Analysis
Gas Dilution System Certification
,',:.ffihi
Main Stack - SME0I I Up, t0 D, Down > l0 D
Asr-2025-2434-00 I RTK - Magna, UT Page 3-l
, i ('lrl..llC^t (l li( r il'Site Specrfic Tesr I'lan
Testing Methodologl'
(CERMS). The relative accuracy of the CERMS will be determined based on procedures found in 40 CFR 60,
Performance Specifi cation 6.
3.2 U.S. EPA Reference Test Method 34 - Oxygen/Carbon Dioxide
The oxygen (Oz) and carbon dioxide (CO:) testing will be conducted in accordance with U.S. EPA Reference'l'est
Method 3A. Data will be collected online and reported in one-minute averages. 'l'he sampling system will consist
of a stainless steel probe, Teflon sample line(s), gas conditioning system and the identified gas analyzer. The gas
conditioning system will be a non-contact condenser used to remove moisture from the stack gas. If an unheated
Teflon sample line is used, then a portable non-contact condenser will be placed in the system directly after the
probe. Otherwise, a heated Teflon sample line will be used. The quality control measures are described in Section
3.7.
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
knownquantityofwaterorsilicagel. Eachimpingerwill beanalyzedgravimetricallybeforeandaftereachtestrun
on the same analytical balance to determine the amount of moisture condensed.
3.4 U.S. EPA Reference Test Method 6C - Sulfur Dioxide
The sulfur dioxide (SOz) testing will be conducted in accordance with U.S. EPA Reference Test Method 6C. Data
will be collected online and reported in one-minute averages. The sampling system will consist of a heated stainless
steel probe, Teflon sample line(s), gas conditioning system and the identified analyzer. The gas conditioning system
will be a non-contact condenser used to remove nroisture from the source gas. If an unheated Teflon sample line is
used, then a portable non-contact condenser will be placed in the system directly after the probe. Otherwise, a
heated Teflon sample line will be used. The quality control measures are described in Section 3.7.
The relative accuracy of the SOz CEMS will be determined based on procedures found in 40 CFR 60, Appendix B,
Performance Specifi cation 2.
3.5 U.S. EPA Reference Test Method 7E - Nitrogen Oxides
The nitrogen oxides (NOx) testing will be conducted in accordance with U.S. EPA Reference Test Method 7E. l)ata
will be collected online and reported in one-nrinutc averages. The sampling system will consist of a stainless steel
probe, Teflon sample line(s), gas conditioning system and the identified gas analyzer. The gas conditioning system
will be a non-contact condenser used to remove nroisture from the stack gas. If an unheated Teflon sample line is
used, then a portable non-contact condenser will be placed in the system directly after the probe. Otherwise, a
heated Teflon sample line will be used. The quality control measures are described in Section 3.7.
The relative accuracy of the NOx CEMS will be determined based on procedures found in 40 CF'R 60, Appendix B,
Performance Specifi cation 2.
3.6 U.S. EPA Reference Test Method 205 - Gas Dilution System Certification
A calibration gas dilution system field check will be conducted in accordance with U.S. EPA Reference Method
205. An initial three (3) point calibration will be conducted, using individual Protocol I gases, on the analyzer used
to complete the dilution system field check. Multiple dilution rates and total gas flow rates will be utilized to fbrce
the dilution system to perform two dilutions on each mass flow controller. The diluted calibration gases will be sent
directly to the analyzer, and the analyzer response will be recorded in an electronic field data sheet. A mid-level
AST-2025-2434-00 I R'lK-Magna,LJ'I'Page 3-2
pul6rlpE)
lr- ( ltl.l l(l i\t ,ll()l \ire Spectf c Test Plan
'l'esting Methodology
supply gas, with a cylinder concentration within lloh of one of the gas divider settings described above, will be
introduced directly to the analyzer, and the analyzer response recorded in an electronic field data sheet. The
cylinder concentration and the analyzer response must agree within 2%o. These steps will be repeated three (3)
times. The average analyzer response must agree within2oh of the predicted gas concentration. No single injection
shall differ more than 2o/o fron the average instrument response for that dilution.
3.7 Quality Assurance/Quality Control - U.S. EPA Reference Test Methods 3.A, 6C and 7E
LPA Protocol I Calibrution (iases
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.
Direct Calibralion & ('alihration Error Test
Low Level gas will be introduced directly to the analyzer. After adjusting the analyzer to the Low-Level gas
concentration and once the analyzer reading is stable, the analyzer value will be recorded. This process will be
repeated for the High-Level gas. For the Calibration Error Test, Low, Mid, and High-Level calibration gases will be
sequentially introduced directly to the analyzer. The Calibration Error for each gas must be within 2.0 percent of the
Calibration Span or 0.5 ppmvl%o absolute difference.
System Bias and Resytnse 7'ime
High or Mid-t,evel gas (whichever is closer to the stack gas concentration) will be introduced at the probe and the
time required for the analyzer reading to reach 95 percent or 0.5 ppmlo/o (whichever was less restrictive) of the gas
concentration will be recorded. The analyzer reading will be observed until it reaches a stable value, and this value
will be recorded. Next, Low-Level gas will be introduced at the probe and the time required for the analyzer reading
todecreasetoavaluewithin5.0percentor0.5ppml%o(whicheverwaslessrestrictive)will berecorded. IftheLow-
Level gas is zero gas, the acceptable response must be 5.0 percent of the upscale gas concentration or 0.5 ppml%o
(whichever was less restrictive). The analyzer reading will be observed until it reaches a stable value, and this value
will be recorded. The measurement system response time and initial system bias will be determined from these data.
The System Bias for each gas rnust be within 5.0 percent of the Calibration Span or 0.5 ppmv/7o absolute difference.
Posl'l'est Syslem Bias Chec'ks
High or Mid-t,evel gas (whichever is closer to the stack gas concentration) will be introduccd at the probe. After the
analyzer response is stable, the value will be recorded. Next, Low-Level gas will be introduced at the probe, and the
analyzer value will be recorded once it reaches a stable response. The System Bias for each gas must be within 5.0
percent of the Calibration Span or 0.5 ppmv/7o absolute difference or the data is invalidated, and the Calibration
Error'l'est and System Bias must be repeated.
Post'l'est Drift C hecks
The Drift between pre- and post-run System Bias must be within 3 percent of the Calibration Span or 0.5 ppmv/%
absolute difference or the Calibration Error Test and System Bias must be repeated.
Stratification ('heck
To determine the number of sampling points, a gas stratification check will be conducted prior to initiating testing.
The pollutant concentrations will be measured at twelve traverse points (as described in Method l) or three points
(16.7,50.0 and 83.3 percent of the measurement line). Each traverse point will be sanrpled for a minimum of twice
the system response tirne.
ASI'-2025-2434-00 I RTK - Magna, IJT Page 3-3
tt ( !t.ttcn I Gil()lll Sire SpeciJic Test Plan
Testing Methodology
lf the pollutant concentration at each traverse point does not differ more than 5%o or 0.5 ppml}.3o (whichever is less
restrictive) of the average pollutant concentration, then single point sampling will be conducted during the test runs.
If the pollutant concentration does not meet these specifications but differs less than l0o/oor 1.0 ppm/0.5% from the
average concentration, then three (3) point sampling will be conducted (stacks less than 7.8 f'eet in diameter - 16.7,
-50.0 and 83.3 percent of the measurement line; stacks greater than 7.8 feet in diameter - 0.4, 1.0, and 2.0 meters
from the stack wall). If the pollutant concentration differs by more than l0% or 1.0 ppm/0.5Yo from the average
concentration,thensamplingwill beconductedataminimumoftwelve(12) traversepoints. Copiesofstratification
check data will be included in the Quality Assurance/Quality Control Appendix of the report.
NO, Converler Check
An NO: - NO converter check will be performed on the analyzer prior to initiating testing or at the completion of
testing. An approximately 50 ppm nitrogen dioxide cylinder gas will be introduced directly to the NOx analyzer and
the instrument response will be recorded in an electronic data sheet. The instrument response must be within +/- l0
percent of the cylinder concentration.
Data ('olleclion
A Data Acquisition System with battery backup will be used to record the instrument response in one (l) minute
averages. Thedatawill becontinuouslystoredasa*.CSVfileinExcel formatontheharddriveofacomputer. 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-2025-2434-00 I RTK - Magna. UT Page 3-4
Ii: l'f'l|(,i',I ; ti () ii I
Site Spectfic Test Plun
Qua I i t1, il s s u ran c e I' rogra nt
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 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 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 fbr 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: 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 'l'esting 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 equiprnent.
e Dry Gas Meter and Orifice. A full rneter 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 nreter's orifice pressure differential (AH(0). AIIiance 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.
o Pitot Tubes and Manometers. Type-S pitot tubes that meet the geometric criteria required by LJ.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 awind 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.
o Temperature Measurins 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 nraximum
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.
AS'r-202s-2434-00 I R1'K - Magna. U'f Page 4- |
put6lpe
Ii.tl[.|on l (]li()lrl Sire Specifc Tesr Plan
Quality Assurance Progrant
Barometer. 'Ihe 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 .t 2 percent absolute. Barometers not meeting this
requirement are adjusted or taken out ofservice.
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 internally, they are weighed on a
NlsTtraceablebalance. Iftheweightdoesnotmeettheexpectedcriteria,theyarereplaced.
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, urnbilical
Iines, 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 tesl
method(s). General QC measures for the test program include:
. 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 I0% 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.
AsT-2025-2434-00 l RTK - Magna, UT Page 4-7
Aliare
I r' i rl!ll
Site Specific Test Plan
Rio Tinto Kennecott
4700 Daybreak Parkway
South Jordan. LJT 84095
Source to be Tested: Acid Plant 'l'ail Gas SME0I
Proposed Test Date: June 25,2025
Proj ect No. AST-2025-2434-002
rb
Prepared By
Alliance'fechnical Group, LLC
3683 W 2270 S, Suite E
West Valley City. UT 84120
' [ffi-i-PAa{[rvtrtlr or
t:vYfeqlU.tl] !- o tJ3t=|ry
rlt\./istoN oF AIR oIJALITY
pul6rrpE)
Tt_cllNtcAt_ Gnot.lP Site Specific Test Plan
Test Program Summary
Resulatorv Information
Permil Nos.
Regulatory Citation
Source Information
DAQE-AN r03460061-22
Title v operating Permit 3500030004
40 CFR 60, Appendix B, PS 2
Source Name
Acid Plant Tail Gas
Contact Information
Permit ID
SMEOI Ib
Source ID
Tail Gas
Target Parameter
SOz
Test Location
Kennecott Utah Copper, LLC
4700 Daybreak Parkway
South Jordan, UT 84009
Jenny Esker
j enny.esker@riotinto. com
(801) s69-6494
Sean Daly
sean.daly3 @riotinto.com
(801) 204-2s63
Test Company
Alliance Technical Group, LLC
3683 W 2270 S, Suite E
West Valley City, UT 84120
Project Manager
Charles Horton
charles. horton@al I iancetg.com
(3s2) 663-7s68
Field Team Leader
Ryan Lyons
ryan. lyons@all iancetg.com
(708) 2 l4-4850
(subject to change)
QA/QC Manager
Kathleen Shonk
katie.shonk@all iancetg.com
(812) 4s2-478s
Test Plan/Report Coordinator
Delaine Spangler
de laine.spangl er(@alli ancetg.com
/\ST-2025-2434-002 RTK - Magna, UT Page i
pilr6rpe
Site Spectfic Tesr Plan
Table ofContentsTECIINICAL GROUP
TABLE OF CONTENTS
2.0 Summary of Test Program ............2-l
2-2 Process/Control System Parameters to be Monitored and Recorded ................. ...................2-l
3.1 U.S. EPA Reference Test Method 4 - Moisture Content......... ....................... 3- I
3.2 U.S. EPA Reference Test Method 6C - Sulfur Dioxide......... ..............,..........3-l
3.3 U.S. EPA Reference Test Method 205 - Gas Dilution System Certification. .......................3-1
3.4 Quality Assurance/Quality Control - U.S. EPA Reference Test Method 6C................. .......3-2
LIST OF TABLES
Table 2-l: Program Outline and Tentative Test Schedule ......................2-l
Table2-2: Relative Accuracy Requirements and Limits.... ....................2-2
AST-202s-2434-002 RTK - Magna, UT Page ii
A/l6rrEE)
ItClll'll(lAt Gn()|{,Site Specrfic Test Plan
Introduclion
1.0 Introduction
Alliance Technical Group, LLC (Alliance) was retained by Rio Tinto Kennecott (RTK) to conduct performance
specification (PS) testing at the Smelter facility located in Magna, Utah. Portions of the facility are subject to
provisions of the 40 CFR 60, Appendix B, PS 2, the Utah Department of Environmental Quality, Division of Air
Quality (UDAQ) Approval Order (AO) DAQE-AN103460061-22 and the Title V Operating Permit No.
3500030004. Testing will include conducting a relative accuracy test audit (RATA) to determine the relative
accuracy (RA) of the continuous emissions monitoring system (CEMS), 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
UDAQ and Title V permits and 40 CFR 60, Appendix B, PS 2.
l.l Facility Descriptions
The offgases from the flash smelting and converting furnaces are treated in the double contact acid plant. The acid
plant is equipped with a SOu CEMS and is designed to operate with a tail gas SO2 concentration of 200 parts per
million, dry volume basis (ppmvd) or less during steady state operations. The tail gas exhaust stack from the acid
plant is vented to the main stack.
1.2 CEMS Descriptions
Pollutant
Parameter: SOz
Make: Unisearch Associates lnc.
Model: DAS-AR2047-00-FC-S02-B-P
SerialNo.: DAS22-001
Span: 0 l50ppm/0-l,500ppm
1.3 Project Team
Personnel planned to be involved in this project are identified in the following table.
Table l-2: Project Team
1.4 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, safefy glasses with side
RTK Personnel Sean Daly
Jenny Esker
Regulatory Agency UDAQ
Alliance Personnel Ryan Lyons
other field personnel assigned at time of testing event
AST-2025-2434-002 RTK - Magna, UT Page l-l
pul6rEEI
Site Specifc Test Plan
IntroductionTTCIINICATGNOUP
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.
AST-2025-2434-002 RTK - Magna, UT Page l-2
pul6rpe
TECHNICAL GROUP Site Specifc Test Plan
Summary ofTest Programs
2.0 Summary of Test Program
To satisfu the requirements of the UDAQ and Title V permits and 40 CFR 60, Appendix B, PS 2, the facility will
conduct a performance test program to determine the compliance status of SME0I I b.
2.1 General Description
All testing will be performed in accordance with specifications stipulated in U.S. EPA Reference Test Methods 4
and 6C. 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 and 40 CFR 60,
Appendix B, PS 2.
Emissions testing will be conducted on the exhaust of SMEOI lb.
Performance testing will be conducted at greater than 50%o operating load.
Each of the 9-12 RATA test runs will be 2l minutes in duration.
Each of the 3-4 test runs for moisture content will be 60 minutes in duration.
The CEMS times are reported in Mountain Standard Time (year-round); prior to sampling the RM data
logger will be synched to CEMS time.
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:
CEMS Data
Production Data
2.3 Proposed Test Schedule
Table 2-1 presents an outline and tentative schedule for the emissions testing progr€rm.
Table 2-l: Program Outline and Tentative Test Schedule
a
a
a
a
a
a
a
DAY I - Iune24,2025
Equipment Setup & Pretest QA/QC Checks
DAY 2 - 1une25,2025
AST-2025-2434-002 RTK - Magna, UT Page 2-'l
pur6rrce
TECIlNICAL GROUP Site Specifc Test Plan
Sunmary ofTest Programs
2.4 Emission Limits
Emission limits for each pollutant are below.
Table2-2: Relative Accuracy Requirements and 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
following information.
o Introductior - 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 orvendorguarantees 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 Calculalions - Example calculations for each target parameter.
Field Data - Copies of actual handwritten or electronic field data sheets.
Quality Control Data - Copies of all instrument calibration data and/or calibration gas certificates.
Process Operaling/Control System Data - Process operating and control system data (as provided by RTK)
to support the test results.
a
a
a
a
a
AST-2025-2434-002 RTK - Magna, UT Page2-2
pill6rrcE>
It-(,llNl(iAt (illo!P Sile Specifc Test Plan
Testing 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 equiprnent, procedures and quality assurance measures necessary for the
completionofthetestprogrammeetorexceedthespecificationsofeachrelevanttestmethod. Theemissiontesting
program will be conducted in accordance with thetest 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 Method 4 - Moisture Content
The stack gas moisture content will be determined in accordance with U.S. EPA Reference l"est Method 4. The gas
conditioning train will consist of a series of chilled impingers. 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.
3.2 U.S. EPA Reference Test Method 6C - Sulfur Dioxide
The sulfur dioxide (SOz) testing will be conducted in accordance with U.S. EPA Reference Test Method 6C. Data
will be collected online and reported in one-minute averages. The sampling system will consist of a heated stainless
steel probe, Teflon sample line(s), gas conditioning system and the identified analyzer. The gas conditioning system
will be a non-contact condenser used to remove moisture from the source gas. If an unheated Teflon sample line is
used, then a portable non-contact condenser will be placed in the system directly after the probe. Otherwise, a
heated Teflon sample line will be used. The quality control measures are described in Section 3.4.
The relative accuracy of the SOz CEMS will be determined based on procedures found in 40 CFR 60, Appendix B,
Performance Specifi cation 2.
3.3 l.l.S. EPA Reference Test Method 205 - Gas Dilution System Certification
A calibration gas dilution system field check will be conducted in accordance with U.S. EPA Reference Method
205. An initial three (3) point calibration will be conducted, using individual Protocol I gases, on the analyzer used
to complete the dilution system field check. Multiple dilution rates and total gas flow rates will be utilized to force
the dilution system to perform two dilutions on each mass flow controller. The diluted calibration gases will be sent
directly to the analyzer, and the analyzer response will be recorded in an electronic field data sheet. A mid-level
supply gas, with a cylinder concentration within l\Yo of one of the gas divider settings described above, will be
introduced directly to the analyzer, and the analyzer response recorded in an electronic field data sheet. The
cylinder concentration and the analyzer response must agree within 2o/o. These steps will be repeated three (3)
Moisture Content Gravimetric Analysis
Sulfur Dioxide Instrumental Analysis
Gas Dilution System Certification
AST-2025-2434-002 RTK - Magna, UT Page 3- I
Site Specific I'est Plan
Testing Methodolo*-
times. The average analyzer response must agree within2Yo of the predicted gas concentration. No single injection
shall differ more than 2%o from the average instrument response for that dilution.
3.4 Quality Assurance/Quality Control - U.S. EPA Reference Test Method 6C
El)..| ['rotoc'ol I Calibrution (iuses
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.
Direct Calibration & Calibration Eruor Test
Low l,evel 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 forthe High-Level gas. Forthe Calibration ErrorTest, Low, Mid, and High-Level calibration gases will be
sequentially introduced directly to the analyzer. The Calibration Error for each gas must be within 2.0 percent of the
Calibration Span or 0.5 ppmv/% absolute difference.
Syslem Ilias and Response'l'ime
High or Mid-Level gas (whichever is closer to the stack gas concentration) will be introduced at the probe and the
time required for the analyzer reading to reach 95 percent or 0.5 ppmlo/o (whichever was less restrictive) of the gas
concentration will be recorded. The analyzer reading will be observed until it reaches a stable value, and this value
will be recorded. Next, [,ow-[,evel gas will be introduced at the probe and the time required for the analyzer reading
to decrease to a value within 5.0 percent or 0.5 ppm/% (whichever was less restrictive) will be recorded. If the Low-
Level gas is zero gas, the acceptable response must be 5.0 percent of the upscale gas concentration or 0.5 ppmloh
(whichever was less restrictive). The analyzer reading will be observed until it reaches a stable value, and this value
will be recorded. The measurement system response time and initial system bias will be determined from these data.
The System Bias for each gas rnust be within 5.0 percent of the Calibration Span or 0.5 ppmv/7o absolute difference.
Posl'l'est Sy.stem Bias Checks
High or Mid-Level gas (whichever is closer to the stack gas concentration) will be introduced at the probe. After the
analyzer response is stable, the value will be recorded. Next, Low-Level gas will be introduced at the probe, and the
analyzer value will be recorded once it reaches a stable response. The System Bias for each gas must be within 5.0
percent of the Calibration Span or 0.5 ppmv/o% absolute difference or the data is invalidated, and the Calibration
Error Test and System Bias must be repeated.
Posl T'esl Drift Checks
The Drift between pre- and post-run System Bias must be within 3 percent of the Calibration Span or 0.5 ppmv/%
absolute difference or the Calibration Error Test and System Bias must be repeated.
Stratificalion Check
To determine the number of sampling points, a gas stratification check will be conducted prior to initiating testing.
The pollutant concentrations will be measured at twelve traverse points (as described in Method l) or three points
(16.7,50.0 and 83.3 percent of the measurement line). Each traverse point will be sampled for a nrinimum of twice
the systern response time.
lf the pof lutant concentration at each traverse point do not differ more than 5% or 0.5 ppmll.3%o (whichever is less
restrictive) of the average pollutant concentration, then single point sampling will be conducted during the test runs.
AST-2025-2434-002 R'l'K - Magna. UT Pagc 3-2
pul6rrpE)
TTCIINICAL Gt]OUP Site Specific Test Plan
Testing Methodology
If the pollutant concentration does not meet these specifications but differs less than 10o/o or I .0 ppm/0.5% from the
average concentration, then three (3) point sampling will be conducted (stacks less than 7.8 feet in diameter - 16.7,
50.0 and 83.3 percent of the measurement line; stacks greater than 7.8 feet in diameter - 0.4, 1.0, and 2.0 meters
from the stack wall). If the pollutant concentration differs by more than 10% or 1.0 ppm/0.5o/o from the average
concentration, then sampling will be conducted at a minimum of twelve ( I 2) traverse points. Copies of stratification
check data will be included in the Quality Assurance/Quality Control Appendix of the report.
Data Collection
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-2025-2434-002 RTK - Magna, UT Page 3-3
AI Site Speclfic Test Plan
Q ua I i 4, A -s sura n ce P ro g ro nt
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 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 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 retuming from the field is inspected before it is
returned to storage. During the course of these inspections, items are cleaned, repaired, reconditioned and
recal ibrated where necessary.
Calibrations are conducted in a nranner, 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 Measurenrent 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 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 50% since the last full meter calibration. This check is performed after each test series.
Pitot Tubes and Manonreters. Type-S pitot tubes that meet the geometric criteria required by U.S. EPA
Reference l'est Method 2 are assigned a coefficient of 0.84 unless a specific coefficient has been
determined frorm a wind tunnel calibration. lf a specific coefficient from a wind tunnel calibration has been
obtained that coefficierrt will be used in lieu of 0.84. Standard pitot tubes that meet the geometric criteria
required by LJ.S. EPA Reference Test Method 2 are assigned a coefficient of 0.99. Any pitot tubes not
meeting the appropriate geornetric criteria are discarded and replaced. Manonreters are verified to be level
and zeroed prior to each test run and do not require further calibration.
Temperature Measurinq Devices. All thermocouple sensors mounted in Dry Gas Meter Consoles are
calibrated semi-annually with a NIS'1 -traceable thermocouple calibrator (temperature simulator) and
verified during field use using a second NIS'l'-traceable meter. NISI'-traceable thermocouple calibrators
are calibrated annually by an outside laboratory.
Nozzles. Nozzles are nreasured three (3) times prior to
difference between any two (2) dimensions is 0.004 in.
Digital Calipers. Calipers are calibrated annually by
annually by an outside laboratory.
initiating sampling with a caliper. The nraximunr
Alliance by using gage blocks that are calibrated
/\ST-2025-7434-007 Rl'K Magna. U'l
(rt [.] ( ) L ] I )
Site Specific Test Plan
Quality Assurance Progranr
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 meetin! this
requirement are adjusted or taken out ofservice.
Balances and Weights. 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 nrethane/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 l'ield Sampling
Field sampling will be done in accordance with the Standard Operating Procedures (SOP) for the applicable test
method(s). Ceneral 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.
o The sampling port will be sealed to prevent air from leaking from the por1.
. 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.
. All raw data will be maintained in an organized manner.
o AII raw data will be reviewed on a daily basis for completeness and acceptability.
AST-2025-2434-002 RTK - Magna, U1'Page 4-2