DAQ-2024-008170

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-511-24
Site ID 10119 (B5)

Tony Pollock, Environmental Specialist
Chevron Products Company
685 South Chevron Way
North Salt Lake City, Utah 84054

Dear Mr. Pollock:

Re: Chevron Products Company (Chevron) – Pretest Protocol for Hydrogen Sulfide (H2S),
SO2, NOx, CO, and O2 Relative Accuracy Test – Davis County

The Utah Division of Air Quality (DAQ) reviewed Chevron’s pretest protocol received on May
20, 2024. The proposed test shall be performed under the following conditions:

Chevron’s monitoring systems to be certified:

Point Source Channel Manufacturer Model # Monitor SN

SRU1
VFR Optical Scientific OFS-2000 0502166E
O2 Ametek 9900 ZW-9900-S1332-1
SO2 Ametek 9900 ZW-9900-S1332-1

SRU2
VFR Thermox OFS-2000 9080423
O2 Ametek 9900 AV-9000WM-10235-1A
SO2 Ametek 9900 AV-9000WM-10235-1A

FCC
O2 Siemens Ultramat/Oxymat J7-447
SO2 Siemens Ultramat J6-73
NOx Western Research 9200 NOx ZW-9900-1334-1
CO Siemens Ultramat J6-783
Boiler 7 O2 Ametek 9900 ZE9900-10941-1
NOx Ametek 9900 ZE9900-10941-1
Flare 3 H2S Siemens Maxum II OKB30068232740010
Refinery Fuel Gas H2S Siemens Maxum II 30019536380010

Alliance Technical Group will conduct a relative accuracy/performance specification test on
Chevron’s continuous monitoring system.

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DAQC-511-24
Page 2

Relative accuracy must be determined in the units of the emission standard or equivalent units of
the emission standard, i.e., tons/year shall be tested in pounds/hour or lb Hg/MM ton clinker
30-DRA shall be tested as lb Hg/MM ton clinker.

The DAQ understands that testing will be conducted as follows:

Test Date Point Source Parameter EPA Reference Method
8/26/2024 FCCU Regeneration Vent O2, SO2, NOx, & CO 1, 2, 3A, 6C, 7E, and 10
8/21/2024 SRU Unit 1 Flow, O2, and SO2 1, 2, 3A, 4, and 6C 8/22/2024 SRU Unit 2
8/23/2024 Boiler #7 O2 and NOX 3A, 7E, and 19
8/20/2024 Flare #3 H2S Method 15 8/19/2024 Fuel Gas Mix Point

• Reference Method 1 - Sample and Velocity Traverses for Stationary Point Sources
as outlined in 40 CFR 60 Appendix A shall be used to determine the location and
number of sampling points as applicable.

• Reference Method 2 - Determination of Stack Gas Velocity and Volumetric Flow
Rate – (Type S Pitot Tube) as outlined in 40 CFR 60 Appendix A.

• Reference Method 3A - Determination of Oxygen and Carbon Dioxide
Concentrations in Emissions from Stationary Point Sources – (Instrumental
Analyzer Procedure) as outlined in 40 CFR 60 Appendix A.

• Reference Method 4 - Determination of Moisture Content in Stack Gases as
outlined in 40 CFR 60 Appendix A shall be used to determine the stack gas
moisture content.

• Reference Method 6C - Determination of Sulfur Dioxide Emissions from
Stationary Point Sources - (Instrumental Analyzer Procedure) as outlined in 40
CFR 60 Appendix A.

• Reference Method 7E - Determination of Nitrogen Oxide Emissions from
Stationary Point Sources - (Instrumental Analyzer Procedure) as outlined in 40
CFR 60 Appendix A.

• Reference Method 10 - Determination of Carbon Monoxide Emissions from
Stationary Point Sources – (NDIR Instrumental Procedure) as outlined in 40 CFR
60 Appendix A.

• Reference Method 15 - Determination of Hydrogen Sulfide Content of Fuel Gas
Streams in Petroleum Refineries as outlined in 40 CFR 60 Appendix A.

• Reference Method 19 - Determination of volumetric flow rate as outlined in 40
CFR 60 Appendix A.
DAQC-511-24
Page 3

• Deviations - The Director or the representative of the Director must be notified of
and approve deviations of the Reference Method test. Any deviation from these
conditions without approval from the DAQ may constitute rejection of these tests.

Acceptance of a protocol does not relieve the owner/operator and the testing
contractor from strict adherence to all applicable EPA methods, DAQ policies,
Utah Air Quality Rules (UAQR), and methods approved by the Director. Any
deviation from EPA methods, DAQ policies, UAQR, and methods approved by the
Director must be addressed separately and express written consent given prior to
commencement of testing.

• Field data (Point Source emission data and test data) shall be turned over to the
DAQ in a timely manner for review.

• The Director will determine the relative accuracy of each monitoring system based
on Point Source continuous emission monitoring data and test data acquired during
the test.

• All test reports must be submitted to the Director not later than 60 days after
completion of the test.

• The test report shall include all raw calibration data, raw emission data with date,
time stamps.

Relative accuracy test reports must contain:

1. Point source continuous monitor, channel, manufacturer, and serial number,

2. Raw stack test data and continuous monitor data with date and time stamps.

3. Emission data reported in concentration (ppm or %) and units in the applicable
emission limit.

The DAQ requires that all test reports include a statement signed by a responsible official
certifying that:

1. Testing was conducted while the Point Source was operating at the rate and/or
conditions specified in the applicable approval order, operating permit, or federal
regulation.

2. During testing, the Point Source combusted fuels, used raw materials, and
maintained process conditions representative of normal operations, and operated
under such other relevant conditions specified by the Director.

3. Based on information and belief formed after reasonable inquiry, the statements
and information contained in the report are true, accurate, and complete.
DAQC-511-24
Page 4

Should you have any questions concerning this matter, contact me at [phone] or by email
at [e-mail].

Sincerely,

Rob Leishman, Environmental Scientist
Major Source Compliance Section

RL:rh

cc: Davis County Health Department
Alliance Technical Group

* $ . # ( ) - — 4 A C v A ? A C ? H w D A ˜
Rob Leishman Jr