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Home My WebLink AboutDAQ-2024-0104411 DAQC-909-24 Site ID 10122 (B5) MEMORANDUM TO: CEM FILE – BIG WEST OIL – Sulfur Recovery Unit (SRU), Amine Plant, South and West Flares THROUGH: Harold Burge, Major Source Compliance Section Manager FROM: Rob Leishman, Environmental Scientist DATE: September 6, 2024 SUBJECT: Source: Sulfur Recovery Unit (SRU), Amine Plant, South and West Flares Contact: Brady Miller – 385-324-1275 Faithe Schwartzgraber – 801-296-7763 Location: 333 West Center Street, North Salt Lake, Davis County, UT Test Contractor: Erthwrks, Inc. FRS ID#: UT0000004901100008 Permit/AO#: AO DAQE-AN10122066-15, dated May 18, 2015 Subject: Review of RA/PST Protocol dated September 3, 2024 On September 3, 2024, DAQ received a protocol by email for a RA/PST (relative accuracy/performance specification test) of the Big West Oil SRU, Amine Plant, South and West flares in North Salt Lake, UT. Testing will be performed on October 22-24, 2024, to determine the relative accuracy of the H2S, O2, 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. RM11 used to determine H2S content of fuel gas in petroleum refineries: OK 7. RM 15 to determine total H2S concentration from stationary sources by GC/FPD: OK DEVIATIONS: No deviations were noted. CONCLUSION: The protocol appears to be acceptable. RECOMMENDATION: Send attached protocol review and test date confirmation notice. 1 8 2 Emission Testing Protocol for Big West Oil, LLC at the North Salt Lake Refinery on the Amine Unit West Flare South Flare Sulfur Recovery Unit Permit No: Approval Order DAQE-AN101220081-24 prepared for Test Dates: Week of October 21, 2024 Erthwrks Project No. 9845 Erthwrks Project No. 9845 —Big West Oil North Salt Lake Refinery H2S and SO2 CEMS RATA Testing —Version 2 (9/1/2024) Endorsement Page This protocol was developed in accordance with the requirements designated in the applicable regulatory permit(s) and or regulatory rules. To the best of my knowledge the techniques, instrumentation, and calculations presented in this protocol will serve to complete the test campaign requirements accurately and efficiently. Erthwrks, Inc. Name: Luke Morrison Title Project Manager Jas Signature: This protocol has been reviewed for accuracy and completeness. The actions presented in this protocol are, to the best of my knowledge, an accurate representation of the necessary work scope needed to successfully complete the requirements of the test campaign. Erthwrks operates in conformance with the requirements of ASTM D7036-04 Standard Practice for Competence of Air Emission Testing Bodies. Erthwrks, Inc. Name: John Wood Title Technical Director Signature: 2 of 14 Erthwrks Project No. 9845 —Big West Oil North Salt Lake Refinery H2S and SO2 CEMS RATA Testing —Version 2 (9/1/2024) Table of Contents 1.0 INTRODUCTION ........................................................................................................ 4 1.1 Contact Information/On-Site Personnel ....................................................................4 2.0 FACILITY DESCRIPTION ......................................................................................... 5 3.0 SAMPLING AND ANALYTICAL PROCEDURES .................................................. 6 3.1 Gaseous Sampling – H2S ...........................................................................................6 3.2 Gaseous Sampling – SO2 and O2 ...............................................................................6 3.3 EPA Method 4 Moisture Determination (Modified) .................................................8 3.4 RATA Procedures ......................................................................................................8 4.0 General Work Sequence,Site Hazards and Mitigation, and Tentative Schedule ........ 9 4.1 General / Overall Safety Precautions and Risk Mitigation ........................................9 4.2 Tentative Schedule ...................................................................................................10 List of Tables Table 1: Test Matrix ..................................................................................................................... 5 Table 2: Big West Oil CEMS Details .......................................................................................... 5 Table 3: Tentative Work Schedule ............................................................................................. 10 APPENDICES A. Example RATA Run DATA and Calculations 3 of 14 Erthwrks Project No. 9845 —Big West Oil North Salt Lake Refinery H2S and SO2 CEMS RATA Testing —Version 2 (9/1/2024) 1.0 INTRODUCTION Erthwrks, Inc. has been contracted to provide air emission testing services for Big West Oil (BWO) at the North Salt Lake Refinery located in North Salt Lake, UT. This test program is scheduled for the week of October 21, 2024. These units are operated as required under the Permit No. Approval Order DAQE- AN101220081-24 and EPA Title 40 CFR Part 60, Appendix F. 1.1 Contact Information/On-Site Personnel Big West Oil, LLC Brady Miller Environmental Engineer 333 W Center St. North Salt Lake, UT 84054 385-324-1275 brady.miller@bigwestoil.com Erthwrks, Inc. Luke Morrison Project Manager P.O. Box 150549 Austin, TX 78715 512-962-7661 office 888-573-9994 fax Lmorrison@erthwrks.com Erthwrks, Inc. John Wood Technical Director P.O. Box 150549 Austin, TX 78715 512-585-1685 office 888-573-9994 fax jwood@erthwrks.com Facility Location: Big West Oil, LLC North Salt Lake Refinery 1300 South Fort Street North Salt Lake, UT 48217 4 of 14 Erthwrks Project No. 9845 —Big West Oil North Salt Lake Refinery H2S and SO2 CEMS RATA Testing —Version 2 (9/1/2024) Source Name Regulation Test Parameters EPA Methodology Applicable Std/ Permit Limit No. of Runs / Duration Amine Unit RATA H2S EPA M.15, PS 7 162 ppm 9, 30-min runs West Flare RATA H2S EPA M.15, PS 7 162 ppm 9, 30-min runs South Flare RATA H2S EPA M.15, PS 7 162 ppm 9, 30-min runs SRU RATA O2 EPA M.3A, PS 3 NA 9, 21-min runs SO2 EPA M.6C, PS 2 NA 2.0 FACILITY DESCRIPTION Located in North Salt Lake City, Utah, the facility is a high conversion refinery operated by Big West Oil LLC, a wholly owned subsidiary of FJ Management Inc. The facility has a total capacity of 35,000 barrels per day and refines a combination of Utah, Wyoming and Canadian crude oils into high-quality motor fuels and other specialty chemicals. Big West Oil products meet or exceed government standards for clean transportation fuels, as well as customer needs for engine performance and cold flow qualities. Unit Parameter Make Model Serial No. Amine H2S Ametek 5100 HD 1021950 West Flare H2S EXTREL MAX 300-IG 61727 South Flare H2S EXTREL MAX 300-IG 61728 SRU O2/SO2 Rosemount/Emerson X-Stream X2 XMF08002693435 Table 1: Test Matrix Table 2: Big West Oil CEMS Details 5 of 14 Erthwrks Project No. 9845 —Big West Oil North Salt Lake Refinery H2S and SO2 CEMS RATA Testing —Version 2 (9/1/2024) 3.0 SAMPLING AND ANALYTICAL PROCEDURES 3.1 Gaseous Sampling – H2S In accordance with EPA Performance Specification 7, the analysis of the fuel gas sample streams will be conducted following all procedures as specified in USEPA Method 15. Erthwrks will utilize an SRI Model 8610 Gas Chromatograph (GC) equipped with an FPD detector. Three calibration gas concentrations, using a calibration gas dilution system, will be delivered to the GC and analyzed in triplicate. These triplicate values will be recorded and averaged, wherein a graphical plot of concentration versus the GC peak area values will be created and used to calculate the concentration of the unknown sample. Utilizing a Teflon sample line, Erthwrks will direct the sample, under positive pressure, directly to the GC (no bag sampling). Erthwrks will then conduct a series of 30-minute test runs comprising of at least two (2) sample injections per test run. After the testing program, a post- test analysis of the mid-calibration standard will be performed and must be within 5% of the original curve. If this post-test criteria are not met, Erthwrks will create an additional complete post-test calibration curve and will use the calibration data that calculates the highest emission value in accordance with the method. EPA Audit samples are not available for Method 15. 3.2 Gaseous Sampling – SO2 and O2 For all gaseous sampling, Erthwrks will insert a stainless-steel probe, of sufficient length to reach all sampling points, into a sampling port that is located on the stack in accordance with EPA Method 1. The sample is extracted through the probe, a heated Teflon sampling line, to a heating filter. The sample then enters a minimum contact sample conditioner that cools and removes moisture from the gas matrix prior to entering the Erthwrks sampling manifold. For this project, the following Reference Methods will be used as applicable:  EPA Method 3A for the determination of O2 concentration  EPA Method 6C for the determination of SO2 concentration Erthwrks will follow all quality assurance and quality control procedures as defined in US EPA 40 CFR 60 Appendix A. The Calibration Error (CE) Test will be conducted as specified in EPA Method 7E §8.2.3. In accordance with this requirement, a three-point analyzer calibration error test will be conducted prior to sampling. The CE test will be conducted by introducing the low, mid, and high-level calibration gasses (as defined in EPA Method 7E §3.3.1-3) sequentially and the response will be recorded. The results of the CE test are acceptable if the calculated calibration error is within ±2.0% of calibration span (or ≤ 0.5 ppmv). The Initial System Bias and System Calibration Error Check will be conducted in accordance with EPA Method 7E §8.2.5. The upscale calibration gas will be introduced at the probe upstream of all sample system components and the response will be recorded. The procedure will be repeated with the low-level gas and the response will be recorded. The sample system 6 of 14 Erthwrks Project No. 9845 —Big West Oil North Salt Lake Refinery H2S and SO2 CEMS RATA Testing —Version 2 (9/1/2024) response time will also be recorded. This specification is acceptable if the calculated values of the system calibration error check are within ±5.0% of the calibration span value (or ≤0.5 ppmv). After each compliance test run, the sample system bias check will be conducted to validate the run data. The low-level and upscale drift will be calculated using Equation 7E-4. The run data is valid if the calculated drift is within ±3.0% of the calibration span value (or ≤0.5 ppmv). After each test run, the effluent gas concentration will be calculated as specified in EPA Method 7E §12.6. The arithmetic average of all valid concentration values will be adjusted for bias using equation 7E-5B. All raw data is recorded and automatically saved onto the Erthwrks cloud server and is directly linked to the emission calculation worksheets to insure accurate transfer of the raw data and the accuracy of the calculations. EPA Audit samples are not available for EPA Methods 3A or 6C. The figure below details the Erthwrks Gaseous Sampling System. 7 of 14 Erthwrks Project No. 9845 —Big West Oil North Salt Lake Refinery H2S and SO2 CEMS RATA Testing —Version 2 (9/1/2024) 3.3 EPA Method 4 Moisture Determination (Modified) Where applicable to correct measurements to a dry or wet basis, a modified EPA Method 4 rain will be used to determine the moisture of the exhaust stack. The sampling will be conducted at a single point through an unheated sampling line and through four impingers containing water and silica gel place in an ice bath. Alternatively, the sample may be taken as a slip stream off the heated sampling line in order to sample at the same sampling points as the Method 7E sampling location. The sampling will be conducted at a constant rate, for the duration of the gaseous emission test runs, and the beginning and final dry gas meter readings will be recorded. Moisture will be determined gravimetrically in accordance with EPA Method 4. 3.4 RATA Procedures The RATA testing will be conducted following the sampling and measurement procedures found in the EPA Part 60, Appendix B, Performance Specifications which requires that EPA Reference Methods, from EPA Part 60, Appendix A, be utilized to conduct independent stack emissions measurements for comparison with installed CEMS readings. The following performance specifications will be used during this testing program:  EPA Performance Specification 7 for H2S Relative Accuracy  EPA Performance Specification 2 for SO2 Relative Accuracy  EPA Performance Specification 3 for O2 Relative Accuracy As required, the use EPA Protocol 1 gases are mandatory and will be used for this portion of the project. In addition, EPA Method 205 may be used for the generation of calibration standards for the Erthwrks analytical instrumentation. A minimum of nine (9) RATA test runs will be conducted at each exhaust stack for a minimum duration of thirty (30) minutes for each run for H2S, and twenty-one (21) minutes for O2 and SO2. During each 30-minute test run for H2S, a minimum of two (2) GC injections will take place. A maximum of twelve (12) RATA test runs will be conducted and up to three test runs may be discarded and not used to determine relative accuracy. The results of the reference method tests will be compared to CEMS measurement data from the same time periods to determine the relative accuracy of the CEMS. The Standard Deviation will be calculated following Equation PS.2, 2-4: The Confidence Coefficient will be calculated following Equation PS.2, 2.5: The Relative Accuracy will be calculated using Equation PS.2, 2-6: 𝑆𝑑ൌ ඨ∑𝑑𝑖2𝑛 𝑖ൌ1 െ ሾ∑𝑑𝑖𝑛 𝑖ൌ1 ሿ2 𝑛 𝑛െ1 CC ൌ t ଴.ଽ଻ହ Sୢ nଵ/ଶ RAୖ୑ ൌ หdୟ୴୥ ห൅|CC| RMୟ୴୥ ൈ 100 8 of 14 Erthwrks Project No. 9845 —Big West Oil North Salt Lake Refinery H2S and SO2 CEMS RATA Testing —Version 2 (9/1/2024) All detailed calculations and complete example calculations will be provided in the final report. 4.0 General Work Sequence,Site Hazards and Mitigation, and Tentative Schedule Erthwrks works diligently to eliminate and minimize potential hazards as they apply to our equipment and the test procedures used during the field campaign. A list of safety risk mitigation measures to be employed by the Erthwrks teams during the field campaign is summarized in subsections below. These mitigation measures range from general items applicable to the overall field campaign as well as specific measures associated with the mobile lab/electrical equipment as well as the field execution. The minimum PPE requirements will include hard hats, safety glasses with side shields, steel-toed safety shoes, hearing protection, fire resistant clothing, fall protection, and a personal H2S monitor. The following hazards are expected during the field test campaign:  Working at heights.  Using and transporting compressed gases.  Electrical hazards from high voltage plant/generator power sources and operation of electrical equipment inside and outside the test van.  Heat stress and fatigue.  Fire hazards associated with non-intrinsically safe equipment.  Hot surfaces (stacks and sample ports will be at high temperatures).  Tripping hazards present around test van (multiple power cords connected to test van and sample line) and on sampling platform. 4.1 General / Overall Safety Precautions and Risk Mitigation  All Erthwrks personnel attend annual basic plus mandatory trainings, including all required site-specific training and background checks.  All field team members will be equipped with proper PPE compliant with BWO procedures.  Per Erthwrks requirements, a Job Safety Analysis (JSA) form will be prepared by all members of the field staff prior to commencement of the field campaign.  Each day will begin with a TBT conducted by the field team lead discussing potential hazards, and evacuation routes specific to that day’s location within BWO.  No work will begin until a proper permit has been issued and all necessary BWO Operations staff has been informed.  The mobile lab will be parked at the nearest allowable/safest location below the stack area. 9 of 14 Erthwrks Project No. 9845 —Big West Oil North Salt Lake Refinery H2S and SO2 CEMS RATA Testing —Version 2 (9/1/2024)  A field technician will ascend the stack to the sampling platform and use a rope to haul a heated sampling line to the platform. The sample line will be secured to the platform by use of rope or suitable temporary fasteners.  All elevated work, including work on the sample platform, will be done with proper harnessing and fall protection equipment (if required) and approved by BWO.  Technicians working on the stack platform will have appropriate heat resistant gloves when removing sampling port plugs and when handling hot sampling probes.  All hand tools will be equipped with lanyards and stored in tool bags to prevent dropped objects.  The sampling line will be secured to the platform and at other point(s) on the unit to minimize swinging.  Once tests at a particular stack are completed, a field technician will ascend to the stack platform and carefully lower the heated sample line. The power supply will be unhooked from the lab and the area cleared (with good housekeeping). Operations will be informed, and the lab will be driven away from the area and parked in an approved area of the plant or at the next testing location.  Setup and teardown procedures will involve all Field Team staff 4.2 Tentative Schedule Scheduled Date Equipment/Description Test Parameters October 21, 2024 Mobilization NA October 22, 2024 SRU RATA: SO2, O2 October 23, 2024 West Flare RATA: H2S South Flare RATA: H2S October 24, 2024 Amine Unit RATA: H2S Table 3: Tentative Work Schedule 10 of 14 Appendix A Example RATA Run Data and Calculations 11 of 14 Erthwrks Relative Accuracy Test Audit--H2S RATA Performance Specification 7 Rheniformer Test Run Run 1 Run 2 Run 3 Run 4 Run 5 Run 6 Run 7 Run 8 Run 9 Date 6/12/2024 6/12/2024 6/12/2024 6/12/2024 6/12/2024 6/12/2024 6/12/2024 6/12/2024 6/12/2024 Start Time 19:56 20:26 20:56 21:26 21:56 22:26 22:56 23:26 23:56 End Time 20:26 20:56 21:26 21:56 22:26 22:56 23:26 23:56 0:26 RM H2S (ppmvw)2.31 2.35 2.41 2.50 2.54 2.59 2.58 2.64 2.65 CEMS H2S (ppmvw) 7.17 7.06 6.97 6.83 6.97 6.87 7.06 7.14 7.10 Abs. Diff. -4.86 -4.71 -4.56 -4.33 -4.43 -4.28 -4.48 -4.50 -4.45 Accept or Reject Accept Accept Accept Accept Accept Accept Accept Accept Accept Applicable Standard (ppmv) 162 Mean of the Difference (davg)-4.51 Standard Deviation (Sd)0.18 Confidence Coefficient (CC) 0.14 Relative Accuracy via AS, RA AS 2.87% ← Pass †RA AS (Applicable Standard) must be less then 10% H2S RATA--Performance Specification 7 EXAMPLE12 of 14 Erthwrks RATA Example Calculations Example Calculations for H2S RATA Arithmetic Mean--Mean of the Difference between reference method and client CEMS, d avg Eq. 2-3 where:d =absolute difference between reference method and client CEMS i =run number d 1 =-4.86 d 4 =-4.33 d 7 =-4.48 d 10 =0 d 2 =-4.71 d 5 =-4.43 d 8 = -4.50 d 11 =0 d 3 = -4.56 d 6 = -4.28 d 9 = -4.45 d 12 =0 n =number of runs =9 davg =-4.51 Standard Deviation, S d Eq. 2-4 1/2 1.65E+03 9 8 S d =0.18 Confidence Coefficient, CC Sd n1/2 Eq. 2-5 where:t0.975 = 2.306 1.81E-01 3 CC =0.14 Relative Accuracy, RA AS Eq. 2-6 where:AS =the unit's permit limit or applicable standard AS = 162 4.5111 + 1.39E-1 RA AS =2.87% CC =2.306 * S d =1.83E+02 - CC =t0.975 RA AS =* 100162   n i iavgdnd 1 1 1 2 1 1 2         n n di d S n in i i d 100AS CCdRAavg AS EXAMPLE13 of 14 Erthwrks Example Calculations Example Calcs :Fuel gas Example Calcs for Pollutant :H2S CV = 50.0 = Low Level Target concentration of calibration gas, ppmv. CDir = 20.0 = Mid Level Target concentration of calibration gas, ppmv. CS = 5.0 = High Level Target concentration of calibration gas, ppmv. CS = 4460.5 = Low Level Average GC Response SBi = 765.7 = Mid Level Average GC Response SBf = 43.9 = High Level Average GC Response GC Calibration Curve (Polynomial Excel Generated) y = ax2 + bx + c where:a = 1.7092 b = 3.7678 c = 0 Run 1 Example Calculation y = 17.850 (average response Run 1) solution =x = where:a = 1.7092 b = 3.7678 c = 0.000 ( c - y ) x = -3.7678 [ 3.77^2 - 4 ( 1.7092 ) -( 17.85 ) ]^1/2 x = 2.31 ppmv -b + [b2 - 4(a)(c-y)]1/2 2(a) 2 ( 1.7092 ) EXAMPLE 14 of 14