DAQ-2024-010442

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-910-24
Site ID 10122 (B5)

Brady Miller, Environmental Engineer
Big West Oil
333 West Center Street
North Salt Lake, UT 84054

Dear Mr. Miller:

Re: Big West Oil – Pretest Protocol for Flow, Oxygen (O2), Sulfur Dioxide (SO2), and Hydrogen
Sulfide (H2S) Relative Accuracy Test – Davis County

The Utah Division of Air Quality (DAQ) reviewed Big West Oil’s pretest protocol dated September 3,
2024. The proposed test shall be performed under the following conditions:

Big West Oil’s monitoring system to be certified:

Point Source Channel Manufacturer Model # Monitor SN
Sulfur Recovery Unit
SRU
O2 Emerson / Rosemount X-Stream X2 XMF08002693435
SO2 Emerson / Rosemount X-Stream X2 XMF08002693435
Amine Unit H2S Ametek 5100 HD 1021950
South Flare H2S Extrel Core Mass MAX 300-IG 61728
West Flare H2S Extrel Core Mass MAX 300-IG 61727

Erthwrks, Inc. will conduct a relative accuracy/performance specification test on Big West Oil’s
continuous monitoring system.

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.

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DAQC-910-24
Page 2

The DAQ understands that Erthwrks, Inc. will conduct testing as follows:

Test Date Point Source Parameter EPA Reference Method
October 22, 2024 SRU
Flow Method 1, 2, 3A, and 4
O2 Method 3A
SO2 Method 6C
October 23, 2024 West Flare H2S 15
October 23, 2024 South Flare H2S 15
October 24, 2024 Amine Unit H2S 11

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

• Reference Method 15 - Determination of H2S Concentrations Using a Gas
Chromatograph with Flame Photometric Detector as outlined in 40 CFR 60 Appendix A.
Zero drift and calibration drift checks are required in accordance with Performance
Specification 7.

• 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 shall be provided to the DAQ in a timely manner for review.

DAQC-910-24
Page 3

• The Director will determine the relative accuracy of each monitoring system based on
Point Source continuous emission monitoring data and test data acquired by the staff
member of the DAQ 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 and raw emission data with date and
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.

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:jl

CC: Davis County Health Department
Erthwrks, Inc.
* $ . # ( ) - — + @ E v A ? A C @ ? w A H ˜
Rob Leishman Jr