DAQ-2025-000598

SilverEagle
REFINING
fri,!.lrii; .,/i;/r I
January 23,2025
Mr. Bryce Bird, Director
Utah Department of Environmental Quality
Division of Air Quality
P.O. Box 144820
Salt Lake City, Utah 84114-4820
Re: February 2025 SRU Efficiency Test 30-day Notification and Submission of SRU Efficiency Test
Protocol.
Dear Mr. Bird:
Silver Eagle plans to conduct sulfur removal efficiency testing of their Sulfur Recovery Unit (SRU) the
week of February 24 through February 28,2025. Silver Eagle hereby submits the following protocol for
testing the efficiency of the SRU.
Silver Eagle uses a unique sulfur recovery system. The SRU does not employ the oil refining standard
Amine/Clause sulfur recovery system. Silver Eagle uses a NASH system that directly scrubs H2S from
the plant gases using a solution of Sodium Hydroxide. The H2S-Io-NASH reaction occurs in one vessel;
therefore, removal efficiency can be simply calculated by measuring the H2S concentrations at the inlet
and effluent of the NASH reactor vessel(s).
Silver Eagle's NASH Unit treats the following sulfur bearing streams:
MDDW Fractionator off-gas
MDDW Low Pressure Separator (LPS) off-gas
MDDW High Pressure Separator (HPS) off-gas
MDDW Stabilizer off-gas
All of the above gas streams combine into a single pipe that enters the NASH unit. The treated gas exits
the NASH unit and is sent to the plant fuel gas mixing drum.
The removal efficiency of the NASH unit will be determined as follows:
Testing will be conducted with the MDDW operating at its anticipated maximum production rate.
Efficiency testing procedures will be as follows:
l.The H2S concentration of the fuel gas streams entering and exiting the NASH Unit will be
measured with the use of concentration stain tubes (Gastech, RAE, Draeger or equivalent). H2S
measurements will be made at the inlet and then, as soon as possible, at the outlet of the NASH
unit. One measurement of inlet gas coupled with one measurement at the outlet gas will constitute
one set ofdata.
Six data sets will be taken over a 3-day period. Six removal efficiency calculations will be
performed, one for each data set. The SRU's efficiency shall be the average of the six sets.
The inlet concentration of H2S is expected to be two percent or less by volume; therefore the reduction in
mass and volumetric flow rates due to the removal of H2S in the NASH unit will be negligible and we
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2355 South I100 West . Woods Cross, Utah 84087
REVIEWEDInitials:Date: Jan 30, 2025Compliance status: In ComplianceFile #: 10124 (B2)
propose not to include them in the calculation of the percent reduction of sulfur. The percent reduction of
sulfur will be calculated as follows:
[(ConcSenteringSRU \ I (ConcSexitingSnu \ )]mm I 001 : P ercent Reductiono/Sulfur
(ConcSenteringsRu Y+ )
m
Feel free to contact me if you need addition information concerning this notification. Thank you.
Sincerely,
Cc
Blaine Zwahlen,@
for Silver Eagle Refining-Woods Cross Inc.
James Shupe
Josh Sorenson
Gigi Camarena
Mike Klotovich
2355 South I100 West . Woods Cross, Utah 84087