DAQ-2025-000755

1

DAQC-136-25
Site ID 10122 (B4)

MEMORANDUM

TO: STACK TEST FILE – BIG WEST OIL, LLC – North Salt Lake Refinery

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Robert Sirrine, Environmental Scientist

DATE: February 5, 2025

SUBJECT: Source: H-101 stacks A and B, H-621, 622, 624 (Single Stack), and Wabash Boiler
Location: 333 West Center Street, North Salt Lake, Davis County, Utah
Contact: Brady Miller, 385-324-1275
Tester: Erthwrks, Inc. Luke Morrison – 512-962-7661
FRS ID #: UT0000004901100008
AO #: DAQE-AN101220081-24, dated May 6, 2024
Subject: Review of Pretest Protocol received January 31, 2025
On January 31, 2025, Utah Division of Air Quality (DAQ) received a pretest protocol for sources H-101
stacks A and B, H-621, 622, 624 Single Stack, and the Wabash Boiler all located and operating at the Big
West Oil (BWO) refinery in North Salt Lake, Utah. Testing is scheduled to be performed March 3-7, 2025,
to determine NOx emission factors specified in Conditions II.B.9.a, II.B.9.d, and d.1-2.

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 7E used to determine NOx emissions: OK

DEVIATIONS: No deviations were noted.

CONCLUSION: The protocol appears acceptable.

RECOMMENDATION: Send protocol review and test date confirmation notice.

ATTACHMENTS: Pretest Protocol received January 31, 2025
Big West Oil Certified Pretest Protocol Letter received January 31, 2025
* - / $ - - $ )

Emission Testing Protocol

for
Big West Oil, LLC

at the
North Salt Lake Refinery

Determination of NOX lb/MMBtu

Four (4) Emission Sources

Prepared For:

Test Dates: Week of March 3rd, 2025
Erthwrks Project No. 10066
Erthwrks Project No. 10066—Big West Oil North Salt Lake Refinery—Emission Test March 2025
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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

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, Inc.

Name: John Wood

Title Technical Director

Signature:

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Table of Contents
1.0 INTRODUCTION ........................................................................................................ 4
1.1 Contact Information ...................................................................................................4
2.0 SAMPLING AND ANALYTICAL PROCEDURES .................................................. 5
2.1 EPA Reference Method Testing ................................................................................5
2.1.1 Gaseous Sampling – NOx, O2 ............................................................................5
2.3 Sampling Site Location ..............................................................................................7
3.0 General Work Sequence and Site Hazards and Mitigation .......................................... 7
3.1 General / Overall Safety Precautions and Risk Mitigation ........................................7

List of Tables
Table 1: Test Matrix ...................................................................................................................... 5

List of Figures
Figure 1: Example Erthwrks Sampling System Diagram ............................................................ 6

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1.0 INTRODUCTION

Erthwrks, Inc. has been contracted to provide air emission testing services for Big West Oil, LLC
at the North Salt Lake Refinery located in North Salt Lake, UT. Within this facility there are four
(4) sources that will be tested for the determination of Oxides of Nitrogen (NOX) in lb/MMBtu.

1.1 Contact Information

Big West Oil, LLC
Brady Miller
Environmental Engineer
333 W Center St.
North Salt Lake, UT 84054
385-324-1275
[e-mail]

Erthwrks, Inc.
Luke Morrison
Project Manager
P.O. Box 150549
Austin, TX 78715
512-962-7661 office
888-573-9994 fax
[e-mail]

Erthwrks, Inc.
John Wood
Technical Director
P.O. Box 150549
Austin, TX 78715
512-585-1685 office
888-573-9994 fax
[e-mail]

Facility Location
Big West Oil, LLC
North Salt Lake Refinery
333 W. Center St.
North Salt Lake, UT 84054

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Source Name Test Parameters EPA
Methodology #Runs/Duration Applicable
Standard
H-101
Stack A NOx, O2 EPA M.3A, 7E 3 x 60-min NA
H-101
Stack B NOx, O2 EPA M.3A, 7E 3 x 60-min NA
H-621, H-622, H-624
Single Stack NOx, O2 EPA M.3A, 7E 3 x 60-min NA
Wabash Boiler NOx, O2 EPA M.3A, 7E 3 x 60-min NA

2.0 SAMPLING AND ANALYTICAL PROCEDURES

2.1 EPA Reference Method Testing

2.1.1 Gaseous Sampling – NOx, O2

For all gaseous sampling, Erthwrks will insert a stainless-steel, shepherd-hook probe, of sufficient
length to reach a sampling location located in 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 7E for the determination of NOx 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
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).
Table 1: Test Matrix
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After each test run, or groups of runs, 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.

In accordance with EPA Method 7E, Section 8.5, the post run bias check/drift assessment will be
conducted after every 1-hour run. If a compliance test is being conducted concurrently with a
RATA test, the compliance test runs will be 63 minutes in duration.

Figure 1: Example Erthwrks Sampling System Diagram
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2.3 Sampling Site Location

Because the heater stacks subject to this testing programming do not have sampling ports,
Erthwrks will use a “shepherds-hook” probe to meet the sampling location requirement of EPA
Method 1. Sampling will be conducted from a single point.

3.0 General Work Sequence and Site Hazards and Mitigation

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 3.1 through 3.4. 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 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.
3.1 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 Big West Oil,
LLC 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 Big West Oil, LLC .
• No work will begin until a proper permit has been issued and all necessary Big West Oil,
LLC Operations staff has been informed.
• The mobile lab will be parked at the nearest allowable/safest location below the stack
area.
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• 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 Big West Oil,
LLC .
• 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.
• Technicians will be on the sample platform only during setup, tear down, and during the
initial stratification traverse. Communication between technicians on the stack platform
and on the ground will be done through intrinsically safe radios, or explosion proof mobile
phones.
• 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.

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