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Home My WebLink AboutDAQ-2025-0015311 DAQC-277-25 Site ID 10123 (B4) MEMORANDUM TO: STACK TEST FILE – HF SINCLAIR WOODS CROSS REFINING, LLC THROUGH: Harold Burge, Major Source Compliance Section Manager FROM: Paul Morris, Environmental Scientist DATE: March 13, 2025 SUBJECT: Sources: Heaters 8H2, 12H1, 20H2, 20H3, 24H1, 25H1, Furnaces 8H2, 24H1, and Boilers #5, #8, #10, and #11 Contact: Travis Smith – 801-299-6625 Location: 393 South 800 West, Woods Cross, Davis County, UT Tester: Alliance Technical Group, LLC FRS ID #: UT000004901100013 Permit/AO#: Approval Order (AO) DAQE-AN101230057-23, dated November 15, 2023 Subject: Review of Stack Test Protocol dated March 4, 2025 On March 10, 2025, the Utah Division of Air Quality (DAQ) received a protocol for testing of the HF Sinclair Woods Cross Refining’s Heaters 8H2, 12H1, 20H2, 20H3, 24H1, 25H1, Furnaces 8H2, 24H1, and Boilers #5, #8, #10, and #11 located in Woods Cross, UT. Testing will be performed April 7-18, 2025, to determine compliance with AO Conditions II.B.1.a. 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 content: OK 6. RM 10 used to determine CO content: OK 7. RM 25A used to determine VOC content: OK DEVIATIONS: No deviations were noted. CONCLUSION: The protocol appears to be acceptable. RECOMMENDATION: Send protocol review and test date confirmation notice. ATTACHMENTS: Pretest protocol dated March 4, 2025 6 3 UTAH DFPARTMENT OF r;lVlSlON OF AIR OUALITY ,.dttFfinctorr March 4,2025 Mr. Bryce Bird, Director Division of Air Quality Utah Department of Environmental Quality 195 North 1950 West Salt Lake City, Utah 841l6 Certified Mail: 7022 0410 0002 3551 6592 CO, CO2, NOx, and VOC Compliance Testing - 8H2, 12H1,20H2,20H3, 24H1,25H1, and Boilers #5,#8, #10, and #11. HF Sinclair Woods Cross Refining LLC, Davis County Director Bird: In accordance with Section R307-165-3, Condition II.B.1.a of Approval Order DAQE-AN101230057-23, and Conditions ILB.l4.b.l,II.B.l4.c.l, and II.B.14.d.l of Title V Operating Permit I100013001, HF Sinclair Woods Cross Refining LLC is providing notification of source testing planned to be conducted at the Woods Cross Refinery. Alliance Technical Group, LLC of Salt Lake City, UT has been contracted to conduct: 1. CO compliance stack testing of the following emission sources: - 8H2, Crude Furnace #l - 20H3, Reactor Charge Heater -24H1, Crude Unit Furnace - 25H1, FCC Feed Heater - Boiler #1 1 2. CO2 compliance stack testing of the following emission source: - 8H2, Crude Furnace #l 3. NOx compliance stack testing of the following emission sources: - 8H2, Crude Furnace #1 - 12H1, NHDS Reactor Charge Furnace - 20H2, Fractionator Charge Heater - 20H3, Reactor Charge Heater - 24H1, Crude Unit Furnace - 25H1, FCC Feed Heater - Boiler #5 - Boiler #8 HF SinclairWoods Cross Refining LLC 1070 W. 500 S, West Bountiful, UT 84087 801 -299-6600 | HFSinclair.com RE: - Boiler #10 - Boiler #l I 4. VOC compliance stack testing of the following emission source: - Boiler #l I This testing program is planned for April 7 - April 18,2025. A copy of the test protocol is enclosed. If you have any questions or need additional information, please call me at (801) 299-6625 or email at ft ravis. sm ith@.hfsinclair. com. F. Travis Smith Environmental Specialist Enclosure cc: E. Benson (r) File 2.4.4 K. Amold J. Barton Site Specific Test Plan HF Sinclair Woods Cross Refining, LLC 1070 West 500 South West Bountiful, UT 84087 Sources to be Tested: Multiple Sources Proposed Test Dates: April 7 - ll,14 - 18,2025 Project No. AST-2025-l4l 4 Prepared By Alliance Technical Group, LLC 3683 W 2270 S, Suite E West Valley City, UT 84120 pilt6rpe I I (;ill..ll(;r\l (rl1()ili)Site Specifrc Test Plan Test Program Summarv Regulatory Information Permit No. Source Information DAQE-AN10t230057-23 Source Name Refinery Gas Fired Process Heater Gas Oil Hydrocracking (GHC) Fractionator Charge Heater Gas Oil Hydrocracking (GHC) Fractionator Charge Heater Crude Unit Furnace No. 2 FFCU #2 Feed Heater Crude Unit Furnace No. I Boiler No. 5 Boiler No. 8 Boiler No. l0 Boiler No. I I Contact Information Source ID l2Hl 20H2 20H3 24Hr 25Hr 8H2 B-05 B-08 B-10 B-l I Target Parameters NOx NOx NOx, CO NOx, CO NOx, CO CO2, NOx, CO NOx NOx NOx NOx, CO, VOC Test Location HF Sinclair Woods Cross Refining, LLC 1070 West 500 South West Bountiful, UT 84087 Eric Benson eric.benson@hfsinclair.com (801) 299-6623 F. Travis Smith ftravis. smith@hfsinc lair.com (80t) 299-662s Test Company Alliance Technical Group, LLC 3683 W 2270 S, Suite E West Valley City, UT 84120 Project Manager Charles Horton charles. horton@alliancetg.com (3s2) 663-7568 Field Team Leader Alan Jensen alan j ensen@alliancetg. com (847) 220-3949 (subject to change) QA/QC Manager Kathleen Shonk katie. shonk@alliancetg.com (812) 4s2478s Test Plan/Report Coordinator Delaine Spangler delaine. spangler@alliancetg.com AST-2025-14r4 HF Sinclair - West Bountiful. UT Page i Site Speci/ic Test Plan Table of Contents TABLE OF CONTENTS l.l Emission Unit and Control Unit Descriptions............... ......... l-2 2.0 Summar of Test Program........ ......2-l 2.2 Process/Contol System Parameters to be Monitored and Recorded................. ........,.......2-l 2.3 Proposed Test Schedule .............2-l 3.1 U.S. EPA Reference Test Methods I and 2 - Sampling/Traverse Points and Volumetric Flow Rate ..... 3-l 3.2 U.S. EPA Reference Test Method 3,{ - Oxygen/Carbon Dioxide......... ...... 3-1 3.3 U.S. EPA Reference Test Method 4 - Moisture Content......... .................... 3-2 3.4 U.S. EPA Reference Test Method 7E - Nitrogen Oxides.......... .............,....3-2 3.5 U.S. EPA Reference Test Method l0 - Carbon Monoxide..... .....................3-2 3.6 U.S. EPA Reference Test Method 25A -Volatile Organic Compounds ....,.3-2 3.7 Quality Assurance/Quality Control - U.S. EPA Reference Test Methods 3A,78 and 10....................... 3-3 3.8 Quality Assurance/Quality Control - U.S. EPA Reference Test Method 25A........................................ 3-4 LIST OF TABLES Table 2- l : Program Outline and Tentative Test Schedule ...................... 2-2 AST-2025-1414 HF Sinclair - West Bountiful. UT Page ii pill6rpe Sile Specific Test Plan Introductiona ltl'.li(.11i (, It ( 1.0 Introduction Alliance Technical Group, LLC (Alliance) was retained by HF Sinclair Woods Cross Refining,LLC (HF Sinclair) to conduct compliance testing at the Woods Cross refinery in West Bountiful, Utah. Portions of the facility are subject to provisions of the Utah Department of Environmental Quality, Division of Air Quality (UDAQ) Permit No. DAQE- AN I 0 1230057-23. Testing will be conducted to determine the emission rate of nitrogen oxides (NOx) at the exhaust of Refinery Gas Fired Process Heater (l2Hl), Gas Oil Hydrocracking Fractionator Charge Heaters (20H2), Boiler No. 5 (B-05), Boiler No. 8 (B-08), and Boiler No. 10 (B- I 0). Testing will also determine the emissions rates of NOx and carbon monoxide (CO) at the exhaust of Gas Oil Hydrocracking Fractionator Charge Heaters (20H3), Crude Unit Furnace No. 2 (24H1), FFCU #2Feed Heater (25H1), Crude Unit Fumace No. I (8H2). Testing will also include determining the emission rate of NOx, CO, and volatile organic compounds (VOC) from the exhaust of Boiler No. I I (B-r l). This site-specific test plan (SSTP) has been prepared to address the notification and testing requirements ofthe UDAQ permit. AST-2025-t414 HF Sinclair - West Bountiful. UT Page l-l Site Specific Test Plan lnlroduclion Emission Unit and Control Unit Descriptions Unit ID Process Description Air Pollution Controls t2Hl NHDS Reactor Charge Fumace. 50.2 MMBtu,4rr process furnace, fired on plant gas NGULNB 20H2 Gas Oil Hydrocracker (GHC) Fractionator Charge Heater, 47.0 MMBtU/hr HHV, fired on plant gas, natural draft,4 burners, up-fired fumace. Stack temperature approximately 5 l0 to 650"F. Ultra-low NOx burners 20H3 Gas Oil Hydrocracker Charge Heater, 39.7 MMBtu/hr HHV, fired on plant gas, natural draft, 6 bumers (Next Generation, Ultra Low NOx), and up-fired furnace. Stack temperature approximately 646'F. Ultra-low NOx burners 24Hl Crude Unit No. 2 Furnace, 32.5 MMBtu/hr process fumace, fired on plant gas natural draft, 4 burners, and up-fired furnace. Stack temperature approximately 460'F. Ultra-low NOx burners 25Hl Fluidized Catalytic Cracking Unit (FCCU) #2 Feed Heater, 17.7 MMBtU/hr HHV, fired on plant gas, natural draft, 3 burners, and up-fired fumace. Stack temperature approximately 650"F. Ultra-low NOx burners 8H2 Process Heater, 99 MMBtuAr HHV, fired on plant gas. Stack temperature approximately 640 to 720oF. Ultra-low NOx burners Boiler No. 5 Steam boiler, 70.0 MMBtufrr, fired on plant gas SCR Boiler No. 8 Steam boiler, 92.7 MMBtu/hr HHV, fired on plant gas, forced draft, I burner, side-fired fi.rrnace, no air preheat. Stack temperature approximately 440 to 480'F. Low-NOx bumers and selective catalytic reduction using aqueous or anhydrous ammonia Boiler No. l0 Steam boiler, 89.3 MMBtU/hr HHV, fired on plant gas, forced draft, I burner, side-fired fumace, no air preheat. Stack temperature approximately 3 l0-500"F. Selective catalytic reduction using aqueous or anhydrous ammonia Boiler No. 1 I Steam boiler, 89.3 MMBtU/hr HHV, fired on plant gas, forced draft, I burner, side-fired furnace, no air preheat. Stack temperature approximately 3 l0-500'F. Low-NOx burners and selective catalytic reduction using aqueous or anhydrous ammonia AST-2025- l4 I 4 HF Sinclair - West Bountiful, UT Page l-2 pill6rpe Ti(. lll'.ttCAI (jln()Sile Specific Tesl Plan Inlroduction 1.2 Project Team Personnel planned to be involved in this project are identified in the following table. Table l-l: Project Team 1.3 SafetyRequirements Testing personnel will undergo site-specific safety training for all applicable areas upon arrival at the site. Alliance personnel will have current OSHA or MSHA safety training and be equipped with hard hats, safety glasses with side shields, steel-toed safety shoes, hearing protection, fire resistant clothing, and fall protection (including shock corded lanyards and full-body hamesses). Alliance personnel will conduct themselves in a manner consistent with Client and Alliance's safety policies. A Job Safety Analysis (JSA) will be completed daily by the Alliance Field Team Leader. HF Sinclair Personnel F. Travis Smith Regulatory Agency UDAQ Alliance Personnel Alan Jensen other field personnel assigned at time of testing event AsT-2025-1414 HF Sinclair - West Bountiful. UT Page l-3 Site SpeciJic Test Plan Summam ofTesl Proprams 2.0 Summary of Test Program To satisfy the requirements of the UDAQ permit, the facility will conduct a performance test program to determine the compliance status of Heaters 12H1,20H2,20H3,24H1,25H1,8H2, and BoilerNos. 8 - I l. 2.1 General Description All testing will be performed in accordance with specifications stipulated in U.S. EPA Reference Test Methods 3A, 78, 10, 19 and 25A. Table 2-l presents an outline and tentative schedule for the emissions testing program. The following is a summary of the test objectives. Testing will be performed to demonstrate compliance with the UDAQ permit. Emissions testing will be conducted on the exhaust of Heaters 12H1,20H2,20H3,24H1,25H1,8H2, and BoilerNos.8-ll. Performance testing will be conducted at the maximum normal operation load for each source. Each of the three (3) test runs will be approximately 60 minutes in duration for each source. 2.2 Process/Control System Parameters to be Monitored and Recorded Plant personnel will collect operational and parametric data at least once every l5 minutes during the testing. The following list identifies the measurements, observations and records that will be collected during the testing program: Calculated fuel gas flow rate - mscf/d or mscf/hr; Fuel gas GHV - Btu/scf; Heat Input - MMBtU/hr; Fuel Gas Analysis Ammonia flow rate (if the unit is equipped with SCR and if ammonia flow rate is monitored), Stack Oz 2.3 Proposed Test Schedule Table 2- I presents an outline and tentative schedule for the emissions testing program a a a a a a a a a a AST-2025-14 t4 HF Sinclair - West Bountiful, UT Page 2-l Fla Site Specif.c Test Plan Summary ofTest Programs Table 2-l: Program Outline and Tentative Test Schedule - Week I DAY I -April7,2025 Equipment Setup & Pretest QA/QC Checks, setup on Heater 20H2 4hr DAY2-April8,2025 Heater 20H2 Oz 3A 3 60 min l0 hr NOx 7E Mass Emission Factors l9 Heater 20H3 Oz 3A J 60 min NOx 7E CO l0 Mass Emission Factors l9 Setup on l2Hl DAY 3 - April9,2025 Heater l2Hl o:3A J 60 min l0 hr NOx 7E Mass Emission Factors l9 Setup on 8H2 DAY4-April 10,2025 Heater 8H2 Oz / COz 3A J 60 min l0 hr NOx 7E CO l0 Mass Emission Factors l9 Setup on B-l I DAY5-April 11,2025 B-l I Oz I COt 3A J 60 min l0 hr BWS 4 NOx 7E CO l0 VOC 25A Mass Emission Factors l9 AST-2025- l4 I 4 HF Sinclair - West Bountiful, UT Page 2-2 pJ/l6rpe '; 'rl, t;. .i : Table 2-2: Program Outline and Tentative Test Schedule - Week 2 Sile Specirtc Test Plan Summary of Test Programs ffi ffiffi DAY I -April 14,2025 B-5 Oz 3A I 60 min l0 hr NOx 7E CO t0 Mass Emission Factors l9 Setup on 24Hl DAY2-April 15,2025 Heater 24Hl Oz 3A J 60 min l0 hr NOx 7E CO l0 Mass Emission Factors l9 Heater 251 Oz 3A 5 60 min NOx 7E CO l0 Mass Emission Faclors l9 Setup on B-08 DAY4-April 17,2025 B-08 Oz 3A J 60 min l0 hr NOx 7E Mass Emission Factors l9 B-10 Oz 3A 5 60 minNOx7E Mass Emission Factors t9 DAY5-April 18,2025 Contingency Day AST-2025-14 l4 HF Sinclair - West Bountiful, UT Page 2-3 G Site SpeciJic Test Plan Sumnary ofTest Programs 2.4 Emlssion Llmits Emission limits for each pollutant are below. Table 2-2: Emission Limlts 2.5 Test Report The final test report must be submitted within 60 days of the completion of the performance test and will include the following information. o Introductioz - Brief discussion of project scope of work and activities. o Results and Discussion - A summary of test results and process/control system operational data with comparison to regulatory requirements or vendor guarantees along with a description of process conditions and,/or testing deviations that may have affected the testing results. o Methodologt - A description of the sampling and analytical methodologies. o Sample Calculations - Example calculations for each target parameter. o Field Dala - Copies of actual handwritten or electronic field data sheets. o Quality Conlrol Data - Copies of all instrument calibration data and/or calibration gas certificates. t Process Operating/Conffol System Data - Process operating and conhol system data (as provided by HF Sinclair) to support the test results. NOx; 0.10 lbfir,IMBtu NOx: 0.04 IbA,IMBtu NOx: 0.04 lb/I{MBtu CO:0.04lbA,IMBtu NOx: 0.04 lbA,IMBtu CO: 0.04 lb/]vlMBtu NOx:0.04lbA{MBtu CO: 0.04 lbA,IMBtu NOx: 0.02lbA,IMBtu NOx: 0.02 lb[r,IMBtu CO: 0.037 lbA,IMBtu VOC: CO: 0.004 lbA,IMBtu AST-2025-1414 HF Sinclair- West Bountiful, UT Page24 Parameter U.S. EPA Reference Test Methods Notes/Remarks Volurnetric Flow Rate t&2 Full Velocity Travcrscs Oxygen / Carbon Dioxide 3A Instrunrental Analysis Moisture Contcnt 4 Gravintetric Analysis Nitrogen Oxidcs 7E lnstrumental Analysis Carbon Monoxide l0 Instrumental Analysis Mass Emission Factors t9 Fucl Faclors/Heal Inputs Volatile Organic Compounds 25A Instrumental Analysis Gas Dilution Systenr Certification 205 Allalpe Site Spctilic Test Plul Testing lfuthodologv 3.0 Testing Methodology This scction provides a description of the sanrpling and analytical proccdures for cach tcst nrethod that will bc employed during thc tcst program. All cquipment, procedurcs and quality assurancc measurcs neccssary for the cornpletion of thc test program llrcct or excccd the spccificatrons oIeach rclevant tcst method. The emission testing program will be conductcd in accordancc with the test mcthods listed in Table 3-1. Table 3-l: Source Testing Methodology All stack diamcters. depths, widths, upstrcam and downstreanr disturbance distances and nipple lcngths will bc nreasured on site with an EPA Method I verillcation nleasuren)ent provided by the Field Team Leader. These nleasurements will be included in the test report. 3.1 U.S. EPA Refercnce Tcst Methods I and 2 - Sampling/Travcrsc Points and Volumetric Flow Rate Thc sampling location and nunrbcr of traverse (sampling) points will bc selected in accordancc with U.S. EPA Rcfcrence Test Method l. To dcterminc thc minimum number of traversc points. the upstrcam and downstreanr distances will be equated into equivalent dianreters and compared to Figure I -l (tbr isokinetic sanrpling) and/or Figure l-2 (nreasuring velocity alone) in U.S. EPA Referencc Test Mcthod l. Full velocity lravcrses will be conducted in accordancc with U.S. EPA Rclcrence Test Method 2 to determine thc average stack gas velocity pressure. static pressure and temperature. The velocity and static pressure measurement systor will consist ol a pitot tubc and inclined manometer. Thc stack gas tcmperature will bc measured with a K- typc thcmrocouplc and pyrometer. 3.2 U.S. EPA Reference Test Method 3A - Oxygen/Carbon Dioxide Thc oxygen (Or) and carbon dioxidc (CO2) tcsting will be conducted in accordancc with U.S. EPA Refercnce Tcst Method 3A. Data will be collected online and reported in one-nrinute averages. The sampling system will consist of a stainless stcol probc, Tcflon samplc linc(s), gas condilioning syslem and the identified gas analyzcr. The gas conditioning system will be a non-contact condenser used to remove moisture fiom the stack gas. If an unheated Tcflon samplc linc is uscd. then a portable non-contacl condcnscr will be placed in thc systenr dircctly aflcr thc probc. Otherwise, a heated Tellon sample line will be used. The quality control measures are described in Section 3.7. AST-2025-t4I4 I IF Sinclair - West Bountifirl. UT Page 3-l F::AIfatpE)Site Specific Test Plan Testing Methodologl' 3.3 U.S. EPA Reference Test Method 4 - Moisture Content The stack gas moisture content u,ill be determined in accordance with U.S. EPA Reference Test Method 4. The gas conditioning train will consist of a series of chilled impingers. Prior to testing, each impinger will be filled with a known quantity of water or silica gel. Each impinger will be analyzed gravimetrically before and afler each test run on the same analytical balance to determine the amount of moisture condensed. 3.4 U.S. EPA Reference Test Method 7E - Nitrogen Oxides The nitrogen oxides (NOx) testing will be conducted in accordance with U.S. EPA Reference Test Method 78. Data will be collected online and reported in one-minute averages. The sampling system will consist of a stainless steel probe, Teflon sample line(s), gas conditioning system and the identified gas analyzer. The gas conditioning system will be a non-contact condenser used to remove moisture from the stack gas. If an unheated Teflon sample line is used, then a portable non-contact condenser will be placed in the system directly after the probe. Otherwise, a heated Teflon sample line will be used. The quality control measures are described in Section 3.8. 3.5 U.S. EPA Reference Test Method l0 - Carbon Monoxide The carbon monoxide (CO) testing will be conducted in accordance with U.S. EPA Reference Test Method 10. Data will be collected online and reported in one-minute averages. The sampling system will consist of a stainless steel probe, Teflon sample line(s), gas conditioning system, and the identified gas analyzer. The gas conditioning system will be a non-contact condenser used to remove moisture from the gas. If an unheated Teflon sample line is used, then a portable non-contact condenser will be placed in the system directly after the probe. C)therwise, a heated Teflon sample line will be used. The quality control measures are described in Section 3.8. 3.6 U.S. EPA Reference Test Method 19 - Mass Emission Factors Fuel gas samples will be collected by HollyFrontier in stainless steel canisters from a sample tap in the fuel gas supply to the unit being tested. These samples will be analyzed for hydrocarbons and diluents by gas chromatography with flame ionization and thermal conductivity detection. The fuel gas samples will be analyzed by HollyFrontier according to standard operating procedures (e.g., FUELGAS5.M "RGA for Phillips Refining at Wood's Cross, UT - gas method", 712912014). Carbon, hydrogen, oxygen and nitrogen contenl and higher (gross) heating value will be calculated based on fuel gas composition, for use in determining the dry oxygen-based "F factor" (Fa) according to EPA Method 19. 3.7 U.S. EPA Reference Test Method 25A -Volatile Organic Compounds The volatile organic compounds (VOC) testing will be conducted in accordance with U.S. EPA Reference Test Method 25A. Datawill becollectedonlineandreportedinone-minuteaverages. Thesamplingsystemwillconsistofastainless steel probe, heated Teflon sample line(s) and the identified gas analyzer. The quality control measures are described in Section 3.9. 3.8 U.S. EPA Reference Test Method 205 - Gas Dilution System Certification A calibration gas dilution system field check will be conducted in accordance with U.S. EPA Reference Method 205. An initial three (3) point calibration will be conducted, using individual Protocol I gases, on the analyzer used to complete the dilution system field check. Multiple dilution rates and total gas flow rates will be utilized to force the dilution system to perfornr two dilutions on each mass flow controller. The diluted calibration gases will be sent directly to the analyzer, and the analyzer response will be recorded in an electronic field data sheet. A mid-level supply gas, with a cylinder concentration within l0% of one of the gas divider settings described above, will be introduced directly to the analyzer, and the analyzer response recorded in an electronic field data sheet. The cylinder concentration and the analyzer response must agree within 27o. These steps will be repeated three (3) times. The AST-2025-14 l4 Ill" Sinclair- West Bountitul. UT Page 3-2 r--a?--AliatpE)Site Specirtc Test Plan Testing Methodologl' average analyzer response must agree within2%o of the predicted gas concentration. No single injection shall differ more than Zoh from the average instrument response for that dilution. 3.9 Quality Assurance/Quality Control - U.S. EPA Reference Test Methods 3A, 7E and l0 Cylinder calibration gases will meet EPA Protocol I (+l- 2%) standards. Copies of all calibration gas certificates will be included in the Quality Assurance/Quality Control Appendix of the report. Low Level gas will be introduced directly to the analyzer. After adjusting the analyzer to the Low-Level gas concentration and once the analyzer reading is stable, the analyzer value will be recorded. This process will be repeated for the High-Level gas. For the Calibration Error Test, Low, Mid, and High-Level calibration gases will be sequentially introduced directly to the analyzer. The Calibration Error for each gas must be within 2.0 percent of the Calibration Span or 0.5 ppmvl%, absolute difference. High or Mid-Level gas (whichever is closer to the stack gas concentration) will be introduced at the probe and the time requircd for the analyzer reading to reach 95 percent or 0.5 ppml%o (whichever was less restrictive) of the gas concenffation will be recorded. The analyzer reading will be observed until it reaches a stable value, and this value will be recorded. Next, Low-Level gas will be introduced at the probe and the time required for the analyzer reading to decrease to a value within 5.0 percent or 0.5 ppm/% (whichever was less restrictive) will be recorded. If the Low- Level gas is zero gas, the acceptable response must be 5.0 percent of the upscale gas concentration or 0.5 ppmloh (whichever was less restrictive). The analyzer reading will be observed until it reaches a stable value, and this value will be recorded. The measurement system response time and initial system bias will be determined from these data. The System Bias for each gas must be within 5.0 percent of the Calibration Span or 0.5 ppmv/% absolute difference. High or Mid-Level gas (whichever is closer to the stack gas concentration) will be introduced at the probe. After the analyzer response is stable, the value will be recorded. Next, Low-Level gas will be introduced at the probe, and the analyzer value will be recorded once it reaches a stable response. The System Bias for each gas must be within 5.0 percent of the Calibration Span or 0.5 ppmv/% absolute difference or the data is invalidated, and the Calibration Error Test and System Bias must be repeated. The Drift between pre- and post-run System Bias must be within 3 percent of the Calibration Span or 0.5 ppmv/% absolute difference or the Calibration Error Test and System Bias must be repeated. To determine the number of sampling points, a gas stratification check will be conducted prior to initiating testing. The pollutant concentrations will be measured at twelve traverse points (as described in Method I ) or three points (16.7,50.0 and 83.3 percent of the measurement line). Each traverse point will be sampled for a minimum of twice the system response time. If the pof lutant concentration at each traverse point does not differ more than 5o/o or 0.5 ppn/O.3% (whichever is less restrictive) of the average pollutant concentration, then single point sampling will be conducted during the test runs. If the pollutant concentration does not meet these specifications but differs less than llYo or 1.0 ppm10.5% from the average concentration, then three (3) point sampling will be conducted (stacks less than 7.8 feet in diameter - 16.7, 50.0 and 83.3 percent of the measureme nt line; stacks greater than 7.8 feet in diameter - 0.4, I .0, and 2.0 meters from the stack wall). If thc pollutant concentration differs by more than l0% or 1.0 ppm/0.5oh from the average concentration, then sampling will be conducted at a minimum of twelve ( I 2) traverse points. Copies of stratification check data will be included in the Quality AssuranceiQuality Control Appendix of the report. AST-2025- l4 I 4 HF Sinclair - West Bountiful. [-IT Page 3-3 Site Specirtc Te.sr PIan Testing Methodology An NOz - NO converter check will be performed on the analyzer prior to initiating testing or at the completion of testing. An approximately 50 ppm nitrogen dioxide cylinder gas will be introduced directly to the NOx analyzer and the instrument response will be recorded in an electronic data sheet. The instrumenl response must be within +/- l0 percent of the cylinder concentration. A Data Acquisition System with battery backup will be used to record the instrument response in one (l) minute averages. The data will be continuously stored as a *.CSV file in Excel format on the hard drive of a computer. At the completion of testing, the data will also be saved to the Alliance server. All data will be reviewed by the Field Team Leader before leaving the facility. Once arriving at Alliance's office, all written and electronic data will be relinquished to the report coordinator and then a final review will be performed by the Project Manager. 3.10 Quality Assurance/Quality Control - U.S. EPA Reference Test Method 25A Cylinder calibration gases will meet EPA Protocol I (+l- 2%\ standards. Copies of all calibration gas certificates will be included in the Quality Assurance/Quality Control Appendix of the report. Within two (2) hours prior to testing, zero gas will be introduced through the sampling system to the analyzer. After adjusting the analyzer to the Zero gas concentration and once the analyzer reading is stable, the analyzer value will be recorded. This process will be repeated for the High-Level gas, and the time required for the analyzer reading to reach 95 percent of the gas concentration will be recorded to determine the response time. Next, Low and Mid-Level gases will be introduced through the sampling system to the analyzer, and the response will be recorded when it is stable. All values must be less than +/- 5 percent of the calibration gas concentrations. Mid-Level gas will be introduced through the sampling system. After the analyzer response is stable, the value will be recorded. Next, Zero gas will be introduced through the sampling system, and the analyzer value recorded once it reaches a stable response. The Analyzer Drift must be less than +/- 3 percent of the span value. A Data Acquisition System with battery backup will be used to record the instrument response in one (l) minute averages. The data will be continuously stored as a *.CSV file in Excel format on the hard drive of a computer. At the completion of testing, the data will also be saved to the Alliance server. All data will be reviewed by the Field Team Leader before leaving the facility. Once arriving at Alliance's office, all written and electronic data will be relinquished to the report coordinator and then a final review will be performed by the Project Manager. AST-2025- l4 I 4 HF Sinclair - West Bountiful. UT Page 3-4 F.}--Allalpe Site Specrfic Te.st Plan Quality Assurance Program 4.0 Quality Assurance Program Alliance follows the procedures outlined in the Quality Assurance/Quality Control Management Plan to ensure the continuous production of useful and valid data throughout the course of this test program. The QC checks and procedures described in this section represent an integral parl of the overall sampling and analytical scheme. Adherence to prescribed procedures is quite often the most applicable QC check. 4.1 Equipment Field test equipment is assigned a unique, permanent identification number. Prior to mobilizing for the test program, equipment is inspected before being packed to detect equipment problems prior to arriving on site. This minimizes lost time on the job site due to equipment failure. Occasional equipment failure in the field is unavoidable despite the most rigorous inspection and maintenance procedures. Therefore, replacements for critical equipment or components are brought to the job site. Equipment retuming from the field is inspected before it is retumed to storage. During the course of these inspections, items are cleaned, repaired, reconditioned and recalibrated where necessary. Calibrations are conducted in a manner, and at a frequency, which meets or exceeds U.S. EPA specifications. The calibration procedures outlined in the U.S. EPA Methods, and those recommended within the Quality Assurance Handbook for Air Pollution Measurement Systems: Volume III (EPA-600/R-94/038c, September 1994) are utilized. When these methods are inapplicable, methods such as those prescribed by the American Society for Testing and Materials (ASTM) or other nationally recognized agency may be used. Data obtained during calibrations is checked for completeness and accuracy. Copies of calibration forms are included in the report. The following sections elaborate on the calibration procedures followed by Alliance for these items of equipment. Dry Gas Meter and Orifice. A full meter calibration using critical orifices as the calibration standard is conducted at least semi-annually, more frequently if required. The meter calibration procedure determines the meter correction factor (Y) and the meter's orifice pressure differential (AH@). Alliance uses approved Alternative Method 009 as a post-test calibration check to ensure that the correction factor has not changed more than 57o since the last lull meter calibration. This check is performed after each test series. Pitot Tubes and Manometers. Type-S pitot rubes that meet the geometric criteria required by U.S. EPA Reference Test Method 2 are assigned a coefficient of 0.84 unless a specific coefficient has been determined from a wind tunnel calibration. If a specific coefficient from a wind tunnel calibration has been obtained that coefficient will be used in lieu of 0.84. Standard pitot tubes that meet the geometric criteria required by U.S. EPA Reference Test Method 2 are assigned a coefficient of 0.99. Any pitot tubes not meeting the appropriate geometric criteria are discarded and replaced. Manometers are verified to be level and zeroed prior to each test run and do not require further calibration. Temperature Measuring Devices. All thermocouple sensors mounted in Dry Gas Meter Consoles are calibrated semi-annually with a NIST-traceable thermocouple calibrator (temperature simulator) and verified during field use using a second NlST-traceable meter. NlST-traceable thermocouple calibrators are calibrated annually by an outside laboratory. Nozzles. Nozzles are measured three (3) times prior to initiating sampling with a caliper. The maximum difference between any two (2) dimensions is 0.004 in. Digital Calipers. Calipers are calibrated annually by Alliance by using gage blocks that are calibrated annually by an outside laboratory. AST'-2025- 14 t4 HF Sinclair Wcst Bountiful, UT Page 4- I Site Specrrtc Te-tt Plan Quality Assurance Program Barometer. The barometric pressure is obtained from a nationally recognized agency or a calibrated barometer. Calibrated barometers are checked prior to each field trip against a mercury barometer. The barometer is acceptable if the values agree within * 2 percent absolute. Barometers not meeting this requirement are adjusted or taken out ofservice. Balances and Weishts. Balances are calibrated annually by an outside laboratory. A functional check is conducted on the balance each day it is used in the field using a calibration weight. Weights are re-certified every fwo (2) years by an outside laboratory or internally. If conducted intemally, they are weighed on a NIST traceable balance. lf the weight does not meet the expected criteria, they are replaced. Other Equioment. A mass flow controller calibration is conducted on each Environics system annually following the procedures in the Manufacturer's Operation manual. A methane/ethane penetration factor check is conducted on the total hydrocarbon analyzers equipped with non-methane cutters every six (6) months following the procedures in 40 CFR 60, Subpart JJJJ. Other equipment such as probes, umbilical lines, cold boxes, etc. are routinely maintained and inspected to ensure that they are in good working order. They are repaired or replaced as needed. 4.2 Field Sampling Field sampling will be done in accordance with the Standard Operating Procedures (SOP) for the applicable test method(s). General QC measures for the test program include: . Cleaned glassware and sample train components will be sealed until assembly. a a a a a a a Sample trains will be leak checked before and after each test run. Appropriate probe, filter and impinger temperatures will be maintained. The sampling port will be sealed to prevent air from leaking from the port. Dry gas meter, AP, AH, temperature and pump vacuum data will be recorded during each sample point. An isokinetic sampling rate of 90-l l0% will be maintained, as applicable. All raw data will be maintained in an organized manner. All raw data will be reviewed on a daily basis for completeness and acceptability. * .'i-ft A;:l i)t rr,^J?ilr1[.NTOF - I, NV i IiCNi.lt: NTAL QI JALITYi ---t I I I t_ L',i,215;;651 OF AtR OUAI tTy rt , I ^Ilr: iI AST-2025 HF Sinclair West Bountiful. IJT Pagc 4-2