DAQ-2025-001760

1

DAQC-316-25
Site ID 10335 (B5)

MEMORANDUM

TO: CEM FILE – TESORO REFINING AND MARKETING COMPANY, LLC – Salt
Lake City Refinery

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Rob Leishman, Environmental Scientist

DATE: March 26, 2025

SUBJECT: Sources: V-917 Fuel Gas Drum, North and South Flare
Contact: Rheannon Schaefer – 801-367-8102
Location: 474 West 900 North, Salt Lake City, Salt Lake County, UT
Test Contractor: Alliance Technical Group, LLC
FRS ID#: UT0000004903500004
Permit/AO#: Approval Order (AO) DAQE-AN103350075-18, dated
January 11, 2018
Subject: Review of RA/PST Protocol dated March 14, 2025

On March 14, 2025, DAQ received a protocol for a RA/PST (relative accuracy/performance specification
test) of the Tesoro V-917 Drum, and North and South Flares in Salt Lake City, UT. Testing will be
performed on August 5-7, 2025, to determine the relative accuracy of the H2S monitoring systems.

PROTOCOL CONDITIONS:

1. RM 11 used to determine H2S content of fuel gas in petroleum refineries: OK

DEVIATIONS: No deviations noted.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: Send attached protocol review and test date confirmation notice.

ATTACHMENT: Tesoro Refining and Marketing Company’s RATA Protocol

1 8 2
^i\w/.
salt Lake city Refinery
474 west 900 North
salt Lake city, uT 84103-1494
Tesoro Refining &
Marketing Company LLC
A subsidiary of Marathon Petrolsum Corporation
March 14,2025
Mr. Paul Morris
Division of Air Quality
Department of Environmental Quality
195 North 1950 West
P.O. Box 144820
Salt Lake City, UT 84114-4820
Tesoro Relining and Marketing Company's
Salt Lake City Refinery
FCCU WGS Coke Burn Emissions Test Protocol
Fuel Gas Y-917 HzS RATA Protocol
North & South Flare HzS RATAs Protocol
Dear Mr. Morris:
Enclosed please find the Fluid Catalytic Cracking Unit (FCCU) Wet Gas Scrubber (WGS)
Method 58 Particulate Matter Test, the Fuel Gas (V-917) HzS Relative Accuracy Test Audit
(RATA), and the North & South Flare HzS Relative Accuracy Test Audits (RATAs) Protocols
scheduled for the weeks of May 20,2025, and August 5,2025.
The purpose of the Fluid Catalytic Cracking Unit Wet Gas Scrubber (WGS) Method 58
Partiiulate Matter Test is to demonstrate the compliance status of the source with respect to
NSPS Subpart Ja PM emission standard of I pound per 1000 pounds coke burn off. The PM test
results will be used to determine the new operational parameters for the WGS (differential
pressure and liquid-to-gas ratio) and the ESP (primary power and secondary current).
Please contact me at [phone] if you have any questions.
Sincerely,
Environmental Specialist
Enclosure
ENVIRONMENTAL QUALITY
NI\/ISION OF AIR OTJALITY
Rheannon SchaefEr
rrareAI
TECHNICAL GROUP
Site Specific Test Plan
Tesoro Refining and Marketing Company
Salt Lake City Refinery
474 West 900 North
Salt Lake City, UT 84103
Sources to be Tested: Fuel Gas Y-9l7,North & South
Flares
Proposed Test Dates: August 5 - 7,2025
Proj ect No. AST- 2025 - t L 42
Prepared By
Alliance Technical Group, LLC
3683 W 2270 S, Suite E
West Valley City, LIf 84120
L-l ,1i.i r)Ff)Atl lrlFlll OF
t jvlL,J l\.1Vr:NTAL Q t JA LITYI
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Hr,rrr.( lx-, [i rfr riz{ [
, '/i :llC,ll OF Alll Ot!ALITY
Site Specific Test Plan
Test Program Summary
Resulatory Information
Permit No.
Regulatory Citations
Source Information
DAQE-ANl033s007s-18
40 CFR 60, Appendix B, Performance Specification 7
40 CFR 60, Subpart Ja
Source Natne
Y-917 Fuel Gas Line
North Flare
South Flare
Contact Information
Target Parameter
HzS
HzS
HzS
Test Location
Tesoro Refining and Marketing Company
Salt Lake City Refinery
474 West 900 North
Salt Lake City, UT 84103
Facility Contact
Rheannon Schaefer
Rschaefer@marathonpetoleum. com
(801) 367-8r02
Test Company
Alliance Technical Group, LLC
3683 W 22705, Suite E
WestValley City, UT 84120
Project Manager
Charles Horton
charles.horton@lliancetg. com
(3s2) 663-7s68
Field Team Leader
Alan Jensen
alan [e-mail]
(2s6)221-94s7
(subject to change)
QA/QC Manager
Kathleen Shonk
[e-mail]
(8t2) 4s2478s
Test Plan/Report Coordinator
Delaine Spangler
delaine. [e-mail]
AST-2025-l 142 MPC - Salt Lake City, UT Page i
pul6lpe
TECI-] NICAL GROUP Site Specilc Test Plan
Table of Contents
TABLE OF CONTENTS
2.0 Summary of Test Program .................2-l
2.2 Process/Control System Parameters to be Monitored and Recorded ................ 2-l
3.1 U.S. EPA Reference Test Method I I - Hydrogen Sulfide...... ..... 3-1
LIST OF TABLES
Table 2-l: Program Outline and Tentative Test Schedu1e................... ......2-l
Table2-2: RelativeAccuracyRequirementsandLimits... ........................2-2
LIST OF APPEIIDICES
Appendix A Example Field Data Sheets
MPC - Salt L,akc City, UTAST-2025-1 142
pul6lpe
TECI]NICi\L GNOUF)
Site Specific Test Plan
Intrcduction
1.0 Introduction
Alliance Technical Group, LLC (Altiance) was retained by Marathon Petroleum Corporation (MPC) to conduct
performance specification (PS) testing at the Tesoro Refining and Marketing Company (Tesoro) Salt Lake City,
Utah refinery. Portions of the facility are subject to provisions of the 40 CFR 60, Appendix B, PS 7, 40 CFR 60,
Subpart Ja and the Utah Department of Environmental Quality, Division of Air Quality (UDAQ) Pennit No. DAQE-
AN103350075-18. Testing will include conducting a relative accuracy test audit (RATA) to determine the relative
accgracy (RA) of the hydrogen sulfide (HzS) continuous emissions monitoring system (CEMS) serving the North
and South Flares and the V-917 Fuel Gas Drum.
This site-specific test plan (SSTP) has been prepared to address the notification and testing requirements of the
UDAQ permit.
1.1 CEMS Descriptions
Parameter:
Make:
Model:
Serial No.:
Span:
North Flare
Pollutant
HzS
Siemens
Maxum II TCD
30048895441610
0-300 ppm
South Flare
Pollutant
HzS
Siemens
Maxum II TCD
30048895441060
0-300 ppm
Fuel Gas Drum
Pollutant
HzS
Siemens
Maxum II TCD
300488s3581060
0-300 ppm
1.2 Project Team
Personnel planned to be involved in this project are identified in the following table'
Table l-1: ProjectTeam
1.3 Sefety Requirements
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 haining and be equipped with an HzS monitor, 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 harnesses). Alliance personnel will conduct themselves i1 3 6anns1
consistent with Client and Alliance's safety policies.
A Job Safety Analysis (JSA) will be completed daily by the Alliance Field Team Leader.
MPC Personnel Rheannon Schaefer
Regulatory Agency UDAQ
Alliance Personnel Alan Jensen
other field personnel assigned at time of testing event
AST-2025-l 142 MPC - Salt Lake City, UT Page l-1
AI Site Specific Test Plan
Summary ofTest Programs
2.0 Summary of Test Program
To satisff the requirements of the UDAQ permit, the facility will conduct a performance test program to determine
the compliance status of the Fuel Gas Drum, and the North and South Flare CEMS.
2.1 General Description
All testing will be performed in accordance with specifications stipulated in U.S. EPA Reference Test Method ll.
Table 2-l presents an outline and tentative schedule for the emissions testing program. The following is a summary
ofthe test objectives.
Testing will be performed to demonstrate compliance with the UDAQ permit and 40 CFR 60, Appendix B,
PS 7 and Subpart Ja.
Emissions testing will be conducted on the exhausts of the V-917 Fuel Gas Drum and the North and South
Flares.
Testing will be conducted while each source is operating at greater than 50% of the maximum normal load.
Each of the 9-12 test runs will be approximately 3O-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:
o CEMS Data
2.3 Proposed Test Schedule
Table 2-l presents an outline and tentative schedule for the emissions testing program
Table 2-l: Program Outline and Tentative Test Schedule
Fla
a
a
Testing Locetion Paremeter US EPA Method No. ofRuns Run Duration EsL Onsite
Time
DAY I -August 4,2025
Equipment Setup & Pretest QA/QC Checks 6hr
DAY2-August 5,2025
North Flare HzS 1l 9-12 30 min l0-12 hr
DAY3-August6,2025
South Flare HzS u 9-t2 30 min l0-12 hr
DAY4-August7,2025
Fuel Gas Line V-917 H:S 1l 9-t2 30 min 8hr
DAY5-August8,2025
Contingency Day (if needed)
MPC - Salt Lake City, UT
Siu Specffrc Test Plan
Sumtury of Tes Prcgrams
2.4 Emission I.lmlts
Emission limig for each pollutant are below.
Teble 2-2: Relative Accurecy Requlrements and Llmits
60, Appendix B, PS 7
and Subpart Ja162 ppmvd (3 hr average)520% of RM or < l0% of AS
60, Appendix B, PS 7162 ppmvd (3 hr average)-20 % of RM or <10 % of ASFuel Gas
Line V-917
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 Introductzbz - Brief discussion of project scope of work and activities.
o Results and Discussion - A summary of test results and process/contol 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 rezults.
o Methodolog - Adescription of the sampling and analytical methodologies.
. Sample Calcalatiotts - Example calculations for each talget parameter.
o Field Data - Copies of actual handwritten or electonic field data sheets.
t euatity Control Data- Copies of all instnrment calibration data and/or calibration gas certificates.
. process Operating/Control System Data -Process operating and contol system data (as provided by MPC)
to support the test results.
AST-2025-1142 MPC - Salt Lakc City, UT Page2-2
AI Site Specific Test Plan
Testing Methodology
3.0 Testing Methodology
This section provides a description of the sampling and analytical procedures for each test method that will be
employed during the test program. All equipment, procedures and quality assurance measrues necessary for the
completion of the test program meet or exceed the specifications of each relevant test method. The emission testing
program will be conducted in accordance with the test methods listed in Table 3-1.
Table 3-1: Source Testing Methodology
All stack diameters, depths, widths, upstream and downstream disturbance distances and nipple lengths will be
measured on site with a verification measurement provided by the Field Team Leader.
3.1 U.S. EPA Reference Test Method 1l - Hydrogen Sulfide
The hydrogen sulfide (HzS) testing will be conducted in accordance with U.S. EPA Reference Test Method I l. The
complete sampling system will consist of a Teflon probe, five (5) midget impingers, dry gas meter, and pump. The
first impinger will contain 15 mL of hydrogen peroxide (HrOz), the second impinger will be empty and the third,
fourth and fifth impingers will contain 15 mL of cadmium sulfate (CdSOr). Before and after each test run, the
sampling system will be leak checked.
Following each test run, the sampling train will be connected to a charcoal tube and the system will be purged with
ambient air for l5 minutes to ensure that all HzS is removed from the HzOz The contents of the first impinger will
be discarded. An acidified iodine (I2) solution will be added to each impinger and these contents will be transferred
to an iodine flask. The sample analysis will be performed onsite by titrating the sample with 0.01 N sodium
thiosulfate until the solution turned a light yellow color. At this point four (4) mL of starch indicator solution will
be added to the sample and will be repeated until the sample retumed to a colorless state. The titrant volumes for the
endpoints will be recorded and used in the emission calculations.
The relative accruacy of the HzS CEMS will be determined based on procedures found in 40 CFR 60, Performance
Specif,rcation 7
F
TA
Paremeter U.S. EPA Reference
Test Methods Notes/Itemarks
Hydrogen Sulfide ll Constant Rate Sampling
AST-2025-1 142 MPC - Salt Lake City, UT Page 3-1
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TICIlI.JICAL (]NOUP
4.0 QualitY Assurance Program
Alliance follows the procedures outlined in the Quality Assurance/Quality contol 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 part of the overall sampling and analytical scheme'
Adherence to prescribed procedures is quite ofte'n the most applicable QC check.
4.1 Equipment
Field test equipment is assiped a unique, permanent identification number. Prior to mobilizing for the test
progpm, equipment is inspected before being packed to detect equipment problems prior to aniving 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 returning from the field is inspected before it is
returned 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-600iR-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'
o Barometer. The barometric pressure is obtained from a nationally recogpized 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 of service'
o Other Equipment. A mass flow contoller calibration is conducted on each Environics system annually
following the procedures in the Manufacturer's Operation manual. 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:
o The sampling port will be sealed to prevent air from leaking from the port.
o All raw data will be maintained in an organized manner'
. All raw data will be reviewed on a daily basis for completeness and acceptability.
AST-2025-1r42 MPC - Salt L,ake CitY, UT Page 4-1
H2S Summary
Location: -
Source: -
Project No.: -
Run
No.Dste
Time Reference Method
H2S
ppmvd
CEMS
H2S
ppmvd
Averrge
Difference
ppmvdStertEnd
I
2
3
4
5
6
7
8
9
l0
ll
l2
Average
Standard Deviation (Sd)
Applicable Source Standard (AS)162
Confidence Coeflicient (CC)
Relative Accuracy @A)
Acceptability Criteria - Mean Reference Method 320Vo
Performance Specification Methoc PS 7 (RM ls)
Conlidence Coeflicient, CC
CC=
where,
h.qzs
n
sd
CC
mean difference
b.czs
n
Sd
RM
RA
#.rrl
#N/A
Relative Accuracy, RA
* ='-*;;x[*'''1.,,.
where,
= degrees offreedom
= number of runs selected for calculating the RA
= standard deviation ofdifference
= confidence coefficient
= average difference of Reference Method and CEMS
: degrees offreedom: number of runs selected for calculating the RA
= standard deviation ofdifference
= reference method
= relative accuracy
#N/A
9F
gEa6
IIeEacIU
HO
0zoo!r
co6
6!
ta€lau,xcEA9AEHH
aotQ
Run 1 Data
Perameter Irrs
Uncorrected Run Average (C*J
Corrected Run Averege (Corr)
QA/QC
Locrdon: -
Sourcc: --
Prolect No.: -
Devlce GC-FPD
Meke
Model
SAl
Compound Bottle ID Concentration Mol.hvt.
H2S 34.08
Cat QA
LoadoD -Socc. -
PreJGctNc -Ddc:
TID:
E2S EtLlndcrubndoDstrilhd cm(ppu)Mtdlfldcdtbrdost Ddrd cmGnu)If,Id.l Cdlbndon st0drd cole Gpr)
Iai.dior xr AC Yoiatia XT tc Ydrlatior RT AC YEId ton
Mu
Recovery-Drift QA
Locetion: --
Source: --
Project No.: --
GC Drift (Using H2S Gas)
Pre-Test Post-Test
Datr Dett
Timr Timr
Injection #Measured Concentration (ppm)94 Yaiation Measured Concenhation (ppm)% Variation %Dnfr
I
2
3
Mean
Pre Test System Recovery (Using HrS Gas)
Datt
Timr
Iniection #Measured Concentration (ppm)ok Yaiation Gas Concentration 7o Recoverv
1
2
3
Mean
Post Test System Recovery (Using HrS Gas)
Detr
Time
Iniection #Measured Concentration (oom)'l Yaiation Gas Concentration o/o Recoverv
I
2
3
Mean
Correction Factor I -
Example Calculations
Corrected Concentration, PPmvd
Crrs = Coo xRF
where,
Coas
RF
Cnzs
: average H2S concentration observed during test, ppmvd
: system recovery correction factor, unitless
: average H2S concentation during test, ppmvd