DAQ-2025-001773

1

DAQC-309-25
Site ID 10122 (B5)

MEMORANDUM

TO: CEM FILE – BIG WEST OIL

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Rob Leishman, Environmental Scientist

DATE: March 24, 2025

SUBJECT: Source: Sulfur Recovery Unit (SRU), Milli-Second Catalytic Cracker
Unit (MSCC), Amine Plant, South and West Flares
Contact: Brady Miller – 385-324-1275
Faithe Schwartzengraber – 801-296-7763
Location: 333 West Center Street, North Salt Lake, Davis County, UT
Test Contractor: Erthwrks, Inc.
FRS ID#: UT0000004901100008
Permit/AO#: AO DAQE-AN0122066-15 dated May 18, 2015
Subject: Review of RA/PST Protocol dated March 17, 2025
On March 20, 2025, Utah Division of Air Quality (DAQ) received a protocol by mail for a RA/PST
(relative accuracy/performance specification test) of the Big West Oil SRU, MSCC, Amine Plant, South
and West flares in North Salt Lake, Utah. Testing will be performed on May 6-8, 2025, to determine the
relative accuracy of the NOX, CO, CO2, H2S, O2, and SO2 monitoring systems.

PROTOCOL CONDITIONS:

1. RM 1 used to determine sample velocity traverses: OK
2. RM 3A used to determine dry molecular weight of the gas stream: OK
3. RM 4 used to determine moisture content: OK
4. RM 6C used to determine SO2 emissions: OK
5. RM 7E used to determine NOX concentrations of emissions: OK
6. RM 10 used to determine CO concentrations of emissions: OK
7. RM 15 to determine total H2S concentration from stationary sources by GC/FPD: OK

DEVIATIONS: No deviations were noted.

CONCLUSION: The protocol appears to be acceptable.

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

1 8 2
333 W. Center Street . North Salt Lake Utah 84054 . 80L.296.7700. www.bigwestoil.com
March 17,2025
CERTIFIED MAIL
RETURN RECEIPT NO. 9589 0710 5270 2348 497419
Rob Leishman
Division of Air Quality
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144820
Salt Lake City, Utah 84114-4820
DEPARTMENT6?-
Eil\4RoNMENrer- q,iAlnv
MAR 2 0 2025
uvrsloN OF AtR ouAl.IIY
RE: 2Q2025 Amine, SRU, MSCC, and Flares RATA Testing Protocol - Big West Oil
Mr. Leishman,
Enclosed is the site-specific testing protocol for the relative accuracy test audits (RATA) that
Erthwrks will be conducting on Big West Oil's Amine Unit, Sulfur Recovery Unit, MSCC Unit,
West Flare, and South Flare. These tests will be conducted on the week of May 5,2025. Erthwrks
will be conducting these RATAs in accordance with 40 CFR 60's Appendices B and F.
For questions regarding this RATA testing protocol, please contact Brady Miller at (385) 324-
1275.
Environmental Engineer
Enclosure: Erthwrks RATA Testing Protocol
Sincerely,
Brady Mil
A'R EM'SS'ONS TEST'NG FOR
'NDUSIRYEmission Testing Protocol
Big *..fLiL LLC
ot the
North Salt Lake Refinery
oEpenrurrut oF
ENVIRONMENTAL QUAUTY
|',lAR 2 0 2[t?5
DIV]SION OF AIR OUAI.JTY
on the
Amine Unit
West Flare
South Flare
Sulfur Recovery Unit
MSCC
Permit No: Approval Order DAQE-AN101220081-24
Test Dates: Week of May 5,2025
Erthwrks Project No. 9920
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CARBSTAE
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
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 operates in
conformance with the requirements of ASTM D7036-04 Standard Practice for Competence of
Air Emission Testing Bodies.
Erthwrks,Inc.
Name: John Wood
Title Technical Director
Signature:T
erfm Erthwrks Project No. 9920 -Big West Oil North Salt Lake Refinery
Annual CEMS RATA Testing -Version 2 (31t312025)
Page 2 of 15
1.0 [NTRODUCTION...... ......................4
l.l Contact Information/On-Site Personnel ............4
2.0 FACILTTY DESCRIPTION........... ..................... s
3.0 SAMPLING AND ANALYTICAL PROCEDURES........... ....................6
3.1 Gaseous Sampling - HzS ...............6
3.2 Gaseous Sampling - SOz and Oz ......................7
3.3 EPA Method 4 Moisture Determination (Modified)......... .....................8
3.4 RATA Procedures ........9
4.0 General Work Sequence,Site Hazards and Mitigation, and Tentative Schedule...... l0
4.1 General / Overall Safety Precautions and Risk Mitigation. ..................10
4.2 Tentative Schedule.... ...................1I
List of Tables
Table l: Test Matrix ......................5
Table 2: BigWest Oil CEMS Details ..............6
Table 3: Tentative Work Schedule... ...............1I
APPENDICESA. Example RATA Run DATA and Calculations
erfm Erthwrks Project No. 9920 -Big West Oil North Salt Lake Refinery
Annual CEMS RATA Testing -Version 2 (3/1312025)
Page 3 of 15
Erthwrks, [nc. has been contracted to provide air emission testing services for Big West Oil
(BWO) at the North Salt Lake Refinery located in North Salt Lake, UT. This test program is
scheduled for the week of May 5,2025.
These units are operated as required under the Permit No. Approval Order DAQE-
AN101220081-24 and EPA Title 40 CFR Part 60, Appendix F.
Big West Oil, LLC
Brady Miller
Environmental Engineer
333 W Center St.
Norrh Salt Lake, uT 84054
385-324-1275
brady. miller@bigwestoi I. com
Erthwrks,Inc.
Luke Morrison
Project Manager
P.O. Box 150549
Austin, TX 78715
512-962-7661 office
888-573-9994 fax
Lmorrison@erthwrks. com
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
erfrrA
Erthwrks Project No. 9920 -Big West Oil North Salt Lake Refinery
Annual CEMS RATA Testing -Version 2 (3/L3/2O25)
Page 4 of 15
Table 1: Test Matrix
Amine Unit RATA HzS EPA M.I5
PS7 162 ppm 9, 30-min runs
West Flare RATA HzS EPA M.I5
PS7 162 ppm 9, 30-min runs
South Flare RATA HzS EPA M.I5
PS7 162ppm 9, 30-min runs
MSCC RATA
NOx EPA M.7E PS2 60ppm @,0.0%02
9, 2l-min runsCOEPA M.IO PS 4/4A 500ppm @.0.0%02
SO,EPA M.6C PS 2 50 ppm @,0.0%02
Or. CO,EPA M.3A PS 3 NA
SRU RATA Oz.SOz EPA M.3A,6C
PS2,3 NA 9, 2l-min runs
Located in North Salt Lake City, Utah, the facility is a high conversion refinery operated by Big
West Oil LLC,a wholly owned subsidiary of FJ Management Inc. The facility has a total capacity
of 35,000 barrels per day and refines crude oils into gasoline and diesel products. Big West Oil
products meet or exceed government standards for clean transportation fuels, as well as customer
needs for engine perforrnance and cold flow qualities.
erfrm Erthwrks Project No. 9920 -Big West Oil North Salt Lake Refinery
Annual CEMS RATA Testing -Version 2 (3/73120251
Page 5 of 15
able 2:West Oil CEMS Details
Amine Unit HzS Ametek 5100 HD 1021950
West Flare HzS EXTREL MAX 3OO-IG 61727
South Flare HzS EXTREL MAX 3OO-IG 61728
SRU OzlSOz Rosemount/Emerson X-Stream X2 XMFO8002693435
MSCC
NOx/SOz ABB Limas 1l 400000744810
CO/COz ABB Uras 26 01400301913010L
Ot ABB Maenos 206 01400100978401L
In accordance with EPA Performance Specification 7, the analysis of the fuel gas sample streams
will be conducted following all procedures as speciflied in USEPA Method 15. Erthwrks will
utilize an SRI Model 8610 Gas Chromatograph (GC) equipped with an FPD detector. Three
calibration gas concentrations, using a calibration gas dilution system, will be delivered to the
GC and analyzed in triplicate. These triplicate values will be recorded and averaged, wherein a
graphical plot of concentration versus the GC peak area values will be created and used to
calculate the concentration of the unknown sample.
Utilizing a Teflon sample line, Erthwrks will direct the sample, under positive pressure, directly
to the GC (no bag sampling). Erthwrks will then conduct a series of 30-minute test runs
comprising of at least two (2) sample injections per test run. After the testing program, a post-
test analysis of the mid-calibration standard will be performed and must be within 5% of the
original curye. If this post-test criteria are not met, Erthwrks will create an additional complete
post-test calibration curve and will use the calibration data that calculates the highest emission
value in accordance with the method. EPA Audit samples are not available for Method 15.
erfm Erthwrks Project No. 9920 -Big West Oil North Salt Lake Refinery
Annual CEMS RATA Testing -Version 2 (3/1312025)
Page 5 of 15
For all gaseous sampling, Erthwrks will insert a stainless-steel probe, of sufficient length to reach
all sampling points, into a sampling port that is located on the stack in accordance with EPA
Method l. 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:
o EPA Method 3A for the determination of Oz/COz concentrationo EPA Method 6C for the determination of SOz concentrationo EPA Method 7E for the determination of NOx concentration
o EPA Method l0 for the determination of CO 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 L5.lyo of the calibration span value (or <0.5 ppmv).
After each compliance test run, 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.Uyo 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 512.6. The arithmetic average of all valid concentration values will be adjusted for bias using
equation 7E-58.
All raw data is recorded and automatically saved onto the Erthwrks cloud server and is directly
linked to the emission calculation worksheets to insure accurate transfer of the raw data and the
accuracy of the calculations. EPA Audit samples are not available for EPA Methods 3A or 6C.
The figure below details the Erthwrks Gaseous Sampling System.
erfm Erthwrks Project No. 9920 -Big West Oil North Salt Lake Refinery
Annual CEMS RATA Testing -Version 2 (3/L3/2O25)
Page 7 of 15
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Where applicable to correct measurements to a dry or wet basis, a modified EPA Method 4 rain
will be used to determine the moisture of the exhaust stack. The sampling will be conducted at a
single point through an unheated sampling line and through four impingers containing water and
silica gel place in an ice bath. Alternatively, the sample may be taken as a slip stream off the
heated sampling line in order to sample at the same sampling points as the Method 7E sampling
location. The sampling will be conducted at a constant rate, for the duration of the gaseous
emission test runs, and the beginning and final dry gas meter readings will be recorded. Moisture
will be determined gravimetrically in accordance with EPA Method 4.
Erthwrks Project No. 9920 -Big West Oil North Salt Lake Refinery
Annual CEMS RATA TestinB -Version 213/73/20251
Page 8 of 15
erfm
The RATA testing willbe conducted following the sampling and measurement procedures found
in the EPA Part 60, Appendix B, Performance Specifications which requires that EPA
Reference Methods, from EPA Part 60, Appendix A, be utilized to conduct independent stack
emissions measurements for comparison with installed CEMS readings. The following
performance specifications will be used during this testing program:
o EPA Performance Specification 7 for HzS Relative Accuracy
o EPA Performance Specification 2 for NOx and SOz Relative Accuracy
o EPA Performance Specification 3 for Oz and COz Relative Accuracyo EPA Performance Specification 4/4A for CO Relative Accuracy
As required, the use EPA Protocol I gases are mandatory and will be used for this portion of the
project. In addition, EPA Method 205 may be used for the generation of calibration standards
for the Erthwrks analytical instrumentation.
A minimum of nine (9) RATA test runs will be conducted at each exhaust stack for a minimum
duration of thirty (30) minutes for each run for H2S, and twenty-one (21) minutes for NOx, CO,
Oz, COz and SOz. During each 30-minute test run for HzS, a minimum of two (2) GC injections
will take place. A maximum of twelve (12) RATA test runs will be conducted and up to three
test runs may be discarded and not used to determine relative accuracy. The results of the
reference method tests willbe compared to CEMS measurement data from the same time periods
to determine the relative accuracy of the CEMS.
The Standard Deviation will be calculated following Equation P5.2,2-4:
Sa=
The Confidence Coefficient will be calculated following Equation P5.2,2.5:
S,CC: ts.e75 f
The Relative Accuracy will be calculated using Equation PS.2, 2-6:
Mpy=ffirroo
All detailed calculations and complete example calculations will be provided in the final report.
Erthwrks Project No. 9920 -Big West Oil North Salt Lake Refinery
Annual CEMS RATA Testing -Version 2l3/L3120251
Page 9 of 15
erfrm
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 below. 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 minimum PPE requirements will include hard hats, safety
glasses with side shields, steel-toed safety shoes, hearing protection, fire resistant clothing, fall
protection, and a personal HzS monitor. 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.
. AII Erthwrks personnel attend annual basic plus mandatory trainings, including all
required site-specific training and background checks.
o All field team members will be equipped with proper PPE compliant with BWO
procedures.
o 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 BWO.
No work will begin until a proper permit has been issued and all necessary BWO
Operations staff has been informed.
. The mobile lab will be parked at the nearest allowable/safest location below the stack
area.
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 BWO.
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erfrm Erthwrks Project No. 9920 -Big West Oil North Salt Lake Refinery
Annual CEMS RATA Testing -Version 2 (3/13/2025lr
Page 10 of 15
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.
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
Table 3: Tentative Work Schedule
May 7,2025
RATA: 02, SOz
May 8,2025 RATA: NOx, CO, SOz, Oz,
erfra Erthwrks Project No. 9920 -Big West Oil North Salt Lake Refinery
Annual CEMS RATA Testing -Version 213/l3l2}25l
Page 11 of 15
Page 12 of 15
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Erthwrks RATA Example Calculations
d our
where:
::ZA,Eq.2-3
absolute difference between reference method and client CEMS
run number
d r = -4.86
d z = -4.71
d s = '4.56
d4
d5
d6
-4.33
-4.43
-4.28
dt =
da=
ds =
-4.48
-4.50
-4.45
dto
drr
drz
=0
=0
=0
d"rg =
n = number of runs =
4.51
Eq.24
]''
{,
1.65E+031.83E+02
So=
CC=
where:
CC=
CC=
RAAS
where:
RAns =
RAns =
h.gzs
h.97s -
2.306 '
0.14
nlt2
2.306
1.81E-01
3
x 100
the unit's permit limit or applicable standard
162
1.39E-1 r
Eq.2-5
lo,,rl* lcq
AS
AS=
AS=
4.5111 +
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162 100
Page 14 of 15
Erthwrks Example Calculations
Example Calcs : Fuelgas
Example Calcs for Pollutant : H2S
Cv = 50.0 = Low Level Target concentration of calibration gas, ppmv.
Cor, = 20.0 = Mid Level Target concentration of calibration gas, ppmv.
CS = 5.0 = High Level Target concentration of calibration gas, ppmv.
Cs = 4460.5 = Low Level Average GC Response
SBi = 765.7 = Mid LevelAverage GC Response
SBr = 43.9 = High LevelAverage GC Response
GC Calibration Curve (Polynomial Excel Generated)
y=axz+bx+c
where: a = 1.7092[ = 3.7678c= 0
Run 1 Example Calculation
y = 17.850
solution= x= -[+[b2-4(aXc-v)11/2
(average response Run 1)
2(a\
where: a = 1.7492[ = 3.7678c = 0.000 (c-y)
x= -3.7678 13.77^2- 4(1.7092) -(17.85)1 112
2 ( 1.7092 )
x = 2.31 ppmv
Page 15 of 15