DAQ-2025-001774

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. 800 346-3128
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality

Tim Davis
Interim Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-310-25
Site ID 10122 (B5)

Brady Miller, Environmental Engineer
Big West Oil
333 West Center Street
North Salt Lake, Utah 84054-2805

Dear Mr. Miller:

Re: Big West Oil – Pretest Protocol for Flow, Oxygen (O2), and Sulfur Dioxide (SO2) and
Hydrogen Sulfide (H2S) Relative Accuracy Test – Davis County

The Utah Division of Air Quality (DAQ) reviewed Big West Oil’s pretest protocol dated March
17, 2025. The proposed test shall be performed under the following conditions:

Big West Oil’s monitoring system to be certified:

Point Source Channel Manufacturer Model # Monitor SN
West Flare H2S Extrel Core Mass MAX 300-IG 61727
South Flare H2S Extrel Core Mass MAX 300-IG 61728
Amine Unit H2S Ametek 5100 HD 1021950
SRU O2 Emerson / Rosemount X-Stream X2 XMF08002693435
SO2 Emerson / Rosemount X-Stream X2 XMF08002693435
MSCC
CO ABB Uras26 01400301913010L
CO2 ABB Uras26 01400301913010L
NOx ABB Limas11 400000744810
O2 ABB Magnos206 01400100978401L
SO2 ABB Limas11 400000744810

Erthwrks, Inc. will conduct a relative accuracy/performance specification test on Big West Oil’s
continuous monitoring system.

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DAQC-310-25
Page 2

Relative accuracy must be determined in the units of the emission standard or equivalent units of
the emission standard, i.e., tons/year shall be tested in pounds/hour or lb Hg/MM ton clinker
30-DRA shall be tested as lb Hg/MM ton clinker.

The DAQ understands that Alliance Source Testing will conduct testing as follows:

Test Date Point Source Parameter EPA Reference Method
May 6, 2025 West Flare H2S Method 15
South Flare H2S Method 15
May 7, 2025
Amine Unit H2S Method 15
O2 Method 3A
SO2 Method 6C
May 8, 2025 MSCC
CO2 & O2 Method 3A
SO2 Method 6C
NOx Method 7E
CO Method 10

• Reference Method 1 - Sample and Velocity Traverses for Stationary Point Sources
as outlined in 40 CFR 60 Appendix A shall be used to determine the location and
number of sampling points as applicable.

• Reference Method 3A - Determination of Oxygen and Carbon Dioxide
Concentrations in Emissions from Stationary Point Sources – (Instrumental
Analyzer Procedure) as outlined in 40 CFR 60 Appendix A.

• Reference Method 4 - Determination of Moisture Content in Stack Gases as
outlined in 40 CFR 60 Appendix A shall be used to determine the stack gas
moisture content.

• Reference Method 6C - Determination of Sulfur Dioxide Emissions from
Stationary Point Sources - (Instrumental Analyzer Procedure) as outlined in 40
CFR 60 Appendix A.

• Reference Method 7E - Determination of Nitrogen Oxide Emissions from
Stationary Point Sources - (Instrumental Analyzer Procedure) as outlined in 40
CFR 60 Appendix A.

• Reference Method 10 - Determination of Carbon Monoxide Emissions from
Stationary Point Sources – (NDIR Instrumental Procedure) as outlined in 40 CFR
60 Appendix A.

• Reference Method 15 - Determination of H2S Concentrations Using a Gas
Chromatograph with Flame Photometric Detector as outlined in 40 CFR 60
Appendix A. Zero drift and calibration drift checks are required in accordance with
Performance Specification 7.
DAQC-310-25
Page 3

• Deviations - The Director or the representative of the Director must be notified of
and approve deviations of the Reference Method test. Any deviation from these
conditions without approval from the DAQ may constitute rejection of these tests.

Acceptance of a protocol does not relieve the owner/operator and the testing
contractor from strict adherence to all applicable EPA methods, DAQ policies,
Utah Air Quality Rules (UAQR), and methods approved by the Director. Any
deviation from EPA methods, DAQ policies, UAQR, and methods approved by the
Director must be addressed separately and express written consent given prior to
commencement of testing.

• Field data shall be provided to the DAQ in a timely manner for review.

• The Director will determine the relative accuracy of each monitoring system based
on Point Source continuous emission monitoring data and test data acquired by the
staff member of the DAQ during the test.

• All test reports must be submitted to the Director not later than 60 days after
completion of the test.

• The test report shall include all raw calibration data, raw emission data with date,
time stamps.

Relative accuracy test reports must contain:

1. Point source continuous monitor, channel, manufacturer, and serial number,

2. Raw stack test data and continuous monitor data with date and time stamps.

3. Emission data reported in concentration (ppm or %) and units in the applicable
emission limit.

The DAQ requires that all test reports include a statement signed by a responsible official
certifying that:

1. Testing was conducted while the Point Source was operating at the rate and/or
conditions specified in the applicable approval order, operating permit, or federal
regulation.

2. During testing, the Point Source combusted fuels, used raw materials, and
maintained process conditions representative of normal operations, and operated
under such other relevant conditions specified by the Director.

3. Based on information and belief formed after reasonable inquiry, the statements
and information contained in the report are true, accurate, and complete.

DAQC-310-25
Page 4

Should you have any questions concerning this matter, contact me at [phone] or by email
at [e-mail].

Sincerely,

Rob Leishman, Environmental Scientist
Major Source Compliance Section

RL:rh

cc: Davis County Health Department
Erthwrks, Inc.
* $ . # ( ) - — - A D v A ? A D @ E w @ G ˜
Rob Leishman Jr