DAQ-2025-002067

1

DAQC-364-25
Site ID 10124 (B5)

MEMORANDUM

TO: CEM FILE – SILVER EAGLE REFINING

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Rob Leishman, Environmental Scientist

DATE: April 10, 2025

SUBJECT: Source: Main Plant Fuel Gas Line
Contact: Blaine Zwahlen – 801-298-3211
Location: 2355 South 1100 West, Woods Cross, Davis County, UT
Test Contractor: Alliance Technical Group
FRS ID#: UT0000004901100019
Permit/AO#: Approval Order (AO) DAQE-AN101240030-16 dated
November 9, 2016
Subject: Review of RA/PST Protocol dated March 25, 2025
On March 28, 2025, Utah Division of Air Quality (DAQ) received an email containing a protocol for a
RA/PST (relative accuracy/performance specification test) of the Silver Eagle Refining main fuel line in
Woods Cross, Utah. Testing will be performed on May 22, 2025, to determine the relative accuracy of the
H2S monitoring systems.

PROTOCOL CONDITIONS:

1. RM15 used to determine H2S content of fuel gas in stationary sources by GCFPD: 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
$ilverhgle
REF'N'NG
SAF T. 5 U STAI NAA L E, S E RVIC E
tYo.dtCto' Ut Lt,nrto. Wf
March 25,2025
Mr. Bryce Bird, Director
Utah Department of Environmental Quality
Division of Air QualityAttn: Rob Leishman Jr.
P.O. Box 144820
Salt Lake city, utah 84114-4820
H2S CEM Relative Accuracy Test Audit (RATA)
Dear Rob:
This is to notifr you that Silver Eagle Refining-Woods Cross [nc. plans to conduct a H2S CEM
Relative Accuracy Test Audit (RATA). The tentative test date is May 22,2025. Alliance
Technical Group, LLC will conduct the RATA test. Attached is the RATA Site Specific Test
Plan.
Please contact me if you have any questions about this notification.
Sincerely,
for Silver Eagle Refining-Woods Cross Inc.
Cc James Shupe
Josh Sorenson
Gigi Camarena
Mike Klotovich
Cody Coleman
Oepenrnt-Erur-F
EhtvtRONMEUer- diriUrV
MAR 2 8 2025
ofvtsro{ oF An orr uw
Re:
2355 South 1100 West . Woods Cross, Utah 84087
Allare
Site Specific Test Plan
Silver Eagle Refining
Woods Cross Refinery
2355S1100W
Woods Cross, UT 84087
Source to be Tested: Flare/Fuel Gas
Proposed Test Date: May 22,2025
Proj ect No. AST-2025-17 66
Prepared By
Alliance Technical Group, LLC
3683 W 2270 S. Suite E
West Valley City, UT 84120
ffi$rfloo,lou*
rTA
l
AI Site $ecific Test Plan
Test Propram Summary
ResulatorY Information
Permit No.
Regulatory Citations
Source Information
DAQE-AN r 01240030- l6
40 CFR 60, Appendix B, Performance Specification 7
40 CFR 60, Subpart J
Source Name
Flare/Fuel Gas
Contact lnformation
Target Parameter
HzS
Test Location
Silver Eagle Refining
Woods Cross Refinery
2355S1100W
Woods Cross, UT 84087
Facility Contact
Blaine Zwahlen
bzwah len@silvereaglerefi ning.com' (80r) 298-3211
Test Company
Alliance Technical Group, LLC
3683 W 2270 S, Suite E
West Valley City, UT 84120
Project Manager
Charles Horton
charles.horton@all iancetg.com
(3s2) 663-7s68
Field Team Leader
Alan Jensen
alan j [e-mail]
[phone]
(subject to change)
QA/QC Manager
Kathleen Shonk
[e-mail]
(812) 4s2-478s
Test Plan/Report Coordinator
Delaine Spangler
[e-mail]
AST-2025- I 766 Silver Eagle - Woods Cross, UT Page i
AI Site Specific Tesr Plan
Table of Contents
TABLE OF CONTENTS
l.l Process/Control System Descriptions.. ................ l-l
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 15 - Hydrogen Sulfide ........3-l
LIST OF TABLES
Table 2-l: Program Outline and Tentative Test Schedule ......................2-l
Table2-2: Relative Accuracy Requirements and Limits.... ....................2-2
rTA
l.
AST-2025- I 766 Silver Eagle - Woods Cross, UT Page ii
A/ffape Site Specrfic Test Plan
Introduclion
1.0 Introduction
Alliance Technical Group, LLC (Alliance) was retained by Silver Eagle Refining (Silver Eagle) to conduct
performance specification (PS) testing at the Woods Cross Refinery. Portions of the facility are subject to
provisions of the 40 CFR 60, Appendix B, PS 7, Subpart J, and the Utah Department of Environmental Quality,
Division of Air Quality (UDAQ) Approval Order (AO) DAQE-AN I 0 I 240030- 16. Testing will include conducting
a relative accuracy test audit (RATA) to determine the relative accuracy (RA) of the hydrogen sulfide (HzS)
continuous emissions monitoring system (CEMS) serving the Fuel Gas and Flare Gas.
This site-specific test plan (SSTP) has been prepared to address the notification and testing requirements of the
UDAQ permit.
l.l Process/ControlSystemDescriptions
Silver Eagle owns and operates a continuous monitoring system located downstream of the primary fuel mixing
drum to determine compliance with the sulfur dioxide (SO:) and H:S limits of NSPS Subpart J. The facility records
the output of the system, for measuring the H:S concentration in the plant fuel gas. SO: emissions are calculated
assuming 100% of the H:S in the plant fuel gas is combusted forming SO: at a ratio of 34lbs of H:S equals 64lbs of
SOz.
1.2 CEMS Descriptions
Parameter:
Make:
Model:
Serial No.:
Span:
Pollutant
HuS
Siemens / Siemens
Maxum II / Maxum II
3003955 r 97 / HOU3007584r 3700r 0
0-300 ppm
1.3 Project Team
Personnel planned to be involved in this project are identified in the following table.
Table l-l: Project Team
1.4 Safety 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 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.
Silver Eagle Personnel Blaine Zwahlen
Regulatory Agency UDAQ
Alliance Personnel Alan Jensen
other field personnel assigned at time oftesting event
AsT-2025- I 766 Silver Eagle - Woods Cross. UT Page l-l
,?"Aliarpe Site Specrfic Test Plan
Summary ofTest Programs
2.0 Summary of Test Program
To satisf the requirements of the UDAQ permit and 40 CFR 60, Appendix B, PS 7 and Subpart J, the facility will
conduct a performance test program to determine the compliance status of the Flare/Fuel Gas CEMS.
2.1 General Description
All testing will be performed in accordance with specifications stipulated in U.S. EPA Reference Test Method 15.
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, 40 CFR 60, Appendix B, PS
7 and Subpart J.
Emissions testing will be conducted on the Flare/Fuel Gas CEMS.
Each of the l2 test runs will be 30 minutes in duration.
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:
a
a
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
Testing Locetion Parrmeter US EPA Method No. ofRuns Run Duretion Est.Onsite
Tlme
DAY I -May21.2025
Equipment Setup & Pretest QA/QC Checks 4hr
DAY 2 -May 22,2025
Flare/Fuel Gas H:S l5 l2 30 min l0 hr
DAY 3 -May 23,2025
Contingency Day (if needed)
AST-2025- | 766 Silver Eagle - Woods Cross, UT Page 2- I
Aliatpe Site Spec'tfic Test Plan
Summary ofTest Programs
2.4 Emission Limits
Emission limits for each pollutant are below.
Table 2-2: Relative Accuracy Requirements and Limits
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 Introduction - Brief discussion of project scope of work and activities.
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.
lllethodologt - A description of the sampling and analytical methodologies.
Sample Calculations Example calculations for each target parameter.
Field Dato - Copies of actual handwritten or electronic field data sheets.
Quality Control Data - Copies of all instrument calibration data and/or calibration gas certificates.
Process OperatingiConlrol Syslem Data Process operating and control system data (as provided by Silver
Eagle) to support the test results.
a
a
a
a
a
Source CEMS Required Reletive
A norr rl nv
Appliceble Stendard /
Limit Citetion
Flare/Fuel
Gas H:S <20 % (RM) or <10 % (AS)162 ppm 60, Appendix B, PS 7
AST-2025- I 766 Silver Eagle - Woods Cross, UT Page 2-2
Affiarpe Site Spectfic Test Plan
Tes ting ltlethotloIog1
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 zrssurance measures 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- L
Table 3-l: Source Testing Methodology
All stack diameters, depths, widths, upstream and downstream disturbance distances and nipple lengths will be
measured on site with an EPA Method I verification measurement provided by the Field Team Leader. These
measurements will be included in the test report.
3.1 U.S. EPA Reference Test Method 15 - Hydrogen Sulfide
The hydrogen sulfide testing will be conducted in accordance with U.S. EPA Reference Test Method 15. The sampling
system will consist of a heated Teflon probe. heated Teflon sample line, gas conditioning system, leak-free pump,
unheated Teflon sample line, and a gas chromatograph (GC) equipped with a flame photometric detector (FPD). Each
test run will consist of a minimum of 2 injections performed over a period of at least 30 minutes.
The GC/FPD will be calibrated for each sulfide compound (H1S) with a certified calibration gas diluted with a dilution
system validated in accordance with EPA Method 205 to produce three (3) or more concenffation levels spanning the
linear range of the FPD. Calibration precision, sample line loss, and calibration drift test values will be maintained in
accordance with EPA Method l5 requirements.
Paremeter U.S. EPA Reference
Test Methods Notes/Remarhs
Hydrogen Sulfide l5 Direct Interface/GCFPD Analysis
AST-2025- I 766 Srlver Eagle - Woods Cross, UT Page 3- I
FAlfatrce Site Specrfic Test 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 part 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 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 Ill (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
t}te meter correction factor (Y) and the meter's orifice pressure differential (AH@) Alliance uses approved
Altemative Method 009 as a post-test calibration check to ensure that the correction factor has not changed
more than 57o since the last full meter calibration. This check is performed after each test series.
Temperature Measurins Devices. AII thermocouple sensors mounted in Dry Gas Meter Consoles are
calibrated semi-annually with a NlST-traceable thermocouple calibrator (temperature simulator) and
verified during field use using a second NIST-traceable meter. NlST-traceable thermocouple calibrators
are calibrated annually by an outside laboratory.
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 of service.
Other Equipment. 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.
AST-2025- I 766 Silver Eagle - Woods Cross, UT Page 4- I
AI Site Specific Test Plan
Quality Assurance Program
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:
. Appropriate probe, filter and impinger temperatures will be maintained.
r 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.
o An isokinetic sampling rate of 90-l l0% will be maintained, as applicable.
. AII raw data will be maintained in organized manner.
o All raw data will be reviewed on a daily basis for completeness and acceptability.
FIA
i
AST-2025- I 766 Silver Eagle - Woods Cross, UT Page 4-2