DAQ-2025-002632

1

DAQC-520-25
Site ID 10123 (B5)

MEMORANDUM

TO: CEM FILE – HF SINCLAIR WOODS CROSS REFINING LLC

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Rob Leishman, Environmental Scientist

DATE: May 28, 2025

SUBJECT: Source: Crude Unit Process Heater 8H2
Contact: Matt Howes – 801-397-7412
Location: HF Sinclair Woods Cross Refinery, Davis County, UT
Test Contractor: Alliance Technical Group
FRS ID#: UT0000004901100013
Permit/AO#: AO DAQE-AN101230057-23 dated November 15, 2023
Subject: Review of RA/PST Protocol dated May 6, 2025

On May 15, 2025, Utah Division of Air Quality (DAQ) received a protocol for a RA/PST (relative
accuracy/performance specification test) of the HF Sinclair Woods Cross Refinery Crude Unit Process
Heater 8H2 in Woods Cross, Utah. Testing will be performed on July 2, 2025, to determine the relative
accuracy of the O2 monitoring systems.

PROTOCOL CONDITIONS:

1. RM 3A used to determine dry molecular weight of the gas stream: OK
2. RM 4 used to determine moisture content: OK
3. RM 205 used to validate gas dilution systems for field instrument calibration: 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
I
RE:Relative Accuracy Test Audit (RATA) - Crude Unit Process Heater 8H2
HF Sinclair Woods Cross Refining LLC - Woods Cross, Davis County
Director Bird:
ln accordance with Section R307-165-3, and Condition ll.B.1.a of Approval Order AN101230053-22, HF
Sinclair Woods Cross Refining LLC is providing notification of source testing planned to be conducted at
the Woods Cross Refinery. Alliance Source Testing of Salt Lake City, UT. has been contracted to conduct:
Relative Accuracy Test Audit (RATA) of the Crude Unit Process Heater 8H2 (Unit 8) Continuous
Emission Monitoring System (CEMS).
ThistestingprogramisplannedforJuly2nd,2O2S. Acopyofthetestprotocolisenclosed. lfyouhave
any questions or need additional information, please contact me at [phone].
May 6th, 2025
Director
Division of Air Quality
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, Utah 84116
Matt Howes
Environmenta I Engineering Specialist
Enclosure
E. Benson (r) File 2.4.L.4.2.1
D. Simmonds
Certified Mail: 9589 0710 5270 2858 5275 72
DEPARTMENT OF
ENVIRONMENIA OUAI'TY
MAY I 5 Zl?s
Drvtstor.t oF AtR qnuw
,.tttF$nctor
HF Sinclair Woods Cross Refining LLC
1070 W. 500 S, West Bountiful, UT 84087
801-299-6600 | HFSinclair.com
FlareAI
TECHNICAL GBOU
Site Specific Test Plan
HF Sinclair Woods Cross Refining, LLC
1070 West 500 South
West Bountiful, UT 84087
Source to be Tested: Heater 8H2
Proposed Test Date: July 2,2025
Proj ect No. AST- 2025 -2 l2l -002
Prepared By
Alliance Technical Group, L
3683 W 2270 S, Suite
West Valley City, UT
UTAH DEPARTMENT OF
ENVTRONMENTAL OUALITY
lilAY 1 5 2n25 I
DIVISION OF AIR OUALITY
I
T AI
ii'Site Specific Test Plan
Test Program Summary
t Requlatorv Information
Permit No.
Regulatory Citation
Source Information
DAQE-AN l0 t230055-23
40 CFR 60, Appendix B, Performance Specification 3t
t
I
Source Name
Process Heater 8H2
Contact Information
Target Parameter
Oz
I
T
I
I
T
I
I
t
I
I
Test Location
HF Sinclair Woods Cross Refining, LLC
1070 West 500 South
West Bountitul, UT 84087
Eric Benson
eric.benson@HF Sinclair.com
(801) 2e9-6623
Matthew Howes
matthew.howes@HFS inclair.com
(80t\ 397-7412
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) 464-0372
Field Team Leader
Ryan Lyons
ryan. lyons@stacktest. com
(708) 2 l 4-4850
(subject to change)
QA/QC Manager
Kathleen Shonk
katie.shonk@al I iancetg. com
(8t2) 4s2-478s
Test PlanlReport Coordinator
Delaine Spangler
delaine.spangler@stacktest. com
AST-2025-2t21-002 HF Sinclair - West Bountiful, UT
I
I
I
I
I
t
AI Site Specific Test Plan
Table ofContents
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 3.{ - Oxygen. ......................3-l
3.2 U.S. EPA Reference Test Method 4 - Moisture Content......... .......................3-1
3.3 U.S. EPA Reference Test Method 205 - Gas Dilution System Certification. .......................3-1
3.4 Quality Assurance/Quality Control - U.S. EPA Reference Test Method 3A................. .......3-2
LIST OF TABLES
Table 2- l: Program Outline and Tentative Test Schedule ......................2-l
lEerla
ir .'.
I
I
t
t
I
I
I
t
t
I
T
t
t
AST-2025-212t-002 HF Sinclair - West Bountifirl. UT Page ii
I
I
I
T
t
t
I
I
put6rpe
Tf CIlNICAL GNOI,t F)
Site Specific Test Plan
Intoduction
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 West Bountiful, Utah facility. Portions of the facility are subject to provisions
of 40 CFR 60, Appendix B, PS 3 and the Utah Department of Environmental Quality, Division of Air Quality
(UDAQ) Permit No. DAQE-AN101230055-23. Testing will include conducting a relative accuracy test audit
(RATA) to determine the relative accuracy (RA) as outlined in Table l-l below.
Table l-l: Test Matrix
This site-specific test plan (SSTP) has been prepared to address the notification and testing requirements of the
UDAQ permit.
1.1 Process/ControlSystemDescriptions
The 8H2 process heater is fired with refinery gas and is rated at 99 MMBtu/trr. Refinery personnel will access and
report refinery CEMS results on the day of the RATA.
1.2 CEMS Descriptions
Pollutant
Oz(wet)
Ametek
Thermox WDG-IV
10208656
High
1.3 Project Team
Personnel planned to be involved in this project are identified in the following table.
Table l-2: Project Team
Parameter:
Make:
Model:
Serial No.:
Span:
t
t
t
I
I
I
I
I
I
I
I
HF Sinclair Personnel Eric Benson
Matthew Howes
Regulatory Agency UDAQ
Alliance Personnel Ryan Lyons
other field personnel assigned at time oftesting event
AST-2025-2 I 2 l -002 HF Sinclair- West Bountifirl, UT Page l-l
t
t
I
I
I
T
t
I
I
I
t
t
I
I
t
I
I
I
pjlt6
:; t'I'
Site Specrfic Test Plan
Introduction
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 futl-body harnesses). 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.
I
AST-2025-2I2l-002 HF Sinclair - West Bountiful. UT Page l-2
I
I
t
T
t
I
. Testing will be performed to demonstrate compliance with the UDAQ permit and 40 CFR 60, Appendix B,
t l:'or,""s testing will be conducted on the GEMS serving Heater 8H2.
o PS testing will be conducted at greater than 50% of the maximum normal [oad.I ' ::::,::T.l;l'"x:iTiil#il:;:J,:::;'JiTffi:::.'+;'ilfiJ l'l':,1#ilH:l;'Lt ff;
I 2.2 ;::"::r:- ;'",,.,.., to be Monitored and Recorded
Plant personnel will collect operational and parametric data at least once every l5 minutes during the testing. The
I fotlowing list identifies the measurements, observations and records that will be collected during the testingI program:
I o GEMS Data
o Operating Load
I 23 Proposed Test ScheduleI Table2-l presentsanoutlineandtentativeschedulefortheemissionstestingprogram.
I Table 2-l: Program Outline and Tentative Test Schedule
Tcsting Locetion Peremcter US EPA Mcthod No ofRuns Run Duretlon Est Onsite
Time
DAY l-luly2,2025
Heater 8H2
BWS 4 3-4 60 min
l0 hr
o:3A 9-12 2l min
2.4 Emission Limits
Emission limits for each pollutant are below.
Table 2-2: Emission Limits
1r-Alianoe Sire Spec(ic Test Plan
SummaryofTest Programs
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 Heater 8H2.
2.1 General Description
All testing will be performed in accordance with specifications stipulated in U.S. EPA Reference Test Methods 3A
and 4. Table 2-l presents an outline and tentative schedule for the emissions testing program. The following is a
summary of the test objectives.
I
I
t
I
t
I
Source CEMS Required Relative Accuracv Citation
Heater 8H2 O: (o/o vw)<20 % (RM) or r I 7o O: (avg. diff.)60, Appendix B, PS 3
AST-2025-2121-002 HF Sinclair - West Bountrt'ul IJT Page 2- I
I
I
I
I
t
T
I
I
t
I
AI
Site Specrfc Test Plan
Sumnary ofTest Programs
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.
c 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 Dara - Copies of actual handwritten or electronic field data sheets.
o Quality Control Data - Copies of all instrument calibration data and/or calibration gas certificates.
o Process Operating/Control System Data - Process operating and control system data (as provided by HF
Sinclair) to support the test results.
=lalEe
I
I
I
I
I
t
I
I
I
AST-2025-2 l2 l -002
lii
I
I Aliatpe Site Spectfc Test Plan
7'esting lvle thodology
I
T
I
I
I
I
t
T
T
I
I
t
T
I
t
t
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 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 3-1.
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 3A - Oxygen
The oxygen (O:) testing will be conducted in accordance with U.S. EPA Reference Test Method 3A. Data will be
collected online and reported in one-minute av€rages. 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 3.4.
The relative accuracy of the O: CEMS will be determined based on procedures found in 40 CFR 60, Appendix B,
Performance Specifi cation 3.
3.2 U.S. EPA Reference Test Method 4 - Moisture Content
The stack gas moisture content will be determined in accordance with U.S. E,PA 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
knownquantityofwaterorsilicagel. Eachimpingerwill beanalyzedgravimetricallybeforeandaftereachtestrun
on the same analytical balance to determine the amount of moisture condensed.
3.3 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 perform fwo 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 2%. These steps will be repeated three (3)
Pemmetcr U.S. EPA Rcference
Test Methods Notos/Remerks
Oxygen 3A Instrumental Analysis
Moisture Content 4 Gravimetric Analysis
Gas Dilution Syslem Certification 20s
t
AsT-2025-2r2r-002 FIF Sinclarr - West Bountiful. UT Page 3- |
I
I
I
t
I
t
T
t
I
I
I
T
I
t
I
I
I
I
Site Specrfic Test Plan
Testing Methodology
times. The average analyzer response must agree within2oh of the predicted gas concentration. No single injection
shall differ more than 2o/o from the average instrument response for that dilution.
3.4 Quality Assurance/Quality Control - U.S. EPA Reference Test Method 3A
Cylinder calibration gases will meet EPA Protocol I (+l- 2o/r) 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% absolute difference.
High or Mid Level gas (whichever is closer to the stack gas concentration) will be introduced at the probe and the
time required for the analyzer reading to reach 95 percent or 0.5o/o (whichever was less restrictive) of the gas
concentration 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 0.5o/o (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%o (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 0.5oh 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 0.5o/o 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 0.5o/o 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 fwelve 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 pollutant concentration at each traverse point does not differ more than 5o/o or 0.3o/o (whichever is less
restrictive) of the average pollutant concentration, then single point sampling will be conducted duringthe test runs.
Ifthe pollutant concentration does not meet these specifications but differs less than l0% or 0.5% 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 measurement line; stacks greater than 7.8 feet in diameter - 0.4, 1.0, and 2.0 meters from the
stack wall). If the pollutant concentration differs by more than l0% or 0.5Yo from the average concentration, then
sampling will be conducted at a minimum of fwelve ( l2) traverse points. Copies of stratification check data will be
included in the Quality Assurance/Quality Control Appendix of the report.
I
AST-202s-2l2l-002 HF Sinclair - West Bountiful. UT Page 3-2
I
I
I
I
I
I
I
I
I
I
I
I
AI Site Specrfic Test Plan
Testing Methodology
A Data Acquisition System with battery backup will be used to record the instument 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.
FIA
t
I
I
I
I
I
T
AST-2025-2 I2l-002 HF Sinclair - West Bountiful, UT
t
I
I
T
I
t
I
I
t
t
T
I
I
I
I
T
I
I
Site Specific Test Plan
Qualiry 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
progrnm, 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 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-600/R-941038c, 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 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 5%o since the last full meter calibration. This check is performed after each test series.
e Pitot Tubes and Manometers. Type-S pitot tubes 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 coeflicient 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.
o Temperature Measuring Devices. All 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 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.
. Diqital Calipers. Calipers are calibrated annually by Alliance by using gage blocks that are calibrated
annually by an outside laboratory.
t
AST-2025-2t21-002 HF Sinclair - West Bountiful, UT Page 4- I
t
t
I
T
I
T
T
I
t
t
t
t
I
I
I
T
I
I
Site Specific Test 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 i 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 two (2) years by an outside laboratory or internally. If conducted internally, they are weighed on a
NIST traceable balance. If the weight does not meet the expected criteria, they are replaced.
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.
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 Cleaned glassware and sample train components will be sealed until assembly.
o Sample trains will be leak checked before and after each test run.
. Appropriate probe, filter and impinger temperatures will be maintained.
o 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.
r All raw data will be maintained in organized manner.
. All raw data will be reviewed on a daily basis for completeness and acceptability.
I
AST-202s-2l2l-002 HF Sinclair - West Bountiful, UT Page 4-2