DAQ-2025-002634

1

DAQC-522-25
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: Fluidized Catalytic Cracking Unit (FCCU) Unit 25
Contact: Matt Howes – 801-397-7412
Location: Woods Cross, 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 Protocols dated May 6, 2025
On May 13, 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 Refining LLC Refinery FCCU
Unit 25 in Woods Cross, Utah. Testing will be performed on July 1, 2025, to determine the relative
accuracy of the O2, CO2, NOX, SO2, and CO monitoring systems.

PROTOCOL CONDITIONS:

1. RM 1 used to determine sample velocity traverses: OK
2. RM 2 used to determine stack gas velocity and volumetric flow rate: OK
3. RM 3A used to determine dry molecular weight of the gas stream: OK
4. RM 4 used to determine moisture content: OK
5. RM 6C used to determine SO2 emissions: OK
6. RM 7E used to determine NOX concentrations of emissions: OK
7. RM 10 used to determine CO concentrations of emissions: OK
8. RM 205 used to certify the gas dilution system: 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
,.tttF$nctorr
HF Sinclair Woods Cross Refining LLC
1070 W.500 S, West Bountiful, UT 84087
801 -299-6600 | HFSinclair.com
otpnHruerur oFENUHONMENIAL OIJAIITY
MAY 1 3 2A25
DMSION OF AIR q'A.'TY
May 5, 2025
Director
Division of Air Quality
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, Utah 84116
Certified Mail: 7012 2920 0000 3468 7454
RE: Relative Accuracy Test Audit (RATA) - Fluid Catalytic Cracking Unit
HF Sinclair Woods Cross Refining tLC - Woods Cross, Davis County
Director Bird:
ln accordance with Section R307-155-3, 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 Audits (RATA) of the Fluid Catalytic Cracking Unit (Unit 25) Continuous
Emission Monitoring Systems (CEMS).
This testing program is planned for the week of July 7,2025. A copy of the test protocol is enclosed. lf
you have any questions or need additional information, please call me at [phone].
/%4---
Matt Howes
Environmental Engineering Specialist
Enclosure
cc: E. Benson (r) File 2.4.1.6.2.1
D. Simmonds
At6rreI l (_' i l l'\ i t) z\ t (l tl (l [] tr
Site Specific Test Plan
HF Sinclair Woods Cross Refining, LLC
1070 West 500 South
West Bountiful, UT 84087
Source to be Tested: FCCU WGS Unit 25
Proposed Test Date: July 1,2025
Project No. AST-2025 -21 2 I -00 1
Prepared By
Alliance Technical Group, LL
3683 W 2270 S, Suite
West Valley City, UT
ffiffiFPARTMFNT oF
e r[vi io u rrre urau o ueltIY
VAY 1 3
DIVISION OF AIR OUALIW
pjlt6T
T Site Spectfic Test Plan
Test Program Summary
Regulatorv InformationI
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Permil No.
Regulalory Citations
Source Information
DAQE-AN 10123005s-23
40 CFR 60, Appendix B, Performance Specifications 2, 3, 4 and 6
Source Name
Fluid Catalytic Cracking Unit
(FCCU) Wet Cas Scrubber
(wGS)
Contact Information
Source ID
Unit 25
Target Parameters
VFR, Oz, COz, SOz, NOx, CO
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Test Localion
HF Sinclair Woods Cross Refining,LLC
1070 West 500 South
West Bountiful, UT 84087
Eric Benson
eric.benson@HF Sinclair.com
(9ot) 299-6623
Matthew Howes
matthew.howes@HFS inc lair.com
(80t) 397-74r2
Tesl 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@stacklest. com
(708) 214-48s0
(subject to change)
QA/QC Manager
Kathleen Shonk
katie. shonk@al I iancetg.com
(812) 4s2-478s
Test Plan/Report Coordinator
Delaine Spangler
[e-mail]
AsT-2025-212t-001 HF Sinclair - West Bountiful. UT
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AI Site Specific Test Plan
Table ofContents
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 Methods I and2 - Sampling/Traverse Points and Volumetric Flow Rate........3-l
3.2 U.S. EPA Reference Test Method 3A - Oxygen/Carbon Dioxide......... .........3-l
3.3 U.S. EPA Reference Test Method 4 - Gas Moisture Content......... ................3-2
3.4 U.S. EPA Reference Test Method 6C - Sulfur Dioxide......... .........................3-2
3.5 U.S. EPA Reference Test Method 7E - Nitrogen Oxides .........3-2
3.6 U.S. EPA Reference Test Method l0 - Carbon Monoxide..... ........................3-2
3.7 U.S. EPA Reference Test Method 205 - Gas Dilution System Certification. .......................3-3
3.8 Quality Assurance/Quality Control - U.S. EPA Reference Test Methods 3A, 6C, 7E and l0 ................... 3-3
LIST OF TABLES
Table 2- l: Program Outline and Tentative Test Schedule ......................2-2
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AST-2025-212t-001 HF Sinclair - West Bountiful. UT Page ii
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Site Specifc Test Plan
Introduction
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 2, 3, 4 and 6 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-1 below.
Table l-l: Test Matrix
FCCU WGS Unit 25
Orygen (Oz), Carbon Dioxide (COz), Sultur Dioxide
(SOz), Nitrogen Oxide (NOx), Carbon Monoxide
(CO), Volumetric Flow Rate (VFR)
This site-specific test plan (SSTP) has been prepared to address the notification and testing requirements of the
UDAQ permit.
l.l Facility Descriptions
The FCCU is a stacked type of UOP technology. Reduced crude from the bottom of the crude tower is pumped to
storage or straight to the FCCU. Feed is heated in an exchanger and mixed with recycled (fractionation tower
bottoms) and side cut heavy gas oil. The combination is mixed with hot regenerated catalyst and is vaporized in the
riser entering the bottom ofthe reactor. As the vapor rises to the reactor, cracking takes place with carbon deposited
on the catalyst. Spent catalyst leaves the reactor through a steam stripping leg and flows to the regenerator where air
is blown in and the carbon is burned offreactivating the catalyst. Cyclones in the reactor and regenerator separate
catalyst from the gases and vapors.
Cracked products leave the reactor and go to the fractionator where they are separated into gas, LPF, gasoline, light
gas and heavy gas oil. Regenerator off-gases are ducted to a WGS for particulate matter removal before gases are
vented to the atmosphere through a vertical lgg-foot-tall stack. The WGS is a control device for particulate matter.
1.2 CEMS Descriptions
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Parameter:
Make:
Model:
Serial No.:
Pollutant
SOz
SICK
MCSIOOE
15062323
Pollutant
NOx
SICK
MCSIOOE
r5062323
Pollutant
CO
SICK
MCSIOOE
15062323
Diluent
OzlCOz
SICK
MCSIOOE
15062323
Flow Rate
VFR
Teledyne Monitor Labs
Ultraflow 150
1,500,000
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Site Specific Test Plan
Introduction
1.3 Project Team
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Personnel planned to be involved in this project are identified in the following table.
Table l-2: Project Team
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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 harnesses). Alliance personnel will conduct themselves in a manner consistent with
Client and Alliance's safety policies.
A Job Safety Analysis (JSA) wilt be completed daily by the Alliance Field Team Leader.
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HF Sinclair Personnel Eric Benson
Matthew Howes
Regulatory Agency UDAQ
Alliance Personnel Ryan Lyons
other field personnel assigned at time oftesting event
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AI Site Specific Test Plan
Sumnwry ofTest Programs
2.0 Summary of Test Program
To satisfr the requirements of the UDAQ permit, the facility will conduct a performance test program to determine
the compliance status of the FCCU WGS Unit 25.
2.1 General Description
All testing will be performed in accordance with specifications stipulated in U.S. EPA Reference Test Methods l, 2,
3A,4,6C,78, and 10. 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 and 40 CFR 60, Appendix B,
PS 2, 3, 4 and6.
Emissions testing will be conducted on the CEMS serving the FCCU WGS Unit 25.
PS testing will be conducted at greater than 50% of the maximum normal load.
The stack flow RATA will include a minimum of nine (9) and a maximum of twelve (12) velocity profiles
conducted per U.S. EPA Reference Test Method 2. Concurrent dry gas molecular weight and stack gas
moisture measurements will be made per U.S. EPA Reference Test Methods 3A and 4, respectively. Each
flow profile will be conducted for 2l minutes. Moisture test runs will be conducted to span multiple flow
runs and will consist of 3 - 4 60-minute runs.
The SOz RA will be shown in pounds per hour (lb/hr) as well as in parts per million dry (ppmvd).
The flow RATA will be conducted concurrently with the gas RATA for emission rate calculations.
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:
rla
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CEMS data
CERMS data
2.3 Proposed Test Schedule
Table 2-1 presents an outline and tentative schedule for the emissions testing program.
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Af;lEE)Site Specrfic Test Plan
Summary ofTest Programs
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Table 2-l: Program Outline and Tentative Test Schedule
2.4 Emission Limits
Emission limits for each pollutant are below.
Table 2-2: Emission Limits
Testing Locetion Peremcter US EPA Mcthod No. ofRuns Run Dumtlon Est. Onsitc
Tlme
DAY I - June 30, 2025
Equipment Setup & Pretest QA/QC Checks 4hr
DAY 2 - July l, 2025
FCCU WGS Unit 25
VFR t-2 9-t2 2l min
r0 hr
BWS 4 3-4 60 min
01 / co:3A
9-t2 2l min
SO:6C
NOx 7E
CO l0
Source CEMS Rcquired Rclrtive
Accurrcv
Applicrblc Stenderd /
Limit Citrtion
Unit 25
VFR 120 o/o 60, Appendix B, PS 6
o:<20%(RM)orrl%oOt
(avs. diff.)60, Appendix B, PS 3
CO:S20 % (RM) or + I %o COz
(avs. diff.)60, Appendix B, PS 3
SO:S20 % (RM) or 510 % (AS)50 ppmvd @ 0o/o 02 60, Appendix B, PS 2
NOx <20 % (RM) or Sl0 % (AS)80 ppmvd @O%Ot 60, Appendix B, PS 2
CO <10 % (RM) or 55 % (AS)500 ppmvd @0o/oOz 60, Appendix B, PS 4
AST-2025-2121-001 IIF Srnclarr West Bountitul. UT Page 2-2
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I Site Specific Test Plan
Summary ofTest Programs
2.5 Test Report
I The final test report must be submitted within 60 days of the completion of the performance test and will include the
I following information.
e Introductior - Brief discussion of project scope of work and activities.
I . 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 conditionsI : y!i;ti;-:::i:::!x;:il;Tl:#ililil:ill:::.:'..'
I : ;:::,,i":";:ii:;'-^::;:llT',':'J#i,f:ffi;:l"ilTliii.a,ibra,i.n gas ce.inca,es
o Process Operating/Control System Data - Process operating and control system data (as provided by HF
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Sinclair) to support the test results.
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Aliatpe Site Specrrtc T'est Plan
Tesring lvlerhodologl
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 Methods I and 2 - Sampling/Traverse Points and Volumetric Flow Rate
The sampling location and number of traverse (sampling) points will be selected in accordance with U.S. EPA
Reference Test Method l. To determine the minimum number of traverse points, the upstream and downstream
distances will be equated into equivalent diameters and compared to Figure l-2 in U.S. EPA Reference Test Method
t.
Full velocity traverses will be conducted in accordance with U.S. EPA Reference Test Method 2 to determine the
average stack gas velocity pressure, static pressure and temperature. The velocity and static pressure measurement
system will consist of a pitot tube and inclined manometer. The stack gas temperature will be measured with a K-
type thermocouple and pyrometer.
Stack gas velocity pressure and temperature readings will be recorded during each test run. The data collected will
be utilized to calculate the volumetric flow rate for comparison to the continuous emission rate monitoring system
(CERMS). The relative accuracy of the CERMS will be determined based on procedures found in 40 CFR 60,
Performance Specifi cation 6.
3.2 U.S. EPA Reference Test Method 3A - Oxygen/Carbon Dioxide
The oxygen (O:) and carbon dioxide (CO:) testing will be conducted in accordance with U.S. EPA Reference Test
Method 3A. Data witl be collected online and reported in one-minute averages. 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
Perameter U.S. EPA Refcrence
Test Methods Notes/Remerks
Volumetric Flow Rate t&2 Full Velocity Traverses
Oxygen / Carbon Dioxide 3A Instrumental Analysis
Moisture Contenl 4 Gravimetric Analysis
Sulfur Dioxide 6C lnstrumental Analysis
Nitrogen Oxides 7E lnstrumental Analysis
Carbon Monoxide l0 lnstrumental Analysis
Gas Dilution System Certification 205
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AI Site Specific Test Plan
Testing Methodology
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
3.8.
The relative accuracy of the Oz and COz CEMS will be determined based on procedures found in 40 CFR 60,
Appendix B, Performance Specification 3.
3.3 U.S. EPA Reference Test Method 4 - Gas Moisture Content
The stack gas moisture content will be determined in accordance with U.S. EPA 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
known quantity of water or silica gel. Each impinger will be analyzed gravimetrically before and after each test run
on the same analytical balance to determine the amount of moisture condensed.
3.4 U.S. EPA Reference Test Method 6C - Sulfur Dioxide
The sulfur dioxide (SO2) testing will be conducted in accordance with U.S. EPA Reference Test Method 6C. Data
will be collected online and reported in one-minute averages. The sampling system will consist of a heated stainless
steel probe, Teflon sample line(s), gas conditioning system and the identified analyzer. The gas conditioning system
will be a non-contact condenser used to remove moisture from the source 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 3.8.
The relative accuracy of the SOz CEMS will be determined based on procedures found in 40 CFR 60, Appendix B,
Performance Specifi cation 2.
3.5 U.S. EPA Reference Test Method 7E - Nitrogen Oxides
The nitrogen oxides (NOx) testing will be conducted in accordance with U.S. EPA Reference Test Method 7E. Data
will be collected online and reported in one-minute averages. 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 3.8.
The relative accuracy of the NOx CEMS will be determined based on procedures found in 40 CFR 60, Appendix B,
Performance Specification 2.
3.6 U.S. EPA Reference Test Method 10 - Carbon Monoxide
The carbon monoxide (CO) testing will be conducted in accordance with U.S. EPA Reference Test Method 10.
Data will be collected online and reported in one-minute averages. 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 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 3.8.
The relative accuracy of the CO CEMS will be determined based on procedures found in 40 CFR 60, Appendix B,
Performance Specifi cation 4.
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Site Specifc Test Plan
Testing Methodology
3.7 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 l0o/o of one of the gas divider settings described above, will be
introduced directly to the analyzer, and the analyzer response recorded in an electonic field data sheet. The
cylinder concentration and the analyzer response must agree within 2%o. These steps will be repeated three (3)
times. The average arlalyzer response must agree within 2o/o of the predicted gas concentration. No single injection
shall differ more than 2o/o from the average instrument response for that dilution.
3.8 Quality Assurance/Quality Control - U.S. EPA Reference Test Methods 3A, 6C, 7E and l0
Cylinder calibration gases will meet EPA Protocol I (+l- 2o/o) 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 ppmvl%;o 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 0.5 ppml%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 0.5 ppm/% (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 ppml%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 0.5 ppmv/% 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 0.5 ppmv/%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 0.5 ppmv/%
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 twelve traverse points (as described in Method 1) 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.
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AI Site Specific Test Plan
Testing Methodolopy
If the pollutant concentration at each traverse point does not differ more than 5o/o or 0.5 ppm/O.3o/o (whichever is less
restrictive) of the average pollutant concentration, then single point sampling will be conducted during the test runs.
If the pollutant concentration does not meet these specifications but differs less than l0o/o or I .0 ppm/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 1.0 ppm/0.5o/ofrom the average
concentration, then sampling will be conducted at a minimum of twelve (12) traverse points. Copies of stratification
check data will be included in the Quality Assurance/Quality Control Appendix of the report.
An NOz - NO converter check will be performed on the analyzer prior to initiating testing or at the completion of
testing. An approximately 50 ppm nitrogen dioxide cylinder gas will be introduced directly to the NOx analyzer and
the instrument response will be recorded in an electronic data sheet. The instrument response must be within +A l0
percent of the cylinder concentration.
A Data Acquisition System with battery backup will be used to record the instrument 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.
lEerta
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Site Specifc Test Plan
Qual ity A s s uranc e P rog ra m
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, perrnanent identification number. Prior to mobilizing for the test
program, 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.
e 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 conection 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.
o 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 coefficient 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. NIST-traceable thermocouple calibrators
are calibrated annually by an outside laboratory.
o 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.
AST-2025-2121-001 HF Sinclair - West Bountiful, UT Page 4- I
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Site Spectfic 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 + 2 percent absolute. Barometers not meeting this
requirement are adjusted or taken out of service.
Balances and Weiehts. 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 intemally, 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.
. Sample trains will be leak checked before and after each test run.
o Appropriate probe, filter and impinger temperatures will be maintained.
. 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.
o All raw data will be maintained in organized manner.
e All raw data will be reviewed on a daily basis for completeness and acceptability.
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AST-2025-2121-001 HF Srnclair - West Bountiful, UT Page 4-2