DAQ-2024-007339

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. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
DAQC-313-24
Site ID 10124 (B5)

Blain Zwahlen, Environmental Engineer
Silver Eagle Refining
2355 South 1100 West
P.O. Box 870298
Woods Cross, UT 84087

Dear Mr. Zwahlen:

Re: Silver Eagle Refining (Silver Eagle) – Pretest Protocol for Hydrogen Sulfide (H2S)
Relative Accuracy Test – Davis County

The Utah Division of Air Quality (DAQ) reviewed Silver Eagle’s pretest protocol dated April 2,
2024. The proposed test shall be performed under the following conditions:

Silver Eagle’s monitoring system to be certified:

Point Source Channel Manufacturer Model # Monitor SN
Plant Gas Main Fuel Line H2S Siemens Maxum II 3003955197
Siemens Maxum II HOU30075841370010

Alliance Technical Group will conduct a relative accuracy/performance specification test on
Silver Eagle’s continuous monitoring system.

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.

The DAQ understands that testing will be conducted as follows:

Test Date Point Source Parameter EPA Reference Method
May 15-16, 2024 Plant Gas Main Fuel Line H2S Method 15

- / & ) Þ Û Ù Û Ý
DAQC-313-24
Page 2

• Reference Method 15 – Determination of Hydrogen Sulfide emissions from
stationary sources by GCFPD as outlined in 40 CFR 60 Appendix A.

• 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 (Point Source emission data and test data) shall be turned over 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 no later than 60 days after
completion of the test.

• The test report shall include all raw calibration data and raw emission data with
date and 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.
DAQC-313-24
Page 3

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

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:jl

cc: Davis County Health Department
Alliance Technical Group
* $ . # ( ) - — + - C v A ? A C @ A w A E ˜
Rob Leishman Jr