DAQ-2024-005010

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-097-24
Site ID 10122 (B5)

Brady Miller, Environmental Engineer
Big West Oil Company
333 West Center Street
North Salt Lake, UT 84054

Dear Mr. Miller:

Re: Big West Oil Company - Pretest Protocol for Carbon Monoxide (CO), Carbon Dioxide
(CO2), Nitrogen Oxides (NOx), Oxygen (O2), Sulfur Dioxide (SO2) and Total
Hydrocarbons (THC) Relative Accuracy Test - Davis County

The Utah Division of Air Quality (DAQ) reviewed Big West Oil Company’s pretest protocol
dated January 24, 2024. The proposed test shall be performed under the following conditions:

Big West Oil Company’s monitoring system to be certified:

Point Source Channel Manufacturer Model # Monitor SN
MSCC
Regenerator Vent
CO ABB Uras26 01400301913010L
CO2 ABB Uras26 01400301913010L
NOx ABB Limas11 400000744810
O2 ABB Magnos206 01400100978401L
SO2 ABB Limas11 400000744810
Primary VRU TVOC Infrared Industries IR 8400D 5583
Backup VRU TVOC Infrared Industries IR 8400D 3560

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DAQC-097-24
Page 2

Alliance Technical Group will conduct a relative accuracy/performance specification test on Big
West Oil Company’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
March 12, 2024 MSCC
CO2 and O2 Method 3A
SO2 Method 6C
NOx Method 7E
CO Method 10
March 13, 2024 Primary VRU THC Method 25B
March 14, 2024 Backup VRU THC Method 25B

• 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 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 25B - Determination of Total Gaseous Organic Concentrations Using a
Non-dispersive Infrared Analyzer as outlined in 40 CFR 60 Appendix A. Zero drift and
calibration drift checks are required at the beginning and end of each run.

• Reference Method 205 – Gas Dilution System Certification – 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.

DAQC-097-24
Page 3

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 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-097-24
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

HB:RL:jl

cc: Davis County Health Department
Alliance Technical Group

* $ . # ( ) - — F v A ? A C @ @ w ? H ˜
Rob Leishman Jr