DAQ-2024-004087

SilverEagle
REFINING
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January 4,2024
Mr. Bryce Bird, Director
Utah Department of Environmental Quality
Division of Air Quality
P.O. Box 144820
Salt Lake City, Utah 84114-4820
Re: December 2023 SRU Efficiency Test Results and
Test Protocol for Additional Efficiency Testing.
Dear Mr. Bird:
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30-day Notification and Submission of SRU
Enclosed are the December 2023 effrciency test results for Silver Eagle Refining-Woods Cross
Inc.'s NASH Sulfur Recovery Unit. On December 26 through December 28,2023. efficiency
testing was conducted in accordance with the protocol submitted to the State on November 27,
2023, and as described in Silver Eagle Refining's Approval Order DAQE-AN101240030-16
(dated Nov. 9, 2016), Condition II.B.4. The Sulfur removal efficiency was 99.78oh.
To produce on-specification winter diesel products the severity of processing must be increased. This in
tum increases the amount of off gas produced. Therefore, Silver Eagle plans to conduct additional sulfur
removal efficiency testing of the Sulfur Recovery Unit the week of February 12 through February 16,
2024. Silver Eagle hereby submits the following protocol for testing the efliciency of the SRU.
Silver Eagle uses a unique sulfur recovery system. The SRU does not employ the oil refining standard
Amine/Clause sulfur recovery system. Silver Eagle uses a NASH system that directly scrubs H2S from
the plant gases using a solution of Sodium Hydroxide. The H2S{o-NASH reaction occurs in one vessel;
therefore, removal efficiency can be simply calculated by measuring the H2S concentrations at the inlet
and effluent of the NASH reactor vessel(s).
Silver Eagle's NASH Unit treats the following sulfur bearing streams:
MDDW Fractionator off-gas
MDDW Low Pressure Separator (LPS) off-gas
MDDW High Pressure Separator (HPS) off-gas
MDDW Stabilizer off-gas
All of the above gas streams combine into a single pipe that enters the NASH unit. The treated gas exits
the NASH unit and is sent to the plant fuel gas mixing drum.
The removal efficiency of the NASH unit will be determined as follows:
Testing will be conducted with the MDDW operating at its anticipated maximum production rate.
Efficiency testing procedures will be as follows:
1. The H2S concentration of the fuel gas streams entering and exiting the NASH Unit will be
measured with the use of concentration stain tubes (Gastech, RAE, Draeger or equivalent). H2S
measurements will be made at the inlet and then, as soon as possible, at the outlet of the NASH
2355 South I100 West . Woods Cross, Utah 84087
unit. One measurement of inlet gas coupled with one measurement at the outlet gas will constitute
one setofdata.
2. Six data sets will be taken over a 3-day period. Six removal efficiency calculations will be
performed, one for each data set. The SRU's efficiency shall be the average of the six sets.
The inlet concentration of H2S is expected to be two percent or less by volume; therefore the reduction in
mass and volumetric flow rates due to the removal of H2S in the NASH unit will be negligible and we
propose not to include them in the calculation of the percent reduction of sulfur. The percent reduction of
sulfur will be calculated as follows:
[(ConcSenteringSRU
yI I - (ConcSexitingSnu y+)t
mm 0 0) : P e rc e nt Re duc t io no/Sulfur
(ConcSenteringsRu \ )
m
Feel free to contact me if you need addition information concerning this notification. Thank you.
Sincerely,
@-WBlaine Zwahlen,{E
for Silver Eagle Refining-Woods Cross Inc.
Cc Mike Platz
James Shupe
Mandy Joseph
Gigi Camarena
Mike Klotovich
2355 South I100 West . Woods Cross, Utah 84087
Silver Eagle Refining - Woods Cross, lnc.
NASH Sulfur Recovery Unit Efficiency Test - December 2023
H2S, ppm
Test Dates:
Date
12t26t2023
12t26t2023
12t2712023
12t27t2023
12t28t2023
12t28t2023
Time
10:00
12:00
7:50
13:25
9:30
11:15
ln
1,500
1,000
1,100
1 ,150
1,200
1,000
Out
2.5
2.5
2.5
2
2.5
3
H2S Removal
Efficiency, %
99.83%
99.75%
99.77%
99.83%
99.79%
99.70o/o
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H2S Re moval Eficiency o/o =
il;l\/l;iloN OF A!R QL!At-lTY
Average 99.78o/o
l(Concentrat ion S Entering SRU , ppm) - (Concentrat ion S Exiting SRIJ , ppm)l _ ,nn
(Concentration S Entering SRU, ppm)
lnlet RAE Tube P/N: 10-103-40, range 0.1 -2.0o/o
lnlet HoneywellTube P/N: 10-103-30, range 100-2000 ppmv
Outlet HoneywellTube P/N: 10-103-04, range 0.2 - 3 ppmv
SRU Efficiency Calculated in Accordance with AO DAQE-AN101240030-16 (dated Nov. 9, 2016), Condition ll.B.4