DAQ-2024-004338

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-1350-23
Site ID 10335 (B5)

Crystal Beffa, Environmental Engineer
Tesoro Refining and Marketing Company, LLC
474 West 900 North
Salt Lake City, Utah 84103-1494

Dear Ms. Beffa:

Re: Tesoro Refining and Marketing Company, LLC (Tesoro) – Pretest Protocol for Carbon
Monoxide (CO), Carbon Dioxide (CO2), Sulfur Dioxide (SO2), Nitrogen Oxides (NOx),
and Oxygen (O2) Relative Accuracy Test – Salt Lake County

The Utah Division of Air Quality (DAQ) reviewed Tesoro’s pretest protocol dated December 5,
2023. The proposed test shall be performed under the following conditions:

Tesoro’s monitoring system to be certified:

Point Source Channel Manufacturer Model # Monitor SN
FCCU REGEN
Primary
CO Horiba CMA-467H EASVUCN2
CO2 Horiba CMA-467H EASVUCN2
O2 Horiba CMA-467H EASVUCN2
FCCU REGEN
Redundant
CO Horiba CMA-467H XU2F2W0
CO2 Horiba CMA-467H XU2F2W0
O2 Horiba CMA-467H XU2F2W0
COB Bypass
Primary
O2 Horiba GI-761CU N203PGVV
SO2 Horiba GI-761CU N203PGVV
NOx Horiba GI-761CU N203PGVV
Wet Gas Scrubber
Primary
O2 CAI 700 1908029
NOx CAI 700 1908029
SO2 Teledyne T100H 429
CO Horiba VIA-510 NP7X7084
Wet Gas Scrubber
Secondary
O2 CAI 700 1908030
NOx CAI 700 1908030
SO2 Teledyne T100H 428
CO Horiba VIA-510 UG7U00B
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DAQC-1350-23
Page 2

Alliance Technical Group, LLC will conduct a relative accuracy/performance specification test on
Tesoro’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
January 22-25,
2024
FCCU REGEN Primary and Redundant, COB
Bypass Primary and Redundant, and Wet Gas
Scrubber Primary and Redundant.
CO2 and O2 Method 3A
SO2 Method 6C
NOx Method 7E
CO Method 10

• 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 4 - Determination of Moisture Content in Stack Gases as
outlined in 40 CFR 60 Appendix A shall be used to determine the stack gas
moisture content.

• 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 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.
Acceptance of a protocol does not relieve the owner/operator and the testing
DAQC-1350-23
Page 3

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-1350-23
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

RL:rh

cc: Salt Lake County Health Department
Alliance Technical Group, LLC

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Rob Leishman Jr