DAQ-2024-007728

1

DAQC-408-24
Site ID: 10123 (B4)
MEMORANDUM

TO: STACK TEST FILE – HF SINCLAIR WOODS CROSS REFINING, LLC

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Paul Morris, Environmental Scientist

DATE: May 1, 2024

SUBJECT: Sources: 19H1 and Boiler #9
Contact: Travis Smith – 801-299-6625
Location: 393 South 800 West, Woods Cross, Davis County, UT
Tester: Alliance Technical Group, Inc.
FRS ID #: UT000004901100013
Permit/AO#: Approval Order (AO) AN101230057-23 dated November 15, 2023
Subject: Review of Stack Test Protocol dated April 16, 2024

On April 23, 2024, the Utah Division of Air Quality (DAQ) received a protocol for testing of the HF
Sinclair Woods Cross Refining process heater units 19H1 and Boiler #9 located in Woods Cross, Utah.
Testing will be performed May 23 and 24, 2024, to determine compliance with AO Conditions II.B.6.b
and II.B.6.c. Testing for these units was originally scheduled for April 1-5, 2024, but could not be
completed due to a process unit upset at the time.

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 7E for the determination of NOx emissions: OK
6. RM 10 for the determination of CO emissions: OK
7. RM 205 used for gas dilution system certification: OK

DEVIATIONS: No deviations were noted.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: Send protocol review and test date confirmation notice.

ATTACHMENTS: Pretest protocol dated April 16, 2024

6 , 3
,,tttF$nctor tIfAH DEPARTITIENT OF
ENVIRONMENIAL OUATITY
APR Z 3 'ii)',;\
DIVISION OF AtR QUALIN'
April16,2024
Mr. Bryce Bird, Director CertifredMail:7l22 0410 0002 3551 6523
Division of Air Quality
Utah Dept. of Environmental Quality
195 North 1950 West
Salt L,ake city, Utah 841l6
RE: CO Compliance Testing Reschedule Notification - 19H1, DHT Charge Furnace
HF Sinclair Woods Cross Refining LLC, Davis County
Dear Mr. Bird:
HF Sinclair Woods Cross Refining LLC, TIFSWCR, is submitting this notification to inform UDAQ that
the performance testing of 1 9H I has been rescheduled from the dates of April I , 2024 - April 5, 2024, as
stated in the protocol and initial test notification letter, dated February 29,2024. Testing has been
rescheduled due to a process unit upset at the time of initial testing.
Additionally, in accordance with Section R307-165-3, and Condition II.B.l.a of Approval Order DAQE-
ANI01230057-23, HF Sinclair Woods Cross Refining LLC is providing notification of source testing
planned to be conducted at the Woods Cross Refinery. Alliance Technical Group, LLC of Salt Lake City,
[-II, has been contracted to conduct the testing.
19Hl testing for CO is now planned to commence on May 24,2024. A copy of the test protocol is
enclosed.
If you have any questions or need additional information, please contact F. Travis Smith at (801) 299-
6625.
Sincerely,
F. Travis Smith
Environmental Specialist
c: E. Benson (r)File2.4.4
J. Barton
J. Orr
HF Sinclair Woods Cross Refining LLC
1070 W. 500 S, West Bountiful, UT 840&7
801-299-6600 | HFSinclair.com
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Site Specific Test Plan
HF Sinclair Woods Cross Refining, LLC
1070 west 500 South DtvrstoN oF AtR QuALtTv
West Bountiful, UT 84087
Source to be Tested: Boiler No. 9 & Heater 19Hl
Proposed Test Dates: May 23 & 24,2024
Fla
Proj ect No. AST-2024-2224
Prepared By
Alliance Technical Group, LLC
3683 W 2270 S, Suite E
West Valley City, UT 84120
pd/lffirrrc.e
TECHNICAL GROUP Site Specific Test Plan
Test Program Summary
Regulatory Information
Permit No.
Source Information
DAQE-ANl0t2300s7-23
Source Name
Refinery Gas Fired Boiler
Refinery Gas Fired Process Heater
Source ID
Boiler No. 9
l9Hl
Target Parameter
NOx
CO
Contact Information
Test Location
HF Sinclair Woods Cross Refining,LLC
1070 West 500 South
West Bountiful, UT 84087
Eric Benson
eric.benson@hfsinclair. com
[phone]
F. Travis Smith
fo avis. smith@hfsinclair. com
(801) 299-662s
Test Company
Alliance Technical Group, LLC
3683 W 2270 S, Suite E
West Valley City, UT 84120
Project Manager
Charles Horton
charles.horton@alliancetg. com
(3s2) 663-7s68
Field Team Leader
Tobias Hubbard
tobias. hubbard@alliancetg. com
(60s) 64s-8s62
(subject to change)
QA/QC Manager
Kathleen Shonk
katie. [e-mail]
(812\ 4s2478s
Test Plan/Report Coordinator
Delaine Spangler
delaine. spangler@alliancetg. com
AST-2024-2224 IIF Sinclair- West Bountifi.rl, UT Page i
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Site Specific Test PlanTECIINICAL GROUP
TABLE OF CONTENTS
l.l Emission Unit and Control Unit Descriptions............. .............. l-l
2.0 Summar of Test Program....... .......-....2-l
2.2 ProcesslControf Systsm Parameters to be Monitored and Recorded ..,.,..,..-..,..2-l
2.3 Proposed Test Schedule.................. .....................2-l
3.1 U.S. EPA Reference Test Method 34. - Oxygen/Carbon Dioxide........ ......... 3-l
3.2 U.S. EPA Reference Test Method 7E - Nitrogen Oxides......... ..................... 3-l
3.3 U.S. EPA Reference Test Method l0 - Carbon Monoxide.... ........................ 3-l
3.4 U.S. EPA Reference Test Method 205 - Gas Dilution System Certification. .....................3-2
3.5 Quality Assurance/Quality Control - U.S. EPA Reference Test Methods 3A, 7E and 10.......................3-2
LIST OF TABLES
Table 2-l: Program Outline and Tentative Test Schedu1e................... ......2-l
AST-2024-2224 HF Sinclair- West Bountiful, UT Page ii
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(illl.Il(lAt ()noi.it,Site Specific 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 Woods Cross refinery in West Bountiful, UT. Portions of the facility are
subject to provisions of the Utah Department of Environmental Quality, Division of Air Quality (UDAQ) Permit
No. DAQE-ANI01230057-23. Testing will be conducted to determine the emission rate of nitrogen oxides (NOx)
from the exhaust of Boiler No. 9 and the emission rate of carbon monoxide (CO) at the exhaust of Heater l9H L
This site-specific test plan (SSTP) has been prepared to address
UDAQ permit.
the notification and testing requirements of the
l.l Emission Unit and Control Unit Descriptions
1.2 Project Team
Personnel planned to be involved in this project are identified in the following table.
Table 1-1: Project Team
1.3 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) will be completed daily by the Alliance Field Team Leader.
Unit ID Process Description Air Pollution Controls
Boiler No. 9 Steam boiler, 89.3 MMBtu/hr HHV, fired on plant gas,
forced draft, I burner, side-fired fumace, no air preheat.
Stack temperature approximately 360-500'F.
Selective catalytic reduction using
aqueous or anhydrous ammonia
l9Hl Diesel Hydrotreater (DHT) Reactor Charge Heater,23
MMBtu/hr HHV, fired on plant gas, natural draft, 3
bumers, up-fired furnace. Stack temperature
approximately 640 to 720'F.
Low NOx bumers
HF Sinclair Personnel F. Travis Smith
Regulatory Agency UDAQ
Alliance Personnel Tobias Hubbard
other field personnel assigned at time of testing event
AST-2024-2224 HF Sinclair West Bountiful, UT Page 1-l
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TECHNICAL GROUP Site Specifc Test Plat
Sumttnry of Test Programs
2.0 Summary of Test Program
To satisfy the requirements of the UDAQ permit, the facility will conduct a perforrnance test program to determine
the compliance status of Boiler No. 9 and Heater l9Hl .
2,1 General Description
All testing will be performed in accordance with specifications stipulated in U.S. EPA Reference Test Methods 3A,
7E, and 10. Table 2-l presents an outline and tentative schedule for the emissions testing progpm. The following is
a summary of the test objectives.
Testing will be performed to demonstrate compliance with the UDAQ perrnit.
Emissions testing will be conducted on the exhaust of Heater l9Hl and Boiler No. 9
Perfomtance testing will be conducted at the marimum normal operation load for each source.
Each of the three (3) test runs will be approximately 60 minutes in duration for each source.
2.2 Process/Control System Parameters to be Monitored and Recorded
Plant personnel will collect operational and parametric data at least once every 15 minutes during the testing. The
following list iderftifies the measurements, observations and records that will be collected during the testing
program:
Calculated fuel gas flow rate - mscfld or mscflhr
Fuel gas GHV - Btu/scf
Heat Input -MMBtu/hr
Fuel Gas Analysis
Ammonia flow rate (if the unit is equipped with SCR and if ammonia flow rate is monitored)
2.3 Proposed Test Schedule
Table 2-l presents an outline and tentative schedule for the emissions testing program.
Table 2-1: Program Outline and Tentative Test Schedule
a
a
a
a
a
a
o
a
a
DAYI-May23,2024
Equipment Setup & Pretest QA/QC Checks
DAY2-May24,2024
AST-2024-2224 IIF Sinclair- West Bouatiful, UT Page2-l
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Site Specific Test Plan,=""*,"o,_ aroouo ,,.,orr.r",,",,*,o,,
2.4 Emission Limits
Emission limits for each pollutant are below.
Table 2-2: Emission Limits
2.5 Test Report
The final test report must be submiffed within 60 days of the completion of the performance test and will include the
following information.
o Introduction -Brief discussion of project scope of work and activities.
Results and Discussion - A surnmary of test results and process/control system operational data with
comparison to regulatory requirements or vendor guarantees along with a description of process conditions
and/or testing deviations that may have affected the testing results.
Methodologlt - A description of the sampling and analytical methodologies.
Sample Calculations - Example calculations for each target parameter.
Field Data - Copies of actual handwritten or electronic field data sheets.
Laboratory Data - Copies oflaboratory report(s) and chain ofcustody(s).
Quality Control Data - Copies of all instrument calibration data and/or calibration gas certificates.
Process Operating/Control System Data - Process operating and control system data (as provided by HF
Sinclair) to support the test results.
a
a
a
a
a
a
NOx: 0.02 lbA4MBtu
Heater l9Hl CO: 0.040 lb/]vlMBtu
AST-2024-2224 HF Sinclair- West Bountiful. UT Page2-2
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Site Specifc Test Plan
Testing MethodolopvTECI.I NICAL GROUP
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 3-1: Source Testing Methodology
All stack diameters, depths, widths, upstream and downsteam 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 Method 3A - Oxygen/Carbon Dioxide
The oxygen (Oz) and carbon dioxide (COz) testing will be conducted in accordance with U.S. EPA Reference Test
Method 3,{. 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
3.5.
3.2 U.S. EPA Reference Test Method 7E - Nitrogen Oxides
The nirogen 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 3.5.
3.3 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 3.5.
Oxygen / Carbon Dioxide
Gas Dilution System Certification
AST-2024-2224 HF Sinclair - West Bountiful, UT Page 3-l
pd/a6rpe
Site SpeciJic Test Plan
Testing Methodolowi \J l(;i\ I () {t ().1 t)
3.4 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 two dilutions on each mass flow controller. The diluted calibration gases will be sent
directly to the analyzer, and the analyzer response recorded in an electronic field data sheet. The analyzer response
must agree within 2Yo of the actual diluted gas concentration. A second Protocol I calibration gas, with a cylinder
concentration within l0% of one of the gas divider settings described above, will be introduced directly to the
analyzer, and the analyzer response recorded in an electronic field data sheet. The cylinder co4cenffation and the
analyzer response must agree within2o/o. These steps will be repeated three (3) times.
3.5 Quality Assurance/Quality Control - U.S. EPA Reference Test Methods 3A, 7E and 10
Cylinder calibration gases will meet EPA Protocol I (+l- 2%) 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 ppmvlo/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 ppmlo/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/o/o (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 ppm/%
(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/o/o 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/% 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.
AST-2024-2224 HF Sinclair - West Bountiful, UT Page 3-2
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Site Spec{ic Test Plan
Testins MethodolowTECIINICAT GROUP
If the pollutant concentration at each traverse point do not differ more than 5o/o or 0.5 ppm/0.3% (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 l\oh or 1.0 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 10o/o or 1.0 ppm/0.5% from 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 Contol 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 +/- 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.
AST-2024-2224 HF Sinclair - West Bountiful, UT Page 3-3
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, permanent 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 retuming 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-94/038c, 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.
o 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 correction factor (Y) and the meter's orifice pressure differential (AH@). Alliance uses approved
Alternative Method 009 as a post-test calibration check to ensure that the correction factor has not changed
more than 5% 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. NlST-traceable thermocouple calibrators
are calibrated annually by an outside laboratory.
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.
Disital Calipers. Calipers are calibrated annually by Alliance by using gage blocks that are calibrated
annually by an outside laboratory.
AST-2024-2224 HF Sinclair West Bountiful, UT Page 4-l
4.2
I t ciit,t ICAI Gno[]t,Site Specific Test Plan
Qua I ily A s surance P ro pram
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 ofservice.
Balances and Weiehts. Balances are calibrated annually by an outside laboratory. A functional check is
conducted on the balance each day it is use 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 o4 girch F.nvironics 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.
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.
o Sample trains will be leak checked before and after each test run.
. Appropriate probe, filter and impinger temperatures will be maintained.
e 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.
r An isokinetic sampling rate of 90-l l0% will be maintained, as applicable.
o All raw data will be maintained in organized manner.
o All raw data will be reviewed on a daily basis for completeness and acceptability.
UTAH DEPARTMENT OF
ENVIRONMENTAL QUAUry
UiVISION OF AIR QUALIT\.
AST-2024-2224 HF Sinclair West Bountiful, UT Page 4-2
,dttF$nctor
HF SinclairWoods Cross Refining LLC
1070 W. 500 S, West Bountiful, UT 84087
801 -299-6600 | HFSinclair.com
UTAH DEPARruE}.IT OF
ENVIRONMENTAL OUATITY
APR 23 Zc,Zl
DIVISION OF AIR QUALM'
April16,2024
Mr. Bryce Bird, Director Certified Mail: 7022 0410 0002 3551 6530
Division of Air Quality
Utah Dept. of Environmental Quality
195 North 1950 West
salt lake city, Utah 84116
RE: NOx Compliance Testing Reschedule Notification - Boiler #9
IIF Sinclair Woods Cross Refining LLC, Davis County
Dear Mr. Bird:
HF Sinclair Woods Cross Refining LLC, HFSWCR, is submitting this notification to inform UDAQ that
the performance testing of Boiler #9 has been rescheduled from the dates of April 1,2024 - April 5,2024,
as stated in the protocol and initial test notification letter, dated February 29,2024. Testing has been
rescheduled due to equipment maintenance that was taking place at the time of initial testing.
Additionally, in accordance with Section R307-165-3, and Condition tr.B.l.a of Approval Order DAQE-
ANI01230057-23, tIF Sinclair Woods Cross RefiningLLC is providing notification of source testing
planned to be conducted at the Woods Cross Refinery. Alliance Technical Group, LLC of Salt Lake City,
UT, has been contracted to conduct the testing.
Boiler #9 testing for NOx is now planned to commence on May 23,2024. A copy of the test protocol is
enclosed.
For reference, Boiler #9 was last tested for NOx on May 27,202I.
If you have any questions or need additional information, please contact F. Travis Smith at (801) 299-
6625.
Sincerely,
F. Travis Smith
Environmental Specialist
c: E. Benson (r\Fite2.4.4
J. Barton
J. Orr
AtAre
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Site Specific Test Plan
HF Sinclair woods cross Refining, LLC
ijtVl$ioN oF AIR QuAL[y
1070 West 500 South
West Bountiful, UT 84087
Source to be Tested: Boiler No. 9 & Heater l9H1
Proposed Test Dates: May 23 & 24,2024
Project No. AST -2024-2224
Prepared By
Alliance Technical Group, LLC
3683 W 2270 S, Suite E
West Valley City, UT 84120
All6nrc.eTECHNICAL GROUP Site Specific Te* Plan
Test Prosran Surrrrrl,ary
Requlatory Informetion
Permit No.
Source Informatlon
DAQE-4I.I10t2300.57-23
Source Name
Refinery Gas Fired Boiler
Refinery Gas Fired Process Heater
Target Parameter
NOx
CO
Test Location
HF Sinclair lVoods Cross Refining, LLC
1070 West 500 South
WestBountiful, UT 84087
- Eric Benson
[e-mail]
[phone]
F. Travis Smith
fu avis. [e-mail]
(80t)299-662s
Test Company
Alliance Technical Crroup, LLC
3683W 2270 S, Suito E
West Valley City, UT Ml20
ProjectManago
Charles Horton
[e-mail]
Qs2)663-7s68
Field Team Leader
Tobias Hubbard
[e-mail]
(605\ @s-8s62
(zubject to change)
QA/QCManager
Kathleen Shonk
[e-mail]
(812\452478s
Test Plan/Report Coordinator
Delaine Spanglo
[e-mail]
AST-202*2224 HF Sinclair - Wcst Bormtitul, UT Page i
TABLE OF CONTENTS
l.l Emission Unit and Control Unit Descriptions............. .............. l-1
2.0 Summar of Test Program....... ............2-l
2,2 Process/Control Syslem Parameters to beMonitored and Rec-orded.*--* ,,.,-,,...2=l
2.3 Proposed Test Schedule.................. .....................2-l
3.1 U.S. EPA Reference Test Method 3A - Oxygen/Carbon Dioxide................... ................... 3-1
3.2 U.S. EPA Reference Test Method 7E -Nitrogen Oxides......... ..................... 3-l
3.3 U.S. EPA Reference Test Method l0 - Carbon Monoxide.... ........................ 3-l
3.4 U.S. EPA Reference Test Method 205 - Gas Dilution System Certification. .....................3-2
3.5 Quality Assurance/Quality Control - U.S. EPA Reference Test Methods 3A,78 and 10.......... .............3-2
LIST OF TABLES
Table 2-1: Program Outline and Tentative Test Schedu1e................... ......2-l
AST-2024-2224 HF Sinclair- West Bountiful, UT Page ii
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TtCllNtoAt Gn()r.ll)Site SpeciJic 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 Woods Cross refinery in West Bountiful, UT. Portions of the facility are
subject to provisions of the Utah Department of Environmental Quality, Division of Air Quality (UDAQ) Permit
No. DAQE-ANI0I230057-23. Testing will be conducted to determine the emission rate of nitrogen oxides (NOx)
from the exhaust of Boiler No. 9 and the emission rate of carbon monoxide (CO) at the exhaust of Heater I 9H I .
This site-specific test plan (SSTP) has been
UDAQ permit.
prepared to address the notification and testing requirements of the
1.1 Emission Unit and Control Unit Descriptions
1.2 Project Team
Personnel planned to be involved in this project are identified in the following table.
Table 1-1: Project Team
1.3 Safety Requirements
Testing personnel will undergo site-specific safety haining 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, hre 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) will be completed daily by the Alliance Field Team Leader.
Unit ID Process Description Air Pollution Controls
Boiler No. 9 Steam boiler, 89.3 MMBtU/hr HlfV, fired on plant gas,
forced draft, I burner, side-fired fumace, no air preheat.
Stack temperature approximately 360-500"F.
Selective catalytic reduction using
aqueous or anhydrous ammonia
l9Hl Diesel Hydrotreater (DHT) Reactor Charge Heater,23
MMBtu/hr HHV, fired on plant gas, natural draft, 3
bumers, up-fired furnace. Stack temperature
approximately 640 to 720'F.
Low NOx burners
HF Sinclair Personnel F. Travis Smith
Regulatory Agency UDAQ
Alliance Personnel Tobias Hubbard
other field personnel assigned at time of testing event
AST-2024-2224 HI Sinclair - West Bountiful, UT Page l-l
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TECHNICAL GROUP Site Specific Test Plan
Summarv of Test Proprams
2.0 Summary of Test Program
To satisft the requiranents of the UDAQ permit, the facilify will conduct a performance test program to determine
the compliance status of Boiler No. 9 and Heater l9Hl.
2.1 General Description
All testing will be performed in accordance with specifications stipulated in U.S. EPA Reference Test Methods 3A,
78, and 10. Table 2-l presents an outline and tentative schedule for the emissions testing progmm. The following is
a summary of the test objectives.
Testing will be perfonned to demonstrate compliance with the UDAQ permit.
Emissions testing will be conducted on the exhaust of Heater l9Hl and Boiler No. 9
Performance testing will be conducted at the ma"rimum normal operation load for each source.
Each of the three (3) test runs will be approximately 60 minutes in duration for each source.
2.2 Process/Control System Perameters to be Monitored and Recorded
Plant personnel will collect operational and parametric data at least once every 15 minutes during the testing. The
following list identifres the measurements, observations and records ttrat will be collected during the testing
progmm:
Calculated fuel gas flow rate - mscfld or mscflhr
Fuel gas GIIV - Btu/scf
Heat Input - MMBtulhr
Fuel Gas Analysis
Ammonia flow rate (if the unit is equipped with SCR and if ammonia flow rate is monitored)
2.3 Proposed Test Schedule
Table 2-l presents an outline and tentative schedule for the emissions testing program.
Table 2-1: Program Outline end Tentative Test Schedule
a
a
a
a
O
a
a
a
a
DAY I -May 23,2024
Equipment Setup & Pretest QA/QC Checks
DAY2-May24,2024
AST-2024-2224 tIF Sinclair - West Bountiful, UT Page2-l
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TECIJNICAL GROUP Site SpeciJic Test Plan
Summarv of Test Prosrams
2.4 Emission Limits
Emission limits for each pollutant are below.
Table 2-2: Emission Limits
2.5 Test Report
The final test report must be submitted within 60 days of the completion of the performance test and will include the
following information.
c Introduction -Bief discussion of project scope of work and activities.
o Results and Dkcussion - 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 conditions
and./or testing deviations that may have affected the testing results.
o Methodology - A description of the sampling and analytical methodologies.
o Sample Calculations - Example calculations for each target parameter.
o Field Data - Copies of actual handwritten or elechonic field data sheets.
o Lqboratory Data - Copies oflaboratory report(s) and chain ofcustody(s).
c Quality Control Data - Copies of all instrument calibration data and/or calibration gas certificates.
o Process Operating/Control System Data - Process operating and control system data (as provided by HF
Sinclair) to support the test results.
NOx: 0.02 lbA4MBtu
Heater 19Hl CO: 0.040 lb/MMBtu
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Site Specific Test Plan
Testins MethodolopyTECI..INICAL GROUP
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 progam. 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 3-1: Source Testing Methodology
All stack diameters, depths, widths, upstream and downsteam 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 Method 3A - Orygen/Carbon Dioxide
The oxygen (Oz) and carbon dioxide (CO2) testing will be conducted in accordance with U.S. EPA Reference Test
Method 3A. 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 conhol measures are described in Section
3.5.
3.2 U.S. EPA Reference Test Method 7E - Nitrogen Oxides
The nifogen 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 conhol measures are described in Section 3.5.
3.3 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 po(able 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 3.5.
Gas Dilution System Certification
AST-2024-2224 IIF Sinclair- West Bountiful, UT Page 3-l
3.4 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 two dilutions on each mass flow controller. The diluted calibration gases will be sent
directly to the analyzer, and the analyzer response recorded in an electronic field data sheet. The analyzer response
must agree within 2o/o of the actual diluted gas concentration. A second Protocol I calibration gas, with a cylinder
concentration within 10% of one of the gas divider settings described above, will be inhoduced directly to the
analyzer, and the analyzer response recorded in an electronic field data sheet. The cylinder concentration and the
analyzer response must agree within 2Yo. These steps will be repeated three (3) times.
3.5 Quality Assurance/Quality Control - U.S. EPA Reference Test Methods 3A, 7E and 10
Cylinder calibration gases will meet EPA Protocol I (+l- 2%) 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 ppmv/%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 pprn/oh (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 inhoduced 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 ppm/%
(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/o% 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/% 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 ppmvlYo
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 fwelve traverse points (as described in Method l) 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.
AST-2024-2224 HF Sinclair West Bountiful. UT Page 3-2
If the pollutant concentration at each traverse point do not differ more than 5% or 0.5 ppml}.3% (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 l|oh or 1.0 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 10o/o or 1.0 ppm/0.5% from 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 +i- 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.
LST-2024-2224 HF Sinclair- West Bountiful, UT Page 3-3
Site Specific Test Plan
Quality Assurance Program
4.0 Quatity 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, permanent 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-600,1R-94/038c, 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.
o 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 correction factor (Y) and the meter's orifice pressure differential (AH@). Alliance uses approved
Alternative Method 009 as a post-test calibration check to ensure that the correction factor has not changed
more than 5olo since the last full meter calibration. This check is performed after each test series.
r 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 coeff,rcient 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. NlST-traceable thermocouple calibrators
are calibrated annually by an outside laboratory.
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.
Dieital Calipers. Calipers are calibrated annually by Alliance by using gage blocks that are calibrated
annually by an outside laboratory.
AST-2024-2224 HF Sinclair West Bountiful, UT Page 4-l
Ar6r*oriNtoAt 63()i.l l)Site Specific Test Plan
Oualitv Assurance Prosram
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 ofservice.
Balances and Weiehts. Balances are calibrated annually by an outside laboratory. A functional check is
conducted on the balance each day it is use in the field using a calibration weight. Weights are re-certified
every fwo (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 Eouipment. 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.
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:
. Cleaned glassware and sample train components will be sealed until assembly.
o Sample hains will be leak checked before and after each test run.
o Appropriate probe, filter and impinger temperatures will be maintained.
o 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- I I 0% will be maintained, as applicable.
o All raw data will be maintained in organized manner.
. All raw data will be reviewed on a daily basis for completeness and acceptability.
4.2
_!{T4H DFPART^4FMr oFENVIRoN^rFNrar_ oueimv
I D r.,t i' t''
IJ'VISION OF AIR QUALIN'
AST-2024-2224 HF Sinclair - West Bountiful, UT Page 4-2