DAQ-2024-008173

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-516-24
Site ID 10007 (B5)

Javier Sosa Ortiz
Plant Manager
Holcim US Cement
6055 East Croydon Road
Morgan, Utah 84050

Dear Mr. Ortiz:

Re: Holcim (US) Inc. (Holcim) – Pretest Protocol for Carbon Dioxide (CO2), Flow, Nitrogen
Oxides (NOx), Oxygen (O2), Sulfur Dioxide (SO2), Mercury (Hg), Total Hydrocarbons
(THC) Relative Accuracy Test and Carbon Monoxide and Particulate Matter (PM)
Performance Test – Morgan County

The Utah Division of Air Quality (DAQ) reviewed Holcim’s pretest protocol dated May 15, 2024.
The proposed test shall be performed under the following conditions:

Holcim’s monitoring system to be certified:

Point Source Channel Manufacturer Model # Monitor SN
Kiln
CO2
ABB
AFC 5000 3.368022.6
NOx AFC 5000 3.368022.6
O2 AFC 5000 3.368022.6
SO2 AFC 5000 3.368022.6
THC ABB Multi FID 14 3.344762.1
Hg Tekran 3310xi 3122

Mostardi Platt will conduct a relative accuracy/performance specification test on Holcim’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 or lb Hg/MM ton clinker
30-DRA shall be tested as lb Hg/MM ton clinker.
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DAQC-516-24
Page 2

The DAQ understands that Mostardi Platt will conduct testing as follows:

Test Date Point Source Parameter EPA Reference Method
July 16-18, 2024 Kiln
Flow RM 1, 2, & 4
CO2/CO/O2 RM 3A, 320
SO2 RM 320
NOx RM 320
THC RM 25A, 320
Hg RM 30B
July 17, 2024 Clinker Cooler PM RM 1, 2, 3A, & 5
July 18, 2024 Kiln PM RM 1, 2, 3A, & 5

• 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 2 - Determination of Stack Gas Velocity and Volumetric Flow
Rate – (Type S Pitot Tube) as outlined in 40 CFR 60 Appendix A.

• 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 5 - Determination of Particulate Matter from Stationary Point
Sources – 40 CFR 60 Appendix A.

• Reference Method 25A - Determination of Total Gaseous Organic Concentration
Using a Flame Ionization 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 30B - Determination of Total Mercury Concentration Using a
sorbent trap system designed by APEX, Inc. and Ohio Lumex, Inc analyzer as
outlined in 40 CFR 60 Appendix A.

• Reference Method 320 - Determination of CO2, H20, SO2, NOX, and CO emissions
Using a Fourier Transform Infrared (FTIR) Detector as outlined in 40 CFR 60
Appendix A.

• Reference Method 202 - Determination of Condensable Particulate Matter from
Stationary Point Sources – 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-516-24
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-516-24
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

RL:rh

cc: Weber-Morgan Health Department
Mostardi Platt

* $ . # ( ) - — 4 A C v A ? A C @ C w @ E ˜
Rob Leishman Jr