DAQ-2024-006990

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-278-24
Site ID 10007 (B5)

Mark Miller, Environmental Manager
Holcim (US) Inc.
6055 East Croydon Road
Morgan, UT 84050

Dear Mr. Miller:

Re: Holcim (US) Inc. (Holcim) – Pretest Protocol Hydrogen Chloride (HCl) Relative Accuracy
Test – Morgan County

The Utah Division of Air Quality (DAQ) reviewed Holcim’s pretest protocol dated March 18,
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 HCl ABB ACF5000 3.368022.6

Holcim plant staff 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.

The DAQ understands that Holcim Plant personnel’s staff will conduct testing as follows:

Test Date Point Source Parameter EPA Reference Method
May 2, 2024 Kiln HCl EPA PS 15

/ % Û Û Û Ù Û Ý
DAQC-278-24
Page 2

• Test Method EPA Performance Specification 15 – Measurement of Gaseous
Determination of Hydrogen Chloride Emissions at Portland Cement Kilns by
Fourier Transform Infrared (FTIR) Spectroscopy.

• 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
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 and raw emission data with
date and 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.

DAQC-278-24
Page 3

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.

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: TriCounty Health Department

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