DAQ-2024-006988

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-272-24
Site ID 10007 (B5)

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

Dear Mr. Miller:

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

The Utah Division of Air Quality (DAQ) reviewed Holcim’s pretest protocols to conduct HCl
RATA testing, both of which were dated February 21, 2024. The first protocol emailed on
February 21, 2024, specified a test date of “the week of March 18, 2024.” The “updated” version
of the protocol emailed on February 28, 2024, specified a test date of “the week of April 8, 2024.”

Both proposed test protocols were considered deficient upon review. Holcim was contacted by
email, notifying the company personnel of the deficiencies, including:
• Failure to submit the protocol more than 45 days prior to the proposed test date.
• Failure to specify an actual date when testing would be conducted.
• Failure to specify standard test procedure information such as how many total test runs
will be done per test day, estimated run time, how many spiked and unspiked readings
constitute a valid run, etc.

Both of the pretest protocols are hereby rejected for insufficient information. Please submit a
complete pretest protocol for the HCl RATA including the information specified above once that
information comes available. In accordance with UAC R307-170-7(2), notification is required no
less than 45 days prior to testing. A review will be conducted to determine if the protocol contains
sufficient information to demonstrate ample knowledge and technical expertise of the RATA
requirements and testing stipulations specified in 40 CFR Appendix B PS-15 and
UAC R-307-170.

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DAQC-272-24
Page 2

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