DAQ-2024-006987

1

DAQC-271-24
Site ID 10007 (B5)
MEMORANDUM

TO: CEM FILE – HOLCIM – Portland Cement Kiln at Devil’s Slide

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Rob Leishman, Environmental Scientist

DATE: March 14, 2024

SUBJECT: Source: Kiln
Contact: Clint Badger – 801-829-2122
Mark Miller – 972-221-4646
Location: Devil’s Slide, Morgan County, UT
Test Contractor: Holcim In-House Staff
FRS ID#: UT0000004902900001
Permit/AO#: Title V operating permit 2900001004 dated November 18, 2021
Last revised March 25, 2022
Subject: Review of RA/PST Protocols dated February 21, 2024

On February 21, 2024, DAQ received a protocol by email dated February 21, 2024, for a RA/PST
(relative accuracy/performance specification test) of the Holcim Portland Cement Kiln at Devil’s Slide,
Morgan County, UT. Testing was scheduled for “the week of March 18, 2024,” to determine the relative
accuracy of the HCL monitoring systems. Holcim personnel were informed by email on
February 23, 2024, that they failed to submit the protocol 45 days prior to the scheduled test date as
required by UAC R-307-170-7(2).

On February 28, 2024, Holcim submitted an “updated” protocol notification also dated
February 21, 2024. This notification specified a test date of “the week of April 8, 2024,” which is 45 days
from the initial test notification on February 21, 2024. Upon further review, it was noted that the
notification failed to specify what actual days testing was going to occur, how many test runs will be
completed, how many spikes constitute a sample, and how many test runs will be completed on each day.
Without this critical information specified in the protocol, effective auditing of the test is not possible.
Holcim was contacted by email on March 5, 2024, regarding the deficiencies. Since that date, no further
information has come available regarding the specific information contained in the RATA Protocol.

DEVIATIONS: Holcim failed to submit the pretest protocol 45 days prior to testing.
Holcim failed to establish actual test dates. Holcim failed to provide
details of the HCL RATA which are critical in determining if testing will
be conducted in accordance with the methodology specified in PS-15.
RATA Testing for HCl was due in 4Q2023.

CONCLUSION: The protocols are unacceptable as submitted.

RECOMMENDATION: Send a protocol rejection notice.

1 8 2

Holcim (US) Inc.
6055 E. Croydon Rd.
Morgan, Utah 84050

Phone [phone]
www.holcim.com/us

Sent via email

February 21, 2024

Bryce C. Bird, Director
Utah Division of Air Quality
195 North 1950 West
Salt Lake City, UT 84116

Re: HCl Performance Test Notification for Holcim (US), lnc.'s Devil's Slide Cement
Manufacturing Plant in Morgan, UT

Dear Mr. Bird,

Holcim (US) Inc. ("Holcim") owns and operates a Portland cement manufacturing plant located
in Morgan, UT. The Devil's Slide Plant operates under Utah Division of Air Quality issued Title V
Permit, No. 2900001004. The Plant is subject to the National Emission Standards for
Hazardous Air Pollutants for the Portland Cement Industry ("Portland Cement NESHAP"), 40
C.F.R. Part 63, Subpart LLL, and is a major source of HAPs.

Holcim will perform testing and evaluation of the ABB ACF5000 FTIR to meet the HCl
continuous emission monitoring requirements in Subpart LLL. This site-specific HCl CEMS
performance evaluation test plan is prepared to satisfy the requirements of 40 CFR 63, Subpart
A §63.8(e) for the required monitor performance test (i.e., “performance evaluation”). The
performance evaluation will follow the requirements in EPA Performance Specification 15 for
FTIR-based CEMS. The test is currently scheduled to be conducted the week of April 8, 2024
by Holcim Devil’s Slide Plant personnel. Holcim respectfully request a variance to the pre-test
notice time so we can complete this RATA testing expeditiously upon Kiln restart.

If you should have any questions or need additional information, please contact me at
702.358.7280 or by email at [e-mail].
Sincerely,
Mark Miller
Mark Miller
Environmental Director

Enclosure test protocol
Site-Specific HCl CEMS Performance Evaluation Test Plan for
Holcim (US) Inc. Devil’s Slide Plant

Holcim (US) Inc. (“Holcim”) owns and operates a Portland cement manufacturing plant
located in Morgan, Utah. The Devil’s Slide plant is subject to the National Emission
Standards for Hazardous Air Pollutants for the Portland Cement Industry (“Portland
Cement NESHAP”), 40 CFR Part 63, Subpart LLL, and is a major source of HAPs.

The Devil’s Slide plant will perform testing and evaluation of the ABB ACF5000 FTIR to
meet the HCl continuous emission monitoring requirements in Subpart LLL. This site-
specific HCl CEMS performance evaluation test plan is prepared to satisfy the
requirements of 40CFR63, Subpart A §63.8(e) for the required monitor performance test
(i.e., “performance evaluation”). The performance evaluation will follow the
requirements in EPA Performance Specification 15 for FTIR-based CEMS.

Schedule
The performance evaluation is expected to be conducted during the week of April 8,
2024.

Holcim will notify UDAQ as soon as practical of any scheduling changes or delays.

Holcim Contacts
Questions or comments about the test program should be directed to:

Clinton Badger
Environmental Manager
Holcim (US) Inc.
801-829-2122
[e-mail]

Test Services
Holcim will provide the necessary performance evaluation services. Devil’s Slide
Plant personnel will conduct the performance evaluation. These individuals have
extensive experience working with CEMS and HCl emission measurements at the
Devil’s Slide plant.

Objectives and Approach
The objective of this test program is to demonstrate that the ABB ACF5000 HCl
CEMS meets the applicable requirements of Performance Specification 15 (PS 15) for
FTIR-based CEMS. If successful, this will complete the requirements for the monitor
performance test (i.e., “performance evaluation”). The monitor can continue to be
used to acquire HCl emissions data to demonstrate compliance with the emission
limitation and will be subject to ongoing quality assurance requirements in 40CFR60,
Appendix F, Procedure 1.
Subpart LLL, §63.1350(l)(1) states:
“(1) If you monitor compliance with the HCl emissions limit by operating
an HCl CEMS, you must do so in accordance with Performance
Specification 15 (PS 15) of appendix B to part 60 of this chapter, or, upon
promulgation, in accordance with any other performance specification for
HCl CEMS in appendix B to part 60 of this chapter. You must operate,
maintain, and quality assure a HCl CEMS installed and certified under PS
15 according to the quality assurance requirements in Procedure 1 of
appendix F to part 60 of this chapter except that the Relative Accuracy
Test Audit requirements of Procedure 1 must be replaced with the
validation requirements and criteria of sections 11.1.1 and 12.0 of PS 15.”

The above referenced Section 11.1.1 and calculations in Section 12.0 of PS 15
require that the performance of the CEMS be validated by conducting analyte spikes
(also known as “dynamic spikes”) rather than by the more traditional method of
acquiring independent effluent measurements and calculating the relative accuracy.
In addition, PS 15 does not include a 7-day zero and upscale calibration drift test.
However, it does require injection and analysis of a calibration transfer standard
(CTS) on each day of the test program and it requires that the monitor response
agree within ± 5% of the CTS value. CO2 tri blend gas will be used as the CTS gas.
The CTS gas may include other constituents such as SO2 or NO.

Analyte Spiking Procedure
Analyte spiking is the quantitative addition of a known amount of calibration gas
into the effluent gas stream. The exact concentration of the calibration spike gas is
determined by directly analyzing the calibration gas by the FTIR (or using the tag
value if trusted). The calibration gas is then spiked into the CEMS probe
immediately upstream of the particulate matter filter (similar to a normal CEMS
system calibration.) The difference between analyte spiking and system calibrations
is that only a fraction of the total flow is injected into the effluent stream instead of
conducting a “probe flood” or similar procedure that results in 100% calibration gas
in the analyzer cell.

Spike gas is introduced at a rate of no greater than 10% of the total sample flow
rate: i.e., 10:1 dilution so that the sample gas matrix remains mostly unchanged.
(The native effluent concentrations are diluted by the introduction of the spike gas.)
For example if the total system flow is 10 ppm, then the spike flow can be no greater
than 1 lpm. Dynamic spikes that introduce less spike gas than 10:1 (e.g., 15/1 and
20/1) are also acceptable. The nominal HCl concentration of the spike gas cylinder
will be between 40 and 70 ppm. The spike gas will also contain about 330 ppm N 2O
ppm as a tracer to determine spike flow to total flow rate according to equation 3.2
below. The goal is to quantitatively add approximately 4 to 7 ppm of HCl with the
stack gas effluent and then examine the CEMS response to determine if the
sampling and analytical systems are able to produce reliable HCl monitoring data.

The specific procedure is as follows: Analyze the spike gas cylinder directly with the
FTIR. Name the response values as the cylinder reference value (i.e., “tag value”) for
both HCl and N2 O concentrations. Alternately, use the gas supplier provided tag
value if it is a known and trusted value. Obtain stable sequential spectra while
sampling stack gas only while the process is operating at stable conditions and name
this as unspiked sample number 1. Begin injecting HCl spike gas at a 10:1 ratio1 or
less until stable readings are obtained. (ACF5000 values are updated approximately
every 35 seconds and are the result of the co-addition of x FTIR scans. VIM DAS
compiles 1-minute averages but is not synchronized to ACF5000 analysis cycles.)
Collect several sequential measurements and name the initial final stable response
as spiked sample number 1. Collect an additional independent value (separated by 1
or more 1-minute VIM DAS averages) and name this as spiked sample 2. Shut the
spike off and allow the measurements to stabilize back to unspiked effluent only
(“baseline”) concentration. Then, record two independent baseline stable values as
unspiked sample numbers 2 and 3. Repeat this series of spiked and unspiked
samples until there are twelve sets of spiked and unspiked effluent measurements.

Variations in the effluent concentrations of either HCl or the tracer gas N2O during
the analyte spike procedures can adversely affect the results. It is important to
conduct these tests during operating periods when variability of these
concentrations is low. In the event that excess variations in the HCl or N2O
concentrations are observed, it may be necessary to discard affected spike runs and
conduct additional runs.

Sulfur hexafluoride (SF6) is often used for FTIR analyzers as a tracer because SF6 has
a large infrared absorption, is easily measured at low concentrations (especially for
liquid nitrogen cooled MCT detectors) and is not present in the effluent. 5 ppm of

1 Adjust the spike gas flow rate to provide a spiked N2O, value to a level of 0.1 (10%) or less of the direct analysis
value of N2O. For example, if a direct analysis is 330 ppm N2O, then adjust the spike gas flow rate until the
observed stable value of the spiked effluent N2O measurement is about 33 ppm plus the native N2O concentration.
SF6 is a good cylinder concentration for some FTIRs. However, ABB prefers use of
N2O as a tracer since it was already a compound included in their TUV certified
analysis routines. The concentration of N2O in the cylinder must be significantly
higher due to the weaker N2O absorption characteristics. In addition, the
calculations of spike recovery must take into account that there is a low level of N2O
present in the effluent samples at most cement kilns. ABB previously submitted
documentation and procedures supporting the N2O spike procedure to Holcim.
These documents are available upon request. Jim Peeler of EMI derived HCl spike
recovery calculations for the use of N2O as a tracer during the Holicm 2012 HCl
CEMS Field Evaluation. These procedures were validated during the Holcim 2012
study and also used during the Holcim 2015 evaluation of the ABB ACF5000 CEMS.
The dilution factor calculation when the tracer gas is present in the effluent samples
is now included in the Performance Specification 18, Appendix A “Standard Addition
Procedures” as equation A3.

The HCl spike recovery calculations for systems that also measure N2O as used in the
previous Holcim studies and now found in PS18, Appendix A are as follows:

Dilution Factor: 𝐷𝐷𝐷𝐷𝐷𝐷𝐷𝐷 = � N2OObserved − N2ONative � N2OBottle − N2ONative N2OObserved − N2ONative CExpected = CNative �1 − N2O Bottle − N2O � Native N2OObserved − N2ONative + CSpike Gas � N2O Bottle − N2O � Native
Where:
CExpected = HCl expected concentration response for dynamic spike
(i.e., analyte spike) based on the sum of the diluted
native concentration and spike addition
CNative = HCl concentration present in the sample gas without spike
added
N2OObserved = Concentration of N2O observed during dynamic spike
gas injection concurrent with stable spiked HCl
response
N2ONative = N2O concentration in the sample gas without spike added
N2OBottle = Concentration of N2O in spike gas determined from direct
analysis of the spike gas
CSpike Gas = HCl concentration of spike gas as determined from direct
analysis of the spike gas

The definition of the dilution factor above is the reciprocal (i.e., 1/DF) as defined in
PS 15.

Calculate the amount of added HCl in the spiked gas:
Cs = Dir HCl/DF in PS15 Eq. 5 is therefore modified to be:
Cs = Dir HCl*DF
Calculate the Bias:
B = Sm – Mm – Cs

Where:
Sm= mean of average of spiked samples
Mn = mean of average of unspiked samples

Calculate the Standard Deviations:
Calculate the standard deviation and RSD of the spiked samples (and unspiked
sample) differences.

Sds = sqrt( Di2 ) 12
Where:
Di2 = the difference between spiked and unspiked sample pairs; S1-S2
and U1-U2
RSD = Sds/Sm
Calculate the CF:
CF = 1/(1 + B ) Cs Calculate the composite standard deviation of the combined differences: SD = �Sds2 + Sdu2
Determine If Bias is Statistically Significant – Compare t = 2.201 B t = SD
Spreadsheet calculations have been developed for these calculations.

Data Quality Objectives
The data quality objectives are:
• Demonstrate acceptable CTS gas analysis results for each day of the test
program where the ACF5000 response is within ± %5 of the gas value.
• Acquire a minimum of 12 valid spiked and unspiked pairs of samples where
the spike gas flow rate is 10% or less of the total sample flow rate as
determined by the N2 O tracer concentration and the measurements are not
adversely affected by temporal variations in the effluent concentrations
• RSD < 50% for the spiked (and unspiked) paired differences
• If the apparent bias is determined to be statistically significant, the bias
correction factor (CF) shall be between 0.7 and 1.3

CEMS Description and Quality Assurance
An ABB ACF5000 FTIR-based CEMS will be evaluated to determine its ongoing ability
to acquire accurate and precise HCl effluent measurements. The CEMS is a full
extractive (i.e., non-dilution) measurement system. It consists of an M&C sample
probe with provisions for injecting calibration gases and spike gases upstream of the
PM filter, approximately 96 feet of heated sample line (also containing calibration
gas lines and communications) and the ABB FTIR analyzer. The sample lines and
analyzer gas cell are maintained at 180°C (356°F), while the sample probe and PM
filter may be operated at a higher temperature of ~230°C.

The ABB sample probe acquires samples from the stack at the same level used for all
stack sampling activities and a point approximately 1 meter from the stack wall.
RATAs of SO2, NO, O2 and CO2 CEMS have been performed at this location for many
years and there is no evidence of gas concentration stratification and no reason to
expect that such stratification is present.

The ACF5000 will communicate with the VIM DAS that is used to record all emission
monitoring data. All effluent measurements that are used to determine the
ACF5000 performance will be acquired from the VIM DAS records.

Due to delays and technical problems encountered by NIST and EPA, NIST Traceable
HCl calibration gases with an uncertainty of ≤5% are not available. HCl calibration
gases with nominal concentrations of 40 and 70 ppm HCl and 330 ppm N2O will be
used. These gases are being certified in accordance with a broadly applicable EPA
approved alternate method designated Alt-114 which was based on an alternative
method request and supporting information submitted to EPA by Air Liquide. EPA’s
approval is contained in a letter from Steffan Johnson, Group Leader, Measurement
Technology Group, OAQPS, dated Feb. 22, 2016. The designation of these gases are
HCl GMACS and are certified by Air Liquide (now Airgas) by dual interlocking
gravimetric and classical gas analysis methods, each with a total combined
uncertainty of <5%. Additional information regarding the HCl GMACS and an
example certificate of analysis are available upon request.

Compressed HCl calibration gases will be introduced to the ACF5000 using Silconert
Treated dual stage low volume stainless steel regulators and HCl Gas Delivery Panel
Prototype VI and Nitrogen Purge & Purification Panel acquired from Air Liquide.
These devices allow the gas regulators and gas delivery panel to be completely
purged with ultra-dry nitrogen prior to and after the introduction of HCl mixtures to
greatly reduce the potential for internal corrosion and/or HCl losses and to reduce
the time required to achieve stable HCl responses from the ACF5000.

After the performance certification of the ACF5000 for the measurement of HCl
concentrations is successfully completed, the Devil’s Slide plant will continue to
operate the HCl CEMS in accordance with the requirements of 40 CFR 60, Appendix
F, Procedure 1. The span value of the HCl CEMS will be 20 ppm. Daily zero checks
will be performed by injection of zero gas and daily upscale calibration checks will be
performed using an internal gas cell. Quarterly cylinder gas audits will be performed
using HCl GMACS compressed gases at 20-30% of span and 50-60% of span. In
accordance with the explicit requirements of §63.1350(l)(1), dynamic spike
evaluations will be performed annually.
3/18/24, 3:43 PM State of Utah Mail - Holcim Devil's Slide Deviation Report and HCl Performance Test Notification
https://mail.google.com/mail/u/0/?ik=fcfbda028e&view=pt&search=all&permmsgid=msg-a:r-6363706702860862015&dsqt=1&simpl=msg-a:r-6363706…1/5
Rob Leishman Jr <[e-mail]>
Holcim Devil's Slide Deviation Report and HCl Performance Test Notification
Rob Leishman Jr <[e-mail]>Mon, Mar 11, 2024 at 11:54 AM
To: Clinton Badger <[e-mail]>
Cc: Harold Burge <[e-mail]>, "Bird, Bryce" <[e-mail]>, Mark MILLER <[e-mail]>
Thank you. Just make sure that date is 45 days in advance and comes with an updated protocol containing the
clarifications specified in my 3/5/2024 email.
Rob Leishman
On Mon, Mar 11, 2024, 10:55 AM Clinton Badger <[e-mail]> wrote:
Mr. Leishman,
I am working on obtaining a date that is most likely to align with kiln operational status and technician availability, I will
notify you and provide an updated protocol.
On Mon, Mar 11, 2024 at 10:35 AM Rob Leishman Jr <[e-mail]> wrote:
As a reminder, your protocol won't be approved until there are set dates, and the run information and the procedure
questions are clarified in the protocol. You will need to have a complete protocol submitted 45 days in advance of any
RATA testing. If that RATA is not approved prior to testing, the test could be considered invalid. I hope this
clarification is helpful. Have a good day.
Rob Leishman
On Wed, Mar 6, 2024 at 9:26 AM Rob Leishman Jr <[e-mail]> wrote:
Thanks for the clarification. I won't approve the protocol until the dates and times are set. Please update the
protocol with the clarification on the test methodology and procedures to be used (total number of test runs,
duration of test runs, spiked and unspiked injections, etc.), as well as removing the variance request language if a
variance is no longer requested. I can approve a protocol once it is complete and contains the necessary
information to give the Division reasonable assurance that the test will be done correctly. Have a good day.
Rob Leishman
On Wed, Mar 6, 2024 at 6:54 AM Clinton Badger <[e-mail]> wrote:
Mr. Leishman,
We can specify an accurate date range as we get closer, 45 days out it is hard to
determine kiln operational status and electrician and technician staff
availability. Historically we have been able to complete the testing in one day.
We will conduct 12 independent samples of the one hour minimum with a
validation run consisting of at least 24 independent analytical results (12 spiked
and 12 unspiked samples), not a traditional 3 run test.
No, the variance is no longer needed, the variance was originally planned to
accommodate an expedited time frame to conduct after our yearly planned
outage. As we are waiting the 45 days, we will no longer need the variance.
Please let us know if you have any questions.
3/18/24, 3:43 PM State of Utah Mail - Holcim Devil's Slide Deviation Report and HCl Performance Test Notification
https://mail.google.com/mail/u/0/?ik=fcfbda028e&view=pt&search=all&permmsgid=msg-a:r-6363706702860862015&dsqt=1&simpl=msg-a:r-6363706…2/5
On Tue, Mar 5, 2024 at 12:51 PM Rob Leishman Jr <[e-mail]> wrote:
Clint and Mark, I'm reviewing the HCl RATA protocol. It states that testing will be done the week of April 8. Are
there specific test days scheduled within that week or will it be whenever the technician can get to it during
that week? I couldn't find in the protocol any reference to set-up days, test days, etc. Also, how many test runs
(12 valid spiked and unspiked samples in one hour) will be done per day and how many total test runs will be
completed? Will each test run be one hour? PS-15 states that test runs for FTIR spike procedure will be done
over a minimum of one hour. Is there a set time of day that these test runs will be scheduled to be performed
or is this left to the technician's discretion? In the revised protocol letter, there is a statement at the end of
Paragraph 2 stating "Holcim respectfully request a variance to the pre-test notice time so we can complete this
RATA testing expeditiously upon Kiln restart." It appears with the revised date that the request for variance is
no longer necessary. Is Holcim still requesting a variance? Thanks.
Rob Leishman
On Mon, Mar 4, 2024 at 9:56 AM Rob Leishman Jr <[e-mail]> wrote:
Received, I'll contact you if I have any questions. Have a good day.
Rob Leishman
On Tue, Feb 27, 2024 at 3:22 PM Clinton Badger <[e-mail]> wrote:
Mr. Leishman,
Please see updated HCl Performance Notification and Protocol. Let me know if you have any questions.
On Mon, Feb 26, 2024 at 5:20 PM Mark MILLER <[e-mail]> wrote:
Thanks. The HCL SPIKE test will be moved to reflect 45 days from protocol submittal.
Mark Miller, LEED Green Associate
Director of Land and Environment,
Holcim (US), Inc.
15900 Dooley Road
Addison, TX. 75001
P: 972-221-4646
C: 702-358-7280
F: 972-221-5226
[e-mail]
www.materialsthatperform.com

This email is confidential and intended only for the use of the above named addressee. If
you have received this email in error, please delete it immediately and notify us by email
or telephone.
On Fri, Feb 23, 2024 at 4:33 PM Rob Leishman Jr <[e-mail]> wrote:
Since the facility is doing the spike procedure using inhouse personnel, and the company is already
having a lot of issues with failure to comply with other parts of the permit, it might be better to just
schedule the test for 45 days from the date of notification and avoid one more deviation from the
permit. I don't work for your company and can't make the decisions for you. But there is a LONG list
of deviations already, all of which are subject to compliance actions. If the HCl RATA was already
missed or late, I don't see that it would be beneficial or logical to throw more complication (and
documented instances of non-compliance) into the mix. I will process whatever final protocol you
want to submit. Whether it is the one with just over half of the required notification time or another
one with the required 45 days prior notice. Let me know how you'd like to proceed. Have a good day.
3/18/24, 3:43 PM State of Utah Mail - Holcim Devil's Slide Deviation Report and HCl Performance Test Notification
https://mail.google.com/mail/u/0/?ik=fcfbda028e&view=pt&search=all&permmsgid=msg-a:r-6363706702860862015&dsqt=1&simpl=msg-a:r-6363706…3/5
Rob Leishman
On Fri, Feb 23, 2024 at 3:01 PM Mark MILLER <[e-mail]> wrote:
Thanks for the quick response. It is simply that we want to do it as
soon as possible and we will be safely back in operation by then. The
spike test personnel have also cleared themselves/schedules to get it
done that week.
On Fri, Feb 23, 2024 at 3:02 PM Rob Leishman Jr <[e-mail]> wrote:
Received, thank you. What is the reason for not providing 45 days prior notice on the HCL
RATA? Is it just to test expeditiously as stated in the letter, or is there some other reason why the
company needs to deviate from the 45-day prior notification requirement? Thanks in advance for
any information you can provide to clear this up.
Rob Leishman
On Wed, Feb 21, 2024 at 6:08 PM Clinton Badger <[e-mail]> wrote:
Mr. Leishman,
Thank you for taking the time to sit down with us last week. Please find attached letter,
deviation report along with HCl Performance Notification and Protocol. Please let me know if
you have any questions.
--
Clinton Badger
Area Manager, Environment and Public Affairs - Devil's Slide
Holcim (US), Inc.
6055 Croydon Road
Morgan, UT 84050 , United States
Phone [phone]
Mobile [phone]
[e-mail]
www.holcim.com
This email is confidential and intended only for the use of the above named addressee. If you
have received this email in error, please delete it immediately and notify us by email or
telephone.
--
Mark Miller, LEED Green Associate
Director of Land and Environment,
Holcim (US), Inc.
15900 Dooley Road
Addison, TX. 75001
P: 972-221-4646
C: 702-358-7280
F: 972-221-5226
[e-mail]
3/18/24, 3:43 PM State of Utah Mail - Holcim Devil's Slide Deviation Report and HCl Performance Test Notification
https://mail.google.com/mail/u/0/?ik=fcfbda028e&view=pt&search=all&permmsgid=msg-a:r-6363706702860862015&dsqt=1&simpl=msg-a:r-6363706…4/5
www.materialsthatperform.com

This email is confidential and intended only for the use of the above named addressee.
If you have received this email in error, please delete it immediately and notify us by
email or telephone.
--
Clinton Badger
Area Manager, Environment and Public Affairs - Devil's Slide
Holcim (US), Inc.
6055 Croydon Road
Morgan, UT 84050 , United States
Phone [phone]
Mobile [phone]
[e-mail]
www.holcim.com
This email is confidential and intended only for the use of the above named addressee. If you have
received this email in error, please delete it immediately and notify us by email or telephone.
--
Clinton Badger
Area Manager, Environment and Public Affairs - Devil's Slide
Holcim (US), Inc.
6055 Croydon Road
Morgan, UT 84050 , United States
Phone [phone]
Mobile [phone]
[e-mail]
www.holcim.com
This email is confidential and intended only for the use of the above named addressee. If you have received this
email in error, please delete it immediately and notify us by email or telephone.
3/18/24, 3:43 PM State of Utah Mail - Holcim Devil's Slide Deviation Report and HCl Performance Test Notification
https://mail.google.com/mail/u/0/?ik=fcfbda028e&view=pt&search=all&permmsgid=msg-a:r-6363706702860862015&dsqt=1&simpl=msg-a:r-6363706…5/5
--
Clinton Badger
Area Manager, Environment and Public Affairs - Devil's Slide
Holcim (US), Inc.
6055 Croydon Road
Morgan, UT 84050 , United States
Phone [phone]
Mobile [phone]
[e-mail]
www.holcim.com
This email is confidential and intended only for the use of the above named addressee. If you have received this email
in error, please delete it immediately and notify us by email or telephone.