DAQ-2024-007349

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-317-24
Site ID 10303 (B5)

Cody Watkins, Environmental Manager
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638

Dear Mr. Watkins:

Re: Ash Grove Cement Company (Ash Grove) – Pretest Protocol for Carbon Monoxide (CO),
Flow, Nitrogen Oxides (NOx), Oxygen (O2), Mercury (Hg), and Total Hydrocarbons
(VOC/THC) Relative Accuracy Test – Juab County

The Utah Division of Air Quality (DAQ) reviewed Ash Grove’s pretest protocol dated April 3,
2024. The proposed test shall be performed under the following conditions:

Ash Grove’s monitoring system to be certified:

Point Source Channel Manufacturer Model No. Monitor SN
Kiln/Raw
Mill
CO California Analytical Instruments 600 FTIR Z06009
Flow Monitor Labs 150X 1500078
HCL California Analytical Instruments 600 FTIR Z06009
NOx California Analytical Instruments 600 FTIR Z06009
O2 California Analytical Instruments 600 FTIR 10217573A
THC California Analytical Instruments 600 HFID Z06009
Hg Thermo Scientific 80i 1216753345

Mostardi Platt will conduct a relative accuracy/performance specification test on Ash Grove’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.

- / & ) á Û Ù Û Ý
DAQC-317-24
Page 2

The DAQ understands that the test will be conducted as follows:

Test Date Point Source Parameter EPA Reference Method
June 11, 2024 Kiln/Raw
Mill
CO - 6,600 lbs/hr
CO2 - %
NOx - 2.8 lbs/ton clinker
O2 - %
SO2 - 0.4 lbs/ton clinker
THC - 24 ppmvd @7% O2
Hg - 55lb/MM tons clinker
Method 1, 2, 3A, 4, 25A,
30B and 320

• 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 4 – Determination of determine moisture content for Stationary
Point Sources as outlined in 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 Vapor Phase Mercury Emissions
from Coal-Fired Combustion Point Sources Using Carbon Sorbent Traps as
outlined in 40 CFR 60 Appendix A.

When conducting Reference Method 30B with an Ohio Lumex sorbent trap
mercury analyzer, Mostardi Platt shall:

a. Provide the inspector the method detection limit (MDL) prior to testing and
clearly document the MDL in the test report.

b. Insure that each analyzer reading of the multipoint analyzer calibration is within
± 10% of the true value; and the linear correlation coefficient i.e. R2 must be
≥0.99.

DAQC-317-24
Page 3

c. That the independent calibration verification standard (ICVS), section 2 response
factor determination, and continuing calibration verification standard (CCVS)
are clearly identified and meet quality assurance/quality control criteria for
Method 30B.

d. That Table 9-1. Quality Assurance/Quality Control Criteria for Method 30B are
followed.

• Reference Method 320/321 – Measurement of Vapor Phase Organic and Inorganic
Emissions by Fourier transform Infrared (FTIR) Spectroscopy as outlined in 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.

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.

DAQC-317-24
Page 4

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.

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: Central Utah Public Health Department
Mostardi Platt

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