DAQ-2024-004314

1
DAQC-1320-23
Site ID 10007 (B5)

MEMORANDUM

TO: FILE – HOLCIM USA INCORPORATED

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Rob Leishman, Environmental Scientist

DATE: December 7, 2023

SUBJECT: Holcim USA Incorporated (Holcim), Major, Title V, MACT, NSPS, Weber County,
FRS # UT00000049002900001

INSPECTION TYPE: State Electronic Data Report (SEDR) 2Q2023 and 3Q2023 Review

REVIEW DATE: December 7, 2023

SOURCE LOCATION: Devils Slide/Weber County

SOURCE CONTACT: Clinton Badger – 385-489-9736
Weston Fry – 801-829-6821 (Interim Plant Manager as of 7/28/2023)

APPLICABLE
REGULATIONS: Title V Operating Permit
PERMIT NUMBER: 2900001004
DATE OF PERMIT: November 18, 2021
Date of Last Revision: March 25, 2022

Utah Administrative Code (UAC) R307-170-9

SOURCE REVIEW
EVALUATION: Holcim (US) Inc. (Holcim) operates the Devil’s Slide cement
manufacturing facility near Morgan, Utah. Holcim is required to
continuously monitor total hydrocarbon (THC), hydrogen chloride
(HCL), oxygen (O2), nitrogen oxides (NOX), sulfur dioxide (SO2), carbon
dioxide (CO2), mill temperature, and mercury (Hg) emissions in
accordance with Title V operating permit conditions II.B.6.b, II.B.6.d,
II.B.6.g, II.B.6.K, II.B.6.l, and II.b.6.m.

On July 30, 2023, Holcim submitted an SEDR for second quarter 2023
(2Q2023) by email. UAC R307-170-9(1)(c)(i) requires that Holcim
submit the SEDR for 2Q2023 by July 30, 2023. UAC R307-179-9(5)(d)
requires Holcim to submit the results of the current cylinder gas audits
for the 2Q2023 SEDR. On July 31, 2023, Clinton Badger of Holcim was
notified by email that the .CSV format file (ASCII format electronic files
required by R-307-170-9(1)(a)) was not included. Mr. Badger replied on

1 8 2

2
August 11, 2023, with the .CSV format requested. The report was
evaluated on September 12, 2023, and it was found that the cylinder gas
audits (CGA’s) reported in the SEDR were from a prior quarter
(February 13-14, 2023) and not from 2Q2023. Another email was sent to
Mr. Badger requesting clarification about the data and noting that the
CGA’s listed in the report were not from the correct quarter. On
September 19, 2023, Mr. Badger was contacted again by email regarding
the CGA’s listed in the 2Q2023 SEDR. On September 19, 2023, Mr.
Badger replied stating that he missed my prior email and that he would
get back to me regarding the issue. I replied acknowledging receipt of his
reply and hadn’t received any additional information from him regarding
the 2Q2023 SEDR and the corrections to the electronic report for the
CGA’s as of the date of this report.

On November 24, 2023, I emailed Mr. Badger regarding Holcim’s Third
Quarter 2023 (3Q2023) SEDR. UAC #307-170-9(1)(c)(i) requires that
the SEDR for 3Q2023 be submitted by October 30, 2023. As of the date
of this memo, no 3Q2023 SEDR has been received in any format for the
Holcim Devil’s Slide monitors.

Title V operating permit Conditions II.B.6.b.3, II.B.6.d.3, II.B.6.k.3, II.B
6.l.3, and II.B.6.m.3 each require that "Reports shall be submitted
quarterly, as outlined in R307-170, Continuous Emission Monitoring
Program.”

SOURCE INSPECTION
SUMMARY EVALUATION: Holcim is in violation of Title V operating permit Conditions II.B.6.b.3,
II.B.6.d.3, II.B.6.k.3, II.B 6.l.3, and II.B.6.m.3 for failure to submit
complete and accurate quarterly reports for its CEMS as required in
R307-170 and 40 CFR 60.13 for both 2Q2023 and 3Q2023.

CURRENT
RECOMMENDATIONS: Send a NOV for violations of Title V operating permit conditions
II.B.6.b.3, II.B.6.d.3, II.B.6.k.3, II.B 6.l.3, and II.B.6.m.3 for failure to
submit complete SEDR reports for 2Q2023 and 3Q2023.

HIGH PRIORITY
VIOLATOR (HPV): Yes. These violations meet Criterion 5 of the 2014 USEPA HPV Policy.

RECOMMENDATION
FOR NEXT INSPECTION: Check future SEDR’s carefully for accurate information.

ATTACHMENTS: Email thread from July 30, 2023, to November 24, 2023, between
Clinton Badger and Rob Leishman regarding SEDR 2Q2023 and
3Q2023.

12/1/23, 2:21 PM State of Utah Mail - Holcim Q2 SEDR
https://mail.google.com/mail/u/0/?ik=fcfbda028e&view=pt&search=all&permmsgid=msg-a:r-2250663746139513264&dsqt=1&simpl=msg-a:r-2250663…1/3
Rob Leishman Jr <[e-mail]>
Holcim Q2 SEDR
Rob Leishman Jr <[e-mail]>Fri, Nov 24, 2023 at 11:01 AM
To: Clinton Badger <[e-mail]>
Clint, has Holcim submitted a 3Q2023 SEDR?
Rob Leishman
On Tue, Sep 19, 2023 at 1:29 PM Rob Leishman Jr <[e-mail]> wrote:
Sounds good, thank you.
On Tue, Sep 19, 2023 at 12:19 PM Clinton Badger <[e-mail]> wrote:
Rob,
Apologies, if I somehow missed your first email.
Let me look at it and get back to you. If it's a cemlink problem drawing the data I will run that down and get you the
corrected data.
On Tue, Sep 19, 2023 at 10:27 AM Rob Leishman Jr <[e-mail]> wrote:
Hey Clint, still waiting on the clarification to the CGA data in TC260. Any update on when that can be done?
Rob Leishman
On Tue, Sep 12, 2023 at 4:29 PM Rob Leishman Jr <[e-mail]> wrote:
Clint, were there CGA's performed during the quarter? All the CGA results are from February. The rest of the
data in the EER appears to be from 2Q2023.
On Fri, Aug 11, 2023 at 11:25 AM Clinton Badger <[e-mail]> wrote:
Will do, thank you. I should have picked up on the CSV requirement.
On Fri, Aug 11, 2023 at 11:23 AM Rob Leishman Jr <[e-mail]> wrote:
Received, thank you. Please make sure the electronic file and the cover letter are both received prior to the
30th of the month following the quarter in future submissions. I'll contact you if I have any additional
questions. Have a great day.
Rob Leishman
On Fri, Aug 11, 2023 at 10:10 AM Clinton Badger <[e-mail]> wrote:
Please see attached in CSV format.
On Mon, Jul 31, 2023 at 10:38 AM Rob Leishman Jr <[e-mail]> wrote:
Received, thank you. Please send the .csv file to me when you get a chance. UAC R307-170-9(1)(a)
requires that the State Electronic Data Report be submitted in ASCII (.csv) format. Have a great day.
Rob Leishman
On Sun, Jul 30, 2023 at 10:13 PM Clinton Badger <[e-mail]> wrote:
---------- Forwarded message ---------
From: Clinton Badger <[e-mail]>
Date: Sun, Jul 30, 2023 at 10:09 PM
Subject: Holcim Q2 SEDR
To: Rob Leishman Jr <[e-mail]>
Good Afternoon,
12/1/23, 2:21 PM State of Utah Mail - Holcim Q2 SEDR
https://mail.google.com/mail/u/0/?ik=fcfbda028e&view=pt&search=all&permmsgid=msg-a:r-2250663746139513264&dsqt=1&simpl=msg-a:r-2250663…2/3
Please see attached copy of the SEDR report for the 2nd Quarter of 2023 with the original mailed.
Please let me know if you have any questions.
--
Clint Badger
Area Manager, Environment and Public Affairs
Holcim - Devil's Slide Plant
Mobile: [phone]
email: [e-mail]
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.
--
Clint Badger
Area Manager, Environment and Public Affairs
Holcim - Devil's Slide Plant
Mobile: [phone]
email: [e-mail]
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.
--
Clint Badger
Area Manager, Environment and Public Affairs
Holcim - Devil's Slide Plant
Mobile: [phone]
email: [e-mail]
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.
--
Clint Badger
Area Manager, Environment and Public Affairs
Holcim - Devil's Slide Plant
Mobile: [phone]
email: [e-mail]
12/1/23, 2:21 PM State of Utah Mail - Holcim Q2 SEDR
https://mail.google.com/mail/u/0/?ik=fcfbda028e&view=pt&search=all&permmsgid=msg-a:r-2250663746139513264&dsqt=1&simpl=msg-a:r-2250663…3/3
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.