DAQ-2024-004278

1

DAQC-047-24
Site ID 10007 (B2)
MEMORANDUM

TO: FILE – HOLCIM (US) INC. – Devil’s Slide Plant

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joe Rockwell, Environmental Scientist

DATE: January 15, 2024

SUBJECT: Title V Annual Compliance Certification Receipt/Review,
FRS ID # UT0000004902900001

REPORT RECEIVED/
DUE DATE: February 6, 2023/July 30, 2023
Revised report received January 4, 2024.

TITLE V PERMIT #: 2900001004

DATE OF LAST
PERMIT REVISION: March 25, 2022

CERTIFICATION PERIOD: July 1, 2022 – June 30, 2023

FACILITY REPORTED
COMPLIANCE STATUS: Continuous

REPORT EVALUATION:

• Was report submitted on time? Yes
• Did report identify status of compliance for each condition? Yes
• Was compliance status marked as continuous/intermittent for each condition? Yes
• Did report identify method used to determine compliance with each condition? Yes
• Was report signed and properly certified by responsible official? Yes
• Were exceedances/excursions reported? No
• Were deviations reported? No

CURRENT RECOMMENDATION:

The revised report appears to meet the requirements of Title V operating permit condition I.L.
After, the deviations, regarding conditions I.B and II.B.8.a, were changed to continuous and the
report period was corrected to July 1, 2022 – June 30, 2023.

The revised report was received on January 4, 2024. The revised report is considered to have been
received on the same date as the initial report, February 6, 2023.

ATTACHMENTS:

The initial and revised Annual Compliance Certification Reports.
f, HoLcrM
State of Utah
Division of Air Quality
195 North 1950 West
P.O. Box 1W2O
Salt Lake City, Utah, 84114-4820
Holc*n (US)lnc.
6055 E. Crcydon Rd.
Morgan, Utah 84050
UTAH DEPARTMENT OF
ENVIRONMENTAL OUALITY
JAil !, ';t,',-t,
\to",-rd Delivered
DIVISION OF AIR QUALITY
Phone [phone]
wttw.holdm.corn/us
July 28,2A23
Re: Title V Annual Compliane Certification (July 1 2022 to June 30,2023\ and Semi-annual
Compliance Report (January 1,2023 to June 30, 2023)
Enclosed is the Revised Title V Annual Compliance Certification and Revised Semi-annual
Compliance Report for the Holcim (US) lnc. Devil's Slide facility in Morgan, Utah.
lf you have any questions, please contact Clint Badger at 801€29-2122or
clinton. [e-mail]
Weston Fry, lnterim Plant Manager
Holcim (US) lnc.
Devil's Slide Plant
6055 East Croydon Road
Morgan, Utah 84050
801-8296821
CC: Environmental Protection Agency, Region Vlll
Office of Enforcement, Gompliance and Environmental Justice
(mall code SENF)
1595 Wynkoop Street
Denver, CO80202-1129
REVIEWED Initials: Date: Jan 15, 2024Compliance Status: OKFile #: 10007 (B2)Comment: Revised to indicate correct report period and no deviations regarding permit conditions I.B and II.B.8.a.
ffi;.::::>-"--
I
iI L,tlt -42024
TO: Executive Secretary, Utah Air Quality Board
FROM: Holcim (US) Inc. Devil's Slide Plant DIVISION OF AIR OIJAI.ITY
RE: Semi-annual Motritoring Report rnd Annual Title V Compliance Certification for Permit # 2900001004 (Revised )
DATE July 28,2023
In accordance with Operating Permit Provision l.L. and Utah Administrative Code (UAC) R307-415-6c(5), the following compliance certification is submitl
Compliance report from July 1,2022to 1we30,2023
The must be consecutive to the last certification. and cannot cover more than one year. Be sure to submit by the 30
.8.A/as the source operated in compliance with
he operating permit?
Leview subsequent
eports and permit
:onditions
Oontinuous fhis provision could be read to mean that
rny instance of a deviation or excursion
dentified in this report automatically makes
:ompliance with this requir€ment
ntermittent. However, this goneric
:ondition is redundant to other, mor€
rpecific requirements of the permit and
Joes not croate additional substantive
€quirements. Nonetheless, we are
'eporting intermittent compliance here to
rnsure a full disclosure.
c.3 Did the permittee fumish information requested
ry the Executive SecretaqP
\o roquests 0ontinuous
G.1 Did the permittee pay the annual emission fee?rayrnent Oale 081'l'l 12023
lheck #1600014546,14
Sontinuous
G.2 /Vas the Fee paid on Time -ayment uale uu 1't I zuzS
lheck #16000145116114
Continuous
.K.,Vere all application forms, reports and
:ertifications submitted pursuant to the permit
rroperly certified by a responsible official?
rlant Manager (signatur€)
s the responsible official.
Sontinuous
.1.1 )id the permittee submit this compliance
lertification complete & on time?
nformation sent with
:racking number enabled.
]ertification noted as
€ceived on time.
Sontinuous
.L.2 Did the permittee also send all compliance
rertifications to EPA?
nformation sent with
:racking number enabled.
:ertification not6d as
eceived on time.
3ontinuous
.S.1.a Did the permittee properly retain all records
'equired by the permit?
l,ecords on file in the
rarious plant offices.
Sontinuous All reports referenced are kept at the plant
;ite.
.s.'l.b Did the permittee include all applicable
nformation in records of monitoring required
ry the permit?
lecords on Iils in th€
rarious plant offices.
0ontinuous All reports referenced are kept at the plant
site.
.S.2.a Did the p€rmittoe submit monitoring reports
every six months, or more frequently if
specified in Section ll, and were all instances
of deviation from permit r€quirements clearly
identified in the monitoring reports?
{epons suomrneo ev6ry o
nonths by July 30, and
January 30 each year.
Continuous
.s.2.b All reports will be certified by a responsible
rfficial
Records on file & sent to
UDAO
Continuous
5.2.C Did the permittee promptly notify the Executive
Secretary of all deviations from permit
requirements?
Deviation reports filed as
required, k€pt on site.
Continuous
1 of15
t.u Did the permittee submii the emissions
inventory required by R307-150 in accordance
with the requirements of that rule? (This covers
R307-150, 155 and 158 if listed in permit)
S02 Emissions summary
;ubmitted on April '17,
2023.
.;ontinuous
2of 15
REVIEWED Initials: Date: Jan 15, 2024Compliance Status: OKFile #: 10007 (B2)Comment: Revised to indicate correct report period and no deviations regarding permit conditions I.B and II.B.8.a.
ll.B.1.a :or each affected emission unit subject to 40
3FR 63 Subpart LLL, the permittee shall
rrepare a written operation and maintenance
.O & M) plan in accordance with 40 CFR
)3.1347 (a). The plan shall include the
bllowing information.
,lan covers all affected
]mission units and is on
ile at th€ plant
)nvironmental office.
0ontinuous
ll.B.1.a. (1)rrocedures for proper operation and
naintenance of the affected source and air
)ollution control devices in older to meet tho
3mission and operating limits in 40 CFR
,3.1 347(a). The O & M Plan shall address
reriods of startup and shutdown.
Plan includes procedures
for operation and
maintenance of affected
sources and air pollution
control devices, and
addresses periods of
startup and shutdown. The
Plan is kept and
maintainod in the plant
environmental office.
Continuous
l.B.'1.a. (2',Oonective actions to be taken when required
cy 40 CFR 63.1350 (0(3).
Sorrective actions, if any,
are on file in the Plant
Maintenance s)rstem.
Continuous
1.B.1.a.(3)Procedures to be used during an inspection ol
the compononts of the combustion system of
th€ inline
kiln/raw mill at least once per year.
Procedures are outlined in
lhe O&M Plan and records
rf the combustion system
nspection kept on file in
the plant environmental
cffice. Last inspection was
3onducted on O4l 1 212O23.
11.8.1.a.2 Records demonstrating compliance with this
condition shall be maintained in accordance
with 40
CFR 63.1355, Table 1 to 40 CFR 63 Subpart
LLL-Applicability of General Provisions, and
Provislon 1.S.1 of this permit.
:il6s are maintained onsite
br a minimum of 5 years in
nper and electronic
brmats.
lontinuous
11.8.1.a.3(/
w)
ln addition to the requirements in Section lof
this p€rmit, one summary repo( shall be
submitted semiannually within 60 days of the
reporting period for the hazardous air
pollutants monitored at each affected source.
The summary report shall be entitled
'Summary Report - Gaseous and Opacity
Excess Emission and Continuous Monitoring
System Performance' and contain following
information (see permit)
leports submitted every 6
nonths by August 30, and
:ebruary 28 each year via
)EDRI.
lontinuous
11.B.1.a.3(X
)
(X) Within 60 days after the date of completing
each performance evaluation or test, as
defined in 40 CFR 63.2, conducted to
demonstrate compliance with any standard
covered by 40 CFR 63 Subpart LLL, the
permittee shall submit the relative accuracy
test audit data and performance test data,
except opacity data, to the EPA by
successfully submitting the data electronically
via CEDRI and by using the Electronic
Reporting Tool (ERT) (see
https ://www.epa.gov/electronic-reporting-air-
emissions/electronic-reporting-toolert). For
any performance evaluations with no
corresponding RATA pollutants listed on the
ERT website, results of the performance
evaluation shall be submitted to the
Administrator at the appropriate address listed
in 40 CFR 63.13. (40 CFR 63.1354(bX11))
)ata to be submitted within
i0 days of completing
>erformance test.
lontinuous
3of15
ll.B.'l.a.3(Y
)
(Y) For PM performance test reports used to
set a PM CPMS operating limit, the electronic
submission of the test report shall also include
the make and model of the PM CPMS
instrument, serial number of the instrument,
analytical principle of the instrument (e.9. beta
attenuation), span of the instruments primary
analytical range, milliamp value equivalent to
the instrument zero output, technique by which
this zero value was determined, and the
average milliamp signals corresponding to
each PM compliance test run. (40 CFR
63.1354(bX1 l Xii))
PM performance tests
nclude required
nformation.
lontinuous
r.B.1.b Unless otherwise specified in this permit, at all
times, including periods of startup, shutdown,
and malfunction, the permittee shall, to the
extent practicable, maintain and operate any
permitted plant equipment, including
associated air pollution control equipment, in a
manner consistent with good air pollution
control practice for minimizing emissions.
Determination of whether acceptable operating
and maintenance procedures are being used
will be based on information available to the
Director which may include, but is not limited
to, monitoring results, opacity observations,
review of operating and maintenance
procedures, and inspection ofthe source.
[Origin: DAQE-AN1 00070031 -22]. [40 CFR
60.11(d), R307401-BI
Operations and
maintenance records are
kept onsite in SAP.
Continuous
ll.B.1.c All paved / unpaved roads and other unpaved
operational areas that are used by mobile
equipment shall be water sprayed and/or
chemically treated and or swept using a mobile
sweeperto control fugitive dust. The
application of water or chemical treatment shall
be of sufficient frequency and quantity to
maintain a surface material in a damp/moist
condition unless the temperature is below
freezing. The mobile sweeper shall operate as
necessary to control visible fugitive dust
emissions from paved surfaces. [Origin DAQE.
AN01 00070031 -22), 1R307 401 -8, R307-205-71
Logbook of date and type
of control, number of
treatments, rates,
precipitation received, time
of day treatments are
made, and quantity kept in
data historian system.
Temperature information
provided by operational
software / intemet.
Continuous
4of15
[.8.1.d l-he permittee shall comply with the applicable
equirements for servicing of motor vehicle air
ronditioners pursuant to 40 CFR 82, Subpart B
.Servicing of Motor Vehicle Air Conditioners.
prigin: 40 CFR 821. [40 CFR 82.30(b)]
Work orders maintained in
the Maintenance SAP
system.
0ontinuous Licensed operator and equipment work
from the Quarry office. lndividual records
kept at that location.
ll.B.1.e Ihe permittee shall comply with the applicable
equirements for the recycling and emission
'eduction for class I and class ll refrigerants
)ursuant to 40 CFR 82 Subpart F - Recycling
rnd Emissions Reduction. [40 CFR 821. 440
;FR 82.1 50(b)I
Maintenance contracts,
work orders and records of
maintenance of class
refrigerants maintained in
the Maintenance SAP
system.
Continuous
il.8.1.f The permittee shall install and operate
baghouse dust collectors at all conveyor
transfer points at the following affected
emission units: Crusher: lmpact Crusher &
Conveying Operations, Coal: Coal Milling,
Processing & Conveying, and RawMealPrep:
Raw Meal Preparation System. The collectors
shall operate whenever dry conditions wanant
or as determined necessary by the Director.
[Origin: DAQE-AN10007003'1 -22]. [R307-401-
8l
q visual opacity survey is
:ondubted. Records
naintained at the
-'nvi ronmental office.
Sontinuous
l.B.1.g Mining operations and transporting of materials
'rom the mine to the plant shall be limited to
letween 5:00 a.m. and 8:00 p.m. each day.
.Origin: DAQE-AN01 00070031-221. [R307-401
3l
Records maintained on the
..quipment logbook
0ontinuous Records on file in the quarry database
LB.1.h qll PM10 Stack emission releases shall be
rented vertically without any restriction to
lpward momentum at or beyond the stack
rpening. [Origin: DAQE-AN0100070027-20].
'R307-401-8I
Stack release points
nodified to vertical
Jischarge points, fall of
2006. Nofurtherstacks
rave been added.
Sontinuous
5of15
-
il.8.1.i Visible emissions from abrasive blasting
operations shall not exceed 40% opacity,
except for an aggregate
period of three minutes in any one hour.
[Orisin: R307-206]. [R307-2064]
{o abEsr
)lace in tl
rriod per
rcrk orde
Iherefore
o Dlastrng tooK
r reporting
maintenance
s and contracts.
no VEOs uiere
rd.
;ontinuous
ll.B.2.a For the 755 HP generator:
The emergency engine shall not operate on
site for more than I 00 hours per calendar year
for maintenance checks and readiness testing.
The engine may be operated for up to 50 hours
per calendar loar in non€mergency situations.
Any op€ration in non€mergency situations
shall be count€d as part of ths 1 00 hours per
calendar year for maintenance and testing.
There is no time limit on the use of the engine
during emergencies. lOrigin: DAQE-
ANI 00070031 -221. [R307401 €]
Records c
ocated in
fnvironmr
I operation are
lhe
intaloffice
Continuous
l.B.2.b For both the 755 HP and 166 HP generators:
Visible emissions shall be no greater than 10
percent opacity. [Origin: DAQE-AN100070027
201. [R307401-8]
-og book
rours kep
pf operation
f with the
I Additional log
ienvironmental
!^'.'.::,.,ro- "^.,
Continuous
(ept in th(
rffice for r
)pacity dr
:onsecuti'
lave occl
lil;;;;",;
fe operations
h€d.
l.B.2.c l-he permittee shall comply with the following
)perating limitations at all times for the 166 Hp
tmamahav daneEl6r
No condil
f th€ se(
)n - introductior
ion
Continuous
l.B.2.c(1)lhe permittee shall operate the affected
'mission
unit according to the requirements in
10 cFR 63.6640(f)
-og or ho
in file to
,vith the s
rs of operation
row compliance
ction listed.
Continuous
t.B.2.c(2)lhe permittee shall meet the following
equirements at all times, except during
reriods of startup:
Maintena
Mth the €
ce report on file
)ctrical and
ntal
ts.
Continuous
)p€ration or annually, whichever comes first;
). lnspect air cleaner every 1,000 hours of
)peration or annually, whichever comes first;
:. lnspect all hoses and belts every 500 hours
rf operation or annually, whichever comes first,
rnd replace as necessary.
)uring periods of startup, the permittee shall
ninimize the engine's time spent at idle and
ninimize the engine's startup time to a period
reeded for appropriate and safe loading of the
)ngine, not to exceed 30 minutes, after which
iime the non-startup emission limitations apply.
6of15
ll.B.2.c(3)The permittee shall comply with the applicable
general provisions in 40 CFR 63. t -15 as
identified in Table 8 of 40 CFR 63 Subpart
7777.l$ngin: 40 CFR 63 SubpanZTfA. 140
CFR 63.6595(a)(1), 40 CFR 63.6602, 40 cFR
63.6605(a), 40 CFR 63.6625(h), 40 CFR
63.6640(f), 40 CFR 63.6665, 40 CFR 63
Subparl7272 Table 2c, 40 CFR 63 Subpart
7777 Table 81
{our Logs, maintenance
nspections,and data
ecorded in the plant
naintenance system
]ontinuous
il.8.2.d At all times the permittee shall operate and
maintain the 166 Hp emergency generator,
including associated air pollution control
equipment and monitoring equipment, in a
manner consistent with safety and good air
pollution control practices for minimizing
emissions. The general duty to minimize
emissions does not require the permittee to
make any further efforts to reduce emissions if
levels required by this standard have been
achieved. Determination of whether such
operation and maintenance procedures are
being used will be based on information
available to the Executive Secretary which may
include, but is not limited to, monitoring results,
review of operation and maintenance
procedures, review of operation and
maintenance records, and inspection of the
source. [Origin: 40 CFR 63 Subparl7zZl.
[40 CFR 63.65e5(a)(1), a0 cFR 63.6605(b)l
'lours of oporation and
naintenance inspections
rn file.
lontinuous
ll.B.2.e For both the 755 HP and the '166 HP
generators:
The permittee shall only use diesel fuel (e.9.
fuel oil #1, #2, or diesel fuel oil additives) as
fuel in the
emergency generators. All diesel fuel
combusted in the emergency engines shall
meet a sulfur content of
15 ppm or less. [Origin: DAQE-AN100070031-
221. [R307401-8]
)iesel records maintained
n Environmental ffice &
rbtained from
)rocurement Department.
Continuous
7ot15
ll.B.3.a y'isible emissions shall be no greater than 20
rercent opacity from haul roads & operational
rreas used by mobile equipment. [Origin:
)AQE-ANl 00070031 -22). [R307-205, R307-
r01-8I
A visual oliacity survey (6-
points along the roadway)
is conductld monthly.
Records Taintained at the
quarry offi{e and
environm*ltal oftice.
lontinuous
il.8.3.b y'isible emissions shall be no greater than 20
rercent from stockpiles. [Origin: DAQE-
\Nl 00070031 -221. [R307-205, R307401 {]
A visual oilacity survey is
conducted] monthly.
Records nlaintained at the
quarry offi{e and
environm*ltal offic€.
)ontinuous
ll.B.3.c y'isible emissions shall be no greater than ',l0
rercent opacity from drill rig baghouse [Origin:
)AOE-ANl 0007003't -221. [R307401 -8]
A visual of,acity survey is
conducted monthly.
Records rnaintained at the
quarry offi$e and
environmefrta I office.
)ontinuous
ll.B.4.a y'isible emissions shall be no greaterthan 15
rercent opacity from the crusher. [Origin: 40
)FR 60 Subpart OOO, DAQE-AN100070031-
221. [40 CFR 60.672(b), R307-401-8]
A visual ofacity survey is
conducted monthly.
Records rtaintained at the
quarry offile and
environmgntal office.
lontinuous
lt.B.4.b y'isible emissions shall be no greater than 7 A visual o facity survey is lontinuous
prigin:40 CFR 60 Subpart OOOI. [40 CFR
i0.672(a)l
Records
quarry offi
taintained at the
te and
fl.ts.4.C Permiuoe shall install water sprays to control
fugitive emissions in the crusher dump pocket.
The sprays shall operate whenever dry
A visual opacity survey is
conducted monthly.
Records at the
quarry and
al office.
]ontinuous
v
bythe Executive Secretary. Sprays shall not
be required to operate during periods of
freezing temperatures. [Origin: DAQE-
AN'1 00070031 -221. [R307401 -8]
l.B.4.d y'isible emissions shall be no greater than 10 A visual o1 facity survey is lontinuous
,ransfer points on belt conveyors or any other
Subpart OOO affected facility. [40 CFR 60
iubpart OOOI. [40 CFR 60.672(b)]
Records
quarry offi
taintained at the
;e and
t.ts.4.e :missions of particulate matter (PM) shall be
ro greater than 0.05 g/dscm (0.022 gr/dscf)
'rom baghouse stacks. [Origin:40 CFR 60
iubpart OOOI. [40 CFR 60.672(aI
Test condf,rcted week of
July'17, 2023. Previous
test was i{ compliance
with the lihits, awaiting
test resultb.
lontinuous Test conducted May 20't9 with a frequency
of once every 5 years - Previous Report
sent to the state, 2023 Report will be sent
sent to the State upon reciept.
1.8.4.e.3 lhe results of stack testing shall be submitted
o the Director within 60 days of completion of
:he testing. Reports shall clearly identify
'esults as compared to permit limits and
ndicate compliance status. Reports shall be
submitted in accordance with 40 CFR 60.676(f
and as specified in Section I of this permit.
Stack tesB submitted to
Director rafthin 60 days of
completiolt of testing.
]ontinuous Previous reports s€nt to State
8of15
emissions shall be no great€r than
opacity. lOrigin: 40 CFR 60 Subpart Y
at! tvuv, vvo t-
[40 CFR 60.254(a), R307401 {]
9of15
ir
l
ll.B.6.a lhe sulfur content of any coal or mixture of
:oals bumed in the kiln shall not exceed 1.0 lb
;ulfur per MMBTUs of heat input. The sulfur
)ontent of any fuel oil bumed in the kiln shall
rot exceed 0.85 lbs sulfur per million gross
lTUs heat input. [Origin: DAQE-
\Nl 00070031 -22, R307-203-11. [R307-20]1,
1307401-8I
Records o
content ar
Environmr
I coal sulfur
, kopt in th€
rntal Office.
Continuous
il.8.6.b imissions of SO2 shall be no groater than 475
bs./hr. on a rolling 24-hour average and 457
ons/12 RA. [Origin: DAQE-AN100070031-22].
'R307-40141
MOnrtor rn
certified. I
Last RAT/
Iafleo. KAtA
)ata collected.
ldale July2022
Continuous Test results on site and submifted to the
State, No exceedances. See EER report
for quarterly information.
ll.B.6.c imissions of CO shall be no greater than 438
bs./hr. [Origin: DAQE-ANI 00070031-221.
,R3074014I
Test comr
2022.
leted 2OJuly lontinuous
il.B.6.d Emissions of NOX shall be no greater than
1 ,817 tons per rolling 12 month total. [Origin:
DAQE-AN1 00070031 -221. [R307401 -8]
UEM OAI€
monlh rol
in the Pla
system. I
CGA perf
and quarl
RATAtes
2022.
ogs and 12-
rg average kept
tcomputer
ATA tests and
rmed annually
rly respectively.
conducted July
]ontinuous RATA completed successfully July 2022.
ll.B.6.e lhe Permittee shall use only the fuels listed in
,he permit. [Origin: DAQE-ANI00070031-221.
,R3074014I
The list 01
maintaine
productio
available
unit office
'uets us90
on the
reports
t the business
]ontinuous
t.B.6.f lhe Permittee shall not oxc€ed the parameters
isted in this condition for the use of fuel oil.
prigin: DAQE-AN10007003't-221. [R307401-
ll
FUel oil ni
during thi
Productio
fuels avai
business
; not b6en used
period.
reports of other
rble at the
ffice.
lontinuous
ll.B.6.g \s part of demonstration of compliance with
:he dioxinlfuran emission limitations in this
rermit, the permittee shall operate the kiln
;uch that the temperature of the gas at the
Temperatr
PMCD's,
lre prollles of
Dalibration
d/or replacemenl
p probes
i Annual
fr inspection of
I equipment
lin the last
?o21.
I monitoring
lr Semi-Annual
\1H2022.
)ontinuous
rgPUr
of the tem
PMCD) and alkali bypass PMCD, if
lpplicable, does not exceed the applicable
emperature limits (for both raw mill operating
rnd not operating as determined and
)stablished in accordance with 40 CFR
i3.1 349(bX3Xiv) except during periods of
;tartup/shutdown when the temperature limit
nay be exceeded by no more than 10 percent.
lhe permittee shall conduct an inspection of
:he components of the combustion system of
rach kiln or in-line-kiln/raw mill at least onco
)er year. [Origin: 40 CFR 63 Subpart LLL].
40 CFR 63.1 346(a), 40 CFR 63.1 346(b)l
combustio
the burnin
completeo
quarter of
Continuou
reported fr
Report for
t.B.6.h lmissions of Dioxins/Furans (D/F) shall be no
lreater than 0.2 ng/dscm (TEQ) on a dry basis
ronected to 7 percent ox)€en during normal
I est conc
of Januar
prior notif
Eted th6 wBek
3',t,2021. Au
ations sent to
:ordingly. D/F
again July 17-
,port will be senl
lontinuous
JPETAUUTT, I Urs qYgrAUg r9rrrl
nlet to the first PM control device (fabric filter
)r electrostatic precipitator) during the D/F
)erformance test is 400 degrees F or less this
imit is changed to 0.40 ng/dscm (TEQ).
was teste
21 2023,
upon reci
10 of 15
t.B.6.i At all times the permittee shall operate and
maintain any affected source, including
associated air pollution control equipm6nt and
monitoring equipment, in a manner consistent
with safety and good air pollution control
practices for minimizing emissions.
Determination of whether such operation and
maintenance procedures are being used will
be based on information available to the
Director which may include, but is not limited
to, monitoring results, review of operation and
maintenance procedures, review of operation
and maintenance records, and inspection of
the source. [Origin: 40 CFR 63 Subpart LLL].
[40 cFR 63.1348(d)]
SAP maintenance plans,
epairs, and inspection
ecords on file. Visible
smissions monitoring as
,vell as compliance
nonitoring available.
Continuous
8.6 j Combined PM emissions from the in-line
kiln/raw mill and the alkali bypass stack shall
be no greater than 0.07 lb/ton clinker during
normal operation. This condition applies on
and after the compliance date specified in 40
CFR 63.1343. [Origin: 40 CFR 63 Subpart
LLLI. [40 CFR
Performance testing
:onducted July 2O22. T esl
'eport and PM CPMS
ndicated compliance.
Continuous
t.B.6.k Emissions of mercury shall be no greater than
55 lb/MM tons clinker based on a rolling 30-
day average during normal operation. The 30-
day period means 30 consecutive kiln
operating days excluding periods of startup
and shutdown.
3EMs installed, RATA
:ested, QGAs conducted,
}EM data logs kept in
)AS computer system.
Gontinuous {g RATA testing completed 712012022
t.B.6.t Emissions of total hydrocarbon (THC) shall be
no greater than 24 ppmvd, on a dry basis,
measured as propane, corrected to 7 percent
oxygen, based on a rolling 30day average
during normal operation. The 30day period
means 30 consecutive kiln operating days
excluding periods of startup and shutdown.
Any source subject to the 24 ppmvd THC limit
may elect to meet an alternative limit of '12
ppmvd for total organic HAPS.
SHAP performance test
ronducted February2021.
lEMs installed, RATA
:ested, CGAs conducted,
]EM data logs kept in
)AS computer system.
Continuous
l.B.6.m Emissions of HCI shall be no greater than 3
ppmvd, on a dry basis, corrected to 7 percent
oxygen, during normal operation. lf using a
CEMS to determine compliance with the HCI
standard, this standard is based on a rolling 30
day average. The 30iay period means 30
consecutive kiln operating days excluding
periods of startup and shutdown.
lCl spike test conducted
)5t17t2023.
0ontinuous
l.B.6.n )uring periods of startup and shutdown, the
)ermittee shall meet the requirements listed in
i1 ) through (3).
\ll records, reports and
rrocess conditions are
naintained on file or in the
:lant data historian
;ystem.
30ntinuous
l.B.6.n(1))uring startup the permittee shall use any one
)r combination of the following clean fuels:
ratural gas, synthetic natural gas, propane,
listillate oil, synthesis gas (syngas), and ultra-
ow sulfur diesel (ULSD) until the kiln reaches
r temperature of 1200 degrees Fahrenheit.
\ll fuel records and
rrocess conditions are
naintained in the plant
iata historian system.
Sontinuous
1'l of 15
ll.B.6.n(2)Combustion of the primary kiln fuel may
commence once the kiln temperature reaches
1 200 degrees Fahrenheit.
\ll procesg conditions are
naintained in the plant
lata historian system.
lontinuous
ll.B.6.n(3)All dry sorbent and activated carbon systems
that control hazardous air pollutants shall be
tumed on and operating at the time the gas
stream at the inlet to the baghouse reaches
300 degrees Fahrenheit (five minute average)
during startup. Temperature of the gas stream
is to be measured at the inlet of the baghouse
every minute. Such injection systems can be
tumed off during shutdown. Particulate control
and all remaining devices that control
hazardous air pollutants shall be operational
durinq startup and shutdown.
\ll process and monitoring
ronditions are maintained
n the plant data historian
lnd the DAS computer
;ystem.
30ntinuous
ll.B.6.o By Seplember 10, 2023, the permittee shall
submit documentation to the Director on the
status of construction of the SNCR system.
The referenced approval order (AO) may
become invalid if construction is not
commenced by September 10,2023 or il
construction is discontinued for 18 months or
more. To ensure proper credit when notifying
the Director, send the documentation to the
Director, attn.: NSR Section. [Origin: DAQE-
AN1 00070031 -22, R307401 -1 81.
Facility ha8 not
constructed SNCR.
Therefore, no
documentation has been
submitted to the Director.
lontinuous
12 of 15
930,000 short tons per rolling 12 month total.
lOrigin: DAQE-ANO1 00070024-081. [R307-
At all times the permittee shall operate and
maintain any affected source, including
associated air pollution control equipment and
monitoring equipment, in a manner consistent
with safety and good air pollution control
practices for minimizing emissions.
Oetermination of whether such operation and
maintenance procedures are being used will
be based on information available to the
Oirector which may include, but is not limited
to, monitoring results, review of operation and
maintenance procedures, review of operation
and maintenance records, and inspection of
the source. [Origin: 40 CFR 63 Subpart LLL].
[40 cFR 63.1348(d)]
Maintenance records
maintenance work order
system, inspections
Continuous
Emissions of PM shall be no greater than 0.07
clinker during normal operation
testing conducted the
oI July 19-21,2022
approved Method to
SSOL. Protocols,
startup and shutdown, all dry
and activated carbon systems that
hazardous air pollutants shall be tumed
and operating at the time the gas stream at
inlet to the baghouse reaches 300 degrees
ahrenheit (five minute average) during
Temperature of the gas stream shall
measured at the inlet of the baghouse
. Such injection systems can be tumed
during shutdown. Particulate control and all
devices that control hazardous air
shall be operational during startup
shutdown. [Origin: 40 CFR 63 Subpart
. [40 cFR 63.1 343, 40 CFR 63.1 348(bX9)]
process and monitoring
are maintained
the plant data historian
the OAS computer
[.8.7.d
emissions shall be no greater than 10
opacity during all modes of operation
40 CFR 63 Subpart LLLI. DAQE-
1700031 -221. [40 CFR 63.1 34340 CFR
1345, R307401-81
13 of 15
[.8.8.b At all times the pennittee shall operate and
maintain any affected source, including
associated air pollution control equipment and
monitoring equipment, in a manner consistent
with safety and good air pollution control
practices for minimizing emissions.
Determination of whether such operation and
maintenance procedures are being used will
be based on information available to the
Executive Secretary which may include, but is
not limited to, monitoring results, review of
operation and maintenance procedures, revier
ofoperation and maintenance records, and
inspection of the sourco. [Origin: 40 CFR 63
Subpart LLLI. [40 CFR 63.1348(d)]
SAP mainfenance plans,
repairs, and inspections
records on file. Visible
emissions monitoring as
well as compliance
monitoring available.
Continuous
ll.B.9.a Visible emissions shall be no greater than 10
percent opacity. [Origin: 40 CFR 63 Subpart
LLL, DAOE-AN1 00070027-201. [40 CFR
63.1345, R307401-8I
\4ethod 22 visual
)missions tests are
)onducted as required. lf
leeded Mtthod 9 follow-ug
:onducted. Records on
1le.
Sontinuous
[.B.9.b At all times the permittee shall operate and
maintain any affected source, including
associated air pollution control equipment and
monitoring equipment, in a manner consistent
with safety and good air pollution control
practices for minimizing emissions.
Determination of whether such operation and
maintonance procedures are being used will
be based on information available to the
Executive Secretary which may include, but is
not limited to, monitoring results, review of
SAP mainFnance plans,
repairs, and inspections
records on file. Visible
emissions monitoring as
well as coarpliance
monitoring available.
lontinuous
of operation and maintenance records, and
inspection of the source. [Origin: 40 CFR 63
Subpart LLLI. [40 CFR 63.1 348(d)]
l
This souce is oot subjet to Setioa II: Emi$ions Trading, Setion II: Alt@ative Opqating Scriuios, md Sction IV: Acid Rain Provisioro
14 of 15
REVIEWED Initials: Date: Jan 15, 2024Compliance Status: OKFile #: 10007 (B2)Comment: Revised to indicate correct report period and no deviations regarding permit conditions I.B and II.B.8.a.
Gltt-llcdon
Iaeooodlcswi6OocrhgDoeqwUotlXrdUACRt0T,tlS-srLndtdcinhliodbdi.fhdrfunrm&lchlq&v.Iodft6dlh!w;ltr::Simrmrofrtmor[lcoEd.tfrrtb8e!! Orff *
hlty hdnltatlttm
fild a ttE 6! nG rd tl0c of Boodlfc Ofrdrl
2&rdJ3
30.rbu.23
DIVISTON OF AIR OUALITY
15d13
ill HoLoM
January 19,2022
State of Utah
Division of Air Quality
195 North 1950 West
P.O. Box 144820
Salt Lake City, Utah, 841144820
Re: Semi-annual Compliance Report (July 1 , 2022 to December 31, 2022)
Enclosed is the Title V Annual Compliance Certification and Semi-annual Compliance Report for
the Holcim (US) lnc. Devil's Slide facility in Morgan, Utah.
lf you have any questions, please contact Derrick Dease at 719-285-5762 or
[e-mail]
Paul Rogers, Plant Manager
Holcim (US) lnc.
Devil's Slide Plant
6055 East Croydon Road
Morgan, Utah 84050
801-829-6821
CC: Environmental Protection Agency, Region Vlll
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO80202-1129
Holcim (US) lnc.
6055 E. Croydon Rd
Morgan, Utah 84050
UTAH DEPAETfv{[tlT Ot:
ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
Phone[phone]'l
www. holcim.com/us
REVIEWEDInitials: Date: February 21, 2023Compliance Status: Not Compliant File # 10007 (B2)Comment: Document needs to be revised to include the correct report period and date. The deviations in conditions I.B and II.B.8.a need to be deleted. No deviations were reported for this report period. Will be resubmitted in July 2023.
TO: Executive Secretary, Utah Air Quality Board
FROM: Holcim (US) Inc. Devil's Slide Plant
LTTAH DEPARTMENT OF
ENVIRONMENTAL QUALI1Y
FEB 2023
RE: Semi-annual Monitoring Report and Annual Title V Compliance Certification for Permit# 2900001004
DATE January 18, 2022 DIVISION OF AIR QUALITY
In accordance with Operating Pennit Provision I.L. and Utah Administrative Code (UAC) R307-4 l 5-6c(5), the following compliance certification is submitted.
Compliance report from July I, 2022 to December 3 I, 2022
(Note: The certification periods must be consecutive to the last certification. and cannot cover more than one year. Be sure to submit by the date in your pennit!)
Was Compliance during Other info relevant to compliance status,
including references to any and all deviations;
Term Method used to determine report period reasons for "undetermined" status; any compliance status continuous, intermittent excursions or exceedances (for CAM provisions or undetermined? only); etc.
Descriotion of oermit orovision
l.B. This provision could be read to mean that any
instance of a deviation or excursion identified in this
report automatically makes compliance with this
requirement intermittent. However, this generic
condition is redundant to other, more specific
requirements of the permit and does not create
additional substantive requirements. Nonetheless,
Was the source operated in compliance with the Review subsequent reports and we are reporting intermittent compliance here to
operating permit? permit conditions Intermittent ensure a full disclosure.
l.C.3 Did the permittee furnish information requested by the
Executive Secretary? No requests Continuous
l.G.1 Payment Date 8/31/2022
Did the permittee pay the annual emission fee? Doc#1900229882 Continuous
l.G.2 Payment Date 8/31/2021
Was the Fee paid on Time Doc#1900229882 Continuous
l.K.
Were all application forms, reports and certifications
submitted pursuant to the permit properly certified by a Plant Manager (signature) is the
responsible official? responsible official. Continuous
l.L.1 Information sent with tracking
Did the permittee submit this compliance certification number enabled. Certification
complete & on time? noted as received on time. Continuous
l.L.2 Information sent with tracking
Did the permittee also send all compliance certifications number enabled. Certification
to EPA? noted as received on time. Continuous
l.S.1.a
Did the permittee properly retain all records required by Records on file in the various
the permit? plant offices. Continuous All reports referenced are kept at the plant site.
l.S.1.b
Did the permittee include all applicable information in Records on file in the various
records of monitoring required by the permit? plant offices. Continuous All reports referenced are kept at the plant site.
l.S.2.a
Did the permittee submit monitoring reports every six
months, or more frequently if specified in Section II, and Reports submitted every 6
were all instances of deviation from permit requirements months by July 30, and January
clearly identified in the monitoring reports? 30 each year. Continuous
l.S.2.b
All reports will be certified by a responsible official Records on file & sent to UDAQ Continuous
l.S.2.c
Did the permittee promptly notify the Executive Secretary Deviation reports filed as
of all deviations from permit requirements? required, kept on site. Continuous
1.U
Did the permittee submit the emissions inventory required
by R307-150 in accordance with the requirements of that
rule? (This covers R307-150, 155 and 158 if listed in SO2 Emissions summary
permit) submitted on February 23, 2022. Continuous
1 of 13
ll.B.1.e For each affected emission unit subjecl to 40 CFR 63
Subpart LLL, the permittee shall prepare a witten
operetion and maintenanc€ (O & M) plan in accordanc€
with 40 CFR 63.1 347 (a). The plan shall incluG the
folloryino information.
tlan covers all affected amission
mits and is on ,ile at the plant
,nvironmsntal office.Continuoug
1.8.1.a. (
,lan includes procedures for
)p€ration and maintgnanc€ of
Continuous
,fiecled sou,ce and air pollulion control d€vicEs in order
lo me€t the emission and op€rating limits in 40 CFR
t3. 1 347(a). The O & M Plan shall address periods of
stailuo end shutdM
Dntrol devic€s, and addnesss
)eriods of startup snd shutdo^rn.
Ihe Plan is kept and mainiained
n th6 plant mvircndEntel ofiic€.
ll.B.1.a. (2)
Con€ciiv€ ac{ions to b€ laken when requked by 40 CFR
t3.1350 (O(3).
loneGlive actions, if any, are on
ile in ths Plant Maintenance
ivslem Continuous
ll.B. La.(3)
Procsdures to b€ used during an inspedion of lhe
:omponsnts of the combustion system of the inlinE
(ilrvraw mill at least onca oar year.
,rocodures ar6 outlined in tho
)&M Plan and records of the
Dmbustion system inspeclion
(opt on file in tho planl
,nvironmgntal ofiioe. Last
nspoclion was conducled on
v17r20D..Continuous
11.8.1.e.2
RMrds demonstreting @mplianc€ with this condilion
shall b6 maintain6d in accordancs with 40
CFR 63.1355, Tabls 1 to 40 CFR 63 Subpart LLL-
Applicability of General Provisions, and
Provisim l.S I of thi8 oemit
:iles are maintained onsite for a
ninimum ot 5 year6 in paper and
,ectrcnic fomats Continuous
l.B.'1.a.3(A-
rv)
n addition to the requiremenB in Section I of this pormit,
,ne summary reporl shall b€ submitted semiannually
vilhin 60 days of the reporling p€riod for the hazardous
rir pollutants monitored at each sfiectod source. The
ummary r€port shall b€ entitled "Summary Report -
3as€oG and Opacity Excess Emission and Continuous
,onitdng Syst€m Performance" and contain folliling
t^mrtiMl.Effiitr
leports submittsd svery 6
nonttu by August 30, and
:ebruary 28 each y€ar via
tFnpt Conlinmus
1.8.1.a.3(X)
lX) Wthin 60 days alter th6 date of @mpleting each
,erformance evaluation tr test, as dafined in 40 CFR
33,2, conductEd to demonstrate compliance with any
standard covered by 40 CFR B Subpart LLL, th6
c€rmittee shall submit the relative acqracy test audit
Cata and performance test data, oxcopt opacity data, to
)ata submitlod within 60 days of
pmdatim mrfmane test Continuous
,ia CEDRI and by using th3 Elactronic Reporting Tool
IERT) (s@ https://w.epe.gov/elscironic{6porting-air-
emissions/6lstroniereporting{ool-€ri). For any
cerfomance evaluations with no conssponding RATA
collulants listed on the ERT websiie, rosults of the
cerformance evaluation shall bo submitted to th€
Administrator at the appropriats address listsd in zlo CFR
53.13. (/tO CFR 63.1354(bX'1 1 ))
2 al '13
1.8.1.a.3(Y)
Y) For PM performan@ tesl reports used to set a PM
IPMS operating limit, the electronic submission of the
est report shall also include the make and model of the
)M CPMS instrument, serial number of the instrument,
rnalyti€l principlg of the instrumant (e.9. bsta
ittsnuation), span of the instruments primary analytical
ang6, milliamp value equivalent to the instrumsnt zefo
)utput, technique by which this zero value was
l€termined, and the average milliamp signals
:onosponding to each PM @mpliancs tast run. (40 CFR
t3.1354(bX1 1 Xii))
,M perfomance lssts include
eouired information.Continuous
[.8.1.b
Jnless otheMise specified in this permit, at all times,
ncluding periods of startup, shutdM, and malfunctjon,
he pemittee shall, to the extent practi€b16, maintain
rnd opsrate any permitted plant equipment, including
rssociated air pollution control equipment, in a manner
)onsistent with good air pollution mntrol praclice for
ninimizing omissions. Detemination of sfiethea
l@ptable operating and maintenance procedures are
Eing used will be based on informatlon available to the
)irector which may include, but is not limitad to,
nonitoring results, opacity obsarvations, review of
)perating and maintenance procedures, and inspection
f the source. lorigin: OAQE-AN 100070031-22t. 140
IFR 60.1 1(d'.r. R307-401-81
)perations and maintenance
ecords are kept onsite in SAP.Continuous
t.B.'t.c
\ll paved / unpavsd roads and other unpaved operationa
roas that are used by mobile squipment shall be watar
;prayed and/or chomi€lly treated and or swept using a
nobile sweeper to control fugitive dust. The application
f water or chemical treatment shall be of sufiicient
requancy and quantity to maintain a surfa@ material in s
lamp/moist ondition unless the temperature is below
re€zing. The mobile swoeper shall opsrate as ne@ssary
o control visible fugilive dust emissions from paved
iurfaces. lorigin DAQE-AN01 00070031 -221, lR3O7 4O1 -
!. R307-205-71
-ogbook of date and type of
pntrol, number of treatments,
ates, precipitation rsceived, tim(
)f day treatments are made, and
luantity kept in data historian
)ystem. Temp€rature
nformation provided by
)oerational software / internet Continuous
3 of '13
t.B.1.d
Ths permittee shall comply with the applicable
requirgments for servicing of motor vehicle air
conditioners pursuant to 40 CFR 82, Subpari B -
Servicing of Motor Vehicle Air Conditioners. [Origin: 40
cFR 821. I40 CFR 82.30(b)t
A/ork orders maintained in the
Vlaintenane SAP system.Continuous
-icensad op€rator and equipmont work from ths
luarry oltice. lndividual re@rds kept at that
mrlion
t.B.'t.e
fhe permittee shall comply with the applicable
'equirements for the recycling and emission reduction for
Maintenan@ @ntracts, work
orders and records of
Conlinuous
Subpart F - Recycling and Emissions Reduclion. [40
IFR 821. I40 CFR 82.150(b)l
maintained in the Maintanance
SAP svstem
t.B.1.t
fhe pemitlss shall install and operate baghouse dust
)ollec{ors at all conveyor transfer points at the folloring
ffected emission units: Crusher: lmpacl Crusher &
)onveying Operations, Coal: Coal Milling, Pr@ssing &
lonveying, and RawMealPrep: Raw Meal Preparation
lystsm. The collectors shall operate whsnsver dry
)onditions wanant or as determined necessary by the
)irector. torioin: OAOE-AN100070031-221. tR307-401€
\ visual opacity survey is
londucted. Records maintained
al lhe environmental offica Continuous
r.ts.1.9 |,ining operations and transporting of materials from the
nine to th6 plant shall be limited to between 5:00 a.m.
md 8:00 p.m. each day. [Origin: OAQE-4N0100070031
221. IR30740'l-81
lmrds maintained on the
tdlrinmadl lodhook Continuous lecords on file in the ouanv database
t.B.'1.h
\ll PM10 Stack emission releases shall ba vented
/ertiGlly without any restriction to upwerd momentum at
)r beyond the stack opening. lorigin: DAQE-
\N01 00070027-201. IR307-401 €l
Stack release points modified to
vertical discharge points, fall of
2006. No further stacks have
b€en addsd.Continuous
4 of 13
[.8.1.4
/isibl6 emissions from abrasive blasting operations shall
lot exca€d rO% opacity, except for an aggrogale
)eriod ofthree minutes in any one hour. [Origin: R307-
1061. tR307-206{r
,lo abrasive blasting tmk place
n the roporiing p€riod per
mintenanca work ordsrs and
;ontracls. Therefore, no VEOS
vgre dmumented.Continuous
n.b.z.a :or th6 755 HP g€norator:
fhe emergency engino shall not oporats on site for more
han 1 00 houIs per calendar year for maint€nance
)hecks and readinoss tosting. Th€ engino may bo
)porated for up to 50 hourS p€r calsndar y6ar in non-
,mergency situations. Any op€ration in non-€m€rgoncy
iituations shall b€ counted as part of th3 1 00 hours per
)alondar ysar for maintonenco and testing. Th6te is no
ime limit on the us€ of the angine during emergencies.
Origin: DAOE-AN10007 c0,31 -221. [R307-401€l locords of op€ration are located
n the Environmental Ofric€Continuous
il.8.2.b
:or both the 755 HP and 166 HP generators: Msiblo
)missions shall b6 no greater than l0 percent opacity.
Orioin: DAOE.ANl0007@27 -2o1. tR3o7401 €l
-og book of operation hours kopt
Mth the Generalor. Additional
og kept in the environmontal
,fiics for revisw. No omissions
,xos,eding 10% opacity during 12
rour conseculive oporation have
rcur6d Continuous
l.B.2.c
lhe permitte€ shall comply with th6 follo\ring oporating
imitations at all tim€3 for the 166 Hp omergency
|€nErator.
{o condition - introduction ol
he $dion Continuous
l.B.2.c(1)
The permittee shall op€rato the frecled emission unit
accordino to th€ reauiremonts in 40 CFR 63.6640(fl
.og of hours of opgration on file
o show complisnco with the
mtion listed.Conlinuous
t.8.2.c421
The p€rmittos shall me€t th€ follodng requirements at all
times, oxcopt during p€riodE of stsrtup:
a. Chang€ oil and filter every 50O hours of opBration or
annually, whichsver comes firsti
b. ln3p€c.t air cleanor ev6ry 1,000 hours of op€ration or
annually, whichsvor comes firsti
c. lnsp€ci all hos€s and b€lts every 500 hours of
}laintenanco roport on file with
the eloclrical and environmental
Conlinuous
as neoes83ry.
During p€fiods of startup, th€ p€rmitts shall minimize
the ongin€'s time spent at idlo and minimiz6 th6 engino s
startup time to a p€riod ne€ded for appropriate dld sde
loading of the engine, not to exc€€d 30 minut$, afior
$/hich lim6 the non-startup omission limitations apply,
5of13
l.8.2.c(3)
Tho pemittee shall comply with the applicable general
provisions in 40 CFR 63.1{5 as identified in Table I of
40 CFR 63 Subpart ZZZZ. lotigin: 40 CFR 63 Subpart
77771. l4O CFR63.6595(a)(1), a0 CFR 63.6602, 40 CFF
63,660s(a), 40 CFR 63.662s(h),40 CFR 63.6640(0, 40
CFR 63.6665, 40 CFR 63 Subpart ZZZZIable 2c, 40
CFR 63 Suboart ZZZZ Table 8l
Hour Logs, maintenane
inspeclions,and data recorded in
lhe olant mainlenan@ svslem Continuous
LB.2.d
At all times the permittee shall op€rate and maintain the
166 Hp omargsncy gsnerator, including associated air
pollution mnirol equipment and monitoring equipment, in
a manner consistent with safety and good air pollution
control praciices for minimizing emissions. The general
Hours of operation and
maintenene insmclions on tile. Continuous
to make any further efiorts to radu@ emissions if lovels
required by this standard have been achieved.
Detemination of whether such oporation and
maintenan@ proedures are boing used will be based on
infomation available to the Executivs Secretary which
may include, but is not limited to, monitoring results,
review of oporation and mainlenan@ procedures, review
of operation and maintenanca rgcords, and inspection of
the sour6. lorigin: 40 CFR 63 Subpari 77771. [40 CFR
63.6595(aX1 ). 40 CFR 63.6605(b)l
l.B.2.e
For both the 755 HP and the 166 HP gonerators:
The pomittee shall only use dieselfuel (e.9. fuel oil#'1,
#2, or diesel tuel oil additives) as fusl in the
Emargency generators. All diesel fuel combusted in the
gmsrgency engines shall meet a sulfur @ntent of
15 ppm or less. [Origin: DAQE-AN100070031-221. [R307
Diesel rmrds maintained in
Environmental Office & obtained
Cor
6of13
l.B.3.a
/isible emissions 6hall b€ no greater than 20 p€rcent
)pacity from haul roads & op€rationel areas usod by
nobile equipmonl. [Origin: DAOE-ANt0007003l -221.
R307-205. R307-4O1€l
\ visual opacity surv€y (6-points
rlong th€ roadivay) is conductod
nonthly. Records maintainod at
h€ quarry ollica and
)nvironmenial ofiico.Continuous
il.8.3.b
fisible emissions shall be no groatar than 20 p€rcgnt
rom stockpilos. [Origin: DAOE-ANI00070031-22]. [R307
tos. R307-401€l
\ visual opacity survey is
)onducled monthly. Records
naintain€d at the quarry ofiico
ril a^vi. ^6a^t.l ffi.a Continuous
l.B.3.c
/isible Emissions shall b€ no greator than 10 p€rcsnt
)pacity from drill rig baghous€ [Origin: DAQE-
N 1 O0O7m31 -221. IR3O7-rmt -at
\ visual opscity suruey is
,onductod monthly. Records
naintein€d et th€ quarry offios
md environm€ntal office.Continuous
t.u.4.a nsible Emissions shall bs no groatar than 15 parcant
)pacity from the crush€r. lorigin: 40 CFR @ Subpart
)oo, DAQE-AN10O07W31-221. [40 CFR 60.672(b),
1307.{01€l
\ visual opacity survey is
)onduciod monthly. Rocords
naintained at the quany office
nd environmontal ofrice.Conlinuoug
t.B.4.b
y'isible omissiom shall be no groeter than 7 percant
)pacity fiqn beghouso stacks. [Origin: lorigin: 40 CFR
i0 Suboart OOOI lrto CFR 60 672lall
\ visual opacity survoy is
)onducted monthly. Rocords
nainlained at the quarry oflico
nd environmontal ofiico.Cmtinrcus
l.B.4.c
Pomitt€€ shall install water sprays to controltugitive
omissions in tho crushor dump pocket. Ths spray8 shell
op€rato whensver dry condiiions wanant or as
determinsd neco8sery by the Exeqrtive SffiotBry.
Sprays shall not b€ required to op€rato during periods of
tre€zing temperatures. [Origin: DAOE-AN10@70031-
221. lR3O7-{OlAl
\ visual opacity survey ig
Dnducted monthly. Records
naintained at tho quarry offics
md environmenlal offico.Conlinuous
r.B.4.d
y'isiblo emissions shall bs no graator than 10 p€rc€nt
,pacity for fugitive emissions frorn transfer points on b€lt
:onveyors or any other Subpart OOO affected facility.
rO CFR 6O Submrt OOOI. Lm CFR 60 672rbn
A vi8ual opscity $ru6y is
:onduded monthly. Records
Taintain€d at the quarry offic€
and environmental offic€.Continuous
l.E.4.e
:mi$ions of perticulate mattsr (PM) shall b€ no groater
han 0.05 Cds.rn (0.022 grldscf) from baghouse stacks.
Orioin: 40 CFR 50 Submrt OOOI I4o CFR 60 672lall
Tost conduded w€ok of May 13,
2019. Test uras in compliance
with the limit3.Continuous
Test conducted May 2019 with a t€quen61 of onc€
evsrv 5 vears - Reooft 86nt to th€ stat€
1.8.4.e.3
fhe results of sieck t€8ting shall b€ submitted to th€
)irector within 60 days of cornpletion of th€ t€9ting.
leports shall cleerly identify results as compaBd to
)srmit limits and indicate compliance status. Roportg
rhall b6 submitt€d in accofdanc€ with /o cFR 60.676(0
md as smitied in S€dim I of thi3 mmil
Stack tesB submitted to Direclor
within 60 days of completion of
ieslind Conlinuou8 Reoort s€nt to Stat6
l.B.5.a r'rsible emissaon8 ghall b€ no greater than 20 percent
,pacity. lorigin: ,O CFR 60 Subpart Y,
)AOEANt00070031 -
l21. 140 CFR 60.254(a). R3O7-401€l
Uonthly Method 22 and/or 9
nsp€ction rsports availabl€ in
he envircnmntel ofli@.Continuous
7of13
ll.B.6.a
The sulfur contont of any coal or mixture of coals burnod
n ths kiln shall not sxcaed 1.0 lb sultur per MMBTUS of
leat input. The sutfur contsnt ot any tusl oil bumod in
ho kiln shall not sxcoed 0.85 lb8 sultur per million grGS
,TUs h€at input. [Origin: DAOE-ANI 00070031 -22, R30i
l0llI. tR307-203-1. R3O7-{01€l
l6cords of @l sulfur content
rre kept in the Environmental
"lflid Continuous
LB.6.b
:missions of SO2 shall b€ no grsater than 475 lbs./hr. on
l rolling 24+rour averagE and 457 tons/12 RA. lorigin:
)AOF-ANI il)o70031 -))1 teanT -not At
(onitor installed. RATA
:€rtiried. Data collected. Last
IATA date Julv 2022.Continuous
Tost results on sit6 and submitt6d to the Stats. No
exce€danoes. S€€ EER report for quarterly
informalion.
l.B.6.c
:mi$ions of CO shall b€ no great6r then 438 lb./hr
Orioin: DAOE-ANrfi)O7m31 -221 f R3O7-zlOl€l fast completed July 2020.Continuous
Originally sch€duled for April 2oth, 2020 test plan
was submittod accordingly, how€ver due to COVID-
'19 t$ting was postpon€d. Tesl was conducled the
w8ok of July l3th. 2020.
il.8.6.d
:mEsions of NOX shall b€ no greator than 1,817 tons
)€r rolling 12 month tdal. lorigin: OAQE{NI00070031-
)rl tRldTJnt-n!
)EM data logs and 12fionlh
olling average kept in the Plant
)omputer sy3tEm. RATA tests
md CGA porformed annually
md quartorly rBspeclively.
IATA t$t onducrted Julu 2022.Continuous RATA mdoted slJ@stullv Jutu 2m2.
l.B.6.s
The Pemitlee shall u8€ only th€ fu6ls list€d in the p€mit.
Orioin: DAOE-ANl 0007@31 -221. lR3O7-401€l
The list of fu€ls us6d maintained
)n th€ production reports
ryailable at the business unit
tfii.r Continu@s
t.B.5.f
The Pmitt€€ shall not exce€d the parametors listed in
his @ndilion for th€ us of f(El oil. [Origin: DAQE-
\Nt (xx)7oo31 -22t rR307-401 -Al
:uel oil has not b€€n w€d
luring this pariod. Production
€ports of other fu9l9 available at
ha business ofiica.Continuous
ll.B.6.g
\s pari of d€monstration of complianc€ with tho
lioxin/turan omi$ion limitations in this p€rmit, tho
Continuous
,fthe gas at the inlsi to the kiln particulate matter control
levico (PMCD) and alkali bypae8 PMCD, if applicable,
1068 not oxcs€d the applicable tomporaturo limits (for
nd 6tablish€d in accordanc€ witr 40 CFR
i3.134qbx3xiv) axcept during p€riods of
iGrtup/rhutdom when the bmp€raturs limit may b€
,xceadsd by no morc than I 0 p6rcent. Th6 permittee
)alibraiion reporls and/or
:ompl6ted. Annualcombustion
nspoction of th€ buming
Dmbustion sygtom of oach kiln or in-lin6-kiln/ril mill at
aast onoo por year. [Origin: 40 CFR 63 Subpart LLLI.
40 CFR 63.1346(a). 40 CFR 63.1346(b)l
Inueflot d 2022. Corilinuous
nonitoring reported for Semi-
Mnual ReDorl for 2H2022.
t.B.5.h
:missions of Dioxins/Furans (D/F) shall b€ no greater
han 0.2 ng/dscm (TEQ) on a dry basis, correcled to 7
r€rcent oryg6n during nomal op€raiion. lf the average
emp€fature at th6 inl6t to th€ fiBt PM @ntrcl devic€
fabric tiltor or eleclrostetic prscipitator) during tha D/F
)erformanc€ t€st is 400 degrs€s F or less thi3 limit is
hano€d lo 0.40 no/dscm [EQ).
Test conducled th6 w€€k ot
lanuary 31, 2021. All prior
Dtifications sent to agency
rffidindlv Continuous
8of13
tB6i
all timss the permittee shall operate and maintain any
ected sourc, including associated air pollution control
uipment and monitoring equtpment. in a manner
nsistent with safety and good air pollution control
rctaces for manimizing omissions. Oetermination of
ether such operation and maintenance procedures are
ing used will be based on information available to the
ector which may include, but is not limited to,
)nitoring results, review of operation and maintenance
)cedures, review of opgration and maintenance
)ords, and inspection of the source. {Origin: 40 CFR 63
boarl LLLI. t40 CFR 63.1348(d)l
SAP maintenance plans, repairs,
and inspection records on file.
Visible emissions monitoring as
well as compliance monitoring
aveilable Continuous
t.B.6.j
lombined PM emissions from the in-line kiln/raw mill and
he alkali bypass stack shall be no greater than 0.07
b/ton clinker during normal operation. This condition
,pplies on and after the mmpliance date specified in 40
IFR 63.1343. lorigin: 40 CFR 63 Subpart LLL]. [40
]FR
Performance testing conducted
July 2021 . Test report and PM
CPMS indicated compliance.Continuous
r.B.6.k
:missions of merary shall be no greater than 55 lb/MM
ons clinker based on a rolling 30-day average during
lormal operation. The 30day period means 30
:onsecutive kiln operating days excluding periods of
;tartup and shutdown.
CEMs installed, RATA tested,
QGAS conducted, CEM data log!
keot in DAS comouter svstem.Continuous ls RATA testins comoleted 7 12012022
t.B.6.l
:missions of total hydro€rbon (THC) shall be no greater
han 24 ppmvd, on a dry basis, measured as propane,
)orrected to 7 percent oxygen, based on a rolling 30-day
lverage during normal operation. The 30day period
neans 30 consecutive kiln operating days excluding
)eriods of startup and shutdown. Any source subjact to
he 24 ppmvd THC limit may elect to meet an alternative
imit of '12 ppmvd for total orqanic HAPS.
OHAP performance test
conductsd February 2021. CEMs
installsd, RATA tested, CGAS
conducted, CEM data logs kept
in DAS comDuter svstem.Continuous fHC RATA testino comoleled 7 l2Ol2O22
il.8.6.m
:missions of HCI shall be no greater than 3 ppmvd, on a
,ry basis, corrected to 7 perent oxygen, during normal
)peration. lf using a CEMS to determine compliance witl
he HCI standard, this standard is based on a rolling 30-
,ay average. Tho 30iay period means 30 consecutive
iiln operating days excluding periods of startup and
;hutdom.
HCI spike test conducted
11t1t2022.Continuous
t.8.6.n
During periods of startup and shutdoM, the permittee
shall meet the requirements listed in ('1 ) throuqh (3).
\ll records, reports and process
londitions are maintained on file
)r in the plant data historian
Continuous
ll.B.6.n(1)
During starlup the permittee shall use any one or
@mbination of the following clean fuels: natural gas,
synthetic natural gas, propane, distillate oil, synthesis
gas (syngas), and ultra-low sulfur diesel (ULSD) until the
kiln reaches a temperature of 1200 deqrees Fahrenheit.
\ll fuel records and process
)onditions are maintained in the
)lant data historian svstem.Continuous
9 of 13
r.8.6.n(2)
lombustion of the primary kiln fuel may commence on6
he kiln temmreture reeches 120O deorees Fahranhsil
\ll procsss conditions are
naintained in the plant data
ri.t^ri.n cv.tam Continuous
r.B.6.n(3)
\ll dry sorb€nt and aclivatod carbon systems that control
razardous air pollrdants shall bo tumed on and operating
lt the time the gas stream at the inlet to the baghouse
saches 30O degrees Fahrenheit (five minuta average)
luring startup. Temp€raturo of tha gas stream is to be
neasursd at the inlet of the baghouse every minute.
iuch inj€c{ion systems c€n be tumed off during
rhuidown. Particulate control and all remaining devicos
hat control hazardous air pollutants shall be operational
,urino startuo and shutdown.
{l process and monitoring
:onditions are maintained in the
)lant data historian and the DAS
Continuous
[.8.6.o
ly September 10, 2023, the pemitteo shall submit
,rumentation to the Direclor on the status of
Dnstruction of the SNCR system. The rofergnced
pproval order (AO) may become invalid if
Dnstruclion is not @mmenced by September 10, 2023 ot
f @nstruclion is dismntinued for 18 months or
nore. To ensure proper credit shen notifying the
)irector, send the documentation to the Director, attn.:
{SR Section. [Origin: OAQE-AN100070031-22, R307-
lo1-181
:acility has not mnstructed
]NCR. Thsrefore, no
iocumentation has been
,ubmitted to the Direclor.Continuous
10 of 13
t.u. /.4 ,roduction of dinkcr shall b€ no greatof then 930,0@
hod tons p€r rolling 12 month total. lorigin: DAQE-
\Noi(m7oo2rti8l rR307-4Ol-A/, V.VBACT)
tolling 12 month log maintained
)hsile Cmtinuous
t.B.7.b
\t all tim€s th6 pomittee shall op€rate and maintain any
Uaintenanco records availablg
Conlinuous
{uipment and monitoring oquipment, in a manner
:omistent with sefoty and gpod air pollution cootrol
)racticas for manimizing €missiom. Determination of
)€ing us€d will b6 based on informalion availeblo to th6
)ir6ctorwhich may includ€, but is not limitod to,
xocedureS, r€vie\x of operation and maintenancs
€cords, and insp€dion of th6 sourc6. lorigin: 40 CFR 63
tube€n LLLI. 140 CFR 63.1348(d)l
)rder 3yst6m, in3pgctiofts
)ompl€ted and environanontal
mdiam esrcd bv tastim
t.6.t.c
:missions of PM shall bs no groater than 0.07 lb/ton
)linker durino nml omEtim.
,M tosting conduc{ed th€ ws€k
, July 13-15, 2021 uring
,pprovod Mothod to €stablish
}SOL. Protocols, notifi cations,
rnd p€rformanco tests submittod
,ccordinolv.Continuous
{o 6xceodanc6 of the SSOL occuned during th€
Edimmri.Yi
t.E.7.d
During p€riods of Btartup and Ehutdorn, ell dry sorb€nt
\ll procoss end monitoring
pnditions ar€ maintain€d in th€
)lant deta historian and the DAS
morlltr avtlem Continuous
pollutants shall b€ turned on and op€{eting at Slo time
the ges stream at tho inl6t to th€ baghousa rBachos 300
dogreas Fahr6nheit (five minut€ averag6) during sterlup.
T6mp€rature ofth€ gas strsam shsll b6 measured at the
inlet of tho baghow€ svery minut6. Sucfi inioction
systoms can b€ tumod off during 6hutdown. Parliculaio
conlrol and all remaining devices that control hazardous
air pollutanE shall b6 operational during starlup and
shutdo^,n. [Origin: 40 CFR 63 Subpert LLLI. llo CFR
63.1343. /m CFR 63 l34aabYgtl
t.u.u.a
Uisible emi3sions shEll b€ no grsater than 1 0 p6rc.nt
lpacity during all modes of op€ration. lorigin: rO CFR
i3 Subpart LLLI. DAQEdN01700031-221. [40 CFR
ti1.134340 CFR 63.1345. R307J0r{r
vl€thod 22 visual emissions t€st8
tre conducl6d on a daily basis.
l€porE on site in lhe
,nvironmental ollice.lnl€rmittent
ilethod 22 r€cor& aro misging for Odober 24,
November 24, 25, Docamb€r 1 1 , and Decomb€r 'l 9
2021.
t.B.E.b
{t all tim€s the pomittee 6hall op€rate and maintsin eny
rfrecled source, including associated air pollution control
,quipmenl and monitoring oquipment, in a manner
,onsist€nt with safety and good air pollution control
,racticos for minimizing emissions. Dalormination ot
iAP maintonance plans, repairs,
ild insp€cliom records on file.
/isibl€ €missions monitoring as
Yall as compliance monitoring
Nailehle Continuous
,eing us€d will b€ bas€d on information available to the
Executirr€ S€crstary which mey includg, but is not limited
o, monitodng r68ult3, review of op€ration and
mintgnan€ procsduras, rovi€v of op€retim and
neintenancs records, and inspoction of the sourca.
'Orioin: 40 CFR 63 SubD€rt LLLI. t40 CFR 63.1 348(d)l
11 of13
LB.9.a
y'isible emissions shall be no greater than 10 psrcent
)pacity. lorigin: 40 CFR 63 Subpart LLL, OAQE-
qN100070027-201. t40 CFR 63.1345, R307.401-81
ilethod 22 visual emissions tesi!
rre conducted as requirod. lf
Eeded Method 9 follil-up
pnducled. RMrds on file.Continuous
t.B.9.b
At all times the pemittee shall operate and maintain any
affectad sourco, including associsted air pollution @ntrol
equipment and monitoring equipment, in a manner
consistent with safety and good air pollution control
praclices for minimizing emissions. Detsrmination of
)AP maintenance plans, repairs,
rnd inspections records on file.
/isibls amissions monitoring as
yell as @mpliancs monitoring
Continuous
boing used will be based on information available to tho
Ex€cutive Secretary which may include, but is not limited
to, mmitoring rssults, revisw of operation and
maintenance procedures, review of opsration and
maintenanco records, and inspeclion of the sour@.
Iorioin: 40 CFR 63 Suboart LLLI. I40 CFR 63.'1348(dll
sbj@t Tmding,Operating Scenuios,
12 ol 13
Certiftcation
In accordance with Opuating Pmit provisions I.K and UAC R307-415-5d' md bascd on infornation md belief fomed after rcasonable inquiry, I certifu that the
statgmmts and infomation in this docment ue true, accuate, md complete.
Pcnl Roceft Dlcnt Monooer
Print or qpe the nane and title of Respomible Official
Da'le or/a'lto'3 an
13 of 13
*-\- Holcim
Holcim (US) lnc. Phone [phone]
6055 E. Croydon Rd. www.holcim.com/us
Morgan, Utah 84050
Sent Via UPS
To: Executive Secretary, Utah Air Quality Board
From: Holcim (US), Inc. - Devil's Slide Plant
Re: Title V Semiannual Monitoring Report for Permit #2900001004
Date: January 18,2023
ln accordance with Operating Permit provision LS.2.b. and Utah Administrative Code (UAC) R
307-415-6a(3)(c)(i), the following monitoring report is submitted.
This report covers the semiannual period and the annual compliance period from July 1,2022to
December 31,2022.
For the indicated reporting period:
E There were no deviations from any permit requirements.
m Attached is a list of permit requirements for which there were deviations. This list includes
the information required by Operating Permit provisions 1.S.2.a, and UAC R307-415-
6a(3XcXi).
Method 22s tor October 24, November 24, November 25, December 1 1, and December
19,2021 are missing and constitute a deviation. These deviations were reported as they
were discovered throughout the reporting period.
E ln lieu of attaching the above list, deviation reports submitted in accordance with permit
provisions l.S.32.c, and UAC R307-415-6a(3)(cXii) are referenced below.
ln accordance with Operating Permit Provision LK and UAC R307-415-5d, and based on
information and belief formed after reasonable inquiry, I certify that the statements and
information in this document are true, accurate, and complete.
h. Performance. Passion.
REVIEWEDInitials:Date: February 21, 2023Compliance Status: Not Compliant File # 10007 (B2)Comment: Document needs to be revised to include correct permit condition (II.S.2.a). The deviation needs to be deleted, no deviations were reported for this report period.
Official for the Source
Paul Rogers, Plant Manager
Holcim (US) lnc.
Devil's Slide Plant
6055 East Croydon Road
Morgan, Utah 84050
801-829-6821
For Further Information Please Contact:
Derrick Dease
Director, Environment & Land
derrick.dease@holcim. com
Cc: Environmental Protection Agency, Region Vlll
Office of Enforcement, Compliance and Environmental Justice
(mail code SENF)
1595 Wynkoop Street
Denver, CO80202-1129
Sent via UPS
Attachment: Semi-Annual Title V Deviation Report
UTAH DEPABTMENT OF
ENVIRONMENTAL QUALIry
fEE -' i:i't-
DIVISION OF AlR QUALIW