DAQE-AN0007018-05

January 31, 2005

Kevin Ovard

Holcim (US) Inc.

6055 East Croydon Road

Morgan, Utah 84050

Dear Mr. Ovard:

Re: Approval Order: Changes to the Clinker Cooler

Morgan County – CDS A, ATT; NSPS, NESHAPS, HAPs, Title V Major

Project Code: N0007-018

The attached document is the Approval Order (AO) for the above-referenced project.

Future correspondence on this Approval Order should include the engineer's name as well as the DAQE 

number as shown on the upper right-hand corner of this letter. Please direct any technical questions you 

may have on this project to Mr. John D. Jenks. He may be reached at (801) 536-4459.

Sincerely,

Richard W. Sprott, Executive Secretary

Utah Air Quality Board

RWS:RR:JJ:dn

cc: Weber-Morgan Health Department

Mike Owens, EPA Region VIII

150 North 1950 West • PO Box 144820 • Salt Lake City, UT 84114-4820 • phone (801) 536-4000 • fax (801) 536-4099 

T.D.D. (801) 536-4414 • www.deq.utah.gov

State of Utah 

Department of 

Environmental Quality

Dianne R. Nielson, Ph.D.

Executive Director

DIVISION OF AIR QUALITY

Richard W. Sprott

Director

JON M. HUNTSMAN, JR.

Governor

GARY HERBERT

Lieutenant Governor
STATE OF UTAH

Department of Environmental Quality

Division of Air Quality

APPROVAL ORDER: CHANGES TO THE CLINKER 

COOLER 

Prepared By: John D. Jenks, Engineer

(801) 536-4459

Email: jjenks@utah.gov

APPROVAL ORDER NUMBER

DAQE-AN0007018-05

Date: January 31, 2005

Holcim (US) Inc.

Source Contact

Kevin Ovard

(801) 829-2122

Richard W. Sprott

Executive Secretary

Utah Air Quality Board
Abstract

Holcim Inc., submitted a Notice of Intent for a number of modifications at their existing cement plant in 

Morgan, Utah. Given the critical timing of one of these projects – modifications to the clinker cooler 

process to improve cooling and therefore improve reliability of the finishing mills – Holcim has decided 

to break that original project into two sections: this cooler modification request, and the remainder of 

their Notice of Intent to follow as a separate project. This portion of the project involves replacing the 

cooling fans to achieve a higher overall fan capacity, adding a heat exchanger, extending the length of 

the clinker cooler, and adding two compartments to the clinker cooler dust collector. This portion of the 

project does not trigger a Prevention of Significant Deterioration (PSD) review. The second half of the 

project will trigger a PSD review and is currently undergoing PSD modeling review. Morgan County is 

an attainment area of the National Ambient Air Quality Standards (NAAQS) for all pollutants. New 

Source Performance Standards (NSPS) and Maximum Available Control Technology (MACT) 

regulations apply to this source. Title V of the 1990 Clean Air Act applies to this source. The Title V 

operating permit for this source shall be amended prior to the operation of the approved modifications. 

The modifications will result in an increase in PM10 emissions of 7.6 tons per year.

The project has been evaluated and found to be consistent with the requirements of the Utah 

Administrative Code Rule 307 (UAC R307). A public comment period was held in accordance with UAC 

R307-401-4 and no comments were received. This air quality Approval Order (AO) authorizes the project 

with the following conditions, and failure to comply with any of the conditions may constitute a violation 

of this order.

General Conditions:

1. This AO applies to the following company:

Site Office

Holcim (US) Inc.

6055 E. Croydon Road

Morgan, Utah 84050

Phone Number: (801) 829-6821

Fax Number: (801) 829-2100

The equipment listed in this AO shall be operated at the following location:

PLANT LOCATION:

6055 E. Croydon Road, Morgan, Utah 84050 Universal Transverse Mercator (UTM) 

Coordinate System: UTM Datum NAD27

4,545.8 kilometers Northing, 455.4 kilometers Easting, Zone 12

2. Definitions of terms, abbreviations, and references used in this AO conform to those used 

in the Utah Administrative Code Rule 307 (UAC R307), and Series 40 of the Code of 

Federal Regulations (40 CFR). These definitions take precedence, unless specifically 

defined otherwise herein.
DAQE-AN0007018-05

Page 3

3. The limits set forth in this AO shall not be exceeded without prior approval in accordance 

with R307-401.

4. Modifications to the equipment or processes approved by this AO that could affect the 

emissions covered by this AO must be reviewed and approved in accordance with R307-

401-1.

5. All records referenced in this AO or in applicable NSPS and/or NESHAP and/or MACT 

standards, which are required to be kept by the owner/operator, shall be made available to 

the Executive Secretary or Executive Secretary’s representative upon request, and the 

records shall include the two-year period prior to the date of the request. Records shall be 

kept for the following minimum periods:

A. Used oil consumption Three years

B. Emission inventories Five years from the due date of each emission statement 

or until the next inventory is due, whichever is longer.

C. All other records Two years

6. Holcim (US) Inc. shall conduct its operations of the Devil’s Slide Cement Plant in 

accordance with the terms and conditions of this AO, which was written pursuant to 

Holcim (US) Inc.’s Notice of Intent (NOI) submitted to the Division of Air Quality (DAQ) 

on November 2, 2004.

7. This AO shall replace the AO dated November 12, 2003 (DAQE-AN0007015-03).

8. The approved installations and facilities shall consist of the following equipment or 

equivalent*:

A. Five-stage suspension preheater kiln and “AS” precalciner using indirect coal 

firing 

Control Method: Kiln Main Stack Baghouse 135,000 ACFM **

Control Method: Alkali By-Pass Baghouse 75,000 ACFM **

B. Clinker Cooler (upgraded fan capacity and new heat exchanger)

Control Method: Cooler Baghouse (with two new compartments) 129,800 ACFM 

**

C. #1 Finish Mill

Control Method: #1 Separator Baghouse 48,000 ACFM **

Control Method: #1 Cement Mill Baghouse nuisance dust collector

D. #2 Finish Mill

Control Method: #2 Separator Baghouse 43,000 ACFM **

Control Method: #2 Cement Mill Baghouse 17,000 ACFM **

E. #3 Finish Mill

Control Method: #3 Separator Cyclone/Baghouse 4,706 ACFM **

Control Method: #3 Cement Mill Baghouse 25,588 ACFM **
DAQE-AN0007018-05

Page 4

F. Coal Mill

Control Method: Baghouse 28,000 ACFM **

G. 62 additional baghouses of varying capacity for dust control. These include but 

are not limited to baghouses installed in the following areas:

Material Handling

Raw Material Grinding and Storage

Feeding

Cement and Clinker Storage (4 new silos)

H. Various quarry drilling and blasting equipment

I. Haul trucks and front-end loaders

J. Various covered conveyors

K. Various materials handling equipment including: hoppers, blowers, ramps, 

covered storage, and piping

L. Two Diesel Powered Emergency Generators 

* Equivalency shall be determined by the Executive Secretary.

** Flow rates are listed for informational purposes only

9. Holcim shall notify the Executive Secretary in writing when the modification of the 

equipment listed in Condition #8 has been completed and is operational, as an initial 

compliance inspection is required. To insure proper credit when notifying the Executive 

Secretary, send your correspondence to the Executive Secretary, attn: Compliance Section.

If the modification has not been completed within eighteen months from the date of this 

AO, the Executive Secretary shall be notified in writing on the status of the construction 

and/or installation. At that time, the Executive Secretary shall require documentation of 

the continuous construction and/or installation of the operation and may revoke the AO in 

accordance with R307-401-11.

Limitations and Tests Procedures

10. Emissions to the atmosphere at all times from the indicated emission point shall not exceed 

the following rates and concentrations:

Source: Kiln Main Stack Exhaust

Pollutant lb/hr

PM10 ..................................................................14

SO2 ..................................................................104

CO...................................................................438

NOx ..............................................................1,817 Tons/rolling 12-month period
DAQE-AN0007018-05

Page 5

11. Stack testing to show compliance with the emission limitations stated in the above 

condition shall be performed as specified below:

A. Testing Test

Emissions Point Pollutant Status Frequency

Kiln Main Stack PM10.......................* .......................@

SO2.........................* .......................#

NOx........................* .......................##

CO .........................* .......................#

B. Testing Status (To be applied above)

* The initial testing has already been performed.

@ Test every five years. The Executive Secretary may require testing at any

time.

# Test every two years. The Executive Secretary may require testing at any 

time.

## Compliance for NOx emissions shall be demonstrated through use of a 

continuous emissions monitoring system as outlined in Condition 25.

C. Notification

The Executive Secretary shall be notified at least 30 days prior to conducting any 

required emission testing. A source test protocol shall be submitted to DAQ when 

the testing notification is submitted to the Executive Secretary. 

The source test protocol shall be approved by the Executive Secretary prior to 

performing the test(s). The source test protocol shall outline the proposed test 

methodologies, and stack to be tested. A pretest conference shall be held, if 

directed by the Executive Secretary.

D. Sample Location

The emission point shall be designed to conform to the requirements of 40 CFR 

60, Appendix A, Method 1, or other methods as approved by the Executive 

Secretary. Access that meets the standards of the Occupational Safety and Health 

Administration (OSHA) or the Mine Safety and Health Administration (MSHA) 

shall be provided.

E. Volumetric Flow Rate

40 CFR 60, Appendix A, Method 2
DAQE-AN0007018-05

Page 6

F. PM10

For stacks in which no liquid drops are present, the following methods shall be 

used: 40 CFR 51, Appendix M, Methods 201 or 201a. The back half condensibles 

shall also be tested using the method specified by the Executive Secretary. All 

particulate captured shall be considered PM10.

For stacks in which liquid drops are present, methods to eliminate the liquid drops 

should be explored. If no reasonable method to eliminate the drops exists, then the 

following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 

5e as appropriate. The back half condensibles shall also be tested using the 

method specified by the Executive Secretary. The portion of the front half of the 

catch considered PM10 shall be based on information in Appendix B of the fifth 

addition of the EPA document, AP-42, or other data acceptable to the Executive 

Secretary.

The back half condensibles shall not be used for compliance demonstration but 

shall be used for inventory purposes.

G. Sulfur Dioxide (SO2)

40 CFR 60, Appendix A, Method 6, 6A, 6B or 6C

H. Nitrogen Oxides (NOx)

Continuous monitoring as outlined in Condition 25.

I. Carbon Monoxide (CO)

40 CFR 60, Appendix A, Method 10

J. Calculations

To determine mass emission rates (lb/hr, etc.) the pollutant concentration as 

determined by the appropriate methods above shall be multiplied by the 

volumetric flow rate and any necessary conversion factors determined by the 

Executive Secretary, to give the results in the specified units of the emission 

limitation.

K. Existing Source Operation

For an existing source/emission point, the production rate during all compliance 

testing shall be no less than 90% of the maximum production achieved in the 

previous three (3) years

12. Visible emissions from the following emission points shall not exceed the following

values:

A. All kiln exhaust gases - 20% opacity

B. All other point sources - 10% opacity
DAQE-AN0007018-05

Page 7

Opacity observations of emissions from stationary sources shall be conducted according to 

40 CFR 60, Appendix A, Method 9.

13. The following production limit shall not be exceeded:

A. 799,100 tons of clinker per rolling 12-month period

Records of production shall be kept for all periods when the plant is in operation. 

Production shall be determined by maintenance of a supervisor log. Compliance with the 

annual limitation shall be determined on a rolling 12-month total. Based on the twentieth 

day of each month a new 12-month total shall be calculated using the previous 12 months 

of kiln production and shall be kept for all periods when the plant is in operation. 

14. The emergency generator hours of operation for maintenance purposes shall not exceed 60 

hours total per 12-month period. Compliance with the annual limitation shall be 

determined on a rolling 12-month total. Based on the twentieth day of each month a new 

12-month total shall be calculated using the previous 12 months of engine hours and shall 

be kept for all periods when the plant is in operation. Engine hours of operation shall be 

determined by examination of maintenance records, which shall be kept on site.

Roads and Fugitive Dust

15. The facility shall abide by all applicable requirements of UAC R307- 205 for Fugitive 

Emission and Fugitive Dust sources. The provisions of R307-205 shall not apply to any 

sources for which limitations for fugitive dust or fugitive emissions are assigned pursuant 

to R307-401 or R307-305 nor shall they apply to agricultural or horticultural activities.

16. All unpaved roads and other unpaved operational areas that are used by mobile equipment 

shall be water sprayed and/or chemically treated to control fugitive dust. The application 

of water or chemical treatment shall be used. Treatment shall be of sufficient frequency 

and quantity to maintain the surface material in a damp/moist condition unless it is below 

freezing. The opacity shall not exceed 20% during all times the areas are in use. If 

chemical treatment is to be used, the plan must be approved by the Executive Secretary. 

Records of water and/or chemical treatment shall be kept for all periods when the plant is 

in operation. The records shall include the following items:

A. Date

B. Number of treatments made, dilution ratio, and quantity

C. Precipitation received, if any, and approximate amount

D. Time of day treatments were made

E. Records of temperature, if the temperature is below freezing.

17. Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational 

areas shall not exceed 20% opacity. Visible emissions determinations for traffic sources 

shall use procedures similar to Method 9. The normal requirement for observations to be 

made at 15-second intervals over a six-minute period, however, shall not apply. Six 

points, distributed along the length of the haul road or in the operational area, shall be 

chosen by the Executive Secretary or the Executive Secretary’s representative. An opacity

reading shall be made at each point when a vehicle passes the selected points. Opacity 

readings shall be made 1⁄2 the vehicle length or greater behind the vehicle and at 
DAQE-AN0007018-05

Page 8

approximately 1⁄2 the height of the vehicle or greater. The accumulated six readings shall 

be averaged for the compliance value.

18. A dust suppression system shall be installed at the following points to control fugitive 

emissions:

A. Crusher dump pocket – water spray

B. Conveyor transfer points – baghouse dust collectors

The system shall operate whenever dry conditions warrant or as determined necessary by 

the Executive Secretary.

Fuels

19. The owner/operator shall use only the following fuels in the kiln:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil

H. Synthetic Fuel

I. Wood

J. Coal Additives as defined in Condition 19

If any other fuel is to be used, an AO shall be required in accordance with R307-401, 

UAC.

20. The coal additives listed in Condition 19.J shall consist of alternative fuels approved by the 

Executive Secretary. Prior to burning any proposed coal additive, Holcim (US) Inc. shall 

obtain approval from the Executive Secretary. To obtain approval, Holcim (US) Inc. shall 

submit Material Safety Data Sheets (MSDS) or the results of suitable tests giving data 

similar to a Proximate and Ultimate analysis of the proposed coal additive.

Approval by the Executive Secretary shall consist of a letter approving the use of the 

proposed coal additive. Approval is not required to change from one previously approved 

coal additive to another previously approved coal additive.

The average quantity of coal additives burned shall not be greater than 15% of the total 

daily heat input of the kiln and precalciner. Holcim (US) Inc. may increase the average 

quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner 

upon approval by the Executive Secretary in accordance with the approval process 

described in this Condition 20.

21. The sulfur content of any coal or mixture of coals burned shall not exceed 1.0 pound of 

sulfur per million BTUs of heat input. The sulfur content of any fuel oil or diesel burned 

shall not exceed 0.85 pounds sulfur per million gross BTUs heat input. If any type of fuel 

that is to be used that has a higher sulfur content, an AO shall be required in accordance 

with R307-401, UAC.
DAQE-AN0007018-05

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Methods for determining sulfur content of coal and fuel oil shall be those methods of the 

American Society for Testing and Materials, UAC R307-203-1 (4)

(a) For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to 

be used.

(b) For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to 

be used.

(c) For determining the gross calorific (or BTU) content of coal, ASTM Methods D2015-

77 or D3286-85 are to be used.

22. The concentration/parameters of contaminants in any used oil fuel shall not exceed the 

following levels:

1) Arsenic.....................................5 ppm by weight

2) Cadmium..................................2 ppm by weight

3) Chromium..............................10 ppm by weight

4) Lead .....................................100 ppm by weight

5) Total halogens...................1,000 ppm by weight

6) Sulfur .......................................0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100 F.

B. The owner/operator shall provide test certification for each load of used oil fuel 

received. Certification shall be either by their own testing or test reports from the 

used oil fuel marketer. Records of used oil fuel consumption and the test reports 

shall be kept for all periods when the plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be 

burned. The owner/operator shall record the quantities of oil burned on a daily 

basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens 

shall be considered a hazardous waste and shall not be burned in the kiln. The oil 

shall be tested for halogen content by ASTM Method D-808-81, EPA Method 

8240 or Method 8260 before used oil fuel is transferred to the day tank and 

burned.

E. Sources utilizing used oil as a fuel shall comply with the State Division of Solid 

and Hazardous Waste in accordance with R315-15, UAC.

Federal Limitations and Requirements

23. In addition to the requirements of this AO, all applicable provisions of 40 CFR 60, New 

Source Performance Standards (NSPS) Subpart A, 40 CFR 60.1 to 60.18, Subpart F, 40 

CFR 60.60 to 60.66 (Standards of Performance for Portland Cement Plants), Subpart Y, 40 

CFR 60.250 to 60.254 (Standards of Performance for Coal Preparation Plants, and Subpart 

OOO, 40 CFR 60.670 to 60.676 (Standards of Performance for Nonmetallic Mineral 

Processing Plants) apply to this installation. To be in compliance, this facility must 
DAQE-AN0007018-05

Page 10

operate in accordance with the most current version of 40 CFR 60 applicable to this 

source.

24. In addition to the requirements of this AO, all applicable provisions of 40 CFR 63, 

National Emission Standards for Hazardous Air Pollutants for Source Categories Subpart 

A, 40 CFR 63.1 to 63.15 and Subpart LLL, 40 CFR 63.1340 to 63.1359 (National 

Emission Standards for Hazardous Air Pollutants From the Portland Cement 

Manufacturing Industry) apply to this installation. To be in compliance, this facility must 

operate in accordance with the most current version of 40 CFR 63 applicable to this 

source.

Monitoring - Continuous Emissions Monitoring

25. Compliance with the NOx emission limitation in Condition 10 will be through use of a 

continuous emissions monitoring system. The owner/operator shall install, calibrate, 

maintain, and continuously operate a continuous emissions monitoring system on the kiln 

main stack. The owner/operator shall record the output of the system, for measuring the 

NOx emissions. The monitoring system shall comply with all applicable sections of R307-

170, UAC; 40 CFR 51, Appendix P; and 40 CFR 60, Appendix B. Except for system 

breakdown, repairs, calibration checks, and zero and span adjustments required under 

paragraph (d) 40 CFR 60.13, the owner/operator of an affected source shall continuously 

operate all required continuous monitoring devices and shall meet minimum frequency of 

operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.

Records & Miscellaneous

26. At all times, including periods of startup, shutdown, and malfunction, owners and 

operators shall, to the extent practicable, maintain and operate any equipment approved 

under this AO 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 Executive Secretary which may include, but is not limited to, 

monitoring results, opacity observations, review of operating and maintenance procedures, 

and inspection of the source. All maintenance that may affect air emissions performed on 

equipment authorized by this AO shall be recorded, and the records shall be maintained for 

a period of two years.

27. The owner/operator shall comply with UAC, R307-150 Series. Inventories, Testing and 

Monitoring. To be in compliance, this facility must operate in accordance with the most 

current version of the UAC, R307-150 series.

28. The owner/operator shall comply with R307-107, UAC, General Requirements: 

Unavoidable Breakdown. To be in compliance, this facility must operate in accordance 

with the most current version of the UAC, R307-107.

The Executive Secretary shall be notified in writing if the company is sold or changes its name. This AO 

in no way releases the owner or operator from any liability for compliance with all other applicable federal, 

state, and local regulations including UAC R307.

A copy of the rules, regulations and/or attachments addressed in this AO may be obtained by contacting the 

Division of Air Quality. The Utah Administrative Code R307 rules used by DAQ, the NOI guide, and 
DAQE-AN0007018-05

Page 11

other air quality documents and forms may also be obtained on the Internet at the following web site: 

http://airquality.utah.gov/aq_home.htm

Annual emissions for this source (the entire plant) are currently calculated at the following values:

Pollutant Tons/yr

A. PM10 ............................................................297.6

B. SO2 ..............................................................457

C. NOx...........................................................1,825

D. CO ............................................................1,820

E. VOC ............................................................151

Approved By:

Richard W. Sprott, Executive Secretary

Utah Air Quality Board