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HomeMy WebLinkAboutDAQ-2024-0046111 DAQC-CI100510001-24 Site ID 10051 (B1) MEMORANDUM TO: FILE – SWIFT BEEF COMPANY, INC. – Hyrum Meat Packing Plant THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Connor Kijowski, Environmental Scientist DATE: December 21, 2023 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Cache County INSPECTION DATE: November 30, 2023 SOURCE LOCATION: 410 North 200 West Hyrum, UT 84319 DIRECTIONS: The business is known as JBS. Either call the source contact upon arrival or go the HR/Recruitment building directly west of the main building to contact someone as the site is secured. SOURCE CONTACTS: Ruben Van Tassell, Environmental Manager 435.245.2259; ruben.vantassell@jbssa.com OPERATING STATUS: Operating normally at the time of inspection. PROCESS DESCRIPTION: Swift Beef Company operates a beef processing plant and associated facilities in Hyrum. Cattle are brought to the plant by semi-trucks. Approximately 2,000-2,200 cattle are slaughtered per day at the source location. Byproducts of the slaughtering are sent ~ 1 mile away to the rendering plant for processing. The waste generated from the processing of beef is used in various forms. Waste bones, flesh, and blood are shipped to the rendering plant to reduce the weight. Large rotary dryers are used to dry the material. The water from the material is driven off as steam and vented through a stack. The dried material is used in various applications as inedible meat meal, bone meal, and dried blood. Odors are controlled by maintaining a negative pressure inside the rendering plant and passing all of the effluent air through a scrubber system that reacts with the odoriferous compounds, pulling them into an aqueous media. Other cattle products, such as hides and edible sweet bread, are handled in other areas at the source location. Swift Beef Company shares a parent company and property with JBS Carriers. JBS Carriers maintains a truck fleet at the source location. ) 1 2 APPLICABLE REGULATIONS: Approval Order (AO): DAQE-AN100510021-23, dated June 9, 2023 NSPS (Part 60) -Dc : Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, NSPS (Part 60) -IIII : Standards of Performance for Stationary Compression Ignition Internal Combustion Engines, MACT (Part 63) -CCCCCC : National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities, MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines SOURCE EVALUATION: Name of Permittee: Permitted Location: Swift Beef Company, Inc. - Hyrum Meat Packing Plant 410 North 200 West 410 North 200 West Hyrum, UT 843191024 Hyrum, UT 84319 SIC Code: 2011: (Meat Packing Plants) Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 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 Director 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 performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] 3 I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if 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. [R307-401-18] Status: In Compliance. Each condition of Section I was reviewed and appear to be in compliance. The 2020 Emission Inventory was submitted by the required date. The source provided a notification letter indicating the newly permitted equipment has been installed and is operational. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Meat Packing Plant II.A.2 Boiler #1 Boiler Rating: 25.106 MMBtu/hour Burner Type: Low NOx with flue gas recirculation kit installed Date of Construction: 2006 Fuel Type: Natural Gas Secondary: #2 Distillate Fuel or Tallow II.A.3 Boiler #2 Boiler Rating: 20.92 MMBtu/hour Burner Type: Low NOx Location: Refinery Flavor Building Date of Construction: 1972 Fuel: Natural Gas, Biogas II.A.4 Boiler #3 Boiler Rating: 32.66 MMBtu/hour Burner Type: Low NOx Location: Refinery Flavor Building Date of Construction: 2004 Fuel: Natural Gas Secondary: #2 Distillate Fuel II.A.5 Boiler #4 Boiler Rating: 32.66 MMBtu/hour Burner Type: Low NOx Location: Refinery Flavor Building Date of Construction: 2014 Fuel: Natural Gas, Biogas Secondary: #2 Distillate Fuel II.A.6 Boiler #5 Boiler Rating: 25.106 MMBtu/hour Burner Type: Low NOx with flue gas recirculation kit installed Date of Construction: 2006 Fuel Type: Natural Gas Secondary: #2 Distillate Fuel II.A.7 Boiler #6 Boiler Rating: 32.66 MMBtu/hour Burner Type: Low NOx Date of Construction: 2008 Fuel: Natural Gas Secondary: #2 Distillate Fuel 4 II.A.8 Boiler AC Boiler Rating: 20.92 MMBtu/hour Burner Type: Low NOx Location: Rendering Plant Date of Construction: 2000 Fuel: Natural Gas II.A.9 Boiler Truck Wash Boiler Rating: 0.824 MMBtu/hour Location: Truck Washing Building Date of Construction: 2004 Fuel: Natural Gas II.A.10 One (1) Biogas Flare/Combustor Maximum Capacity: 1,100 scfm II.A.11 One (1) Blood Dryer Burner Rating: 4.5 MMBtu/hour Location: Rendering Plant Date of Construction: 1996 II.A.12 One (1) Edible Bone-Meal Dryer Burner Rating: 30.0 MMBtu/hour Location: Rendering Plant Date of Construction: 1991 II.A.13 One (1) Inedible Bone-Meal Dryer Burner Rating: 30.0 MMBtu/hour Location: Rendering Plant Date of Construction: 1991 II.A.14 One (1) Venturi Scrubber Location: Main Plant Building II.A.15 Main Packed Bed Scrubber Location: Main Plant Building II.A.16 North Packed Bed Scrubber Capacity: 60,000 ACFM Location: Rendering Plant II.A.17 South Packed Bed Scrubber Capacity: 75,000 ACFM Location: Rendering Plant II.A.18 One (1) Emergency Engine/Generator Power Rating: 97 hp Fuel: Natural Gas Date of Installation: 2002 II.A.19 One (1) Emergency Generator Engine Rating: 99 hp Fuel: Diesel Fuel Manufacturing Date: 2021 II.A.20 One (1) Horizontal Petroleum Tank Volume: 10,000 gallons Contains: Diesel Fuel Location: Refinery Flavor Building 5 II.A.21 Portable Gasoline Above-Ground Storage Tank Volume: 500 gallons Contains: Gasoline Status: In Compliance. The listed equipment was observed during the inspection. The newly permitted generator (II.A.19) has been installed and is operational. No unpermitted equipment was observed. II.B Requirements and Limitations II.B.1 Site Wide Requirement II.B.1.a The owner/operator shall not feed more than 175,200 tons of feed into the Inedible and Edible Dryers combined per rolling 12-month period, and the owner/operator shall not feed more than 9,267 tons of feed into the Blood Dryer per rolling 12-month period. [R307-401-8] II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records of production feed to the dryers shall be kept for all periods when the plant is in operation. The records of production feed to the dryers shall be kept on a monthly basis. [R307-401-8] Status: In Compliance. The source fed 52,624 tons of feed into the edible and inedible dryers and 4,307 tons of feed into the blood dryer for the rolling 12-month period ending October 2023. Records are kept on a monthly basis. II.B.1.b Visible emissions from the following emission points shall not exceed the opacity limits: A. All Boilers, Dryers and Generator while operating on natural gas-10% opacity B. All Boilers, Dryers and Generator while operating on fuel oil- 20% opacity. C. All Scrubbers - 15% opacity D. Combustion/Flare - No visible emissions E. Emergency Generator Engine - 20% opacity F. All Other Points - 20% opacity. [R307-401-8] II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. No visible emissions were observed from the listed emission points. Refer to the VEO Form in the attachments. II.B.2 Fuel Requirements II.B.2.a The owner/operator shall use the following fuel type for specific equipment: All Boilers: Natural gas and/or biogas as a primary fuel and #2 fuel oil and/or animal tallow as alternative fuels. Blood Dryer: Natural gas. Edible and Inedible Bone Dryers: Natural gas as a primary fuel and #2 fuel oil and/or animal tallow as alternative fuels. 6 Emergency Engine: Natural gas. [R307-401-8] Status: In Compliance. The source indicated the listed fuel types are used for the specifically listed equipment. The source now operates two emergency engines: One engine requires natural gas (II.A.18) and the other requires diesel fuel (II.A.19). Each engine operates on the respective fuel. Refer to Section II.A for more details. II.B.2.b The owner/operator shall not operate the two (2) boilers rated at 25.106 MMBtu/hr and three (3) boilers rated at 32.66 MMBtu/hr, while using distillate fuel as a fuel for more than 48 hours each per rolling 12-month period during operator training, maintenance, or periodic testing. These five (5) boilers may operate with distillate fuel during natural gas curtailment, gas supply interruptions, or startups without any limitation on the use of distillate fuel. [R307-401-8] II.B.2.b.1 To determine compliance with a rolling 12-month total the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records of the hours of operation using distillate fuel for the two (2) 25.106 MMBtu/hr boilers and three (3) 32.66 MMBtu/hr boiler shall be kept and shall include the following: A. The date the distillate fuel was used B. The duration of operation while using distillate fuel C. The reason distillate fuel was used. [R307-401-8] Status: In Compliance. The source indicated that no distillate has been used since 2022, when the last natural gas curtailment occurred. Refer to the 40 CFR 60 Subpart Dc semi-annual report in the attachments for more details. II.B.2.c The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8] II.B.2.c.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] Status: In Compliance. Only ULSD is utilized on site. Refer to the certificate of analysis, provided by the fuel supplier, in the attachments. II.B.3 Biogas Requirements II.B.3.a The owner/operator shall not allow SO2 emissions from biogas and animal tallow fuel combustion to exceed 38.68 tons per rolling 12-month period. [R307-401-8] II.B.3.a.1 The owner/operator shall calculate SO2 emissions by using the following emissions factors A. Animal Tallow combustion: 0.2 lb/1000 gal (Emissions test report) B. Biogas combustion: (0.16356 x S) lb/MMscf (S is the stoichiometric conversion of sulfur to SO2, where S=H2S concentration, ppm). [R307-401-8] II.B.3.a.2 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. [R307-401-8] Status: In Compliance. The source combusted 17.10 tons of SO2 from biogas and animal tallow fuel for the rolling 12-month period ending October 2023. Calculations are made according to this condition and verified during the site visit. 7 II.B.3.b The owner operator shall test the H2S content in the biogas at least once every 12 months. [R307-401-8] II.B.3.b.1 Testing of biogas H2S content shall be conducted according to ASTM Method D5504 or other testing method acceptable to the director. After the initial test, the owner/operator may use a H2S colorimetric gas tube detector (gas tube) for the annual tests. If a gas tube testing is conducted, the owner/operator shall compare the result of the gas tube testing with the most recent test conducted according to ASTM Method D5504 or other testing method acceptable to the director. If the H2S content of the gas tube exceeds the result obtained using ASTM Method D5504 by 10% or greater, the owner/operator shall test the H2S content according to ASTM Method D5504 or other approved method within 30 days of the gas tube test. The owner/operator shall test the H2S content in the biogas according to ASTM Method D5504 at least once every five years. [R307-401-8] Status: In Compliance. The H2S content was last tested April 2023, according to this condition. II.B.3.c All collected biogas shall be routed to the operating combustor/flare, Boiler #2, or Boiler #4 for combustion prior to release in the atmosphere. [R307-401-8] Status: In Compliance. Collected biogas is routed through the listed equipment prior to venting to the atmosphere. II.B.4 Emergency Generator Engine Requirements II.B.4.a The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.4.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. The natural gas engine operated 4.8 non-emergency hours and the diesel engine operated 24.6 non-emergency hours for the rolling 12-month period ending October 2023. Paper logs are kept which include the date, duration, and reason for usage. Logs are scanned once a week. II.B.4.b To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8] Status: In Compliance. Non-resettable hour meters are installed and were observed during the inspection. II.B.4.c The owner/operator shall only use natural gas as fuel in the 97 hp emergency generator engine. [R307-401-8] Status: In Compliance. Only natural gas is used as fuel for the 97 hp emergency generator engine. II.B.4.d The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the 60 kW emergency generator engine. [R307-401-8] 8 II.B.4.d.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [40 CFR 63 Subpart ZZZZ] II.B.4.d.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] Status: In Compliance. Only ULSD fuel is used in the 60 kW (99 hp) emergency generator engine. This was determined from a certificate of analysis provided by the fuel supplier. Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. 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. NSPS (Part 60) -Dc : Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units Status: In Compliance. The source submits semi-annual reports for the amount of fuel, other than natural gas, combusted. The source submitted the report July 6, 2023. Refer to this report in the attachments. NSPS (Part 60) -IIII : Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Status: In Compliance. The source operated the applicable emergency generator engine (II.A.19) for 24.6 hours for the rolling 12-month period ending October 2023. Operation logs are kept and were available during the inspection. The generator engine operates 0.5 hours per week for preventative maintenance testing. Paper logs are scanned once a week. Annual maintenance is performed. MACT (Part 63) -CCCCCC : National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities Status: In Compliance. The source minimizes gasoline spills and cleans up spills as expeditiously as practicable. The above-ground gasoline storage tank utilizes a gasketed seal. The source dispensed 4,200 gallons of gasoline for the 12-month period. MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. This rule applies to the natural gas (II.A.18) & diesel fuel (II.A.19) emergency generator engine. Refer to Condition II.B.4 for more details. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Emission Standards: Sulfur Content of Fuels [R307-203] Status: In Compliance. The source only utilizes ultra-low sulfur fuel. A certificate of analysis was provided after the inspection. Refer to this in the attachments. 9 Standards of Performance for New Stationary Sources [R307-210] Status: In Compliance. This rule is satisfied through compliance with NSPS (Part 60) Subpart IIII and Subpart Dc. National Emission Standards for Hazardous Air Pollutants [R307-214] Status: In Compliance. This rule is satisfied through compliance with MACT (Part 63) Subpart ZZZZ. Nonattainment and Maintenance Areas for PM10 and PM 2.5: Fugitive Emissions and Fugitive Dust [R307-309] Status: In Compliance. All operating areas of the source are paved. No fugitive emissions or dust were observed. Gasoline Transfer and Storage [R307-328] Status: Not Applicable. This area source rule is applicable to gas storage and dispensing operations exceeding 10,000 gallons per month. The source stated that they do not store or dispense 10,000 gallons of gasoline per month. The site dispensed only 4,200 gallons for the 12-month period. EMISSION INVENTORY: Listed before are the 2020 Actual Emissions Inventory provided from Swift Beef Company, Inc. - Hyrum Meat Packing Plant. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN100510021-23, dated June 9, 2023, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 99006.00 N/A Carbon Monoxide 81.46 22.82 Nitrogen Oxides 65.54 19.72 Particulate Matter - PM10 17.53 3.803 Particulate Matter - PM2.5 14.82 2.600 Sulfur Dioxide 38.96 11.18 Volatile Organic Compounds 46.65 1.984 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Acetaldehyde (CAS #75070) 40 N/A Acrolein (CAS #107028) 40 N/A Chlorine (CAS #7782505) 80 80 Formaldehyde (CAS #50000) 780 49.16 Generic HAPs (CAS #GHAPS) 80 N/A Hexane (CAS #110543) 3960 1,180 Toluene (CAS #108883) 140 N/A Xylenes (Isomers And Mixture) (CAS #1330207) 40 N/A 10 PREVIOUS ENFORCEMENT ACTIONS: A Warning Letter (DAQC-1595-22) was issued for the installation of unpermitted equipment. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO): DAQE-AN100510021-23, dated June 9, 2023: In Compliance. The source appears to be well maintained and operated. Records were current and made available during the site visit and after the inspection via email. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect at the regular frequency. The source experienced an Anhydrous Ammonia Leak on August 16, 2023, which is currently being investigated by the EPA. Refer to the attached correspondence for more details. The source plans to add a 500-gallon diesel fuel tank and is currently working with NSR to get the equipment permitted. Look for a new AO prior to inspection. A hardhat, safety glasses, high visibility clothing, and ear plugs are required. Shoe covers and hair nets are required if visiting the production floor. A seven-minute safety video is required before touring the site. NSR RECOMMENDATIONS: Include fuel type requirement for Condition II.B.2.A for the newly installed diesel fuel emergency generator engine ATTACHMENTS: VEO Form, Rolling 12-Month Emission Totals, Section I.8 Notification Letter, 40 CFR 60 Subpart DC Semi-Annual Report, Certificate of Analysis, Anhydrous Ammonia Leak Notification, Fuel Tank Installation Email Correspondence I .-' (grs) July 6,2023 Mr. Bryce Bird *,4.'*Director i,'" Utah Division of Air Quality /- \ P.O. Box 144820 Salt Lake city utah 84114-4820 Subject: 40 CFR 60 Subpart DC fuel quantity report for DAQE-IN100510019-21 Dear Mr. Bird, The New Source Performance Standards for Small Industrial-Commercial-Institutional Steam Generating Units (NSPS Boilers) 40 CFR 60 Subpart Dc requires reporting the quantity of fuel' other than natural gas combusted during the reporting period for Swift Beef Company - Utah DAQ Site ID 10051. Reporting Period: January 1,2023 to July 1,2023 No diesel fuel was used in the boilers for this reporting period. ln accordance with Utah Administrative Code 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. Sincerely, Darren Olsen Plant Manager Conrpliancc Status: r*u loofl HF Sinclair Parco Refining LLC ⦁Laboratory Services⦁Sinclair, WY Certificate of Analysis, Pioneer Pipeline #2 ULSD Diesel Fuel Transferor:HF Sinclair Parco Refining LLC 100 E. Lincoln Highway ⦁ PO Box 277Sinclair, WY 82334EPA Company ID: 5053, Facility ID: 23521 Transferee:ConocoPhillipsPioneer Pipeline600 N. Dairy Ashford RoadHouston, TX 77079-1175EPA Company ID: 4528, Facility ID: 82245 Sample Date: 11/21/2023 Tester(s): Julie Grundman, Julie Grundman Tank Number: Tank 523 Sampler: D. Schneider LIMS ID: 773595 EPA Batch Number: 5053-23521-23-500345 Tender: Available BBLS: Approved By: Date: 11/21/2023 Levi Kronenberger #2 Diesel 15ppm w/w Sulfur Motor Vehicle Diesel Fuel. 15 ppm sulfur (maximum) Undyed Ultra-Low Sulfur Diesel Fuel. For use in all diesel vehicles and engines. Lubricity/conductivity additives may need to be added at the terminal in order for the fuel to meet ASTM D975 requirements. SPECIFICATIONSTestMETHODRESULT MINIMUM MAXIMUM Gravity, API @ 60°F ASTM D4052 37.3 30.0 Flash Point (PMCC), °F ASTM D93 138.0 135.0 Haze @ 50°F ASTM D4176, Proc. 2 1 2 Bright & Clear ASTM D4176 Pass PASS Color ASTM D1500 0.5 2.5 Ash, wt%ASTM D482 <0.001 0.010 Distillation @ 760mmHg, °F ASTM D86 IBP 322.0 REPORT 10 vol.% Recovered 390.5 REPORT 50 vol.% Recovered 494.8 REPORT 90 vol.% Recovered 603.1 540.0 640.0 FBP 649.3 698.0 % Total Recovered 99.6 REPORT % Residue 1.1 REPORT BS&W, vol%ASTM D2709 0.025 0.050 Sulfur, ppm ASTM D7039 4.4 10.0 Copper Strip Corrosion, 3hr @ 122°F ASTM D130 1a 1b CR, Ramsbottom, wt%ASTM D524 0.01 0.35 Thermal Stability, Y Filter ASTM D6468 99.2 82.0 Cetane Index, 4V ASTM D4737, Proc. A 48.3 40.0 Cetane Index, 2V ASTM D976 48.9 40.0 Cloud Point, °F ASTM D5773 0.8 6.0 Pour Point, °F ASTM D5949 -20 -15 Conductivity, pS/m @ T, °C ASTM D2624 3 @ 16.6 10 Viscosity @ 104°F, cSt ASTM D445 2.353 1.9 3.4 NACE Rust Test, Rating TM0172-2001 A B+ HF-V95-348-SW 4,250 1/3/24, 12:30 PM State of Utah Mail - RE: [Ext]- JBS Ammonia Leak Report https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1778372830273429959&simpl=msg-f:1778372830273429…1/11 Chad Gilgen <cgilgen@utah.gov> RE: [Ext]- JBS Ammonia Leak Report 14 messages Crockett, Guy <Guy.Crockett@jbssa.com>Fri, Sep 29, 2023 at 5:54 AM To: Chad Gilgen <cgilgen@utah.gov> Cc: "Van Tassell, Ruben" <Ruben.VanTassell@jbssa.com>, Rik Ombach <ROMBACH@utah.gov> Hi Chad, Here is The Informaon You asked For: 1)The Leak Happened In The Offal Freezer At The JBS Plant In Hyrum Utah On 8/16/2023 at about 9 pm 2)The Leak was Found By A Refrigeraon Mechanic and The PPM Ranged From 3 ppm to 6 ppm on a Hand Meter. 3)The Leak Was On Down Stream Side Of A Flange Gasket On A Check Valve (Sucon Side), On A Hot Gas Line Aer An Evaporator. Sucon Pressure was 6 psig 4)The Control Bank For That Evaporator Was Valved Out at About 3:45 am On 8/17/2023 and the Sucon was le On To Remove any Liquid Ammonia From The Evaporator. The Pump Out Process was started at About 6:30 am. Total Time was about 9 ½ hrs 5)Aer The Leak Was Fixed, The Ammonia Release Was calculated By The PSM employee and was Reported To The NRC at 28 lbs. 6)The Gaskets On Both Sides Of The Check Valve were Replaced and The Employee’s Involved with The Incident and all The Refrigeraon Crew were talked to about what they should have Done to stop the Leak Sooner. From: Chad Gilgen <cgilgen@utah.gov> Sent: Thursday, September 28, 2023 10:45 AM To: Crocke, Guy <Guy.Crockett@jbssa.com> Cc: Van Tassell, Ruben <Ruben.VanTassell@jbssa.com>; Rik Ombach <ROMBACH@utah.gov> Subject: [Ext]- JBS Ammonia Leak Report *Use caution before opening attachments or links!* Hello Guy, Thanks for your time this morning. Per our discussion, you submitted a report for an ammonia leak to the NRC last month (copy attached). In order for us to close this out on our end, I need some additional information since this is a permitted source with the DAQ. REVIEWED Initials: CG Date: 1-3-24 Compliance Status: Ammonia Leak Report and Correspondence File # 10051 (B2) 1/3/24, 12:30 PM State of Utah Mail - RE: [Ext]- JBS Ammonia Leak Report https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1778372830273429959&simpl=msg-f:1778372830273429…2/11 Per R307-107-2. Reporting. (attached), we need a report with the following items: Cause/reason for the release. How much ammonia was released. How long the release went on for. Steps taken to fix the problem and avoid future incidents. For reference, I have also included a copy of the Air Quality Approval Order which references the R307-107 breakdown rule as condition I.6 on page 6 of the document. Thanks and let me know if you have any questions. Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. Disclaimer The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the material from any computer. This email has been checked for viruses. However, JBS USA Food Company and its constituent companies cannot accept responsibility for loss or damages arising from use of this email or attachments and we recommend that you subject these to your virus checking procedures prior to use. Rik Ombach <rombach@utah.gov>Fri, Sep 29, 2023 at 9:03 AM To: Jay Morris <JPMORRIS@utah.gov>, Chad Gilgen <cgilgen@utah.gov> Jay and Chad: Is this something that I should close, do we have additional questions, or do we want to look at an enforcement action? My only thought was asking if this was a preventable leak and what procedures have been taken - if any, to ensure this does not happen again. Just my thoughts though as I am not very familiar with the systems. Thanks, Rik [Quoted text hidden] -- 1/3/24, 12:30 PM State of Utah Mail - RE: [Ext]- JBS Ammonia Leak Report https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1778372830273429959&simpl=msg-f:1778372830273429…3/11 Rik Ombach Manager | Oil and Gas P: (801) 536-4164 airquality.utah.gov [Quoted text hidden] 2 attachments ~WRD000.jpg 1K ~WRD000.jpg 1K Chad Gilgen <cgilgen@utah.gov>Fri, Sep 29, 2023 at 9:28 AM To: "Crockett, Guy" <Guy.Crockett@jbssa.com> Cc: "Van Tassell, Ruben" <Ruben.VanTassell@jbssa.com>, Rik Ombach <ROMBACH@utah.gov> Hello Guy, Thanks for getting back to me. After reviewing what you provided, I have a few additional questions. I'm unfamiliar with this system and need some clarification as follows: What caused the leak? Was it operator error? Systems malfunction? Equipment breakdown? Informational items 1, 2, and 3 appear to discuss the events once the leak was found. What actions were addressed with staff to avoid this happening in the future? How much anhydrous ammonia does JBS store/use on-site? Thanks, Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] 2 attachments 1/3/24, 12:30 PM State of Utah Mail - RE: [Ext]- JBS Ammonia Leak Report https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1778372830273429959&simpl=msg-f:1778372830273429…4/11 ~WRD000.jpg 1K ~WRD000.jpg 1K Chad Gilgen <cgilgen@utah.gov>Fri, Sep 29, 2023 at 9:29 AM To: Rik Ombach <rombach@utah.gov> Cc: Jay Morris <JPMORRIS@utah.gov> Rik, I was putting together a response to JBS when you sent this. I was thinking about an enforcement action as well but was wondering how that would work since ammonia is neither a Criteria Air Pollutant or HAP? It looks like the CAA has provisions under their Emergency Response Program (40 CFR 68 Subpart E) to cite companies for improperly storing anhydrous ammonia where the EPA has initiated enforcement actions but I don't know if we have that kind of authority or would need to get the EPA involved. Thanks, Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] Rik Ombach <rombach@utah.gov>Fri, Sep 29, 2023 at 9:36 AM To: Chad Gilgen <cgilgen@utah.gov> Cc: Jay Morris <JPMORRIS@utah.gov> Those are great questions. This is kinda a new thought process but I think it is possible to use the general requirements of proper maintenance and good air pollution control practices. The EPA oil and gas lawsuits are simply based on proper design and maintenance of controls. Just my opinion though. I'm not really looking for enforcement of everything but I think it is proper to evaluate all of these releases and I thought Jay agreed with that.. Rik [Quoted text hidden] Crockett, Guy <Guy.Crockett@jbssa.com>Fri, Sep 29, 2023 at 10:08 AM To: Chad Gilgen <cgilgen@utah.gov> Cc: "Van Tassell, Ruben" <Ruben.VanTassell@jbssa.com>, Rik Ombach <ROMBACH@utah.gov> 1/3/24, 12:30 PM State of Utah Mail - RE: [Ext]- JBS Ammonia Leak Report https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1778372830273429959&simpl=msg-f:1778372830273429…5/11 The Leak Was Caused By Loose Bolts On a The North Side Of The Check Valve, So It Was Equipment Break Down. The Gaskets were changed To Make Sure we wouldn’t Have A Leak In This locaon In The Future. The Acons that were Addressed was The Maintenance Supervisor and The Refrigeraon Mechanic Didn’t call anyone to Inform them about the Leak and they did Nothing to Contain The Leak. The Maintenance Supervisor and The Mechanic were Talked to By The Maintenance Management. It was Discussed that They need to call people on The Emergency call List unl They get Some One. It Was Also Discussed with them that both Of Them were Qualified to Valve out A Control Bank and Pump It down and They Need to Do the Pump Out, Instead Of Waing For Someone Else to Come In And Do It. This was Also Discussed With The Refrigeraon Crew That were On Different Shis To Help Avoid This Situaon From Happening Again. The Hyrum JBS Plant Has between 80,000 lbs. and 100,000 lbs. Of Ammonia From: Chad Gilgen <cgilgen@utah.gov> Sent: Friday, September 29, 2023 9:29 AM To: Crocke, Guy <Guy.Crockett@jbssa.com> Cc: Van Tassell, Ruben <Ruben.VanTassell@jbssa.com>; Rik Ombach <ROMBACH@utah.gov> Subject: Re: [Ext]- JBS Ammonia Leak Report *Use caution before opening attachments or links!* Hello Guy, Thanks for getting back to me. After reviewing what you provided, I have a few additional questions. I'm unfamiliar with this system and need some clarification as follows: What caused the leak? Was it operator error? Systems malfunction? Equipment breakdown? Informational items 1, 2, and 3 appear to discuss the events once the leak was found. What actions were addressed with staff to avoid this happening in the future? How much anhydrous ammonia does JBS store/use on-site? Thanks, Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) 1/3/24, 12:30 PM State of Utah Mail - RE: [Ext]- JBS Ammonia Leak Report https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1778372830273429959&simpl=msg-f:1778372830273429…6/11 [Quoted text hidden] [Quoted text hidden] Chad Gilgen <cgilgen@utah.gov>Fri, Sep 29, 2023 at 12:03 PM To: "Crockett, Guy" <Guy.Crockett@jbssa.com> Cc: "Van Tassell, Ruben" <Ruben.VanTassell@jbssa.com>, Rik Ombach <ROMBACH@utah.gov> Hello Guy, Thank you for the additional information. I'll take a look at everything provided and let you know if I need anything else. Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] 3 attachments ~WRD000.jpg 1K ~WRD000.jpg 1K ~WRD000.jpg 1K Chad Gilgen <cgilgen@utah.gov>Fri, Sep 29, 2023 at 12:13 PM To: "Wilwerding, Joseph (he/him/his)" <Wilwerding.Joseph@epa.gov> 1/3/24, 12:30 PM State of Utah Mail - RE: [Ext]- JBS Ammonia Leak Report https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1778372830273429959&simpl=msg-f:1778372830273429…7/11 Cc: Rik Ombach <ROMBACH@utah.gov>, Jay Morris <jpmorris@utah.gov> Hello Joe, We recently received a release notification report (attached) of anhydrous ammonia at a beef processing plant with an Approval Order (attached) through the DAQ. Please see below for my correspondence with the source contact. Since anhydrous ammonia is classified as a refrigerant (rather than a Criteria Air Pollutant, VOC, or HAP), it doesn't look like we have anything under our delegated authority that we can use here so I thought I would pass it along to you to see if there is anything more that EPA Enforcement would like to pursue? It looks like 40 CFR Part 68 requires facilities storing/using more than 10,000 lbs of anhydrous ammonia to develop/maintain a Risk Management Program with the EPA. Please let me know your thoughts and if there is anything more I need to be doing on my end. Thanks, Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. ---------- Forwarded message --------- From: Crockett, Guy <Guy.Crockett@jbssa.com> [Quoted text hidden] [Quoted text hidden] 3 attachments ~WRD000.jpg 1K JBS Report.pdf 90K DAQE-AN100510021-23.pdf 3355K Wilwerding, Joseph (he/him/his) <Wilwerding.Joseph@epa.gov>Mon, Oct 2, 2023 at 7:38 AM To: cgilgen <cgilgen@utah.gov> Cc: Rik Ombach <rombach@utah.gov>, Jay Morris <jpmorris@utah.gov>, "Cobb, David" <cobb.david@epa.gov>, "Patefield, Scott" <Patefield.Scott@epa.gov> Hi Chad, thanks for the heads up. I’m forwarding to David Cobb for potential CAA 112r purposes, as well as Scott Patefield (stationary source branch supervisor). I just talked with the site contact listed in the NRC report, Guy Crockett, and was told the following: 1/3/24, 12:30 PM State of Utah Mail - RE: [Ext]- JBS Ammonia Leak Report https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1778372830273429959&simpl=msg-f:1778372830273429…8/11 Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. 28 lbs total release of Anhydrous Ammonia (AA) between 8/16/23 and 8/17/23. Operations technician was doing rounds evening of 8/16/23, went into freezer, smelled AA. Took reading with a handheld meter, saw 6 ppm. The 2 operations personnel onsite didn’t follow SOP, didn’t reach Guy until 3 am. Leak was stopped leak shortly thereafter (‘valved it out’, ‘pumped it down’). Corporate wanted NRC called if didn't know if close to 100 lbs AA reporting threshold or not, so put in report. PSM guy did calculations, 28 pounds. Incident review/response: Loose bolts on check valve; defrost line. 6 psi suction pressure on ammonia inlet side. Changed gasket, tightened bolts; Real problem was the 2 guys onsite didn't do anything about it; didn't call anyone. Could have stopped it quickly. Because went on all night long and didn't know, called NRC. Supervisors have been informed about what should have happened. Operations staff (10-15 people) have been informed and reminded of correct procedure. PSM training is done every year. Guy took all the statements from involved personnel and put them in his report, which will be part of (next) PSM training. I’m not too familiar with AA-applicable regulations, but could dig into it. David and Scott, is this a 112r issue to explore? Appreciate any guidance you might have. Thanks, Joe From: Chad Gilgen <cgilgen@utah.gov> Sent: Friday, September 29, 2023 12:14 PM To: Wilwerding, Joseph (he/him/his) <Wilwerding.Joseph@epa.gov> Cc: Rik Ombach <rombach@utah.gov>; Jay Morris <jpmorris@utah.gov> Subject: Fwd: [Ext]- JBS Ammonia Leak Report [Quoted text hidden] 2 attachments JBS Report.pdf 90K DAQE-AN100510021-23.pdf 3355K Jay Morris <jpmorris@utah.gov>Mon, Oct 2, 2023 at 9:24 AM To: Rik Ombach <rombach@utah.gov> Cc: Chad Gilgen <cgilgen@utah.gov> Thank you both for including me in this discussion. You have handled this perfectly as usual! I'm interested to see how Joseph and the EPA handle the information. 1/3/24, 12:30 PM State of Utah Mail - RE: [Ext]- JBS Ammonia Leak Report https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1778372830273429959&simpl=msg-f:1778372830273429…9/11 Have a great day. Jay Morris Assistant Director Email: jpmorris@utah.gov Phone: Office (801) 536-4079 Main Office: (801) 536-4000 airquality.utah.gov Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] Chad Gilgen <cgilgen@utah.gov>Mon, Oct 2, 2023 at 11:50 AM To: "Wilwerding, Joseph (he/him/his)" <Wilwerding.Joseph@epa.gov> Cc: Rik Ombach <rombach@utah.gov>, Jay Morris <jpmorris@utah.gov>, "Cobb, David" <cobb.david@epa.gov>, "Patefield, Scott" <Patefield.Scott@epa.gov> Hello Joe, Thanks for the update. I appreciate it. Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] 3 attachments image001.jpg 1K image001.jpg 1K 1/3/24, 12:30 PM State of Utah Mail - RE: [Ext]- JBS Ammonia Leak Report https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1778372830273429959&simpl=msg-f:177837283027342…10/11 Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. image001.jpg 1K Wilwerding, Joseph (he/him/his) <Wilwerding.Joseph@epa.gov>Mon, Oct 2, 2023 at 12:06 PM To: cgilgen <cgilgen@utah.gov> Cc: Rik Ombach <rombach@utah.gov>, Jay Morris <jpmorris@utah.gov>, "Cobb, David" <cobb.david@epa.gov>, "Patefield, Scott" <Patefield.Scott@epa.gov> Hi Chad, we’ve exchanged a bit internally, and I believe David Cobb’s group will be reaching out. Thanks again for the heads up, Joe From: Chad Gilgen <cgilgen@utah.gov> Sent: Monday, October 2, 2023 11:50 AM To: Wilwerding, Joseph (he/him/his) <Wilwerding.Joseph@epa.gov> Cc: Rik Ombach <rombach@utah.gov>; Jay Morris <jpmorris@utah.gov>; Cobb, David <cobb.david@epa.gov>; Patefield, Scott <Patefield.Scott@epa.gov> Subject: Re: [Ext]- JBS Ammonia Leak Report [Quoted text hidden] Cobb, David <cobb.david@epa.gov>Tue, Oct 3, 2023 at 12:00 PM To: "Wilwerding, Joseph (he/him/his)" <Wilwerding.Joseph@epa.gov>, cgilgen <cgilgen@utah.gov> Cc: Rik Ombach <rombach@utah.gov>, Jay Morris <jpmorris@utah.gov>, "Patefield, Scott" <Patefield.Scott@epa.gov> Chad, Wanted to give you a quick update on release notification you forwarded. I met with one of our CAA 112r/EPCRA/CERCLA release inspectors this morning and they will follow up with the facility to review the release calculations and incident SOP’s. Depending on how that turns out, we may do an on-site inspection later in 2024 due to the large quantity of ammonia onsite and also since we (EPA CAA 112r/EPCRA team) haven’t been out there since 2017. Thanks again for the information and feel free contact me if you’d like to discuss. David Cobb, Supervisor Toxics & Pesticides Enforcement Section Enforcement & Compliance Assurance Division US EPA Region 8|8ENF-AT-P 303-312-6592| cobb.david@epa.gov Report an environmental violation: https://echo.epa.gov/report-environmental-violations 1/3/24, 12:30 PM State of Utah Mail - RE: [Ext]- JBS Ammonia Leak Report https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1778372830273429959&simpl=msg-f:177837283027342…11/11 [Quoted text hidden] Chad Gilgen <cgilgen@utah.gov>Wed, Oct 4, 2023 at 10:27 AM To: "Cobb, David" <cobb.david@epa.gov> Cc: "Wilwerding, Joseph (he/him/his)" <Wilwerding.Joseph@epa.gov>, Rik Ombach <rombach@utah.gov>, Jay Morris <jpmorris@utah.gov>, "Patefield, Scott" <Patefield.Scott@epa.gov> Hello David, Thank you for the update. Please let me know what you find as a result of your review and if you determine to do an on- site inspection in 2024 as we would like to attend if it works with our schedules. Thanks again, Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] ENVIRONMENTAL INCIDENT REPORT - ANHYDROUS AMMONIA - HYRUM Report Taken By:NRC Date / Time Reported:8/17/2023 08:00 REPORTING PARTY DATES AND TIMES Reporting Party:Guy Crockett Title: Company:JBS Phone:(435) 764-4939 Date & Time Discovered:8/16/2023 21:00 Lead Agency:DAQ Agency Contact: RESPONSIBLE PARTY Name:JBS Phone:(435) 764-4939 Address:410 N 200 W Hyrum, UT INCIDENT LOCATION Incident Address:410 N 200 W Nearest Town:HYRUM County:CACHE Highway:Mile Marker: UTM:(E) 428293 (N) 4610673 Land Ownership:Private First Responders Notified?No INCIDENT SUMMARY Caller is reporting a release of an unknown amount of anhydrous ammonia stemming from a check valve on a hot gas line. The caller stated the cause may be due to equipment failure. There is an active slow release present as they work to resolve the issue. CHEMICAL(S) REPORTED Ammonia N/A - Unknown IMPACTED MEDIA Media Media Other Land Use Waterway Name Near Water Distance NRC Rpt. # Outdoor Air N/A Commercial N/A N/A N/A NOTIFICATIONS MADE Agency Contact Phone Date Time By Active? DAQ Email 8/17/2023 10:15 Daniel Riddle Active Bear River HD Jonathan (435) 792-6500 8/17/2023 10:15 Daniel Riddle Active ACTIONS TAKEN Date Agency Action Action Details Incident notification reports are prepared by DEQ staff using information provided by the reporting party. The information is considered preliminary and is subject to revision. The reported incident and associated details may or may not be valid Report Number 16581Utah Department of Environmental Quality Division of Environmental Response and Remediation 195 North 1950 West Salt Lake City, Utah 84116 Bus. Hours: 801-536-4100 Report Spills 24/7/365: 801-536-4123 1/3/24, 12:32 PM State of Utah Mail - JBS Swift possible new fuel tank https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1780286821678507894&simpl=msg-f:17802868216785078…1/3 Chad Gilgen <cgilgen@utah.gov> JBS Swift possible new fuel tank 6 messages Van Tassell, Ruben <Ruben.VanTassell@jbssa.com>Fri, Oct 20, 2023 at 8:56 AM To: "cgilgen@utah.gov" <cgilgen@utah.gov> Mr. Gilgen, We are considering the purchase of an above ground storage tank for refueling vehicles that use On-Highway diesel fuel here at the main Swift Beef Plant in Hyrum. Most likely it will be at least 500 gallons but possibly larger. What are the main considerations that we should take in determining the size and use of a new tank in accordance with air permits and emissions?? Thank you, Ruben Van Tassell Environmental and Sustainability Manager Ruben.VanTassell@jbssa.com O: 435.245.2259 C: 208.300.0408 www.jbssa.com 410 N. 200 West Hyrum, UT  84319 Disclaimer The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the material from any computer. This email has been checked for viruses. However, JBS USA Food Company and its constituent companies cannot accept responsibility for loss or damages arising from use of this email or attachments and we recommend that you subject these to your virus checking procedures prior to use. Chad Gilgen <cgilgen@utah.gov>Fri, Oct 20, 2023 at 8:57 AM To: ruben.vantassell@jbssa.com I am out on leave until October 23, 2023. If you need immediate assistance, please contact the DAQ Front Desk at 801- 536-4000. Otherwise, I will return your email when I get back. Thanks, Chad 1/3/24, 12:32 PM State of Utah Mail - JBS Swift possible new fuel tank https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1780286821678507894&simpl=msg-f:17802868216785078…2/3 -- Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. Chad Gilgen <cgilgen@utah.gov>Tue, Oct 24, 2023 at 11:55 AM To: "Van Tassell, Ruben" <Ruben.VanTassell@jbssa.com> Hello Ruben, A 500-gallon diesel tank may need to be added to your existing Approval Order. Alan Humpherys with our NSR permitting group can provide additional information on that. I have cc:ed him on my response. It looks like there are some additional regulations the tank may fall under with our Division of Environmental Response & Remediation - Aboveground Petroleum Storage Tanks group. More information on that can be found here - https://deq.utah.gov/environmental-response-and-remediation/aboveground-petroleum-storage-tanks-apst Thanks and let me know if you have any questions. Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] Chad Gilgen <cgilgen@utah.gov>Mon, Oct 30, 2023 at 12:07 PM To: Alan Humpherys <ahumpherys@utah.gov>, "Van Tassell, Ruben" <ruben.vantassell@jbssa.com> Hi Alan, Please see the following email I intended to cc you on last week. Thanks, Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) 1/3/24, 12:32 PM State of Utah Mail - JBS Swift possible new fuel tank https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1780286821678507894&simpl=msg-f:17802868216785078…3/3 Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] Alan Humpherys <ahumpherys@utah.gov>Wed, Nov 1, 2023 at 8:51 AM To: Chad Gilgen <cgilgen@utah.gov> Thanks for the heads up. I'll wait to hear back from the source. [Quoted text hidden] -- Alan Humpherys Manager | Minor NSR Section P: (385) 306-6520 F: (801) 536-4099 airquality.utah.gov [Quoted text hidden] Chad Gilgen <cgilgen@utah.gov>Wed, Nov 1, 2023 at 4:33 PM To: Alan Humpherys <ahumpherys@utah.gov> Hi Alan, I think they wanted you to contact them. I'll forward that correspondence to your attention. Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] 1/3/24, 12:31 PM State of Utah Mail - RE: [Ext]- Re: JBS Swift possible new fuel tank https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1781195895267848216&simpl=msg-f:17811958952678482…1/4 Chad Gilgen <cgilgen@utah.gov> RE: [Ext]- Re: JBS Swift possible new fuel tank 4 messages Van Tassell, Ruben <Ruben.VanTassell@jbssa.com>Mon, Oct 30, 2023 at 9:46 AM To: Chad Gilgen <cgilgen@utah.gov> Chad, All of our exisng tanks are either less than 500 gal and/or resng on concrete so I do not believe that they will be regulated APSTs, the queson about changing our exisng AO for a new tank sll remains. I have not received a response from Mr. Humpherys. Thank you for your me and help with this, Ruben Van Tassell Environmental and Sustainability Manager Ruben.VanTassell@jbssa.com O: 435.245.2259 C: 208.300.0408 www.jbssa.com 410 N. 200 West Hyrum, UT  84319 From: Chad Gilgen <cgilgen@utah.gov> Sent: Tuesday, October 24, 2023 11:56 AM To: Van Tassell, Ruben <Ruben.VanTassell@jbssa.com> Subject: [Ext]- Re: JBS Swi possible new fuel tank *Use caution before opening attachments or links!* Hello Ruben, 1/3/24, 12:31 PM State of Utah Mail - RE: [Ext]- Re: JBS Swift possible new fuel tank https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1781195895267848216&simpl=msg-f:17811958952678482…2/4 A 500-gallon diesel tank may need to be added to your existing Approval Order. Alan Humpherys with our NSR permitting group can provide additional information on that. I have cc:ed him on my response. It looks like there are some additional regulations the tank may fall under with our Division of Environmental Response & Remediation - Aboveground Petroleum Storage Tanks group. More information on that can be found here - https://deq.utah.gov/environmental-response-and-remediation/aboveground-petroleum-storage-tanks-apst Thanks and let me know if you have any questions. Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. On Fri, Oct 20, 2023 at 8:56 AM Van Tassell, Ruben <Ruben.VanTassell@jbssa.com> wrote: Mr. Gilgen, We are considering the purchase of an above ground storage tank for refueling vehicles that use On-Highway diesel fuel here at the main Swift Beef Plant in Hyrum. Most likely it will be at least 500 gallons but possibly larger. What are the main considerations that we should take in determining the size and use of a new tank in accordance with air permits and emissions?? Thank you, 1/3/24, 12:31 PM State of Utah Mail - RE: [Ext]- Re: JBS Swift possible new fuel tank https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1781195895267848216&simpl=msg-f:17811958952678482…3/4 Ruben Van Tassell Environmental and Sustainability Manager Ruben.VanTassell@jbssa.com O: 435.245.2259 C: 208.300.0408 www.jbssa.com 410 N. 200 West Hyrum, UT  84319 Disclaimer The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the material from any computer. This email has been checked for viruses. However, JBS USA Food Company and its constituent companies cannot accept responsibility for loss or damages arising from use of this email or attachments and we recommend that you subject these to your virus checking procedures prior to use. Chad Gilgen <cgilgen@utah.gov>Mon, Oct 30, 2023 at 12:06 PM To: "Van Tassell, Ruben" <Ruben.VanTassell@jbssa.com> Hi Ruben, Thanks for that additional information. I apologize, it looks like I didn't cc Alan on my previous email. I will do that right now. Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] Van Tassell, Ruben <Ruben.VanTassell@jbssa.com>Mon, Oct 30, 2023 at 12:09 PM To: Chad Gilgen <cgilgen@utah.gov> Thanks! [Quoted text hidden] Chad Gilgen <cgilgen@utah.gov>Wed, Nov 1, 2023 at 4:33 PM To: Alan Humpherys <ahumpherys@utah.gov> FYI. 1/3/24, 12:31 PM State of Utah Mail - RE: [Ext]- Re: JBS Swift possible new fuel tank https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1781195895267848216&simpl=msg-f:17811958952678482…4/4 Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] 1/3/24, 12:32 PM State of Utah Mail - RE: [Ext]- Permitting Question https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1781479655242559435&simpl=msg-f:17814796552425594…1/3 Chad Gilgen <cgilgen@utah.gov> RE: [Ext]- Permitting Question 2 messages Van Tassell, Ruben <Ruben.VanTassell@jbssa.com>Thu, Nov 2, 2023 at 12:56 PM To: Alan Humpherys <ahumpherys@utah.gov> Cc: Chad Gilgen <cgilgen@utah.gov> Alan, Our facility is considering purchasing an above ground fuel tank for “On Road” diesel. It would not be greater than 500 gallons. Am I correct in understanding that that size of tank will need to be added by modificaon to our permit? Thank you,   Ruben Van Tassell Environmental and Sustainability Manager Ruben.VanTassell@jbssa.com O: 435.245.2259 C: 208.300.0408 www.jbssa.com 410 N. 200 West Hyrum, UT  84319 From: Alan Humpherys <ahumpherys@utah.gov> Sent: Wednesday, November 1, 2023 5:21 PM To: Van Tassell, Ruben <Ruben.VanTassell@jbssa.com> Cc: Chad Gilgen <cgilgen@utah.gov> Subject: [Ext]- Perming Queson *Use caution before opening attachments or links!* Ruben, 1/3/24, 12:32 PM State of Utah Mail - RE: [Ext]- Permitting Question https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1781479655242559435&simpl=msg-f:17814796552425594…2/3 The Minor Source Compliance Manager mentioned that you might have some questions about modifying the permit for your facility. Please let me know how I can assist you. Thanks, Alan -- Alan Humpherys Manager | Minor NSR Section P: (385) 306-6520 F: (801) 536-4099 airquality.utah.gov https://deq.utah.gov/wp- content/uploads/facebook- 25w.png https://deq.utah.gov/wp- content/uploads/twitter- 25w.png Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. Disclaimer The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the material from any computer. This email has been checked for viruses. However, JBS USA Food Company and its constituent companies cannot accept responsibility for loss or damages arising from use of this email or attachments and we recommend that you subject these to your virus checking procedures prior to use. Alan Humpherys <ahumpherys@utah.gov>Thu, Nov 2, 2023 at 2:20 PM To: "Van Tassell, Ruben" <Ruben.VanTassell@jbssa.com> Cc: Chad Gilgen <cgilgen@utah.gov> Ruben, Yes, if you want to add a storage tank to your facility, you will need to add it to your permit first. If you have questions on how to submit the permit application, please let me know. 1/3/24, 12:32 PM State of Utah Mail - RE: [Ext]- Permitting Question https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-f:1781479655242559435&simpl=msg-f:17814796552425594…3/3 Thanks, Alan [Quoted text hidden] Alan Humpherys Manager | Minor NSR Section P: (385) 306-6520 F: (801) 536-4099 airquality.utah.gov [Quoted text hidden]