DAQ-2024-004844

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DAQC-CI119490001-24
Site ID 11949 (B1)

MEMORANDUM

TO: FILE – SCHREIBER FOODS INCORPORATED – Smithfield Cheese Packing
Facility

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: February 12, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Cache County

INSPECTION DATE: January 24, 2024

SOURCE LOCATION: 2180 West 6550
Smithfield, UT 84335
DIRECTIONS: The plant is actually in Amalga, Utah. Google maps sent us
around the back side of the plant, so just stay on 2180 W until
you get to a bend in the road and that will be the front side of the
plant.

SOURCE CONTACTS: Corene Lewis, Plant Manager
660-223-6148 [e-mail]
Kody Maughan, Environmental Health Manager
435-770-2197 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: This is a cheese production and packaging operations facility.
The cheese arrives in trucks and the milk by tanker trucks. The
finished products are transferred to the Schreiber Logan facility
for shipment. Raw material in the form of cheese ingredients are
ground, blended, and introduced into a cooker. The product is
wrapped, sealed, and packaged for shipment and/or storage. The
two boilers are used for heating, cleaning, and milk
pasteurization.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-ADAQE-AN0119490005-10-11,
dated January 24, 2011
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) ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines,

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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Schreiber Foods Incorporated - Smithfield
Cheese Packing Facility

400 North Washington Street 2180 West 6550 North
Green Bay, WI 54301 Smithfield, UT 84335

SIC Code: 2022: (Cheese - Natural, Processed & Imitation)

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]

Status: In Compliance. No limits set forth in this AO appear to have been exceeded. The
source stated that there have been no modifications to the equipment or processes. The
equipment appeared to be properly operated and maintained according to manufacturer
recommendations. Records are kept as required and were made available after the
inspection. No breakdowns have been reported since the previous inspection. An emissions
inventory was submitted for 2020, and emissions data are reported below.

Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Smithfield Cheese Packing Facility

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II.A.2 Boiler #1
Burner Rating: 50.0 MMBtu per hour
Burner Manufacturer: Limpsfield
Controls: Low NOx Burners &
flue gas recirculation

II.A.3 Boiler #2
Heat Input Rate: 60.6 MMBtu per hour
Manufacturer: Cleaver Brooks
Model Number: DL60L,H
Built & Installed Date: 1990 & 1992

II.A.4 Whey Drying Oven
Heat Input Rate: 7.242 MMBtu per hour
Manufacturer: Sweeney (evaporator), Maxon (duct burner)
Built & Installed Date: 1976

II.A.5 One (1) Emergency Electrical Generator
Rating: 25 kW
Fuel: diesel fuel

II.A.6 Miscellaneous Sources
Two (2) small (<10 square feet) degreasers, #2 oil underground storage tank, waste water treatment
lagoons, 1.5 MMBtu/hr natural gas-fired water heater, whey bagging station, and inkjet printers
(packaging department)
- These sources are listed for informational purposes only -
- Emissions from these sources are insignificant -

Status: In Compliance. No additional unapproved equipment was on site. Source contacts
stated the Whey Drying Oven (II.A.4) has been out of operation since 2008. It still
exists on site, but they do not foresee using it again in the future. One sandblaster
that is vented internally is also onsite.

II.B Requirements and Limitations

II.B.1 The Smithfield Cheese Packing Facility shall be subject to the following:

II.B.1.a The owner/operator shall not exceed the following consumption and production limits:

A. 1,043,383 MMBtu of natural gas consumed per rolling 12-month period

B. 17,520 tons of whey produced 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 twentieth day of each month using data from the previous 12 months.
Records of consumption/production shall be kept for all periods when the plant is in operation.
The records of consumption shall be kept on a monthly basis. Natural gas consumption shall be
determined by direct metering of the owner/operator's gas-fired equipment. The records of
production shall be kept on a daily basis. Production shall be determined by sales records of final
product shipped. [R307-401-8]

Status: In Compliance. Records are kept as required. For the rolling 12-month period from
January - December, 2023, the following was reported:

A. 101,707 MMBtu of natural gas consumed
B. 0 tons of whey produced
See attachment for detailed information.
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II.B.1.b Visible emissions from any stationary point or fugitive emission source associated with the
source or with the control facilities shall not exceed 10% opacity when burning natural gas and
20% opacity when burning fuel oil during natural gas curtailment. [R307-401-8]

II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with
40 CFR 60, Appendix A, Method 9. For sources that are subject to NSPS, opacity shall be
determined by conducting observations in accordance with 40 CFR 60.11(b) and 40 CFR 60,
Appendix A, Method 9. [R307-201-3]

Status: In Compliance. No visible emissions were observed from any point at the time of
inspection. Method 9 was utilized to verify opacity limits. See attached VEO form.

II.B.1.c Emergency generators shall be used for electricity producing operation only during the periods
when electric power from the public utilities is interrupted, or for regular maintenance of the
generators. Records documenting generator usage shall be kept in a log, and they shall show the
date the generator was used, the duration in hours of the generator usage, and the reason for each
generator usage. [R307-401-8]

Status: In Compliance. The source only uses the emergency generator for emergencies and
maintenance. No emergencies requiring its use had occurred since the previous inspection.
The generator is used for ½ an hour once a week, and an additional hour once a month,
both for maintenance purposes. See the attached log.

II.B.2 The Boiler and Oven Stacks shall be subject to the following:

II.B.2.a The height of the boiler stacks shall be no less than 38 feet, as measured from the base of the
building. The boiler stacks shall vent vertically unrestricted with no obstruction beyond the
opening of the stack. The stack height to building ratio may be less than 1.3:1. [R307-401-8]

Status: In Compliance. The height of the stacks for the two boilers were observed to be no
less than 38 feet from the base of the building. Stacks are most visible from roof access.

II.B.2.b The height of the whey dryer stacks shall be no less than 81 feet, as measured from the base of
the building. The stack shall vent vertically unrestricted with no obstruction beyond the opening
of the stack. [R307-401-8]

Status: Not Applicable. The whey dryer has been out of commission since 2008.

II.B.3 All Fuels Consumed on site shall be subject to the following:

II.B.3.a The owner/operator shall use natural gas as fuel in the boilers. Fuel oil #1 or #2 may be used as
an alternate fuel in the boilers during natural gas curtailment. [R307-401-8]

Status: In Compliance. The source has only used natural gas for at least 7 years as there
has been no curtailment in that time.

II.B.3.b The owner/operator shall use natural gas as a primary fuel in the whey drying oven.
[R307-401-8]

Status: Not Applicable. The whey drying oven has not been in use since 2008.

II.B.3.c The owner/operator shall use #1 or #2 diesel fuel for the emergency generator. [R307-401-8]

Status: In Compliance. Only #2 diesel fuel is used in the emergency generator.

II.B.3.d The sulfur content of diesel fuel burned in boilers and emergency generator shall not exceed the
limits specified in 40 CFR 60.4207. [40 CFR 60 Subpart IIII]

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II.B.3.d.1 The sulfur content shall be determined by ASTM Method D-4294-89 or approved equivalent.
Certification of sulfur content shall be test reports from the fuel supplier. [R307-203-1]

Status: In Compliance. ULSD invoices were observed at the time of inspection from
Cardwell Distribution.

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 boilers currently only use natural gas supplied by local natural gas utility.
Records are kept of natural gas use. No curtailment has occurred requiring the use of any fuel oil in 7 or
more years.

NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines

Status: In Compliance. Compliance with this subpart is satisfied by installing a certified engine,
maintaining and operating the engines in accordance with the manufacturer's instructions, installation
of a non-resettable hour meter, and maintaining records of use. All information provided at the time of
inspection indicate this engine is being properly maintained and operated in accordance with this
subpart. See the attachment for the maintenance log for the diesel generator.

MACT (Part 63) ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines

Status: In Compliance. Stationary RICE located at area sources of HAP emissions must comply with
Table 2d to subpart ZZZZ of MACT (Part 63), which requires annual maintenance of hoses, oil, belts,
and filters, and the use of ultra-low sulfur fuel. A non-resettable hour meter was observed at the time of
inspection.

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. ULSD invoices were observed at the time of inspection from Cardwell
Distribution.

Stationary Sources [R307-210]

Status: In Compliance. Compliance with this area source rule is satisfied by compliance with Federal
Requirements NSPS (Part 60) Subparts Dc and IIII. See Section III above for more information.

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National Emission Standards for Hazardous Air Pollutants [R307-214]

Status: In Compliance. Compliance with this area source rule is satisfied by compliance with Federal
Requirement MACT (Part 63) Subpart ZZZZ. See Section III above for more information.

Degreasing and Solvent Cleaning Operations [R307-335]

Status: In Compliance. The two degreasers are stored in enclosed containers. No excess solvent was
exposed at the time of inspection.

EMISSION INVENTORY:

Listed before are the Actual Emissions Inventory provided from Schreiber Foods Incorporated-
Smithfield Cheese Packing Facility for the 2020 emissions reporting year. A comparison of the estimated
total potential emissions (PTE) on AO: DAQE-ADAQE-AN0119490005-10-11, dated January 24, 2011,
is provided. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr Actuals tons/yr
Carbon Monoxide 42.96 4.0143
Nitrogen Oxides 52.88 2.70496
Particulate Matter - PM10 17.20 0.36306
Particulate Matter - PM2.5 17.20 0.36305
Sulfur Dioxide 0.31 0.03062
Volatile Organic Compounds 2.81 0.26308

PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-ADAQE-
AN0119490005-10-11, dated January 24, 2011: In compliance at
the time of inspection. The facility appears to be well-maintained
and operated.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect at typical frequency. You will need to remove all jewelry
and gown up to go through the plant.

NSR RECOMMENDATIONS: Remove whey drying oven if source ever submits new NOI.

ATTACHMENTS: VEO form, natural gas consumption, whey production, generator
maintenance log.

1/2/2023 0.5 Weekly scheduled maintenance
1/9/2023 0.5 Weekly scheduled maintenance
1/14/2023 1 Monthly Maintenance generator check
1/16/2023 0.5 Weekly scheduled maintenance
1/23/2023 0.5 Weekly scheduled maintenance
1/30/2023 0.5 Weekly scheduled maintenance
2/6/2023 0.5 Weekly scheduled maintenance
2/11/2023 1 Monthly Maintenance generator check
2/13/2023 0.5 Weekly scheduled maintenance
2/20/2023 0.5 Weekly scheduled maintenance
2/27/2023 0.5 Weekly scheduled maintenance
3/6/2023 0.5 Weekly scheduled maintenance
3/11/2023 1 Monthly Maintenance generator check
3/13/2023 0.5 Weekly scheduled maintenance
3/20/2023 0.5 Weekly scheduled maintenance
3/27/2023 0.5 Weekly scheduled maintenance
4/3/2023 0.5 Weekly scheduled maintenance
4/8/2023 1 Monthly Maintenance generator check
4/10/2023 0.5 Weekly scheduled maintenance
4/17/2023 0.5 Weekly scheduled maintenance
4/24/2023 0.5 Weekly scheduled maintenance
5/1/2023 0.5 Weekly scheduled maintenance
5/6/2023 1 Monthly Maintenance generator check
5/8/2023 0.5 Weekly scheduled maintenance
5/15/2023 0.5 Weekly scheduled maintenance
5/22/2023 0.5 Weekly scheduled maintenance
5/29/2023 0.5 Weekly scheduled maintenance
6/3/2023 1 Monthly Maintenance generator check
6/5/2023 0.5 Weekly scheduled maintenance
6/12/2023 0.5 Weekly scheduled maintenance
6/19/2023 0.5 Weekly scheduled maintenance
6/26/2023 0.5 Weekly scheduled maintenance
7/1/2023 1 Monthly Maintenance generator check
7/3/2023 0.5 Weekly scheduled maintenance
7/10/2023 0.5 Weekly scheduled maintenance
7/17/2023 0.5 Weekly scheduled maintenance
7/24/2023 0.5 Weekly scheduled maintenance
7/29/2023 1 Monthly Maintenance generator check
7/31/2023 0.5 Weekly scheduled maintenance
8/7/2023 0.5 Weekly scheduled maintenance
8/14/2023 0.5 Weekly scheduled maintenance
8/21/2023 0.5 Weekly scheduled maintenance
8/26/2023 1 Monthly Maintenance generator check
8/28/2023 0.5 Weekly scheduled maintenance
9/4/2023 0.5 Weekly scheduled maintenance
9/11/2023 0.5 Weekly scheduled maintenance
9/18/2023 0.5 Weekly scheduled maintenance
9/23/2023 1 Monthly Maintenance generator check
9/25/2023 0.5 Weekly scheduled maintenance
10/2/2023 0.5 Weekly scheduled maintenance
10/9/2023 0.5 Weekly scheduled maintenance
10/16/2023 0.5 Weekly scheduled maintenance
10/21/2023 1 Monthly Maintenance generator check
10/23/2023 0.5 Weekly scheduled maintenance
10/30/2023 0.5 Weekly scheduled maintenance
11/6/2023 0.5 Weekly scheduled maintenance
11/13/2023 0.5 Weekly scheduled maintenance
11/19/2023 1 Monthly Maintenance generator check
11/20/2023 0.5 Weekly scheduled maintenance
11/27/2023 0.5 Weekly scheduled maintenance
12/4/2023 0.5 Weekly scheduled maintenance
12/11/2023 0.5 Weekly scheduled maintenance
12/18/2023 0.5 Weekly scheduled maintenance
12/25/2023 0.5 Weekly scheduled maintenance
Permit
Reference
Permit Limitation
10.
Emergency generators shall be used for electricity producing operation only during the periods
when electric power from public utilities is interrupted, or for regular maintenance of the
generators. Records documenting generator usage shall be kept in a log and they shall show the
date the generator was used, the duration in hours of the generator usage, and the reason for each
generator usage.
Date the
Generator Was
Used
Duration in Hours
of the Generator
Usage The Reason for Generator Usage