DAQ-2025-001831

DAQE-AN119490006-25

{{$d1 }}

Corene Lewis
Schreiber Foods Incorporated
2180 West 6550 North
Smithfield, UT 84335
[e-mail]

Dear Corene Lewis:

Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN0119490005-11 for a
10-Year Review and Permit Updates
Project Number: N119490006

The attached Approval Order (AO) is issued pursuant to the Division of Air Quality conducting a 10-year
administrative review of this source and its respective AO. Schreiber Foods Incorporated must comply
with the requirements of this AO, all applicable state requirements (R307), and Federal Standards.

The project engineer for this action is Christine Bodell, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as the
DAQE number shown on the upper right-hand corner of this letter.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:CB:jg

cc: Bear River Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Tim Davis
Interim Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

March 27, 2025

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN119490006-25
Administrative Amendment to Approval Order
DAQE-AN0119490005-11 for a 10-Year Review
and Permit Updates

Prepared By
Christine Bodell, Engineer
[phone]
[e-mail]

Issued to
Schreiber Foods Incorporated - Smithfield Cheese Packing Facility

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

March 27, 2025
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-AN119490006-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Schreiber Foods Incorporated Schreiber Foods Incorporated - Smithfield Cheese Packing Facility

Mailing Address Physical Address
2180 West 6550 North 2180 West 6550 North
Smithfield, UT 84335 Smithfield, UT 84335

Source Contact UTM Coordinates
Name: Corene Lewis 426,350 m Easting
Phone: [phone],633,400 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 2022 (Cheese - Natural, Processed & Imitation)

SOURCE INFORMATION
General Description
Schreiber Foods Incorporated (Schreiber Foods) owns and operates a cheese production and packaging
operations facility in Smithfield, Cache County. Raw cheese ingredients and milk arrive on site via trucks.
The materials are ground, blended, and cooked. The product is wrapped, sealed, and packaged for
shipment and/or storage. The two (2) boilers on site are used for heating, cleaning, and milk
pasteurization.

NSR Classification
10-Year Review

Source Classification
Located in Attainment Area
Cache County
Airs Source Size: B

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
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), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
DAQE-AN119490006-25
Page 4

Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Area Source

Project Description
This administrative amendment is to AO DAQE-AN0119490005-11, dated January 24, 2011. The DAQ
is conducting a 10-year review and is updating the language and format. There are no changes to the
operations taking place at the Schreiber Foods Smithfield Cheese Packing Facility.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 61864.00
Carbon Monoxide 0 42.96
Nitrogen Oxides 0 52.88
Particulate Matter - PM10 0 17.20
Particulate Matter - PM2.5 0 17.20
Sulfur Dioxide 0 0.31
Volatile Organic Compounds 0 2.81

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 1940
Change (TPY) Total (TPY)
Total HAPs 0 0.97

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]
DAQE-AN119490006-25
Page 5

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]

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT II.A.1 Smithfield Cheese Packing Facility
II.A.2 Dual-Fuel Boiler #1 Burner Rating: 50.0 MMBtu/hr Burner Manufacturer: Limpsfield Controls: Low NOx burners & flue gas recirculation II.A.3 Dual-Fuel Boiler #2 Heat Input Rate: 60.6 MMBtu/hr Manufacturer: Cleaver Brooks Model Number: DL60L,H Manufacture & Installation Date: 1990, 1992
II.A.4 Whey Drying Oven Heat Input Rate: 7.242 MMBtu/hr Manufacturer: Sweeney (evaporator), Maxon (duct burner) Manufacture& Installation Date: 1976 II.A.5 One (1) Emergency Electrical Generator Engine Rating: 25 kW Fuel: Diesel fuel
II.A.6 Two (2) Degreasers Size: <10 square feet, each II.A.7 Miscellaneous Sources #2 oil underground storage tank, wastewater 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.

DAQE-AN119490006-25
Page 6

SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements:
II.B.1.a The owner/operator shall not consume more than 1,043,383 MMBtu of natural gas per rolling
12-month period. [R307-401-8]

II.B.1.a.1 The owner/operator shall: A. Determine consumption by direct metering of the owner/operator's gas-fired equipment B. Record consumption on a monthly basis C. Use the consumption data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the consumption records for all periods the plant is in operation. [R307-401-8]
II.B.1.b The owner/operator shall not produce more than 17,520 tons of whey per rolling 12-month
period. [R307-401-8]

II.B.1.b.1 The owner/operator shall: A. Determine production by sales records of final product shipped B. Record production on a daily basis C. Use the production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the production records for all periods the plant is in operation. [R307-401-8]
II.B.1.c The owner/operator shall not allow visible emissions from any stationary point or fugitive
emission source associated with the source or with the control facilities to exceed the following
values:

A. 10% opacity when burning natural gas

B. 20% opacity when burning fuel oil during natural gas curtailment.

[R307-401-8]

II.B.1.c.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.1.d The owner/operator shall comply with all applicable requirements of Utah Administrative Code
Rule R307-335: Degreasing. [R307-335]
DAQE-AN119490006-25
Page 7

II.B.1.e The owner/operator shall comply with all applicable requirements of Utah Administrative Code Rule R307-351: Graphic Arts and Rule R307-344: Paper, Film, and Foil Coatings if the owner/operator increases the use of VOC-containing materials, coating products, or solvents such that the rules become applicable to the facility. [R307-401-8]
II.B.2 Boiler and Oven Stack Requirements:
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] 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 whey dryer stacks shall vent vertically unrestricted with no obstruction beyond
the opening of the stack. [R307-401-8]
II.B.3 Fuel Requirements:
II.B.3.a The owner/operator shall use natural gas as the primary fuel in all boilers and in the whey drying
oven. [R307-401-8]
II.B.3.b The owner/operator shall limit fuel oil usage in all dual-fuel boilers to 48 hours each, per rolling 12-month period for periodic testing, maintenance, or operator training. There is no time limit on the use of fuel oil in the dual-fuel boilers during periods of natural gas curtailment, gas supply interruption, or startups. [40 CFR 63 Subpart JJJJJJ, R307-401-8]
II.B.3.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
documenting fuel oil usage in each dual-fuel boiler shall be kept in a log and shall include the
following:
A. The date fuel oil was used
B. The duration of operation in hours

C. The reason for fuel oil usage.
[40 CFR 63 Subpart JJJJJJ, R307-401-8]

II.B.3.c The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in the emergency engine. [R307-401-8]
II.B.3.d The owner/operator shall only combust diesel fuel in the boilers and emergency engine that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or
less. [40 CFR 60 Subpart IIII, R307-401-8]

II.B.3.d.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]
II.B.4 Emergency Electrical Generator Engine Requirements:
II.B.4.a The owner/operator shall not operate the 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 engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
DAQE-AN119490006-25
Page 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 the 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] II.B.4.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN0119490005-11 dated January 24, 2011
DAQE-AN119490006-25
Page 9

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-

RN119490006 March 11, 2025 Corene Lewis
Schreiber Foods Incorporated 2180 West 6550 North Smithfield, UT 84335
[e-mail] Dear Corene Lewis,
Re: Engineer Review - 10-Year Review and Permit Updates: Administrative Amendment to Approval Order DAQE-AN0119490005-11 for a 10-Year Review and Permit Updates Project Number: N119490006 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review (NSR) permitting program. Schreiber Foods Incorporated should complete this review within 10 business days of receipt. Schreiber Foods Incorporated should contact Christine Bodell at [phone] if there are questions or
concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Christine Bodell at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director. If Schreiber Foods Incorporated does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Schreiber Foods Incorporated has concerns that cannot be
resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of Environmental Quality
Tim Davis Interim Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N119490006: Schreiber Foods Incorporated- Smithfield Cheese Packing Facility March 11, 2025 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N119490006 Owner Name Schreiber Foods Incorporated Mailing Address 2180 West 6550 North
Smithfield, UT, 84335 Source Name Schreiber Foods Incorporated- Smithfield Cheese Packing
Facility Source Location 2180 West 6550 North Smithfield, UT 84335
UTM Projection 426,350 m Easting, 4,633,400 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 2022 (Cheese - Natural, Processed & Imitation) Source Contact Corene Lewis Phone Number [phone] Email [e-mail] Billing Contact Corene Lewis
Phone Number [phone] Email [e-mail]
Project Engineer Christine Bodell, Engineer Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted December 27, 2024 Date of Accepted Application December 27, 2024

Engineer Review N119490006: Schreiber Foods Incorporated- Smithfield Cheese Packing Facility March 11, 2025 Page 2
SOURCE DESCRIPTION General Description
Schreiber Foods Incorporated (Schreiber Food) owns and operates a cheese production and packaging operations facility in Smithfield, Cache County. Raw cheese ingredients and milk arrive on site via trucks. The materials are ground, blended, and cooked. The product is wrapped,
sealed, and packaged for shipment and/or storage. The two boilers on site are used for heating, cleaning, and milk pasteurization. NSR Classification: 10 Year Review Source Classification Located in Attainment Area Cache County Airs Source Size: B
Applicable Federal Standards NSPS (Part 60), A: General Provisions 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), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Title V (Part 70) Area Source Project Proposal
Administrative Amendment to Approval Order DAQE-AN0119490005-11 for a 10-Year Review and Permit Updates Project Description This administrative amendment is to Approval Order DAQE-AN0119490005-11, dated January 24, 2011. The DAQ is conducting a 10-year review and is updating the language and format. There are no changes to the operations taking place at the Schreiber Food Smithfield Cheese Packing Facility.
EMISSION IMPACT ANALYSIS This is a 10-Year Review. No changes to equipment or emissions are being made at this time. Therefore, modeling is not required. [Last updated December 27, 2024]

Engineer Review N119490006: Schreiber Foods Incorporated- Smithfield Cheese Packing Facility March 11, 2025 Page 3
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 0 61864.00 Carbon Monoxide 0 42.96
Nitrogen Oxides 0 52.88
Particulate Matter - PM10 0 17.20
Particulate Matter - PM2.5 0 17.20
Sulfur Dioxide 0 0.31
Volatile Organic Compounds 0 2.81 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 1940
Change (TPY) Total (TPY)
Total HAPs 0 0.97

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N119490006: Schreiber Foods Incorporated- Smithfield Cheese Packing Facility March 11, 2025 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding 10 Year Review
This is a 10-Year Review. No changes to equipment or emissions are being made at this time. Therefore, a BACT analysis is not required. [Last updated December 27, 2024]
SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label):
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]

Engineer Review N119490006: Schreiber Foods Incorporated- Smithfield Cheese Packing Facility March 11, 2025 Page 5
SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT
II.A.1 Smithfield Cheese Packing Facility
II.A.2 Dual-Fuel Boiler #1 Burner Rating: 50.0 MMBtu/hr Burner Manufacturer: Limpsfield Controls: Low NOx burners & flue gas recirculation II.A.3 Dual-Fuel Boiler #2 Heat Input Rate: 60.6 MMBtu/hr
Manufacturer: Cleaver Brooks Model Number: DL60L,H Manufacture & Installation Date: 1990, 1992

II.A.4 Whey Drying Oven Heat Input Rate: 7.242 MMBtu/hr Manufacturer: Sweeney (evaporator), Maxon (duct burner)
Manufacture& Installation Date: 1976
II.A.5 One (1) Emergency Electrical Generator Engine Rating: 25 kW
Fuel: Diesel fuel

II.A.6 NEW Two (2) Degreasers Size: <10 square feet, each
II.A.7 Miscellaneous Sources
#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

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label):
II.B REQUIREMENTS AND LIMITATIONS II.B.1 NEW Site-Wide Requirements:

Engineer Review N119490006: Schreiber Foods Incorporated- Smithfield Cheese Packing Facility March 11, 2025 Page 6
II.B.1.a NEW The owner/operator shall not consume more than 1,043,383 MMBtu of natural gas per rolling 12-month period. [R307-401-8]
II.B.1.a.1 NEW The owner/operator shall: A. Determine consumption by direct metering of the owner/operator's
gas-fired equipment.
B. Record consumption on a monthly basis C. Use the consumption data to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months
D. Keep the consumption records for all periods the plant is in operation
[R307-401-8]
II.B.1.b NEW The owner/operator shall not produce more than 17,520 tons of whey per rolling 12-month period. [R307-401-8] II.B.1.b.1 NEW The owner/operator shall: A. Determine production by sales records of final product shipped B. Record production on a daily basis
C. Use the production data to calculate a new rolling 12-month total by the 20th day
of each month using data from the previous 12 months D. Keep the production records for all periods the plant is in operation
[R307-401-8]
II.B.1.c NEW The owner/operator shall not allow visible emissions from any stationary point or fugitive emission source associated with the source or with the control facilities to exceed the following values:
A. 10% opacity when burning natural gas B. 20% opacity when burning fuel oil during natural gas curtailment. [R307-401-8]
II.B.1.c.1 NEW Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.1.d NEW The owner/operator shall comply with all applicable requirements of Utah Administrative Code Rule R307-335: Degreasing. [R307-335]

Engineer Review N119490006: Schreiber Foods Incorporated- Smithfield Cheese Packing Facility March 11, 2025 Page 7
II.B.1.e NEW The owner/operator shall comply with all applicable requirements of Utah Administrative Code Rule R307-351: Graphic Arts and Rule R307-344: Paper, Film, and Foil Coatings if the owner/operator increases the use of VOC-containing materials, coating products, or solvents
such that the rules become applicable to the facility. [R307-401-8] II.B.2 NEW Boiler and Oven Stack Requirements:
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] II.B.2.b NEW The height of the whey dryer stacks shall be no less than 81 feet, as measured from the base of the building. The whey dryer stacks shall vent vertically unrestricted with no obstruction beyond the opening of the stack. [R307-401-8] II.B.3 NEW Fuel Requirements:
II.B.3.a NEW The owner/operator shall use natural gas as the primary fuel in all boilers and in the whey drying oven. [R307-401-8]

II.B.3.b NEW The owner/operator shall limit fuel oil usage in all dual-fuel boilers to 48 hours each, per rolling 12-month period for periodic testing, maintenance, or operator training. There is no time limit on the use of fuel oil in the dual-fuel boilers during periods of natural gas
curtailment, gas supply interruption, or startups. [40 CFR 63 Subpart JJJJJJ, R307-401-8] II.B.3.b.1 NEW 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 fuel oil usage in each dual-fuel boiler shall be kept in a log and shall include the following: A. The date fuel oil was used B. The duration of operation in hours
C. The reason for fuel oil usage
[40 CFR 63 Subpart JJJJJJ, R307-401-8]

II.B.3.c NEW The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the emergency engine. [R307-401-8]
II.B.3.d NEW The owner/operator shall only combust diesel fuel in the boilers and emergency engine that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm
or less. [40 CFR 60 Subpart IIII, R307-401-8] II.B.3.d.1 NEW 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]

Engineer Review N119490006: Schreiber Foods Incorporated- Smithfield Cheese Packing Facility March 11, 2025 Page 8
II.B.4 NEW Emergency Electrical Generator Engine Requirements:
II.B.4.a NEW The owner/operator shall not operate the 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 engine during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.4.a.1 NEW 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 the 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]
II.B.4.a.2
NEW
To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency engine. [R307-401-8, 40 CFR 63 Subpart ZZZZ]

Engineer Review N119490006: Schreiber Foods Incorporated- Smithfield Cheese Packing Facility March 11, 2025 Page 9
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-AN0119490005-11 dated January 24, 2011
REVIEWER COMMENTS
1. Comment regarding 10 Year Review:
The formatting, language, and primary contact of Approval Order DAQE-AN0119490005-11, dated January 14, 2011, have been updated. The 2011 AO did not specify PTEs for CO2e or HAPs. It is assumed the CO2e and HAPs are primarily released from combustion units on site. The total natural gas consumption limit (Condition
II.B.1.a.(A) in the 2011 AO) is based on 8,760 hours of annual operation for all of the natural gas-fired equipment. Therefore, emissions from the boilers, drying oven, and water heater were estimated using 8,760 hours of annual operation and emission factors in AP-42, Chapter 1.4 (Natural Gas Combustion). Emissions from the emergency engine were estimated assuming 100 hours of annual non-emergency use and emission factors in AP-42, Chapter 3.3 (Gasoline And Diesel Industrial Engines).
No changes in equipment or operations are taking place at the facility. The site-wide emission
estimates should be updated when the source applies for a modification in the future.
During the review process, DAQ evaluated the applicability of UAC rules R307-335 (Degreasing), R307-351 (Graphic Arts), and R307-344 (Paper, Film, and Foil Coatings), as the facility is located in Cache County. Schreiber confirmed that R307-335 does apply to the facility as Schreiber uses solvent-based parts degreasers. However, the volatility of the materials used is less than 0.1 mmHg @ 20 degrees
Celsius. Therefore, a control device is not required. Because this rule is applicable to the source, the degreasers in the equipment list have been moved to a separate section in the updated AO, as the degreasers are no longer considered "miscellaneous equipment".
Schreiber confirmed that R307-351 does not apply to the facility because Schreiber uses less than a
combined 450 gallons or more of all VOC-containing materials per year.
Schreiber confirmed that R307-344 does not apply to the facility because Schreiber uses less than a combined 20 gallons or more of coating products and associated solvents per year. [Last updated March 6, 2025] 2. Comment regarding Federal Subpart Applicability: NSPS Subpart Dc 40 CFR 60 (NSPS) Subpart Dc applies to owners/operators of steam generating unit that has a maximum design heat input capacity of 100 MMBtu/hr or less, but greater than or equal to 10 MMBtu/hr. Steam generating unit means a device that combusts any fuel and produces steam or heats water or heats any heat transfer medium. All of the boilers that the source operates are larger than 10 MMBtu/hr. Therefore, NSPS Subpart Dc applies to this facility.

Engineer Review N119490006: Schreiber Foods Incorporated- Smithfield Cheese Packing Facility March 11, 2025 Page 10
NSPS Subpart IIII 40 CFR 60 Subpart IIII applies to owners and operators of Stationary Compression-Ignition Internal Combustion Engines (CI ICE) that commence construction after July 11, 2005, where the stationary CI ICE is manufactured after April 1, 2006. The diesel-fired CI ICE on site was constructed after this date. Therefore, NSPS Subpart IIII applies to the engine on site. MACT Subpart ZZZZ 40 CFR 63 Subpart ZZZZ (National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines) applies to owners and operators of stationary internal combustion engines (RICE) at an area source of HAP emissions. Therefore, MACT Subpart ZZZZ applies to the emergency engine on site.
MACT Subpart JJJJJJ 40 CFR 63 MACT Subpart JJJJJJ (National Emissions Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources) applies to industrial, commercial, or institutional boilers located at an area source of HAP emissions. The boilers on site are considered institutional boilers. While the boilers on site have the capacity to operate on fuel liquid fuel, they are considered gas-fired boilers as defined in 40 CFR 63.11237. A gas-fired boiler burns only gaseous fuels during normal operation and burns liquid fuel only during periods of gas curtailment, gas supply interruption, startups, or periodic testing on liquid fuel. Natural gas-fired boilers are not subject to MACT Subpart JJJJJJ or to any requirements in MACT Subpart JJJJJJ. Therefore, MACT Subpart JJJJJJ does not apply to the facility.
The dual-fuel boilers on site are permitted to operate on liquid fuel for up to 48 hours during any calendar year for periodic testing, maintenance, or operator training.
[Last updated February 25, 2025]
3. Comment regarding Title V Applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following:
1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants. 4. Any Title IV affected source. This facility is not a Title IV source or a major source. The facility is not subject to 40 CFR 61(NESHAP) regulations. It is subject to 40 CFR 60 (NSPS) Subparts A, Dc, and IIII and to 40 CFR 63 (MACT) Subparts A and ZZZZ. NSPS Subpart IIII and MACT Subpart ZZZZ each exempt sources from the obligation to obtain a Title V permit provided that the source is not required to obtain the permit for any other reason. No such reason exists. However, NSPS Subpart Dc does not
include this exemption. Boilers that have the capacity to operate on fuel oil are subject to certain standards and limitations under NSPS Subpart Dc. Therefore, Title V applies to this facility as an area source. [Last updated December 27, 2024]

Engineer Review N119490006: Schreiber Foods Incorporated- Smithfield Cheese Packing Facility March 11, 2025 Page 11
ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology
CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency
FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units
NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit
R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year
UAC Utah Administrative Code VOC Volatile organic compounds
Equipment Details
Rating 119 MMBtu/hour MMBtu/year 1,043,383
Operational Hours 8,760 hours/year hours of op 8,694.86 Firing Normal (based on 8,760 hours of op annually)
Criteria Pollutant
Concentration
(ppm)
Emission
Factor
(lb/10^6 scf)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
NOX 190 22.23 97.37
CO 84 9.83 43.05
PM10 7.6 0.89 3.89
PM2.5 7.6 0.89 3.89
SO2 0.6 0.07 0.31
VOC 5.5 0.64 2.82
Lead 0.0005 0.00 0.00
HAP 0.22 0.97 See Below
Green House Gas Pollutant
Global
Warming
Potential
Emission
Factor
(lb/10^6 scf)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
CO2 (mass basis)1 120,000 14,040 61,496
Methane (mass basis)25 2.3 0.27 1.18
N2O (mass basis)298 2.2 0.26 1.13
CO2e 61,862
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
2-Methylnaphthalene 2.40E-05 2.81E-06 1.23E-053-Methylchloranthrene 1.80E-06 2.11E-07 9.22E-07
7,12-Dimethylbenz(a)anthracene 1.60E-05 1.87E-06 8.20E-06
Acenaphthene 1.80E-06 2.11E-07 9.22E-07
Acenaphthylene 1.80E-06 2.11E-07 9.22E-07
Anthracene 2.40E-06 2.81E-07 1.23E-06
Benz(a)anthracene 1.80E-06 2.11E-07 9.22E-07Benzene2.10E-03 2.46E-04 1.08E-03
Benzo(a)pyrene 1.20E-06 1.40E-07 6.15E-07Benzo(b)fluoranthene 1.80E-06 2.11E-07 9.22E-07
Benzo(g,h,i)perylene 1.20E-06 1.40E-07 6.15E-07Benzo(k)fluoranthene 1.80E-06 2.11E-07 9.22E-07
Chrysene 1.80E-06 2.11E-07 9.22E-07
Dibenzo(a,h)anthracene 1.20E-06 1.40E-07 6.15E-07
Dichlorobenzene 1.20E-03 1.40E-04 6.15E-04
Fluoranthene 3.00E-06 3.51E-07 1.54E-06Fluorene2.80E-06 3.28E-07 1.43E-06
Formaldehyde 7.50E-02 8.78E-03 3.84E-02Hexane1.80E+00 2.11E-01 9.22E-01
Indeno(1,2,3-cd)pyrene 1.80E-06 2.11E-07 9.22E-07Naphthalene6.10E-04 7.14E-05 3.13E-04
Phenanathrene 1.70E-05 1.99E-06 8.71E-06Pyrene5.00E-06 5.85E-07 2.56E-06
Toluene 3.40E-03 3.98E-04 1.74E-03Arsenic2.00E-04 2.34E-05 1.02E-04
Beryllium 1.20E-05 1.40E-06 6.15E-06Cadmium1.10E-03 1.29E-04 5.64E-04
Chromium 1.40E-03 1.64E-04 7.17E-04
Cobalt 8.40E-05 9.83E-06 4.30E-05
Manganese 3.80E-04 4.45E-05 1.95E-04
Mercury 2.60E-04 3.04E-05 1.33E-04Nickel2.10E-03 2.46E-04 1.08E-03Selenium2.40E-05 2.81E-06 1.23E-05
AP-42 Table 1.4-4
Manufacturer
Dataor AP-42 Table
AP-42 Table 1.4-
2
Natural Gas-Fired Boilers & Heaters
AP-42 Table 1.4-
2&
Table A-1 toSubpart A of Part
AP-42 Table 1.4-3
Emission Factor
(lb/10^6 scf)
Page 1 of 3 Version 1.0
November 29, 2018
Equipment Details
Rating 34 hp = (25.4 kw)
Operational Hours 100 hours/yearSulfur Content 15 ppm or 0.0015%
Criteria Pollutant
Emission
Standards
(g/hp-hr)
Emission Factor
(lb/hp-hr)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
NOX 0.031 1.05 0.05
CO 6.68E-03 0.23 0.01
PM10 2.20E-03 0.07 0.00
PM2.5 2.20E-03 0.07 0.00
VOC 2.51E-03 0.09 0.00
SO2 1.21E-05 0.00 0.00 AP-42 Table 3.4-1
HAP 0.00 0.00 See Below
Green House Gas Pollutant
Global
Warming
Potential
Emission Factor
(lb/hp-hr)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
CO2 (mass basis)1 1.15 39 2
Methane (mass basis)25 0 0CO2e2
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
Benzene 9.33E-04 2.22E-04 1.11E-05
Toluene 4.09E-04 9.73E-05 4.87E-06
Xylenes 2.85E-04 6.78E-05 3.39E-061,3-Butadiene 3.91E-05 9.31E-06 4.65E-07
Formaldehyde 1.18E-03 2.81E-04 1.40E-05
Acetaldehyde 7.67E-04 1.83E-04 9.13E-06
Acrolein 9.25E-05 2.20E-05 1.10E-06
Naphthalene 8.48E-05 2.02E-05 1.01E-06
Acenaphthylene 5.06E-06 1.20E-06 6.02E-08
Acenaphthene 1.42E-06 3.38E-07 1.69E-08
Fluorene 2.92E-05 6.95E-06 3.47E-07
Phenanthrene 2.94E-05 7.00E-06 3.50E-07
Anthracene 1.87E-06 4.45E-07 2.23E-08
Fluoranthene 7.61E-06 1.81E-06 9.06E-08
Pyrene 4.78E-06 1.14E-06 5.69E-08
Benz(a)anthracene 1.68E-06 4.00E-07 2.00E-08
Chrysene 3.53E-07 8.40E-08 4.20E-09
Benzo(b)fluoranthene 9.91E-08 2.36E-08 1.18E-09
Benzo(k)fluoranthene 1.55E-07 3.69E-08 1.84E-09
Benzo(a)pyrene 1.88E-07 4.47E-08 2.24E-09
Indeno(1,2,3-cd)pyrene 3.75E-07 8.93E-08 4.46E-09
Dibenz(a,h)anthracene 5.83E-07 1.39E-07 6.94E-09
Benzo(g,h,l)perylene 4.89E-07 1.16E-07 5.82E-09
AP-42 Table 3.3-2,
Table 3.4-3, &
Table 3.4-4
(1,3-Butadiene will
not popluate if the
engine size is greater
than 600 hp. AP-42 does not list 1,3-
Butadiene for engines
greater than 600 hp.)
Diesel-Fired Engines
AP-42 Table 3.3-1
& Table 3.4-1
Manufacturer Data,
AP-42 Table 3.3-1,
& Table 3.4-1
Emission Factor
(lb/MMBtu)
Emergency Engines should equal 100 hours of operation per year
Page 2 of 3 Version 1.1February 21, 2019
CO2e 61,864
HAPs 0.97
Christine Bodell <[e-mail]>
Utah Division of Air Quality - Approval Order Inquiry
Corene Lewis <[e-mail]>Sat, Dec 21, 2024 at 3:04 PM
To: Christine Bodell <[e-mail]>
Christine
I have reviewed with my team and no changes are needed.
Please let me know if you have any questions or need any more information.
Thank you
Corene Lewis
660-223-6148
From: Chrisne Bodell <[e-mail]>
Sent: Wednesday, December 11, 2024 9:04:18 AM
To: Corene Lewis <[e-mail]>
Subject: Utah Division of Air Quality - Approval Order Inquiry

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