DAQ-2024-009606

DAQE-GN159490004-24

{{$d1 }}

James Webb
Align RNG Utah-Milford, LLC
2822 Highway, NC-24 West
Warsaw, NC 28398
[e-mail]

Dear Mr. Webb:

RE: Revocation of Approval Order (AO) DAQE-AN159490002-19 dated December 11, 2019
Project Number: N159490004

The Division of Air Quality (DAQ) received your request to revoke AO DAQE-AN159490002-19 on
July 12, 2024. Align RNG Utah-Milford, LLC requested this AO be revoked due to the facility
permanently ceasing operations. The DAQ has revoked the above-referenced AO effective as of the date
of this letter.

As authorized by the Utah Legislature, the fee for revoking an AO is the actual time spent by the review
engineer and all other staff on the project. Payment should be made to the DAQ upon receipt of the
invoice.

If you have any questions, please contact Lucia Mason, who can be reached at [phone] or
[e-mail].

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:LM:jg

cc: EPA Region 8
Southwest Utah Public Health Department
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#s=Sig_es_:signer1:signature}}

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

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

July 26, 2024

DAQE-AN159490002-19

December 11, 2019

James Webb
Murphy Brown LLC dba Smithfield Foods, Inc.
341 South Main
P.O. Box 100
Milford, UT 84751

Dear Mr. Webb:

Re: Approval Order:
New Hog Farming and Biogas Operation
Project Number: N159490002

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on March 27,
2019. Murphy Brown LLC dba Smithfield Foods, Inc. must comply with the requirements of this AO, all
applicable state requirements (R307), and Federal Standards.

The project engineer for this action is Ana Williams, 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. No public comments were
received on this action.

Sincerely,

Signed by Bryce C. Bird on December 11, 2019

Bryce C. Bird
Director

BCB:AW:sa

cc: Southwest Utah Public 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

GARY R. HERBERT
Governor

SPENCER J. COX
Lieutenant Governor

Department of
Environmental Quality

L. Scott Baird
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

APPROVAL ORDER
DAQE-AN159490002-19
New Hog Farming and Biogas Operation

Prepared By
Ana Williams, Engineer
[phone]
[e-mail]

Issued to
Murphy Brown LLC dba Smithfield Foods, Inc. - Milford Biogas Facility

Signed by Bryce C. Bird on December 11, 2019

Issued By
Bryce C. Bird
Director
Division of Air Quality

Date: December 11, 2019

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.................................................................................................................. 3
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 5
PERMIT HISTORY ..................................................................................................................... 6
ACRONYMS ................................................................................................................................. 7

DAQE-AN159490002-19
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Murphy Brown LLC dba Smithfield Foods, Inc. Murphy Brown LLC dba Smithfield Foods,
Inc.- Milford Biogas Facility

Mailing Address Physical Address
341 South Main, P.O. Box 100 2804 E. Breezy Drive
Milford, UT 84751 Milford, UT 84751

Source Contact UTM Coordinates
Name James Webb 330,499 m Easting
Phone [phone],264,211 m Northing
Email [e-mail] Datum NAD83
UTM Zone 12
SIC code 0213 (Hogs)

SOURCE INFORMATION

General Description
Murphy Brown LLC dba Smithfield Foods, Inc. (Smithfield) has requested a new AO for a new hog
farming and biogas operation located north of Milford. Smithfield is constructing a hog farming
operation, which will include a renewable natural gas process. Smithfield will gather manure from the
livestock barns, process the manure in 26 anaerobic digesters, and sell the resulting biogas as renewable
natural gas. The central biogas treatment process will be located in Beaver County, while the 26 anaerobic
digesters will be located in both Millard and Beaver Counties.

NSR Classification
New Minor Source

Source Classification
Located in Attainment Area
Beaver County
Airs Source Size: SM

Applicable Federal Standards
None

Project Description
Smithfield will operate a new hog farming and biogas operation located north of Milford. Smithfield is
constructing a hog farming operation, which will include a renewable natural gas process. Smithfield will
gather manure from the livestock barns, process the manure in 26 anaerobic digesters, and sell the
DAQE-AN159490002-19
Page 4

resulting biogas as renewable natural gas. Manure will be deposited into the digesters and naturally-
occurring bacteria in the digesters will break down the material, generating biogas. This biogas will then
be collected and sent to a central location to be treated with a membrane system. This membrane system
will separate the biogas into renewable natural gas and sour gas (tail gas). The renewable natural gas will
be compressed and delivered to a pipeline for sale. The tail gas will be sent to a thermal oxidizer.
Smithfield will produce up to 438 million standard cubic feet (MMscf) of biogas per year. The central
biogas treatment process will be located in Beaver County, while the 26 anaerobic digesters will be
located in both Millard and Beaver Counties.

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 26851.00
Carbon Monoxide 5.76
Nitrogen Oxides 8.61
Particulate Matter - PM10 0.30
Particulate Matter - PM2.5 0.30
Sulfur Dioxide 87.96
Volatile Organic Compounds 2.92

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 2
Hexane (CAS #110543) 39
Change (TPY) Total (TPY)
Total HAPs 0.02

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-AN159490002-19
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]

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]

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Murphy Brown LLC dba Smithfield Foods, Inc
Milford Biogas Facility

II.A.2 Twenty-Six (26) Anaerobic Digesters
Contents: Raw Manure
Capacity: 16.848 MMscf/yr biogas (each)
Control: Membrane Skid System

II.A.3 Three (3) Membrane Skids
Maximum Capacity: 700 scfm
Tail Gas Control: Thermal Oxidizer

II.A.4 One (1) Thermal Oxidizer
Fuel: Tail Gas and Natural Gas

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements and Limitations
II.B.1.a The owner/operator shall not allow visible emissions from the thermal oxidizer to exceed 10%
opacity. [R307-401-8]

DAQE-AN159490002-19
Page 6

II.B.1.a.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.b The owner/operator shall not produce more than 438 million standard cubic feet (MMscf) of
biogas per rolling 12-month period. [R307-401-8]

II.B.1.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 biogas production shall be kept for all periods when the plant is in operation. Biogas
production shall be determined by process flow meters and/or sales records. [R307-401-8]

II.B.1.c The owner/operator shall not combust more than 157 million standard cubic feet (MMscf) of tail
gas in the thermal oxidizer per rolling 12-month period. [R307-401-8]

II.B.1.c.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 tail gas combustion shall be kept for all periods when the plant is in operation. Tail gas
combustion shall be determined by process flow meters. [R307-401-8]

II.B.1.d The owner/operator shall not exceed an H2S concentration of 7,000 ppmv in the tail gas sent to
the thermal oxidizer at all times. [R307-401-8]

II.B.1.d.1 The owner/operator shall monitor and record the tail gas H2S concentration once daily, while the
thermal oxidizer is operating. [R307-401-8]

II.B.1.d.2 The owner/operator shall monitor the H2S concentration in the tail gas with equipment located
such that an inspector/operator can safely read the output at any time. [R307-401-8]

II.B.1.d.3 The owner/operator shall calibrate all instruments according to the manufacturer's instructions at
least once every 12 months. [R307-401-8]

II.B.1.e The owner/operator shall control tail gas from the membrane skid system with the thermal
oxidizer at all times while the membrane skid system is operating. Tail gas from the membrane
skid system shall be routed through the thermal oxidizer before being discharged to the
atmosphere. [R307-401-8]

II.B.1.f At all times while operating the membrane skid system, the owner/operator shall maintain a
temperature at or above 1,400oF in the thermal oxidizer. [R307-401-8]

II.B.1.f.1 The owner/operator shall monitor and record the operating temperature of the thermal oxidizer
on a daily basis, while the thermal oxidizer is operating. [R307-401-8]

II.B.1.f.2 The owner/operator shall monitor the operating temperature with equipment located such that an
inspector/operator can safely read the output at any time. [R307-401-8]

II.B.1.f.3 The owner/operator shall calibrate all instruments according to the manufacturer's instructions at
least once every 12 months. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Is Derived From NOI dated March 27, 2019
Incorporates Additional Information dated June 19, 2019

DAQE-AN159490002-19
Page 7

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

Lucia Mason <[e-mail]>
AO Revocation Address Confirmation, 15949 (Division of Air Quality)
4 messages
Lucia Mason <[e-mail]>Thu, Jul 18, 2024 at 9:51 AM
To: [e-mail]
Hi Jim,
I'm working on your AO Revocation Letter. Before I finalize it, can you either confirm that the following is the best company mailing address or provide an updated
address?
Align RNG Utah-Milford, LLC
2822 Hwy. NC-24 West
Warsaw, NC 28398
Thanks,
Lucia
Webb, Jim <[e-mail]>Fri, Jul 19, 2024 at 5:41 AM
To: Lucia Mason <[e-mail]>
That address is to our corporate headquarters. It will eventually make it to me, but it will take a while, that is why the bill is so late. Can you send a hard copy to the
headquarters and email me a copy of the letter?

Jim Webb
Senior Director, SFD Renewables
p: [phone] x46046 c: [phone]
e: [e-mail]
341 S Main St
Milford, Utah 84751
smithfieldfoods.com
[Quoted text hidden]
[Quoted text hidden]
7/22/24, 8:09 AM State of Utah Mail - AO Revocation Address Confirmation, 15949 (Division of Air Quality)
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r4410266486438921828&simpl=msg-a:r4083074667801543708&simpl=msg-f:1805007537706744966&simpl=…1/2
This communication (including any attachments) is confidential and is intended to be privileged pursuant to applicable law. If you are not the intended recipient, or the employee or agent responsible
for delivering it to the intended recipient, then you are hereby notified that the dissemination, distribution or copying of this communication is prohibited. If you received this communication in error,please notify Smithfield Foods, Inc. immediately by telephone [phone]) and then delete this communication and destroy all copies thereof.
Lucia Mason <[e-mail]>Mon, Jul 22, 2024 at 7:21 AM
To: "Webb, Jim" <[e-mail]>
Sounds good. We'll keep the address as is and I'll email you a copy once the Revocation Letter is approved.
[Quoted text hidden]
Webb, Jim <[e-mail]>Mon, Jul 22, 2024 at 7:30 AM
To: Lucia Mason <[e-mail]>
Thank you

Jim Webb
Senior Director, SFD Renewables
p: [phone] x46046 c: [phone]
e: [e-mail]
341 S Main St
Milford, Utah 84751
smithfieldfoods.com

From: Lucia Mason <[e-mail]>
Sent: Monday, July 22, 2024 7:21 AM
To: Webb, Jim <[e-mail]>
Subject: Re: AO Revocaon Address Confirmaon, 15949 (Division of Air Quality)

Sounds good. We'll keep the address as is and I'll email you a copy once the Revocation Letter is approved. On Fri, Jul 19, 2024 at 5: 42 AM Webb, Jim <jwebb@ smithfield. com> wrote: That address is to our corporate headquarters. 
[Quoted text hidden]
[Quoted text hidden]
7/22/24, 8:09 AM State of Utah Mail - AO Revocation Address Confirmation, 15949 (Division of Air Quality)
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r4410266486438921828&simpl=msg-a:r4083074667801543708&simpl=msg-f:1805007537706744966&simpl=…2/2
Lucia Mason <[e-mail]>
Fwd: Smithfield Biogas AO
3 messages
Alan Humpherys <[e-mail]>Wed, Jul 17, 2024 at 8:03 AM
To: Lucia Mason <[e-mail]>
Lucia,
Can you please process this AO revocation?
Site ID: 15949
Peer: Dungan
Thanks,
Alan
---------- Forwarded message ---------
From: Webb, Jim <[e-mail]>
Date: Fri, Jul 12, 2024 at 9:17 AM
Subject: Smithfield Biogas AO
To: [e-mail] <[e-mail]>
Cc: Webb, Jim <[e-mail]>
Alan,
I was directed to you from somebody on the phone when I called in to help with my issue. I have two issues that I need
help with.

The first issue is that we own a biogas plant which has an air permit associated with it. I have attached the AO(DAQE-
AN159490002-19). We have not run the plant since December of 2023. We have decided to shut down the plant and
therefore we would like to cancel the permit.

The second issue is that we have received a bill for NSR 2024 annual fee. Since we have not run the plant at all this year
and If we cancel the permit do we still need to pay the fee? It looks like the fee is for emissions for 2024? I have attached
the bill.

Can you please direct me as to what we need to do. Happy to discuss over the phone as well if that would be easier.
Thanks for your help.

7/17/24, 10:38 AM State of Utah Mail - Fwd: Smithfield Biogas AO
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1804835280539466857&simpl=msg-f:18048352805394668…1/2
Jim Webb
Senior Director, SFD Renewables
p: [phone] x46046 c: [phone]
e: [e-mail]
341 S Main St
Milford, Utah 84751
smithfieldfoods.com

This communication (including any attachments) is confidential and is intended to be privileged pursuant to applicable law. If you are not the
intended recipient, or the employee or agent responsible for delivering it to the intended recipient, then you are hereby notified that thedissemination, distribution or copying of this communication is prohibited. If you received this communication in error, please notify Smithfield Foods,
Inc. immediately by telephone [phone]) and then delete this communication and destroy all copies thereof.
--
Alan Humpherys
Manager | Minor NSR Section
P: [phone]
F: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
2 attachments
Milford - UDEQ Air Approval Order (Permit) - 12.11.19.pdf
104K
SKM_C750i17121015320.pdf
156K
Lucia Mason <[e-mail]>Wed, Jul 17, 2024 at 8:24 AM
To: Alan Humpherys <[e-mail]>
Sounds good. Do I have to do anything related to the billing?
[Quoted text hidden]
Alan Humpherys <[e-mail]>Wed, Jul 17, 2024 at 9:10 AM
To: Lucia Mason <[e-mail]>
No, you don't have to worry about the billing. I've already addressed that with him.
[Quoted text hidden]
7/17/24, 10:38 AM State of Utah Mail - Fwd: Smithfield Biogas AO
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-f:1804835280539466857&simpl=msg-f:18048352805394668…2/2