DAQ-2025-002120

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DAQC-CI140240001-25
Site ID 14024 (B1)

MEMORANDUM

TO: FILE – WEST LIBERTY FOODS L.L.C. – Tremonton Food Preparation Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Daniel Riddle, Environmental Scientist

DATE: April 7, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Box Elder County

INSPECTION DATE: February 5, 2025

SOURCE LOCATION: 845 North 2000 West
Tremonton, UT 84337
SOURCE CONTACTS: Michele Boney, Director of Sustainability
319-627-6144 [e-mail]

OPERATING STATUS: Operating normally at the time of inspection.

PROCESS DESCRIPTION: Food processing plant. Fresh and frozen meat and poultry is
trucked into the facility. Frozen meat is thawed and stored in
coolers. The meat is ground up, blended with ingredients, and
emulsified. It is then stuffed into casings and other packaging
materials to be cooked. Once the cooking processes have been
completed, the product is chilled. Casings are treated and
stripped from the product in preparation for the oil brown
process (frying). Then the product is nitrogen-cooled and ready
for slicing. After slicing, it is molded into packages and labeled.
It is sent through a metal detector and packaged into shipping
containers for shipment. Chicken products may be ground,
blended with various ingredients, cooked, and seared prior to the
quick freeze process and packaging. Sliced meat and chicken
pieces are shipped to Costco, Walmart, Arby’s, McDonalds, and
other outlets. Cold storage is provided by a neighboring
business.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN140240016-23, dated August 9,
2023
NSPS (Part 60) Dc: Standards of Performance for Small
Industrial-Commercial-Institutional Steam Generating Units,

) $ ' $ '
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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

West Liberty Foods L.L.C.- Tremonton Food
Preparation Plant

PO Box 318 207 West Second Street 845 North 2000 West
West Liberty, IA 52776 Tremonton, UT 84337

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]
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.

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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. This AO update was written to include the Charmarker in Condition II.A.26. The source wrote this statement on February 11, 2025. "The Charmarker II.A.26 that this AO was created for is now in storage and not being used. Our market has changed and we needed to remove the equipment." See the attached email correspondence for more information.

Section II: SPECIAL PROVISIONS

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

II.A.1 Tremonton Food Preparation Plant
II.A.2 One (1) 4 MMBtu/hr Boiler Heat input rate: 4MMBtu/hr Fuel: Natural gas
II.A.3 One (1) 32.6 MMBtu/hr Steam Boiler Heat input rate: 32.6 MMBtu per hour Fuel: Natural Gas NSPS Applicability: 40 CFR 60 Subpart Dc
II.A.4 Three (3) 5.6 MMBtu/hr Direct Contact Heaters Heat input rate: 5.6 MMBtu per hour each Fuel: Natural Gas
II.A.5 One (1) 12 MMBtu/hr Thermal Heater Heat input rate: 12 MMBtu per hour Fuel: Natural Gas
II.A.6 One (1) 10 MMBtu/hr Thermal Heater Heat input rate: 10 MMBtu per hour Fuel: Natural Gas
II.A.7 One (1) 4 MMBtu/hr Thermal Heater Heat input rate: 4 MMBtu per hour Fuel: Natural Gas
II.A.8 One (1) 2.25 MMBtu/hr Grill Heat input rate: 2.25 MMBtu per hour Fuel: Natural Gas
II.A.9 Searing Grills #1 & #2 Manufacturer: Convenience Food Systems Model number: TwinGrill 4800/1000 Heat Transfer Media: Thermal Oil
II.A.10 Searing Grills #3 & #4 Manufacturer: Convenience Food Systems Model number: TwinGrill 6000/1000 Heat Transfer Media: Thermal Oil

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II.A.11 One (1) SuperFry Fryer Manufacturer: Convenience Food Systems Model: 8000/1050 Heat Transfer Media: Thermal Oil Control: Venturi Scrubber (Item II.A.16)
II.A.12 One (1) EasyFry Fryer Manufacturer: Convenience Food Systems Model: 3000/1000 Heat Transfer Media: Thermal Oil Control: Venturi Scrubber (Item II.A.16)
II.A.13 Two (2) TurboCook Ovens Manufacturer: Convenience Food Systems Model: CookStar 1000/10-100 Heat Transfer Media: Thermal Oil
II.A.14 Five (5) Steam/Smoke Ovens Manufacturer: Marlen Model: 2X2 Heat Transfer Media: Steam
II.A.15 One (1) Protherm Fryer Heat input rate: 3.3 MMBtu per hour Fuel: Natural Gas Heat Transfer Media: Cooking Oil Control: Venturi Scrubber (Item II.A.16)
II.A.16 Three (3) Venturi Scrubbers Air Flow: 5,000 acfm Controls emissions from the following equipment: SuperFry fryer (Item II.A.11), and EasyFry fryer (Item II.A.12), and Protherm Fryer (Item II.A.15)
II.A.17 One (1) 0.1 MMBtu/hr Fryer Fuel: Natural Gas Heat Transfer Media: Thermal Oil Control: Hood (Item II.A.19)
II.A.18 One (1) 0.09 MMBtu/hr Fryer Fuel: Natural Gas Heat Transfer Media: Thermal Oil Control: Hood (Item II.A.19)
II.A.19 One (1) Test Kitchen Hood Controls emissions from the following equipment: 0.1 MMBtu/hr Fryer (Item II.A.17), 0.09 MMBtu/hr Fryer (Item II.A.18), 0.13 MMBtu/hr Flat Top (Item II.A.20) and 0.041 MMBtu/hr Oven (Item II.A.21)
II.A.20 One (1) 0.13 MMBtu/hr Flat Top Fuel: Natural Gas Control: Hood with grease filters (Item II.A.19)
II.A.21 One (1) 0.041 MMBtu/hr Oven Fuel: Natural Gas Control: Hood with grease filters (Item II.A.19)
II.A.22 One (1) 0.056 MMBtu/hr Oven Fuel: Natural Gas Control: Hood (Item II.A.23)
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II.A.23 One (1) AVI Hood Vent Air Flow: 500 cfm Controls emissions for 0.056 MMBtu/hr oven (Item II.A.22)
II.A.24 One (1) Steam Oven Manufacturer: Marlen Model: 2 Truck Smokehouse Heat Transfer Media: Steam
II.A.25 Various Food Preparation Equipment - listed for informational purposes only - Various Conveyors Various Storage Tanks (Thermal Oil) Various Filters, Slicers, Freezers/Coolers, Meat Presses **Manufacturer and model number information listed for informational purposes only.
II.A.26 One (1) Charmarker Heat input rate: 1.2 MMBtu/hr Fuel: Natural gas
Status: In Compliance. No unapproved equipment was observed at the time of inspection. Additional information obtained at the time of inspection: Condition II.A.2 - this boiler is installed but not in use Condition II.A.5 - this thermal heater is installed but not in use Condition II.A.10 - #3 grill has been sold and #4 grill is in storage Condition II.A.11 - the SuperFry fryer was removed from service in 2024 Condition II.A.13 - one TurboCook oven was removed from service in 2024 Condition II.A.16 - the venturi scrubber associated with the SuperFry fryer was removed from service in 2024 Condition II.A.22 - this natural gas oven has been sold Condition II.A.23 - this hood vent has been sold Condition II.A.26 - the Charmarker is in storage

II.B Requirements and Limitations
II.B.1 Operational Requirements II.B.1.a The owner/operator shall not allow visible emissions from any stationary point or fugitive emission source on site to exceed 10% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3] 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.b The owner/operator shall only use natural gas as fuel in all process equipment on site. [R307-401-8] Status: In Compliance. Only natural gas is used as fuel in processing equipment. II.B.1.c The owner/operator shall maintain records of the amount of natural gas combusted during each calendar month. [40 CFR 60 Subpart Dc] Status: In Compliance. Natural gas is tracked as directed. For the rolling 12-month period from January 2024 - December 2024, a total of 15,023 dekatherms of natural gas were combusted. See the attached table for more information.

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II.B.1.d The owner/operator shall use venturi scrubbers to control particulate emissions from the SuperFry, EasyFry, and Protherm fryers. [R307-401-8] Status: In Compliance. Venturi scrubbers are used to control particulate emissions from the EasyFry and Protherm fryers. The SuperFry fryer and its scrubber were removed from service in 2024. II.B.1.e The owner/operator shall install venturi scrubbers that are certified to meet a control efficiency of no less than 90%. [R307-401-8] II.B.1.e.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed venturi scrubbers. [R307-401-8] Status: In Compliance. The scrubbers are certified 100% efficient for particles 5 microns or greater, 96% efficient for particles 3 microns or greater, and 70% efficient for particles 2 microns or greater. See the attachments for more information. II.B.1.f The owner/operator shall install hood vents with grease filters to control emissions from the following natural gas-fired equipment: 0.1 MMBtu/hr fryer, 0.09 MMBtu/hr fryer, 0.13 MMBtu/hr flat top, 0.041 MMBtu/hr oven, and the 0.056 MMBtu/hr oven. [R307-401-8] Status: In Compliance. All of the hood vents were observed to be installed as required. This requirement pertains to the equipment in Condition II.A.19. II.B.1.g The owner/operator shall install hood vents with grease filters that are certified to meet a control efficiency of no less than 90%. [R307-401-8] II.B.1.g.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records of the manufacturer's emissions guarantee for the installed hood vents with grease filters. [R307-401-8] Status: Not Applicable. The AVI hood vent has been sold and removed from the site. This hood pertained to the equipment in Condition II.A.23.
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 only operate on natural gas. Natural gas consumption is tracked and
recorded on a monthly basis. See condition II.B.1.c for more information.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Stationary Sources [R307-210]

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

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Nonattainment and Maintenance Areas for PM10: Emissions and Fugitive Emissions and Fugitive Dust
[R307-309]

Status: In Compliance. No visible emissions were observed from any point.

EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from West Liberty
Foods L.L.C. - Tremonton Food Preparation Plant on the Approval Order (AO)
DAQE-AN140240016-23, dated August 9, 2023. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
CO2 Equivalent 44529.00
Carbon Monoxide 31.35
Nitrogen Oxides 37.32
Particulate Matter - PM10 12.20
Particulate Matter - PM2.5 12.20
Sulfur Dioxide 0.22
Volatile Organic Compounds 22.79

Hazardous Air Pollutant PTE lbs/yr
Formaldehyde (CAS #50000) 0
Generic HAPs (CAS #GHAPS) 20
Hexane (CAS #110543) 1340

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

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN140240016-23,
dated August 9, 2023, the overall status is: In Compliance. The
facility appears to be well maintained and operated. Required
records were current and made available during the inspection.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as normal.

NSR RECOMMENDATIONS: The source has sold many items in the equipment list. Remove
these items when the source goes through their next AO
modification.

ATTACHMENTS: VEO form, email correspondence, natural gas usage, scrubber
information.
Questar Natural Gas
Account # 8771369110
705 N 2000 W
SLICE
Dates used
from
to
Days in bill
Total used
Dth ea day
Total yr use
FAB
Account # 4000734369
845 N 2000 W
Dates used
from
to
Days in bill
Total used
Dth ea day
Total yr use
JUN 23 JULY 23 AUG 23 SEP 23 OCT 23 NOV 23 DEC 23 JAN 24 FEB 24 MAR 24 APR 24 May 24 JUN 24 JUL 24
06/01/202307/01/202308/01/202309/01/202310/01/202311/01/202312/01/202301/01/202402/01/202403/01/202304/01/202305/01/202306/01/202307/01/2023
02/05/202302/06/202302/07/202302/08/202302/09/202302/10/202302/11/202302/12/202302/01/202402/02/202302/03/202302/04/202302/05/202302/06/2023
29 30 31 29 31 30 31 31 28 30 29 30 29 30
803 726 819 1140 1298 1486 1535 1446 1447 1279 1205 952 953
27.68965517 24.2 0 28.2413793136.7741935543.2666666747.9354838749.5161290351.6428571448.2333333344.1034482840.1666666732.8275862131.76666667
11713.00
JUN 23 JULY 23 AUG 23 SEP 23 OCT 23 NOV 23 DEC 23 JAN 24 FEB 24 MAR 24 APR 24 May 24 JUN 24 JUL 24
06/01/202307/01/202308/01/202309/01/202310/01/202311/01/202312/01/202301/01/202402/01/202403/01/202304/01/202305/01/202306/01/202307/01/2023
06/30/202307/31/202308/31/202309/30/202310/31/202311/30/202312/31/202301/31/202402/01/202402/02/202302/03/202302/04/202302/05/202302/06/2023
29 30 30 30 31 29 31 31 28 30 29 30 29 30
9,802 10,300 10,765 10,747 13,446 13,038 14,291 16,076 11,076 10,998 9,768 7,970 7,031 7,408
338 343.3333333358.8333333358.2333333433.7419355449.5862069 461 518.5806452395.5714286 366.6 336.8275862265.6666667242.4482759246.9333333
136815.00
Questar Natural Gas
Account # 8771369110
705 N 2000 W
SLICE
Dates used
from
to
Days in bill
Total used
Dth ea day
Total yr use
FAB
Account # 4000734369
845 N 2000 W
Dates used
from
to
Days in bill
Total used
Dth ea day
Total yr use
AUG 24 SEP 24 OCT 24 NOV 24 DEC 24
08/01/202309/01/202310/01/202311/01/202312/01/2023
02/07/202302/08/202302/09/202302/10/202302/11/2023
30 29 31 30 31
945 966 1209 1386 1700
31.5 33.31034483 39 46.2 54.83870968
15023.00
AUG 24 SEP 24 OCT 24 NOV 24 DEC 24
08/01/202309/01/202310/01/202311/01/202312/01/2023
02/07/202302/08/202302/09/202302/10/202302/11/2023
30 30 31 30 31
7,306 6,520 8,028 8,079 10,282
243.5333333217.3333333258.9677419 269.3 331.6774194
110542.00
WEST LIBERTY FOODS,L.L.C
Title:West Liberty Foods Air Particulate Reduction Venturi Scrubber Document ID:TRE Venturi Scrubber
Issue Date:8/15/2023 Page 1 of 1
Revision Date:08/15/2023 Approval:EMR SA
West Liberty Foods Tremonton,Quickdraft Venturi Exhauster,and
Demister Filtration System
Features and Benefits
●100%efficient for particles 5 microns or greater
●96%efficient for 3-micron particulate
●70%efficient for 2-micron particulate
●Higher efficiencies are available
●All stainless-steel construction