DAQ-2025-002567

DAQE-

RN100510022 May 5, 2025 Ruben Van Tassell
Swift Beef Company, Inc. 410 North 200 West Hyrum, UT 843191024
[e-mail] Dear Ruben Van Tassell,
Re: Engineer Review - Administrative Amendment: Administrative Amendment to Approval Order DAQE-AN100510021-23 to Allow Biogas to be Sent Offsite for Processing under R307-401-12 Project Number: N100510022 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. Swift Beef Company, Inc. should complete this review within 10 business days of receipt. Swift Beef Company, Inc. 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 Swift Beef Company, Inc. does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Swift Beef Company, Inc. 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 Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N100510022: Swift Beef Company, Inc.- Hyrum Meat Packing Plant May 5, 2025 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N100510022 Owner Name Swift Beef Company, Inc. Mailing Address 410 North 200 West
Hyrum, UT, 843191024 Source Name Swift Beef Company, Inc.- Hyrum Meat Packing Plant
Source Location 410 North 200 West Hyrum, UT 84319
UTM Projection 428,430 m Easting, 4,610,460 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 2011 (Meat Packing Plants) Source Contact Ruben Van Tassell Phone Number [phone] Email [e-mail] Billing Contact Ruben Van Tassell Phone Number [phone]
Email [e-mail] Project Engineer Christine Bodell, Engineer
Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted April 9, 2025 Date of Accepted Application April 10, 2025

Engineer Review N100510022: Swift Beef Company, Inc.- Hyrum Meat Packing Plant May 5, 2025 Page 2
SOURCE DESCRIPTION General Description
Swift Beef Company, Inc (Swift Beef) operates a beef processing plant in Hyrum, Utah. Approximately 2000-2200 cattle a day are processed at the plant. Waste bones, flesh, and blood are shipped to the rendering plant to reduce the weight. Rotary driers are used to dry the material
and the water from the material is driven off as steam and vented through a stack. The facility includes eight (8) boilers, one (1) biogas flare, one (1) blood dryer, one (1) edible bone-meal dryer, one (1) inedible bone-meal dryer, one (1) venturi scrubber, three (3) packed bed scrubbers, two (2) emergency generators, and one (1) horizontal petroleum tank. NSR Classification: Administrative Amendment 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 MACT (Part 63), CCCCCC: National Emission Standards for Hazardous Air Pollutants for
Source Category: Gasoline Dispensing Facilities Title V (Part 70) Area Source Project Proposal Administrative Amendment to Approval Order DAQE-AN100510021-23 to Allow Biogas to be Sent Offsite for Processing under R307-401-12 Project Description
Swift Beef Company, Inc (Swift Beef) has requested an administrative amendment to AO DAQE-AN100510021-23, issued June 9, 2023, to allow for greater flexibility in biogas operations. Under Condition II.B.3.c of the 2023 AO, all collected [raw] biogas is to be routed to the
operating combustor/flare, Boiler #2, or Boiler #4 for combustion prior to release in the atmosphere.
In 2025, Swift Beef entered into a formal agreement with GGUSA Hyrum, LLC to supply raw biogas to their RNG facility located adjacent to the Swift Beef facility. As part of this partnership, Swift Beef is to update its raw biogas with a valve and piping that would allow raw
biogas to be delivered to the new RNG facility for further processing. In the event that GGUSA Hyrum, LLC cannot accept the raw biogas, Swift Beef still has the ability to route the raw biogas to the combustor/flare, Boiler #2, or Boiler #4 for combustion.

Engineer Review N100510022: Swift Beef Company, Inc.- Hyrum Meat Packing Plant May 5, 2025 Page 3
Therefore, the updated Condition shall be updated as follows:
"The owner/operator shall route all collected raw biogas offsite for further processing or to the operating combustor/flare, Boiler #2, or Boiler #4 for combustion prior to release in the atmosphere." Swift Beef is not proposing to increase any production and/or operational limits. No emissions are increasing. This project meets the requirements of UAC R307-401-12 Reduction in Air Pollutants and does not require a public comment period. EMISSION IMPACT ANALYSIS This is an administrative amendment under R307-401-12. No emissions are increasing at this time. Therefore, modeling is not required. [Last updated April 10, 2025]

Engineer Review N100510022: Swift Beef Company, Inc.- Hyrum Meat Packing Plant May 5, 2025 Page 4
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 99006.00 Carbon Monoxide 0 81.46
Nitrogen Oxides 0 65.54
Particulate Matter - PM10 0 17.53
Particulate Matter - PM2.5 0 14.82
Sulfur Dioxide 0 38.96
Volatile Organic Compounds 0 46.65 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 0 40
Acrolein (CAS #107028) 0 40
Chlorine (CAS #7782505) 0 80
Formaldehyde (CAS #50000) 0 780
Generic HAPs (CAS #GHAPS) 0 80 Hexane (CAS #110543) 0 3960 Toluene (CAS #108883) 0 140
Xylenes (Isomers And Mixture) (CAS #1330207) 0 40
Change (TPY) Total (TPY)
Total HAPs 0 2.58
Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N100510022: Swift Beef Company, Inc.- Hyrum Meat Packing Plant May 5, 2025 Page 5
Review of BACT for New/Modified Emission Units 1. BACT review regarding Administrative Amendment
This is an administrative amendment under R307-401-12. No emissions are increasing at this time. Therefore, a BACT analysis is not required. [Last updated April 10, 2025]
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 N100510022: Swift Beef Company, Inc.- Hyrum Meat Packing Plant May 5, 2025 Page 6
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 Meat Packing Plant
II.A.2 Boiler #1 Boiler Rating: 25.106 MMBtu/hour Burner Type: Low NOx with flue gas recirculation kit installed Date of Construction: 2006 Fuel Type: Natural Gas Secondary: #2 Distillate Fuel or Tallow
II.A.3 Boiler #2 Boiler Rating: 20.92 MMBtu/hour Burner Type: Low NOx Location: Refinery Flavor Building Date of Construction: 1972 Fuel: Natural Gas, Biogas
II.A.4 Boiler #3 Boiler Rating: 32.66 MMBtu/hour Burner Type: Low NOx
Location: Refinery Flavor Building Date of Construction: 2004 Fuel: Natural Gas Secondary: #2 Distillate Fuel II.A.5 Boiler #4 Boiler Rating: 32.66 MMBtu/hour
Burner Type: Low NOx Location: Refinery Flavor Building Date of Construction: 2014 Fuel: Natural Gas, Biogas Secondary: #2 Distillate Fuel
II.A.6 Boiler #5
Boiler Rating: 25.106 MMBtu/hour Burner Type: Low NOx with flue gas recirculation kit installed Date of Construction: 2006
Fuel Type: Natural Gas Secondary: #2 Distillate Fuel

Engineer Review N100510022: Swift Beef Company, Inc.- Hyrum Meat Packing Plant May 5, 2025 Page 7
II.A.7 Boiler #6 Boiler Rating: 32.66 MMBtu/hour Burner Type: Low NOx
Date of Construction: 2008 Fuel: Natural Gas Secondary: #2 Distillate Fuel

II.A.8 Boiler AC Boiler Rating: 20.92 MMBtu/hour Burner Type: Low NOx Location: Rendering Plant Date of Construction: 2000 Fuel: Natural Gas

II.A.9 Boiler Truck Wash Boiler Rating: 0.824 MMBtu/hour Location: Truck Washing Building Date of Construction: 2004 Fuel: Natural Gas
II.A.10 One (1) Biogas Flare/Combustor Maximum Capacity: 1,100 scfm

II.A.11 One (1) Blood Dryer Burner Rating: 4.5 MMBtu/hour Location: Rendering Plant
Date of Construction: 1996 II.A.12 One (1) Edible Bone-meal Dryer Burner Rating: 30.0 MMBtu/hour Location: Rendering Plant Date of Construction: 1991
II.A.13 One (1) Inedible Bone-meal Dryer Burner Rating: 30.0 MMBtu/hour Location: Rendering Plant Date of Construction: 1991
II.A.14 One (1) Venturi Scrubber Location: Main Plant Building II.A.15 Main Packed Bed Scrubber Location: Main Plant Building

II.A.16 North Packed Bed Scrubber Capacity: 60,000 ACFM Location: Rendering Plant

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II.A.17 South Packed Bed Scrubber Capacity: 75,000 ACFM Location: Rendering Plant

II.A.18 One (1) Emergency Engine/Generator Power Rating: 97 hp Fuel: Natural Gas Date of Installation: 2002
II.A.19 One (1) Emergency Generator Engine Rating: 99 hp Fuel: Diesel Fuel Manufacturing Date: 2021
II.A.20 One (1) Horizontal Petroleum Tank Volume: 10,000 gallons Contains: Diesel Fuel
Location: Refinery Flavor Building II.A.21 Portable Gasoline Above-Ground Storage Tank Volume: 500 gallons Contains: Gasoline
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 Site Wide Requirement
II.B.1.a The owner/operator shall not feed more than 175,200 tons of feed into the Inedible and Edible Dryers combined per rolling 12-month period, and the owner/operator shall not feed more than 9,267 tons of feed into the Blood Dryer per rolling 12-month period. [R307-401-8] II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records of production feed to the dryers shall be kept for all periods when the plant is in operation. The records of production feed to the dryers shall be kept on a monthly basis. [R307-401-8]

Engineer Review N100510022: Swift Beef Company, Inc.- Hyrum Meat Packing Plant May 5, 2025 Page 9
II.B.1.b NEW The owner/operator shall not allow visible emissions from the following emission points to exceed the following opacity limits: A. All Boilers, Dryers and Generator while operating on natural gas -10% opacity B. All Boilers, Dryers and Generator while operating on fuel oil - 20% opacity.
C. All Scrubbers - 15% opacity
D. Combustion/Flare - No visible emissions
E. Emergency Generator Engine - 20% opacity F. All Other Points - 20% opacity [R307-401-8] II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.2 Fuel Requirements
II.B.2.a The owner/operator shall use the following fuel type for specific equipment:
All Boilers: Natural gas and/or biogas as a primary fuel and #2 fuel oil and/or animal tallow as
alternative fuels.
Blood Dryer: Natural gas.
Edible and Inedible Bone Dryers: Natural gas as a primary fuel and #2 fuel oil and/or animal
tallow as alternative fuels. Emergency Engine: Natural gas. [R307-401-8] II.B.2.b The owner/operator shall not operate the two (2) boilers rated at 25.106 MMBtu/hr and three (3) boilers rated at 32.66 MMBtu/hr, while using distillate fuel as a fuel for more than 48 hours each per rolling 12-month period during operator training, maintenance, or periodic testing. These five (5) boilers may operate with distillate fuel during natural gas curtailment, gas supply interruptions, or startups without any limitation on the use of distillate fuel. [R307-401-8]

Engineer Review N100510022: Swift Beef Company, Inc.- Hyrum Meat Packing Plant May 5, 2025 Page 10
II.B.2.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 of the hours of operation using distillate fuel for the two (2) 25.106 MMBtu/hr boilers
and three (3) 32.66 MMBtu/hr boiler shall be kept and shall include the following:
A. The date the distillate fuel was used
B. The duration of operation while using distillate fuel
C. The reason distillate fuel was used. [R307-401-8]
II.B.2.c The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.2.c.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8] II.B.3 Biogas Requirements
II.B.3.a The owner/operator shall not allow SO2 emissions from biogas and animal tallow fuel combustion to exceed 38.68 tons per rolling 12-month period. [R307-401-8] II.B.3.a.1 NEW The owner/operator shall calculate SO2 emissions by using the following emissions factors: A. Animal Tallow combustion: 0.2 lb/1000 gal
(Emissions test report) B. Biogas combustion: (0.16356 x S) lb/MMscf
(S is the stoichiometric conversion of sulfur to SO2, where S=H2S concentration,
ppm)
[R307-401-8]

II.B.3.a.2 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. [R307-401-8]
II.B.3.b The owner operator shall test the H2S content in the biogas at least once every 12 months. [R307-401-8]

Engineer Review N100510022: Swift Beef Company, Inc.- Hyrum Meat Packing Plant May 5, 2025 Page 11
II.B.3.b.1 Testing of biogas H2S content shall be conducted according to ASTM Method D5504 or other testing method acceptable to the director. After the initial test, the owner/operator may use a H2S colorimetric gas tube detector (gas tube) for the annual tests. If a gas tube testing is
conducted, the owner/operator shall compare the result of the gas tube testing with the most recent test conducted according to ASTM Method D5504 or other testing method acceptable to the director. If the H2S content of the gas tube exceeds the result obtained using ASTM
Method D5504 by 10% or greater, the owner/operator shall test the H2S content according to ASTM Method D5504 or other approved method within 30 days of the gas tube test. The owner/operator shall test the H2S content in the biogas according to ASTM Method D5504 at
least once every five years. [R307-401-8] II.B.3.c NEW The owner/operator shall route all collected raw biogas offsite for further processing or to the operating combustor/flare, Boiler #2, or Boiler #4 for combustion prior to release in the
atmosphere. At no time shall the owner/operator vent the raw biogas directly to the atmosphere. [R307-401-8]
II.B.4 Emergency Generator Engine Requirements
II.B.4.a The owner/operator shall not operate each emergency engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.4.a.1
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 each emergency engine shall be kept in a log and shall include the following:
A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.4.b To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.4.c The owner/operator shall only use natural gas as fuel in the 97 hp emergency generator engine. [R307-401-8] II.B.4.d The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as fuel in the 60 kW emergency generator engine. [R307-401-8]

II.B.4.d.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [40 CFR 63 Subpart ZZZZ]

Engineer Review N100510022: Swift Beef Company, Inc.- Hyrum Meat Packing Plant May 5, 2025 Page 12
II.B.4.d.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel
meets the ULSD requirements. [R307-401-8]

Engineer Review N100510022: Swift Beef Company, Inc.- Hyrum Meat Packing Plant May 5, 2025 Page 13
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-AN100510021-23 dated June 9, 2023
Is Derived From NOI dated April 9, 2025
REVIEWER COMMENTS

1. Comment regarding Reduction in Air Pollutant Applicability: Under Condition II.B.3.c of the 2023 AO, all collected [raw] biogas is to be routed to the operating combustor/flare, Boiler #2, or Boiler #4 for combustion prior to release in the atmosphere. In 2025, Swift Beef entered into a formal agreement with GGUSA Hyrum, LLC to supply raw biogas to their RNG facility located adjacent to the Swift Beef facility. As part of this partnership, Swift Beef is to update its raw biogas with a valve and piping that would allow raw biogas to be delivered to the new RNG facility for further processing. Routing the raw biogas offsite for further processing would reduce the amount of raw biogas sent for combustion on-site. Thus, combustion emissions will be reduced on-site. In the event that GGUSA Hyrum, LLC cannot accept the raw biogas, Swift Beef still has the ability
to route the raw biogas to the combustor/flare, Boiler #2, or Boiler #4 for combustion. The condition was updated to accommodate this to provide Swift Beef with flexibility. Swift Beef will operate under existing emissions limitations. Therefore, this project meets the requirements of Utah Administrative Code R307-401- 12, Reduction in Air Pollutants. [Last updated
May 5, 2025] 2. Comment regarding NSPS & MACT Applicability: 40 CFR 60 (NSPS) 40 CFR 60 Subpart Dc applies to steam generating units for which construction, modification, or reconstruction is commenced after June 9, 1989 and has a maximum design heat capacity of 100
MMBtu/hr or less, but greater than or equal to 10 MMBtu/hr. This facility has six (6) boilers that commenced construction after June 9, 1989 that have a heat capacity between 10 MMBtu/hr and 100 MMBtu/hr, therefore, NSPS Subpart Dc applies to these boilers. Additionally, the boilers are permitted to use #2 distillate fuel or tallow as secondary fuel. These boilers are therefore not considered "natural gas" boilers and are subject to limitations under this Subpart. 40 CFR 60 Subpart IIII applies to stationary reciprocating internal combustion engines (RICE). The 60 kW emergency generator engine uses diesel fuel and was manufactured in 2021. Therefore, NSPS Subpart IIII applies to the 60 kW emergency generator engine. 40 CFR 63 (MACT) 40 CFR 63 Subpart ZZZZ applies to stationary reciprocating internal combustion engines (RICE) at a major or area source of HAP emissions. The emergency generator engine is an existing source that
commenced construction on or before June 12, 2006 at an area source of HAP emissions. Therefore, MACT subpart ZZZZ applies to the emergency generator engine. 40 CFR 63 Subpart CCCCCC applies to gasoline storage tanks at gasoline dispensing facilities that are a source of HAP emissions. The 500-gallon portable gasoline above ground storage tank (AST)

Engineer Review N100510022: Swift Beef Company, Inc.- Hyrum Meat Packing Plant May 5, 2025 Page 14
is an existing source with a throughput of less than 10,000 gallons a month; therefore, Subpart CCCCCC applies to the portable gasoline AST.
40 CFR 63 Subpart JJJJJJ applies to industrial, commercial, and institutional boilers that are major or area HAP sources. The source has five (5) boilers that burn alternative liquid/solid fuel. If periodic testing, maintenance, or operator training on liquid fuel exceeds 48 hours during a calendar year on any of the five (5) boilers, they will be subject to MACT Subpart JJJJJJ. The source does not
burn alternative liquid/solid more than 48 hours a year, therefore MACT Subpart JJJJJJ does not apply to this source. [Last updated May 5, 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 source is not a major source or a Title IV source. The source is subject to 40 CFR 60 NSPS and 40 CFR 63 MACT regulations. This source is not subject to 40 CFR 61 NESHAP regulations. NSPS Subpart IIII, MACT Subpart ZZZZ, and MACT Subpart CCCCCC each exempt sources from the obligation to obtain a permit under 40 CFR part 70 (Title V Permit), if the source is not otherwise required by law to obtain a permit. NSPS Subpart Dc does not include this exemption. Therefore, Title V applies to this facility as an area source. [Last updated May 5, 2025]

Engineer Review N100510022: Swift Beef Company, Inc.- Hyrum Meat Packing Plant May 5, 2025 Page 15
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
Christine Bodell <[e-mail]>
RE: [Ext]- Re: Swift Beef Company DAQE-AN100510021-23
5 messages
Van Tassell, Ruben <[e-mail]>Mon, Feb 24, 2025 at 10:33 AM
To: Christine Bodell <[e-mail]>
Cc: "Leonhard, Kari" <[e-mail]>, "Starnes, John" <[e-mail]>, "[e-mail]" <[e-mail]>
Chrisne,

We are available tomorrow at 1:00 p.m. MST

Thank you,
Ruben

From: Chrisne Bodell <[e-mail]>
Sent: Monday, February 24, 2025 7:48 AM
To: Van Tassell, Ruben <[e-mail]>
Cc: Leonhard, Kari <[e-mail]>; Starnes, John <[e-mail]>; [e-mail]
Subject: [Ext]- Re: Swi Beef Company DAQE-AN100510021-23

CAUTION:*This email originated from outside of the organization. Do not click links or open attachments unless you recognize
the sender and know the content is safe.*

Hello Ruben,

Thank you for reaching out. I would be happy to set up a virtual meeting to discuss any questions you may have.

I have the following availability this week:

Tuesday, February 25, 8 am - 10 am, 12 pm - 5 pm
Wednesday, February 26, 11 am - 5 pm
Thursday, February 27, 10 am - 5 pm

Please let me know if any of these times work for you and your team.

Best,
Christine

On Fri, Feb 21, 2025 at 9:00 AM Van Tassell, Ruben <[e-mail]> wrote:
Hello Christine,

Chad recommended that I reach out to you about discussing modification of our existing Approval Order, specifically condition II.B.3.c of
DAQE-AN100510021-23 to account for bio-gas processes through GGUSA Hyrum LLC. Please let us know if there is a day next week
that would work for you to schedule to meeting.

Thank you,

Ruben Van Tassell
Environmental and Sustainability
Manager
[e-mail]

O: 435.245.2259
C: 208.300.0408
www.jbssa.com
410 N. 200 West
Hyrum, UT  84319

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Van Tassell, Ruben <[e-mail]>Tue, Apr 8, 2025 at 12:27 PM
To: Christine Bodell <[e-mail]>, "Leonhard, Kari" <[e-mail]>, "[e-mail]" <[e-mail]>, "Starnes,
John" <[e-mail]>
Chrisne,

Good Aernoon and thank you for the follow-up email.

The current Swi Beef Approval Order, DAQE-AN100510021-23 secon II.B.3.c, states “All collected biogas shall be routed to the
operang combustor/flare, Boiler #2, or Boiler #4 for combuson prior to release in the atmosphere”. Swi Beef has entered into a
formal agreement with GGUSA Hyrum LLC to supply raw biogas to their RNG facility located adjacent to the Swi Beef facility here in
Hyrum. As part of this partnership, modificaons to the exisng Swi Beef raw biogas line will include a valve and piping that would
allow raw biogas to be delivered to the new RNG facility, or routed to the Swi Beef facility to be combusted in accordance with our
current Approval Order in Boiler #2, or Boiler #4. The opon to bypass the RNG facility, will primarily be used in the event that GGUSA
Hyrum cannot process our biogas.

We respecully request a clerical modificaon to II.B.3.c to allow for the oponal delivery of collected raw biogas to a third party for
further processing, in addion to the exisng combuson opons. This change would provide flexibility for beneficial use of the
biogas, consistent with the intent of reducing emissions and supporng sustainable pracces. We propose the following revised
wording for your consideraon:

“All collected biogas shall be routed to the operang combustor/flare, Boiler #2, Boiler #4, or delivered to a third party for further
processing, prior to release to the atmosphere.”

This requested change does not alter the fundamental nature or emissions profile of the project but instead enables an
environmentally sound alternave to flaring or combuson. We believe this revision may be eligible as a clerical change under UAC
R307-401-8(1), and we respecully request your consideraon for expeding this modificaon without requiring a new Approval
Order.

We have also determined that our current biogas system’s heat exchanger is undersized and creates a boleneck that limits the
volume of biogas that can be routed through the flare or boilers. We are working through our internal process to purchase a larger
heat exchanger for installaon on site that will allow us to combust the enre projected generated biogas.

Please let us know if you need any addional informaon or clarificaon. We appreciate your me and connued support.

Best Regards,

Ruben Van Tassell
Environmental and Sustainability
Manager
[e-mail]

O: 435.245.2259
C: 208.300.0408
www.jbssa.com
410 N. 200 West
Hyrum, UT  84319

From: Chrisne Bodell <[e-mail]>
Sent: Tuesday, April 1, 2025 8:51 AM
To: Van Tassell, Ruben <[e-mail]>; Leonhard, Kari <[e-mail]>; [e-mail];
Starnes, John <[e-mail]>
Subject: [Ext]- Re: Swi Beef Company DAQE-AN100510021-23

CAUTION:*This email originated from outside of the organization. Do not click links or open attachments unless you recognize
the sender and know the content is safe.*

Good Morning All,

I hope you are doing well.

It has been a while, but I believe we concluded the DAQ-Swift Beef meeting on February 25th, 2025 with the assurance that Swift Beef was
having internal discussions regarding how it would like to proceed with having its current Approval Order modified. Swift Beef mentioned
that it would likely take 1-2 months for details to be finalized.

I am reaching out at this time to see if there are any updates or if there are any questions.

Thank you,
Christine
[Quoted text hidden]
Christine Bodell <[e-mail]>Tue, Apr 8, 2025 at 4:59 PM
To: "Van Tassell, Ruben" <[e-mail]>
Cc: "Leonhard, Kari" <[e-mail]>, "[e-mail]" <[e-mail]>, "Starnes, John" <[e-mail]>
Ruben,
Thanks for the update.
The DAQ can proceed with updating the AO administratively to address Approval Order, DAQE-AN100510021-23 Condition II.B.3.c.
Can you please verify that all other information (contact, mailing address, equipment, etc,) on the current Approval Order is still accurate?
Best,
Christine
[Quoted text hidden]
Chad Gilgen <[e-mail]>Tue, Apr 8, 2025 at 5:00 PM
To: [e-mail]
I am out on leave until April 14, 2025, and will only be checking email intermittently during that time. If you need immediate assistance,
please contact the DAQ Front Desk at 801-536-4000.
Thanks,
Chad
--
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
Van Tassell, Ruben <[e-mail]>Wed, Apr 9, 2025 at 2:36 PM
To: Christine Bodell <[e-mail]>
Cc: "Leonhard, Kari" <[e-mail]>, "[e-mail]" <[e-mail]>, "Starnes, John" <[e-mail]>
Chrisne,

Thank you for your prompt review and approval of our requested change. We appreciate your support in our operaons. All
informaon on the current Approval Order, DAQE-AN100510021-23, is accurate.

Please let me know if any further informaon is needed.

Best Regards,

Ruben
[Quoted text hidden]