DAQ-2024-005130

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DAQC-CI104350001-23
Site ID 10435 (B1)

MEMORANDUM

TO: FILE – STERIGENICS US, LLC – Ethylene Oxide Commercial Sterilization Plant

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Susan Weisenberg, Environmental Scientist

DATE: September 22, 2023

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: August 23, 2023

SOURCE LOCATION: 5725 West Harold Gatty Drive International Center
Salt Lake City, UT 84116
DIRECTIONS: From I-80 West bound, take exit 113, 5600 West. Take west
bound Amelia Earhart Drive to Harold Gatty Drive.

SOURCE CONTACTS: Joe Jeppson, General Manager, Salt Lake City
801-328-9901

OPERATING STATUS: Operating normally

PROCESS DESCRIPTION: Disposable medical devices are stored in a warm and humid
environment. After temperature and humidity stabilization the
products are moved to one of ten sterilizer chambers for
sterilization with ethylene oxide (EtO). A source tank scale
controls the volume of EtO pumped into the chambers. After a
prescribed resident time the chambers are purged with nitrogen
or air through the sterilization chamber vacuum exhaust to the
Ceilcote acid water high volume scrubber.

The sterilized product is then moved to one of 14 aeration rooms
and is stored to release the remaining EtO. Emissions from the
aeration rooms are vented through the Advanced Air
Technologies (AAT) scrubber. It is reported that aeration room
emissions can be held if the AAT system malfunctions or
requires maintenance. The AAT adsorber which consists of
seven adsorbent dry beds controls the vacuum vent emissions
during breakdowns and emergency events. The chamber back
vents to the AAT.

The Ceilcote scrubber consists of a packed tower scrubber, two
acid-water reaction glycol storage tanks (17,000 gallons each),
dual recycling plumbing, heat exchanger, and control panel.
Acidified (sulfuric) water/glycol is sprayed from the top of the
tower and the EtO is vented to the bottom. The acidified water
reacts with the EtO to form ethylene glycol. The acidified water

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circulates until the solution reaches a designated glycol
concentration. All or part of the glycol solution is then pumped
to a tank for reuse. Fresh water and sulfuric acid is added as
needed to the system and the process continues

The AAT scrubber system consists of a packed scrubber tower,
three acid water-reaction glycol storage tanks (18,500 gallons
each), seven adsorbent dry beds and a countercurrent flow
running acid-water. This system can use one or two components
to meet the 99% reduction requirement; the acid scrubber (SC1)
and dry beds (SC2). The first component (SC1) is a high air flow
(up to 13,000 cfm), large volume (55,000 gallons) acid water
scrubber capable of handling all the aeration room vents. Due to
the high evaporative water losses the control tank liquid level is
held constant by frequent water addition. The first component,
like the Ceilcote scrubber, uses acid-water that reacts with the
EtO to produce ethylene glycol. The second component (SC2)
consists of seven adsorbent dry beds. Each dry bed is a pair of
drawers filled with dry adsorbent media. The SRI GC is used to
monitor the dry beds when used as a backup system. The acid
scrubber and dry beds are under negative pressure created by a
stack fan drawing up to 13,000 cfm.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN104350030-21, dated March
25, 2021
NSPS (Part 60) JJJJ: Standards of Performance for Stationary
Spark Ignition Internal Combustion Engines,
MACT (Part 63) -O: Ethylene Oxide Emissions Standards for
Sterilization Facilities,
MACT (Part 63) - ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines,

SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Sterigenics US, LLC - Ethylene Oxide
Commercial Sterilization Plant
2015 Spring Road, Suite 650
Oak Brook, IL 60523

5725 West Harold Gatty Drive International
Center
Salt Lake City, UT 84116

SIC Code: 7389: (Business Services, NEC)

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]

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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]

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. No AO limits appeared to have been exceeded based on the site
observations and the submitted documents. No equipment additions or changes to the
process were noted during the inspection. No UAC R307-107 applicable breakdowns are on
record. This site is not subject to Emission Inventory requirements. A startup notification
for Chamber 11 (item II.A.12) was submitted on August 25, 2023. See the attached email
statement. Chambers 12 -17 (items II.A.13 through II.A.18) have not yet been completed.

Section II: SPECIAL PROVISIONS

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

II.A.1 Sterigenics US, LLC
Commercial medical equipment ethylene oxide sterilization facility.

II.A.2 EtO Sterilizer Chamber 1
Capacity: 1,087 cu. ft. (8-pallet)
Manufacture Date: 2004

II.A.3 EtO Sterilizer Chamber 2
Capacity: 1,087 cu. ft. (8-pallet)
Manufacture Date: 2000

II.A.4 EtO Sterilizer Chamber 3
Capacity: 1,087 cu. ft. (8-pallet)
Manufacture Date: 2004

II.A.5 EtO Sterilizer Chamber 4
Capacity: 1,087 cu. ft. (8-pallet)
Manufacture Date: 2003

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II.A.6 EtO Sterilizer Chamber 5
Capacity: 35 cu. ft. (1-pallet)
Manufacture Date: 1990

II.A.7 EtO Sterilizer Chamber 6
Capacity: 1,080 cu. ft. (8-pallet)
Manufacture Date: 1999

II.A.8 EtO Sterilizer Chamber 7
Capacity: 1,087 cu. ft. (8-pallet)
Manufacture Date: 2002

II.A.9 EtO Sterilizer Chamber 8
Capacity: 1,133 cu. ft. (8-pallet)
Manufacture Date: 1990

II.A.10 EtO Sterilizer Chamber 9
Capacity: 283 cu. ft. (2-pallet)
Manufacture Date: 1992

II.A.11 EtO Sterilizer Chamber 10
Capacity: 3,600 cu. ft. (24-pallet)
Manufacture Date: 1997

II.A.12 EtO Sterilizer Chamber 11
Capacity: 198 cu. ft. (1-pallet)
Manufacture Date: 1999

II.A.13 EtO Sterilizer Chamber 12
Capacity: 20 cu. ft. (R&D)

II.A.14 EtO Sterilizer Chamber 13
Capacity: 20 Cu. Ft. (R&D)

II.A.15 EtO Sterilizer Chamber 14
Capacity: 6 cu ft. (R&D)

II.A.16 EtO Sterilizer Chamber 15
Capacity: 12 cu. ft. (R&D)

II.A.17 EtO Sterilizer Chamber 16
Capacity: 20 cu. ft. (R&D)

II.A.18 EtO Sterilizer Chamber 17
Capacity: 20 cu. ft. (R&D)

II.A.19 Ceilcote Scrubber
One scrubber equipped with a packed tower, reaction tanks, dual recycle piping, heat
exchanger and a control panel

II.A.20 Advanced Air Technologies Scrubber
One scrubber equipped with packed tower with a countercurrent flow running acid-water
Maximum air-flow rate: 13,000 cubic feet/minute

II.A.21 Advanced Air Technologies Adsorber
Seven adsorbers consisting of dry beds

II.A.22 Nitrogen Dioxide Sterilizer
Control: Scrubber-Adsorber Cartridges

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II.A.23 Various Water Tube Boilers
Maximum Rated Capacity: Less than 5.0 MMBtu/hr each
Fuel: Natural Gas

II.A.24 Comfort Heaters
Maximum Rated Capacity: Less than 5.0 MMBtu/hr each
Fuel: Natural Gas

II.A.25 Five Non-Volatile Liquid Organic Storage Tanks
Two 17,000 gallon and three 18,500 gallon tanks, for information purposes.

Status: In Compliance. No unapproved equipment was observed operating at the
source location.

Additional equipment and process information gathered at the time of
inspection:

• II.A.13 through II.A.18 - EtO Sterilizer Chambers 12 through 17 - have not
yet been installed.

• II.A.22 - Nitrogen Dioxide Sterilizer - Has been permanently removed.

• II.A.23 - Various Water Tube Boilers - The source currently operates two
Cleaver-Brooks FLX Watertube Boilers rated at 4.5 MMBtu/hr each.

• The source operates a maintenance shop which contains an enclosed abrasive
unit used to sporadically remove calcium deposits.

• The source operates a natural-gas fired emergency generator that was
installed in 2019 with a manufacture date of February 2019. Sterigenics
appears to have submitted the required information to Minor Source NSR.
The issuance of the Modified AO adding this generator to the permit is
pending a complete review of a submitted Reduction in Air Contaminants
request.

II.B Requirements and Limitations

II.B.1 Requirements and Limitations

II.B.1.a The owner/operator shall not use more than 210.2 tons of ethylene oxide gas per rolling 12-
month period. [R307-401-8]

Status: In Compliance. The 12-month rolling total ethylene oxide gas used for the period of
August 2022 through July 2023, was reported as 123.784 tons (247,568 pounds). See the
attached spreadsheet.

II.B.1.a.1 The owner/operator shall:

A. Determine usage with purchase and usage records.

B. Record usage on a daily basis

C. Use the usage data to calculate a new rolling 12-month total by the 28th
day of each month using data from the previous 12 months. [R307-401-8]

Status: In Compliance. The records were provided during the inspection. Totals are
determined by daily usage and purchase data. The data is tabulated into a spreadsheet by
at least the 28th day of each month.

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II.B.1.b The owner/operator shall use ethylene oxide monitoring devices in the dispensing and
sterilization areas. [R307-401-8]

Status: Not Applicable. In compliance/not applicable as these monitoring devices are in
place but used solely to measure the ethylene oxide in the indoor air.

II.B.1.c Visible emissions from the following emission points shall not exceed the following values:

A. AAT scrubber and dry bed system - 0% opacity

B. Storage Tanks - 0% opacity

C. All other points - 20% opacity. [R307-201-3]

Status: In Compliance. No emissions were observed from any scrubber stack, vent, or other
point. See the attached VEO form.

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]

Status: In Compliance. Observations were made in a manner consistent with Method 9.

II.B.2 Scrubber Requirement

II.B.2.a The Ceilcote scrubber shall be used to control all process streams from the sterilization chamber
vacuum pumps. The Advanced Air Technologies (AAT) scrubber and adsorber system shall
control all process streams from the aeration vents. [R307-401-8]

Status: In Compliance. The Ceilcote and AAT scrubbers were observed to be properly
installed to control process streams at the points required.

II.B.2.b Emissions from the Ceilcote scrubber shall be routed to the AAT scrubber and adsorber system.
[R307-401-8]

Status: In Compliance. The Ceilcote scrubber was observed to be routed to the AAT
scrubber and adsorber system.

II.B.2.c The owner/operator shall route all ethylene oxide sterilizer back vent emissions through the AAT
scrubber and adsorber system. [R307-401-8]

Status: In Compliance. All ethylene oxide sterilizer back vent emissions were observed to
be routed through the AAT scrubber and adsorber system.

II.B.2.d In case of an AAT adsorber system breakdown, the Ceilcote scrubber can be rerouted to the
Ceilcote stack to control sterilization chamber vacuum pump emissions. [R307-401-8]

Status: In Compliance. The source contact stated that the Ceilcote scrubber can be
properly rerouted through the Ceilcote stack during the event of the AAT adsorber
breakdown.

II.B.2.e In case of Ceilcote breakdown, the AAT adsorber system shall be used to control the sterilization
chamber vacuum pumps, back vent and aeration emissions. [R307-401-8]

Status: In Compliance. The General Manager confirmed that the AAT adsorber system
will be used as described in the event of a breakdown for the Ceilcote system breakdown.

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II.B.2.e.1 The owner/operator shall not allow the ethylene oxide concentration in the AAT adsorber
exhaust to exceed 5.415 ppmv (24-hour average) in the event of the Ceilcote scrubber breaking
down. This represents a 99% reduction as required by MACT Subpart O. [40 CFR 63 Subpart O,
R307-401-8]

Status: Not Applicable. The Ceilcote scrubber did not experience any breakdown during
the previous rolling 12-month period. Sterigenics EHS Manager, Daniel May, stated that
an "Interlock System" prevents any operation of the system in the event of a Ceilcote
scrubber breakdown.

II.B.2.f The owner/operator shall keep and maintain records of any scrubber breakdowns. [R307-401-8]

Status: In Compliance. This requirement was reviewed during the on-site observations.
The General Manager is aware of the record requirements of any scrubber breakdowns.
No applicable breakdowns had occurred during the previous 12-month period.

II.B.2.f.1 The scrubber breakdown records shall include the following items:

A. Date of breakdown

B. Cause of breakdown

C. Duration of breakdown

D. Any corrective actions taken. [R307-401-8]

Status: Not Applicable. No applicable scrubber breakdowns occurred during the previous
12-month period. The specific items of the required records were reviewed during the
on-site interview.

II.B.2.g The following liquid flow rates in the scrubbers shall be maintained within the indicated ranges:

A. The Ceilcote scrubber average liquid flow rate shall be greater than 80 gallons per
minute

B. The AAT scrubber average liquid flow rate shall be greater than 1,500 gallons per
minute. [R307-401-8]

Status: In Compliance. The scrubbers are equipped with sensors and alarms to ensure the
flow rates are compliant with the established ranges. Site personnel are also trained to
understand the operating requirements. All records reviewed on site were within the limits.
See the attached AAT and Ceilcote Daily record checks as recent examples.

II.B.2.g.1 The owner/operator shall record daily the liquid flow rates. The records shall be kept as long as
the scrubbers are in operation and shall include the following items:

A. Date

B. Scrubber Type

C. Liquid flow rate. [R307-401-8]

Status: In Compliance. The required records indicating the date, time, liquid flow rate, and
the monitoring site personnel are kept. See the attached example of daily AAT and Ceilcote
systems check.

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II.B.2.h The pH of the ethylene glycol solutions in the Ceilcote scrubber shall not exceed 2.0.
[R307-401-8]

Status: In Compliance. Standard operating procedures for the scrubber maintains the pH
of scrubber liquid at 1.0 or less. Weekly Preventive Maintenance is performed for the
scrubber. Each aspect of the maintenance is recorded on a Sterigenics Work Order.
Sequence #50 checks the pH of the scrubber liquid and records the value. All reviewed
records indicated pH values that were under 1.0.

II.B.2.h.1 The owner/operator shall record weekly the pH of the ethylene glycol solutions. The records
shall be maintained for all periods when the Ceilcote scrubber is in operation and shall include
the following items:

A. Date

B. pH. [R307-401-8]

Status: In Compliance. See the attached recent Weekly Preventive Work Orders as
example record keeping. "Seq" 50 records the date, the equipment number, the site
personnel, and the pH measurement.

II.B.2.i The AAT heat exchanger temperature difference between inlet and outlet (delta T) shall be
greater than 5 degrees Fahrenheit. The outlet temperature shall be greater than the inlet
temperature. [R307-401-8]

Status: In Compliance. The AAT heat exchanger temperatures are measured each minute
for all hours of operation and are recorded on graph line charts. Graphs were presented
for several months of operation on site. The reviewed graph recordings indicated that the
temperature differences between inlet and outlet measurements were consistently greater
than 5 degrees Fahrenheit. An alarm system has been installed to ensure that the AAT
temperatures are compliant with the permitted limits and that the outlet temperature is
consistently greater than the inlet temperature.

II.B.2.i.1 The owner/operator shall record daily the delta T and shall keep and maintain a logbook for all
periods when the AAT heat exchanger is in operation. The records shall include the following
items:

A. Date

B. Delta T

C. Any corrective actions taken. [R307-401-8]

Status: In Compliance. A continuous minute to minute temperature graph is recorded and
can be reviewed on site. The recordings provide the date, time, the temperature differential
between the outlet and inlet (Delta T) measurement. The system includes a warning system
that reportedly alerts the operators to noncompliance with the temperature limits and
shuts down as required. Corrective actions are recorded on Work Orders. No applicable
breakdowns occurred within the last 12-months.

II.B.2.j The owner/operator shall sample the AAT scrubber liquor and analyze and record once per week
the ethylene glycol concentration of the scrubber using the test methods and procedures in 40
CFR 63, MACT Subpart O Section 63.365(e)(1). The source shall monitor and record once per
week the liquor level of the Ceilcote scrubber. Monitoring is not required during a week in which
the scrubber unit has not been operated. [40 CFR 63 Subpart O]

Status: In Compliance. Weekly Preventative Maintenance for the acid scrubbers are
conducted for all periods that the system is in operation. The ethylene glycol concentrations
are addressed by "Seq" 100 and 110.

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II.B.2.j.1 The operating parameters for scrubber-liquor in the indicated scrubber shall not exceed the
following:

A. Ceilcote scrubber liquor level 181.5 inches in tank #2 when tank #1 is completely full

B. Ethylene glycol concentration in AAT scrubber 26.7%. [40 CFR 63 Subpart O]

Status: In Compliance. The Weekly Preventative Work Order addresses the scrubber
liquor storage tank level on "Seq 30". The glycol concentration is addressed on "Seq 100".
The reviewed weekly orders indicated that the liquor levels and ethylene glycol
concentrations remained within the limits required by this Condition. Also see the attached
submitted Semi-Annual Subpart O Reports submitted for the applicable time periods.

II.B.2.k The owner/operator shall monitor and record the ethylene oxide concentration according to
Subpart O Section 63.364(e). [40 CFR 63 Subpart O, R307-401-8]

Status: In Compliance. See the applicable portions of the Weekly Preventative Work
Orders and the submitted Subpart O Reports

II.B.2.k.1 In the event of a breakdown of the instrumentation for the hourly monitoring of ethylene oxide
concentrations at the AAT adsorber exhaust, the facility shall take a daily reading at the dry bed
sampling port using a portable Photo Ionization Detector (PID) analyzer, Draeger tube, or
equivalent technology. [R307-401-8]

Status: Not Applicable. There were no breakdowns for the instrumentation used to monitor
the ethylene oxide concentrations during the last 12-month.

II.B.2.l The stack heights shall be as follows:

A. Chamber Room ventilation vents: 27 feet from ground surface

B. AAT and dry bed system stack: 45 feet from ground surface

C. Ceilcote scrubber stack: 40 feet from ground surface. [R307-401-8]

Status: In Compliance. The previous inspection memo DAQC-1543-21 provided
information indicating that the stack heights had met this requirement. The SLC Facility
Manager, Joseph Jeppson, states that both A. - the Chamber Room ventilation and C. the
Ceilcote scrubber, have been rerouted to B., the AAT and dry bed system stack, which is
now 60 feet from the ground surface.

II.B.3 Stack Requirement

II.B.3.a The owner/operator shall monitor and record ethylene oxide concentration according to MACT
Subpart O, Section 63.362(c), Section 63.362(d), and 63.364(e). The AAT scrubber shall not
have less than a 99% reduction in ethylene oxide. [40 CFR 63 Subpart O, R307-401-8]

II.B.3.a.1 Compliance Demonstration
To demonstrate compliance with the emissions limitations above, the owner/operator shall
perform stack testing on the AAT Scrubber according to the stack testing conditions contained in
this permit. [R307-165]

II.B.3.b The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]

II.B.3.b.1 Initial Test
The owner/operator shall conduct an initial stack test within 180 days after start up of combined
scrubber system. [R307-165-2]

Status: In Compliance. The initial stack test was conducted on August 25, 2021.

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II.B.3.b.2 Test Frequency
The owner/operator shall conduct subsequent emission tests within five years after the date of the
most recent emission test. The Director may require the owner/operator to perform an emission
test at any time. [R307-165-2, R307-401-8]

II.B.3.b.3 Notification
At least 60 days prior to conducting an emission test, the owner/operator shall submit a source
test protocol to the Director. The source test protocol shall include:

A. The date, time, and place of the proposed test

B. The proposed test methodologies

C. The stack to be tested

D. The procedures to be used

E. Any deviation from an EPA-approved test method

F. Explanation of any deviation from an EPA-approved test method

If directed by the Director, the owner/operator shall attend a pretest conference. [40 CFR 63,
R307-165-3, R307-401-8]

II.B.3.b.4 Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-
401-8]

II.B.3.b.5 Testing
The owner/operator shall conduct testing according to the approved source test protocol. The
Director may reject emission test data if the test did not follow the approved source test protocol
or if Director was not provided an opportunity to have an observer present at the test. [R307-165-
5, R307-401-8]

II.B.3.b.6 Test Conditions
The owner/operator shall conduct all tests while the source is operating at the maximum
production at which the source will be operated unless otherwise specified in the approved
source test protocol. During the tests, the owner/operator shall burn fuels or combinations of
fuels, use raw materials, and maintain process conditions representative of normal operations. In
addition, the owner/operator shall operate under any other relevant conditions that the Director
specifies. [R307-165-4, R307-401-8]

II.B.3.b.7 Reporting
Within 60 days after completing an emission test, the owner/operator shall submit a copy of the
test results to the Director. [40 CFR 63, R307-401-8]

II.B.3.b.8 Possible Rejection of Test Results
The Director may reject emissions test data if they are determined to be incomplete, inadequate,
not representative of operating conditions specified for the test, or if the Director was not
provided an opportunity to have an observer present at the test. [R307-165-5]

II.B.3.c Test Methods
When performing emission testing, the owner/operator shall use the appropriate EPA-approved
test methods as acceptable to the Director. Acceptable test methods for pollutants are listed
below. [R307-401-8]

II.B.3.c.1 Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other methods if approved by the Director. [R307-165]

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II.B.3.c.2 Ethylene Oxide
40 CFR 63.7 of Subpart A according to applicability in Table 1 of Subpart O, the procedure
listed in Subpart O, 63.360 through 63.367, and the test methods listed in 63.365 of Subpart O.
Temperature, flow rate, and efficiency of control device shall be determined. [R307-401]

II.B.3.c.3 Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2 or other testing methods approved by the Director. [R307-
165]

II.B.3.c.4 Calculation
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation. [R307-165, R307-401]

II.B.3.c.5 Source Operation
The production rate during all compliance testing shall be no less than 90% of the maximum
production achieved in the previous three (3) years. Maximum production rate in this AO shall
mean the production rate in one day (24 hours) at which amount of ethylene oxide is consumed.
[R307-165]

Status: In Compliance. A review of the initial stack test report indicates the requirements
of all applicable conditions were met during the stack test with EtO emissions being
reduced more than 99% from inlet to outlet for both the Ceilcote Scrubber and Ceilcote
Scrubber in series with the AAT Scrubber. See the stack test memo (DAQC-486-22) in the
source file for additional information. Stack testing will next be due in 2026.

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) JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines

Status: In Compliance. 40 CFR 60.4243 requires operating and maintaining the engine as per the
manufacturer's specifications. A contract with the manufacturer for routine maintenance is in place.
Records of the Cummins engine maintenance were available and will be kept for the life of the engine.
Any initial testing requirements should be determined by the DAQ Minor Source Engineering Section
when the pending modified AO that will add this engine to the pending permit.

MACT (Part 63) - O: Ethylene Oxide Emissions Standards for Sterilization Facilities

Status: In Compliance. The applicable requirements of this subpart have been incorporated into the AO
as conditions II.B.2.e.l, II.B.2.j, II.B.2.k, II.B.3.a, and II.B.3.c.2. In addition, see the attached submitted
Semi Annual Subpart O Reports.

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

Status: In Compliance. The operation of the 2019 Cummins C150N6 natural gas fired emergency
generator appears to currently meets the requirements of MACT Subpart ZZZZ for standard
maintenance and operation hours. Maintenance has been contracted with the manufacturer of the
engine. The generator has been installed with a non-resettable meter. An operation log that includes the
date, duration of time, purpose of operation, and the employee initials, was initiated on June 9, 2023.
The generator operated for 6.3 hours from June 9 through August 23, 2023, which would average to
25.2 hours if extended for a 12-month period. A 2021 Cummins EPA Exhaust Emission Compliance
Statement has been submitted and will remain on site for the life of the generator. See the attached
generator documents. It is expected that this generator will be added to a modified AO following the
completion of the current NOI review.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

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

Status: In Compliance. This area source rule is applicable per R307-214-2. Sources Subject to Part
63. (11) 40 CFR Part 63, Subpart O, National Emission Standards for Hazardous Air Pollutants for
Ethylene Oxide Commercial Sterilization and Fumigation Operations.

Nonattainment and Maintenance Areas for PM10: Emission Standards [R307-305]

Status: In Compliance. This area source rule is satisfied by compliance with AO condition II.B.1.c.

EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from Sterigenics US,
LLC - Ethylene Oxide Commercial Sterilization Plant on the Approval Order (AO)
DAQE-AN104350030-21, dated March 25, 2021. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
CO2 Equivalent 3927.00
Carbon Monoxide 1.20
Nitrogen Oxides 3.16
Particulate Matter - PM10 0.39
Particulate Matter - PM2.5 0.39
Sulfur Dioxide 0.02
Volatile Organic Compounds 2.16

Hazardous Air Pollutant PTE lbs/yr
Ethylene Oxide (CAS #75218) 4200
Generic HAPs (CAS #GHAPS) 120

13
PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions within the past five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: Sterigenics was not in compliance with the permitting
requirements of AN104350030-21 dated March 25, 2021 Section
II.A due to the installation of a 2019 Cummins natural gas
generator. Sterigenics, has however, submitted the required
forms to the NSR Minor Source Section to modify the AO. No
additional compliance actions are currently recommended. This
facility was compliant with the other conditions of their AO,
MACT O, and applicable UACR at the time of this inspection.
MACT ZZZZ and NSPS JJJJ provisions for the unpermitted
generator were evaluated. No non-compliant issues were
discovered during the review; however, a complete review of
these federal subparts should be performed after the engine has
been added to the pending modified permit.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Check for a new Modified AO that addresses the Reduction in
Air Contaminants request and that adds the natural gas
emergency generator.

NSR RECOMMENDATIONS: 40 CFR 63 Subpart ZZZZ and 40 CFR 60 Subpart JJJJ
requirements need to be added to the pending modified AO for
the emergency natural gas generator.

Remove II.A.22 – Nitrogen Dioxide Sterilizer as the equipment
has been permanently removed.

Evaluate the removal of Condition II.B.1.b, as the referenced
monitors are used solely to monitor indoor air for worker safety.

ATTACHMENTS: VEO, ETO gas consumption spreadsheet, Chamber 11
installation notification, AAT and Ceilcote Daily Systems Check
example records, Weekly Preventative Maintenance – Acid
Scrubbers Work Order example records, CWM Environmental
AAT Total Glycol analysis example records, Cummins natural
gas emergency generator records, and Subpart O Semi-Annual
Reports.
9/22/23, 7:15 PM State of Utah Mail - Sterigenics SLC - Chamber 11
https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1775233804761466823%7Cmsg-f:1775233804761466823&…1/1
Susan Weisenberg <[e-mail]>
Sterigenics SLC - Chamber 11
1 message
Jeppson, Joseph <[e-mail]>Fri, Aug 25, 2023 at 2:21 PM
To: Susan Weisenberg <[e-mail]>
Cc: "May, Daniel" <[e-mail]>, "Grady, Don" <[e-mail]>
Hello Susan,

The Sterigenics Salt Lake City site has completed the construction and testing of EtO sterilizer Chamber 11, identified in
paragraph II.A.12. We are now preparing to commence utilizing the chamber. Please let me know if you have any
questions or need further information.

Respectfully,

Joe Jeppson
General Manager, Salt Lake City
Sterigenics, A Sotera Health Company
5725 Harold Gatty Dr.
Salt Lake City, UT 84116
O: 801-328-9901
C: 801-698-9961
[e-mail]

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