DAQ-2024-005228

1

DAQC-222-24
CAERS ID 10435 (B4)
MEMORANDUM

TO: STACK TEST FILE – STERIGENICS US, LLC - Ethylene Oxide Commercial
Sterilization Plant – Salt Lake County

THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager

FROM: Kyle Greenberg, Environmental Scientist

DATE: March 6, 2024

SUBJECT: Sources: Ethylene oxide emission-control system - Scrubber
Contact: Daniel May: 262-930-5372
Location: 4201 West 700 South, Salt Lake City, UT 84104
Test Contractor: ECSI, Inc.
Permit/AO#: DAQE-AN104350030-21 dated March 25, 2021
Action Code: TR
Subject: Review of Stack Test Report dated November 3, 2023

On November 3, 2023, DAQ received a test report for the above listed unit. Testing was performed
October 5, 2023, to demonstrate compliance with the emission limits found in condition II.B.3.a of
Approval Order DAQE-AN104350030-21. The calculated test results are:

Source Test
Date
Test
Method
Pollutant Tester Results DAQ Results Limits
Ethylene
oxide
emission-
control system
– Scrubber
Backvents Oct. 5,
2023
CARB
Method
431
ethylene
oxide
99.953%
Reduction
Efficiency
99.972%
Reduction
Efficiency
99% or Greater
Reduction
Efficiency
Ethylene
oxide
emission-
control system
– Scrubber
Aeration Cells
CARB
Method
431
ethylene
oxide
99.946%
Reduction
Efficiency
99.946%
Reduction
Efficiency
99% or Greater
Reduction
Efficiency

DEVIATIONS: None.

CONCLUSION: The stack test report appears to be acceptable.

RECOMMENDATION: It’s recommended the emissions from the Ethylene oxide emission-
control system be considered to have been in compliance with the
emission limits of the Approval Order, during the time of testing.

ATTACHMENTS: DAQ stack test review Excel Spreadsheets; Sterigenics US’ Test Report.

Sterigenics US, LLC Sterigenics US, LLC
Ethylene Oxide Commercial Sterilization Plant Ethylene Oxide Commercial Sterilization Plant
Salt Lake County, Utah Salt Lake County, Utah
Scrubber - Backvents Scrubber - Backvents
Test Date: 10/5/2023 Test Date: 10/5/2023
Run #1 2 3 Average Run #1 2 3 Average
Start Time 9:13 10:40 13:05 Start Time 9:13 10:40 13:05
Stop Time 9:28 10:55 13:20 Stop Time 9:28 10:55 13:20
Sample Duration (minutes)15 15 15 Sample Duration (minutes)15 15 15
wet C2H4O (ppmvw)0.0062 0.0062 0.0062 0.0062 wet C2H4O (ppmvw)14.350 23.9 27.5 21.9
Run #1 2 3 Average Run #1 2 3 Average
Bws Moisture Content (%/100)0.000 0.000 0.000 0.000 Bws Moisture Content (%/100)0.000 0.000 0.000 0.000
dry C2H4O (ppmvd)0.0 0.0 0.0 0.0 dry C2H4O (ppmvd)14.4 23.9 27.5 21.9
1 2 3 Average Permit Limits
dry Outlet C2H4O (ppmvd)0.0062 0.0062 0.0062 0.0062
dry Inlet C2H4O (ppmvd)14.3500 23.8750 27.5008 21.9086
DRE % Destruction Efficancy C2H4O (ppmvd)99.957%99.974%99.977%99.972%99%
Reference Method Calculations
Field Reference Method Data (INLET)
DRE Calculations
Field Reference Method Data (OUTLET)
Reference Method Calculations
Sterigenics US, LLC Sterigenics US, LLC
Ethylene Oxide Commercial Sterilization Plant Ethylene Oxide Commercial Sterilization Plant
Salt Lake County, Utah Salt Lake County, Utah
Scrubber - Aeration Cells Scrubber - Aeration Cells
Test Date: 10/5/2023 Test Date: 10/5/2023
Run #1 2 3 Average Run #1 2 3 Average
Start Time 9:28 10:58 11:58 Start Time 9:28 10:58 11:58
Stop Time 10:28 11:58 12:58 Stop Time 10:28 11:58 12:58
Sample Duration (minutes)60 60 60 Sample Duration (minutes)60 60 60
wet C2H4O (ppmvw)0.0062 0.0062 0.0062 0.0062 wet C2H4O (ppmvw)10.089 11.925 12.733 11.6
Run #1 2 3 Average Run #1 2 3 Average
Bws Moisture Content (%/100)0.000 0.000 0.000 0.000 Bws Moisture Content (%/100)0.000 0.000 0.000 0.000
dry C2H4O (ppmvd)0.0 0.0 0.0 0.0 dry C2H4O (ppmvd)10.1 11.9 12.7 11.6
1 2 3 Average Permit Limits
dry Outlet C2H4O (ppmvd)0.0062 0.0062 0.0062 0.0062
dry Inlet C2H4O (ppmvd)10.0892 11.9250 12.7333 11.5825
DRE % Destruction Efficancy C2H4O (ppmvd)99.939%99.948%99.951%99.946%99%
Reference Method Calculations
Field Reference Method Data (INLET)
DRE Calculations
Field Reference Method Data (OUTLET)
Reference Method Calculations
ECSi

REPORT OF
AIR POLLUTION SOURCE TESTING
OF AN ETHYLENE OXIDE EMISSION-CONTROL SYSTEM
OPERATED BY STERIGENICS U.S., LLC.
IN SALT LAKE CITY, UTAH
ON OCTOBER 5, 2023

Submitted to:

UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
Division of Air Quality
150 North 1950 West
Salt Lake City, Utah 84114-4820

Submitted by:

STERIGENICS, LLC.
5725 West Harold Gatty Drive
Salt Lake City, Utah 84116

Prepared by:

ECSI, INC.
PO Box 1498
San Clemente, California 92674-1498

November 3, 2023
ECSi i
CONTACT SUMMARY

CLIENT FACILITY

Mr. Daniel May Mr. Joseph Jeppson
Director, EH&S - EO Americas General Manager
STERIGENICS US, LLC. STERIGENICS US, LLC.
2015 Spring Road, Suite 650 5725 West Harold Gatty Drive
Oak Brook, Illinois 60523 Salt Lake City, Utah 84116

Phone: [phone] Phone: [phone]
Email: [e-mail] Email: [e-mail]

TEST DATE

Thursday, October 5, 2023

REGULATORY AGENCY

Mr. Chad Gilgen
Environmental Scientist, Minor Source Compliance
UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY (UDEQ)
Department of Air Quality
150 North 1950 West
Salt Lake City, Utah 84114-4820

Phone: [phone]
Email: [e-mail]

TESTING CONTRACTOR

Daniel P. Kremer
President
ECSi, Inc.
PO Box 1498
San Clemente, California 92674-1498

Phone: [phone]
email: [e-mail]
website: www.ecsi1.com

I hereby verify that ECSi is an independent testing laboratory that meets all of the criteria outlined in
SCAQMD Rule 304(k), and that I personally review and certify all test results reported. I have performed
over 3,000 CARB Method 431 ethylene oxide source tests since 1992.

Daniel P. Kremer

ECSi ii
TABLE OF CONTENTS

PAGE NO.

CONTACT SUMMARY i

TABLE OF CONTENTS ii

LIST OF TABLES iii

LIST OF APPENDICES iv

1.0 INTRODUCTION 1

2.0 EQUIPMENT 2

3.0 TESTING 3

4.0 RULE/COMPLIANCE REQUIREMENTS 4

5.0 TEST METHOD REFERENCE 5

5.1 Summary/Introduction 5
5.2 EtO Control Efficiency Measurement 5
5.3 Sample Transport 6
5.4 GC Injection 6
5.5 GC Conditions 7
5.6 Calibration Standards 7
5.7 Sampling Duration 8
5.8 Control Efficiency Calculations 8

6.0 TEST SCENARIO 9

7.0 QA/QC 10

7.1 Field Testing Quality Assurance 10
7.2 Calibration Procedures 10

8.0 TEST RESULTS 11

TABLES 12

APPENDICES 15
ECSi iii
LIST OF TABLES

TABLE DESCRIPTION PAGE NO.

1 Ethylene Oxide Control Efficiency – Backvent 13

2 Ethylene Oxide Control Efficiency –Aeration 14

ECSi iv
LIST OF APPENDICES

APPENDIX DESCRIPTION PAGE NO.

A Calibration Data A-1

B Run #1 Chromatograms - Backvent B-1

C Run #1 Chromatograms - Aeration C-1

D Run #2 Chromatograms - Backvent D-1

E Run #2 Chromatograms - Aeration E-1

F Run #3 Chromatograms - Aeration F-1

G Run #3 Chromatograms - Backvent G-1

H Calibration Gas Certificates H-1

ECSi 1
1.0 INTRODUCTION

On Thursday, October 5, 2023, ECSi performed air pollution source testing of an ethylene oxide (EtO)
emission-control system operated by Sterigenics U.S., LLC. in Salt Lake City, Utah. The control device
tested was a two-stage Advanced Air Technologies Safe Cell emission-control system, which is currently
used to control emissions from fourteen EtO aeration cells. The purpose of the testing program was to
demonstrate continued compliance with the conditions established in the Air Quality Permit granted to
Sterigenics by the Utah Department of Environmental Quality (UDEQ).

ECSi 2
2.0 EQUIPMENT

The gas-sterilization system is comprised of ten commercial sterilizers, which are discharged through liquid-
ring vacuum pumps to a Ceilcote packed tower scrubber emission-control system, ten sterilizer exhaust
vents (backvents), which were discharged to atmosphere at the time of the test, and fourteen aeration cells,
which are discharged to an existing two-stage Advanced Air Technologies (AAT) Safe Cell emission-control
system. As an alternative emission-control scenario, the facility also has the capability to discharge the
outlet of the Ceilcote scrubber to the inlet of the AAT Safe Cell system, referred to as a “double scrub”
configuration, for maximum emissions reduction. The gas-sterilization and emission-control equipment
consist of the following:

• Six Vacudyne Gas Sterilizers, all Model 810, each comprised of a steam-heated 795 cubic foot
interior volume sterilization chamber, a recirculating vacuum pump chamber evacuation system, a
backdraft valve, and a fugitive emissions exhaust hood;

• One Vacudyne Gas Sterilizer comprised of a steam-heated 3600 cubic foot interior volume
sterilization chamber, a recirculating vacuum pump chamber evacuation system, a backdraft valve,
and a fugitive emissions exhaust hood;

• One American Sterilizer Company Gas Sterilizer, Model 1200, comprised of a steam-heated 1133
cubic foot interior volume sterilization chamber, a recirculating vacuum pump chamber evacuation
system, a backdraft valve, and a fugitive emissions exhaust hood;

• One Environmental Tectonics Corporation Gas Sterilizer, Model 1035, comprised of a steam-heated
283 cubic foot interior volume sterilization chamber, a recirculating vacuum pump chamber
evacuation system, a backdraft valve, and a fugitive emissions exhaust hood;

• One National Sterilizer Company Gas Sterilizer, comprised of a steam-heated 35 cubic foot interior
volume sterilization chamber, a recirculating vacuum pump chamber evacuation system, a backdraft
valve, and a fugitive emissions exhaust hood

• Fourteen Aeration Chambers, each comprised of a heated aeration chamber and a chamber
exhaust system.

ECSi 3
Sterilizer vacuum pump emissions are be controlled by:

• One Ceilcote packed tower chemical scrubber, equipped with: a reaction/interface column, 29’ 4”
high, 48” in diameter, with a 20’ bed of #1 Tellerette packing; a 150 GPM scrubber fluid recirculation
system; and two 17,000-gallon reaction/storage tanks.

Aeration emissions are controlled by:

One two-stage Advanced Air Technologies Safe Cell emission-control system, comprised of a packed-tower
chemical scrubber (SC1), equipped with a packed reaction/interface column, a scrubber fluid recirculation
system, and a scrubber fluid reaction/storage tank, and a dry bed reactor/scrubber (SC2), comprised of a
bank of solid-bed reaction vessels, connected in parallel, installed downstream of SC1 and upstream of a
dedicated blower system.
ECSi 4
3.0 TESTING

EtO source testing was conducted in accordance with the procedures outlined in CARB Method 431, the
USEPA approved method specified in 40 CFR, Part 63.365, subpart O. EtO concentration measurement for
each test run was conducted simultaneously at the inlet and outlet of the AAT Safe Cell System during
chamber backvent, and during a one-hour interval of the 24-hour aeration process. A total of three chamber
backvent test runs, and three one-hour aeration test runs, were performed.

During backvent and aeration testing, EtO concentration at the inlet and the outlet of the AAT Safe Cell
System was determined using direct source sample injection into the gas chromatograph (GC). All
backvent and aeration testing was performed using freshly sterilized product. The testing program was
conducted in accordance with the procedures outlined in the following sections.

ECSi 5
4.0 RULE/COMPLIANCE REQUIREMENTS

The EtO gas-sterilization system at Sterigenics U.S., LLC. was tested to evaluate compliance with the
requirements specified in the TCEQ Permit. The current testing was performed to demonstrate continued
compliance with the following requirement:

• Aeration and backvent emissions must be discharged to control equipment which achieves an EtO
emission-reduction efficiency of at least 99.0%.

Testing is required to demonstrate compliance with these requirements. Source testing of the AAT Safe
Cell System is required once every 5 years.
ECSi 6
5.0 TEST METHOD REFERENCE

5.1 INTRODUCTION

EtO source testing was conducted in accordance with the procedures outlined in CARB Method 431, the
USEPA approved method specified in 40 CFR, Part 63.365, subpart O. EtO concentration measurement for
each test run was conducted simultaneously at the inlet and outlet of the AAT Safe Cell System during
chamber backvent, and during a one-hour interval of the 24-hour aeration process. A total of three chamber
backvent test runs, and three one-hour aeration test runs, were performed.

During backvent and aeration testing, EtO concentration at the inlet and the outlet of the AAT Safe Cell
System were determined using direct source sample injection into the gas chromatograph (GC). All
backvent and aeration testing was performed using freshly sterilized product.

Operation and documentation of process conditions was performed by personnel from Sterigenics U.S.,
LLC. using existing monitoring instruments installed by the manufacturer of the equipment to be tested. In
accordance with TCEQ requirements, and the procedures established in USEPA 40 CFR, Part 63.365,
Subpart O, the following parameter was recorded: scrubber liquor level.

5.2 CONTROL EFFICIENCY MEASUREMENT

During backvent and aeration testing, EtO concentration at the inlet and outlet of the AAT Safe Cell System
was determined using direct source sample injection into the GC. Since the source gas flow is identical at
the inlet and outlet of the AAT Safe Cell System control-efficiency of EtO during aeration and backvent was
calculated by comparing the concentration of EtO vented to the system inlet to the concentration of EtO
vented from the system outlet.

CARB Method 431, Appendix A, specifies that AAT Safe Cell System emission-control devices may be
tested, and control efficiency determined, without volumetric flow measurement as long as the following
criteria are met:
1) There is no dilution between the inlet and outlet sampling locations
2) There is identical flow at the inlet and outlet sampling locations, and
3) There is constant flow throughout the duration of the compliance test.
ECSi 7

These conditions were all met during the testing performed at Sterigenics. There is no dilution, and no
introduction of any outside source of airflow into the AAT system between the inlet and outlet sampling
ports. Further, prior years’ testing has exhaustively proven that the inlet and outlet volumetric flows are
identical.

During backvent and aeration, vented gas was analyzed by an SRI, Model 8610, portable gas
chromatograph (GC), equipped with the following: dual, heated sample loops and injectors; dual columns;
and dual detectors. A flame ionization detector (FID) was used to quantify inlet EtO concentration, and a
photoionization detector (PID) was used to quantify low-level EtO concentration at the emission-control
device outlet.

5.3 SAMPLE TRANSPORT

Source gas was pumped to the GC at approximately 2000 cubic centimeters per minute (cc/min) from the
sampling ports through two lengths of Teflon® sample line, each with a nominal volume of approximately 75
cubic centimeters (cc) and an outer diameter of 0.25 inch. At the inlet, the sampling port was located in the
common backvent/aeration discharge duct, upstream of the oxidizer. At the outlet of the AAT Safe Cell
System, sampling ports were located in the exhaust stack downstream of the catalyst bed.

5.4 GC INJECTION

Source-gas samples were then injected into the GC which was equipped with two heated sampling loops,
each containing a volume of approximately 2cc and maintained at 100 degrees Celsius (C). Injections
occurred at approximately five-minute intervals during aeration testing, and at approximately one-minute
intervals during the backvent testing. Helium was the carrier gas for both the FID and PID.

5.5 GC CONDITIONS

The packed columns for the GC were both operated at 90 degrees C. The columns were stainless steel, 6
feet long, 0.125-inch outer diameter, packed with 1 percent SP-1000 on 60/80 mesh Carbopack B. During
the analysis, the FID was operated at 250 degrees C. The support gases for the FID were helium (99.999%
pure), hydrogen (99.995% pure) and air (99.9999% pure). Any unused sample gas was vented from the
GC system back to the inlet of the control device being tested.
ECSi 8

5.6 CALIBRATION STANDARDS

The FID was calibrated for mid-range part-per-million-by-volume (ppmv) level analysis using gas proportions
similar to the following:

1) 100 ppmv EtO, balance nitrogen
2) 50 ppmv EtO, balance nitrogen (audit gas)
3) 10 ppmv EtO, balance nitrogen
4) 1 ppmv EtO, balance nitrogen

The PID was calibrated for low-range ppmv level analyses using gas proportions similar to the following:

1) 100 ppmv EtO, balance nitrogen
2) 50 ppmv EtO, balance nitrogen (audit gas)
3) 10 ppmv EtO, balance nitrogen
4) 1 ppmv EtO, balance nitrogen

Each of these calibration standards was in a separate, certified manufacturer's cylinder. Copies of the
calibration gas laboratory certificates are attached as Appendix H.

5.7 SAMPLING DURATION

Backvent testing was performed in conjunction with normal production operations, during the chamber
exhaust venting which is conducted for each sterilization chamber upon conclusion of the sterilization cycle,
immediately prior to and during chamber unloading. Backvent sampling duration was 15 minutes for each of
the three test runs.

Since aeration is a 24-hour process at this facility, with constant discharge flow from the aeration chambers
to the emission-control system, aeration testing consisted of three 1-hour test runs. Each test run was
performed with freshly sterilized product in the aeration chambers.

ECSi 9
5.8 CONTROL-EFFICIENCY CALCULATIONS

Control efficiency of EtO was calculated for aeration and backvent, using the following CARB-approved
equation:

Efficiency = (Ci - Co / Ci)(100)

Which is a mathematical simplification of the following equation from CARB Method 431, with the identical
inlet/outlet flow value removed:

Efficiency = (Wi - Wo / Wi)(100)
Where:
Wi = Mass flow rate to the control device inlet, pounds, calculated as (Ci)(Fi)
Where:
Ci = EtO concentration at the control device inlet
Fi = Flow rate at the control device inlet
Wo = Mass flow rate from the control device outlet, pounds, calculated as (Co)(Fo)
Where:
Co = EtO concentration at the control device outlet
Fo = Flow rate at the control device outlet

Results of the control-efficiency testing are presented in Section 8.0, and in Tables 1 and 2.
ECSi 10
6.0 TEST SCENARIO

The backvent and aeration testing was performed during normal process load conditions. Three backvent
and three aeration test runs were conducted in series to verify the performance of the emission-control
device. The testing schedule was as follows:

1) Testing equipment was set up and calibrated.
2) Backvent Test Run #1 was conducted with one freshly sterilized production load. Sampling was
performed at the inlet and the outlet of the AAT Safe Cell System.
3) Aeration Test Run #1 was conducted with freshly sterilized product in aeration. Sampling was
performed at the inlet and the outlet of the AAT Safe Cell System.
4) Backvent Test Run #2 was conducted with freshly sterilized product in aeration. Sampling was
performed at the inlet and the outlet of the AAT Safe Cell System.
5) Aeration Test Run #2 was conducted with one freshly sterilized production load. Sampling was
performed at the inlet and the outlet of the AAT Safe Cell System.
6) Aeration Test Run #3 was conducted with freshly sterilized product in aeration. Sampling was
performed at the inlet and the outlet of the AAT Safe Cell System.
7) Backvent Test Run #3 was conducted with one freshly sterilized production load. Sampling was
performed at the inlet and the outlet of the AAT Safe Cell System.
8) Post calibration check was performed, testing equipment was packed.

ECSi 11
7.0 QA/QC

7.1 FIELD TESTING QUALITY ASSURANCE

At the beginning of the test, the sampling system was leak checked at a vacuum of 15 inches of mercury.
The sampling system was considered leak free when the flow indicated by the rotameters fell to zero.

At the beginning of the test, a system blank was analyzed to ensure that the sampling system was free of
EtO. Ambient air was introduced at the end of the sample line and drawn through the sampling system line
to the GC for analysis. The resulting chromatogram also provided a background level for non-EtO
components (i.e. ambient air, carbon dioxide, water vapor) which are present in the source gas stream due
to the ambient dilution air which is drawn into the emission-control device, and due to the destruction of EtO
by the emission-control device which produces carbon dioxide and water vapor. This chromatogram,
designated AMB, is included with the calibration data in Appendix A.

7.2 CALIBRATION PROCEDURES

The GC system was calibrated prior to testing. The pre-test calibration procedure included triplicate
injections of each concentration of calibration gas, for each detector. The lowest concentration of calibration
gas was injected 7-10 times for the detector used at the outlet sampling point, as part of the method
detection limit (MDL) determination for the test. The MDL calculations were performed using a spreadsheet
provided to ECSi by Ned Shappley of the USEPA Measurement Technology Group, in accordance with
USEPA Method 301. The resulting calibration data was entered into the Peaksimple II analytical software,
and a calibration curve for the test was established for each detector.

A gas cylinder of similar composition as the calibration gases, but certified by a separate supplier, was used
to verify calibration gas composition and GC performance (audit gas). This gas was used as a calibration
check at the test’s midpoint, and at the test’s conclusion, to verify that the Peaksimple calibration curve for
each detector was still accurate within 10% of the mean values established in the multipoint calibration.

All calibration gases and support gases used were of the highest purity and quality available. A copy of the
laboratory certification for each calibration gas is attached as Appendix H.
ECSi 12
8.0 TEST RESULTS

The AAT Safe Cell System was found to have an average EtO control efficiency of 99.953 percent for
backvent, and an average EtO control efficiency of 99.946 percent for aeration. In accordance with state
and federal requirements, backvent and aeration discharge streams must be vented to control equipment
with an EtO emission-reduction efficiency of at least 99 percent. The AAT Safe Cell System met this
requirement.

The test results are summarized in Tables 1 and 2. These tables include results for EtO control efficiency of
the emission-control device. Chromatograms and chromatographic supporting data are attached as
Appendices A through G.

ECSi 13

TABLES
TABLE 1
ETHYLENE OXIDE CONTROL EFFICIENCY - BACKVENT
OF AN AAT SAFE CELL ETHYLENE OXIDE EMISSION CONTROL SYSTEM
OPERATED BY STERIGENICS, INC.
IN SALT LAKE CITY, UTAH
ON OCTOBER 5, 2023
RUN INJECTION INLET ETO OUTLET ETO ETO CONTROL
NUMBER TIME CONC. (PPM)(1)CONC. (PPM)(2)EFFICIENCY
1(3) 914 80.2 0.0062 99.992
1 915 9.67 0.0062 99.936
1 916 9.34 0.0062 99.934
1 918 8.90 0.0062 99.930
1 919 8.83 0.0062 99.930
1 920 8.87 0.0062 99.930
1 921 8.70 0.0062 99.929
1 922 8.78 0.0062 99.929
1 924 8.65 0.0062 99.928
1 925 8.70 0.0062 99.929
1 926 8.60 0.0062 99.928
1 927 8.79 0.0062 99.929
1 928 8.52 0.0062 99.927
2(4) 1041 134 0.0062 99.995
2 1043 23.5 0.0062 99.974
2 1044 14.1 0.0062 99.956
2 1045 13.2 0.0062 99.953
2 1046 13.4 0.0062 99.954
2 1047 13.0 0.0062 99.952
2 1048 13.1 0.0062 99.953
2 1049 12.8 0.0062 99.952
2 1050 12.7 0.0062 99.951
2 1052 11.8 0.0062 99.947
2 1053 12.5 0.0062 99.950
2 1054 12.4 0.0062 99.950
3(5) 1306 9.41 0.0062 99.934
3 1307 124 0.0062 99.995
3 1309 25.8 0.0062 99.976
3 1310 22.3 0.0062 99.972
3 1311 21.3 0.0062 99.971
3 1312 19.8 0.0062 99.969
3 1313 19.1 0.0062 99.968
3 1314 18.1 0.0062 99.966
3 1315 17.3 0.0062 99.964
3 1317 18.2 0.0062 99.966
3 1318 17.1 0.0062 99.964
3 1319 17.6 0.0062 99.965
TIME-WEIGHTED AVERAGE: 21.70 0.0062 99.953
UDEQ REQUIRED CONTROL EFFICIENCY: 99%
Notes:
(1) - PPM = parts per million by volume
(2) - 0.0062 ppm was the method detection limit on the day of the test, results with this value are reported as <0.0062 ppm.
(3) - Backvent Phase Test Run #1 started at 09:13, ended at 09:28.
(4) - Backvent Phase Test Run #2 started at 10:40, ended at 10:55.
(5) - Backvent Phase Test Run #3 started at 13:05, ended at 13:20.
ECSi
TABLE 2
ETHYLENE OXIDE CONTROL EFFICIENCY - AERATION
OF AN AAT SAFE CELL ETHYLENE OXIDE EMISSION CONTROL SYSTEM
OPERATED BY STERIGENICS, INC.
IN SALT LAKE CITY, UTAH
ON OCTOBER 5, 2023
RUN INJECTION INLET ETO OUTLET ETO ETO CONTROL
NUMBER TIME CONC. (PPM)(1)CONC. (PPM)(2)EFFICIENCY
1(3) 930 8.98 0.0062 99.931
1 935 9.40 0.0062 99.934
1 940 9.97 0.0062 99.938
1 945 9.93 0.0062 99.938
1 950 9.89 0.0062 99.937
1 955 10.1 0.0062 99.939
1 1000 10.0 0.0062 99.938
1 1005 10.0 0.0062 99.938
1 1010 10.2 0.0062 99.939
1 1015 11.0 0.0062 99.944
1 1020 10.8 0.0062 99.943
1 1025 10.8 0.0062 99.943
2(4) 1100 10.9 0.0062 99.943
2 1105 10.9 0.0062 99.943
2 1110 10.0 0.0062 99.938
2 1115 11.4 0.0062 99.946
2 1120 12.1 0.0062 99.949
2 1125 12.6 0.0062 99.951
2 1130 12.1 0.0062 99.949
2 1135 12.4 0.0062 99.950
2 1140 12.3 0.0062 99.950
2 1145 12.6 0.0062 99.951
2 1150 12.7 0.0062 99.951
2 1155 13.1 0.0062 99.953
3(5) 1200 13.4 0.0062 99.954
3 1205 13.5 0.0062 99.954
3 1210 13.1 0.0062 99.953
3 1215 13.3 0.0062 99.953
3 1220 13.3 0.0062 99.953
3 1225 13.2 0.0062 99.953
3 1230 12.2 0.0062 99.949
3 1235 12.4 0.0062 99.950
3 1240 12.2 0.0062 99.949
3 1245 12.0 0.0062 99.948
3 1250 12.2 0.0062 99.949
3 1255 12.0 0.0062 99.948
TIME-WEIGHTED AVERAGE: 11.58 0.0062 99.946
UDEQ REQUIRED CONTROL EFFICIENCY: 99%
Notes:
(1) - PPM = parts per million by volume
(2) - 0.0062 ppm was the method detection limit on the day of the test, results with this value are reported as <0.0062 ppm.
(3) - Aeration Phase Test Run #1 started at 09:28, ended at 10:28.
(4) - Aeration Phase Test Run #2 started at 10:58, ended at 11:58.
(5) - Aeration Phase Test Run #3 started at 11:58, ended at 12:58.ECSi
ECSi 14

APPENDICES
ECSi A-1

APPENDIX A

Calibration Data
ECSi B-1

APPENDIX B

Run #1 Chromatograms - Backvent
ECSi C-1

APPENDIX C

Run #1 Chromatograms - Aeration
ECSi D-1

APPENDIX D

Run #2 Chromatograms - Backvent
ECSi E-1

APPENDIX E

Run #2 Chromatograms - Aeration
ECSi F-1

APPENDIX F

Run #3 Chromatograms - Aeration
ECSi G-1

APPENDIX G

Run #3 Chromatograms - Backvent
ECSi H-1

APPENDIX H

Gas Certifications