DAQ-2024-004981

Small Source Registration

DAQE-EN161900001-24

{{$d1 }}

Nick Crosby
Utah Public Health Laboratory
4431 South 2700 West
Taylorsville, UT 84129
[e-mail]

Dear Mr. Crosby:

Re: Request for Evaluation of Compliance with Rule R307-401-9, UAC: Small Source Exemption
Project Fee Code: N161900001

On January 3, 2024, the Division of Air Quality (DAQ) received your request for a small source
exemption for Utah Public Health Laboratory - Cremation Facility. The source is located at 4431 South
2700 West, Taylorsville, Salt Lake County. DAQ has determined the small source exemption applies to
the source, as long as the equipment and associated processes operate as specified in the registration
request.

The small source exemption does not exempt a source from complying with other applicable federal,
state, and local regulations and the current Utah Administrative Code. Based on the emissions that you
submitted to DAQ with your registration request, Utah Public Health Laboratory - Cremation Facility is
not required to obtain an approval order under R307-401. If you change your operation such that there is
an increase in emissions, we recommend that you notify us, as an approval order may be required.

As authorized by the Utah Legislature, the fee for issuing this small source exemption is a one-time filing
fee in addition to the actual time spent by the review engineer and all other staff on the project. Payment
should be sent to DAQ upon receipt of the invoice.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

" / 2 / 6 Ú Û Ù Û Ý
DAQE-EN161900001-24
Page 2
Thank you for registering your source with the DAQ. If you have any additional questions, please contact
Dylan Frederick at [phone] or [e-mail].

Bryce C. Bird
Director

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

BCB:ADH:DF:jg

{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#s=Sig_es_:signer1:signature}}

1/31/24, 3:05 PM State of Utah Mail - Public Health Laboratory Clarifications
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r-1352739195058151629&simpl=msg-a:r63633614289061…1/2
Dylan Frederick <[e-mail]>
Public Health Laboratory Clarifications
4 messages
Dylan Frederick <[e-mail]>Wed, Jan 24, 2024 at 12:42 PM
To: "Nicholas Crosby (DHHS)" <[e-mail]>
Good afternoon,
I wanted to reach out to you regarding the application sent to DAQ on December 29th. I've been processing this request,
and after a review by management, I've received the following requests:
1. Can you clarify whether this was a notice of intent application for a permit or a small source exemption request?
Because both forms were submitted in the application my manager wanted this to be cleared up
2. The process is not well defined, so we need a description of the activities going on at the facility that provides more
detail on how emissions are generated at the facility.
3. Combustion emissions for the facility were not estimated. Please provide an estimate for combustion emissions from
burning either natural gas or fuel oil. I can provide some guidance on this for clarity if you'd like, feel free to give me a call.
It would be helpful if you could summarize all emissions in a table or on form 5 of the application you submitted previously.
Let me know if you have any questions, thank you.
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Nicholas Crosby (DHHS) <[e-mail]>Fri, Jan 26, 2024 at 8:00 AM
To: Dylan Frederick <[e-mail]>
Thank you for letting me know, I am sorry for the delayed response, but I have been out sick.
1. This is a small source exemption request. I was not sure after our call if I needed to submit both, but the duplication of
information should have given me a hint.
2. Would this work? The Utah Public Health Laboratory performs diagnostic testing on animal heads and small full body
animal carcasses for rabies. In this process, we take a small amount of tissue from the body mass and run the testing
protocol. The remaining material is stored for a time in frozen conditions while waiting for test results. Positive samples
are sent to CDC. The remaining material needs to be rendered inert. This process will be used to take the material left
over from diagnostic testing and remove any pathogenic material and reduce the remains to white ash. We also process
all newborn bloodspot cards and run our panel of testing on the cards to detect a set panel of issues. The cards take a
small amount of dried blood for the test, and the remaining material is kept for retesting purposes. After a mandated
period of time, the cards are destroyed. The process is to deidentify to the fullest extent, the cards, not to render inert the
material, at this point it is non-pathogenic. The process again is to generate white ash free from information or biological
components.
3. I was unsure of this, we will be using natural gas for combustion. Is there a conversion factor that you would like me to
use based on the BTU, or another calculation that you would suggest. I am open to another call next week if you are
available.
1/31/24, 3:05 PM State of Utah Mail - Public Health Laboratory Clarifications
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r-1352739195058151629&simpl=msg-a:r63633614289061…2/2

[Quoted text hidden]
--
Thank you,
Nick Crosby
Safety Officer
he/him
C: 385.226.2728
[e-mail]
https://uphl.utah.gov/

*************** IMPORTANT MESSAGE ***************
This message, including any attachments, may contain confidential information intended for a specific individual and
purpose, and is protected by law. If you are not the intended recipient, delete this message, including from trash, and
notify me by telephone or email.
If you are not the intended recipient, any distributions or copying of this message, or the taking of any action based on its
content is strictly prohibited.
Dylan Frederick <[e-mail]>Fri, Jan 26, 2024 at 5:47 PM
To: "Nicholas Crosby (DHHS)" <[e-mail]>
Nick,
Thanks for getting these back to me. You've answered the first question, for the second question I might simplify this a bit
to state that material is rendered inert via the cremation chamber, but this also answers my question.
For the natural gas combustion, you can use the attached spreadsheet. The spreadsheet is for natural gas boilers, but
uses emission factors that are for natural gas combustion in general. Input the BTU in MMBtu at the top and the number
of hours annually it will run.
[Quoted text hidden]
DAQ-2018-016584.xlsx
80K
Nicholas Crosby (DHHS) <[e-mail]>Mon, Jan 29, 2024 at 9:20 AM
To: Dylan Frederick <[e-mail]>
Based on 573 CFH, the max hours per year and using 42 1.4-1 for NOX uncontrolled post and the manufacturer testing
average for CO.
DAQ-2018-016584 UPHL.xlsx
[Quoted text hidden]
[Quoted text hidden]
Equipment Details
Rating 1 MMBtu/hour
Operational Hours 1,440 hours/year
Firing Normal
Criteria Pollutant
Concentration
(ppm)
Emission
Factor
(lb/10^6 scf)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
NOX 190 0.14 0.10
CO 15.5 0.01 0.00
PM10 7.6 0.00 0.00
PM2.5 7.6 0.00 0.00
SO2 0.6 0.00 0.00
VOC 5.5 0.00 0.00
Lead 0.0005 0.00 0.00
HAP 0.00 0.00 See Below
Green House Gas Pollutant
Global
Warming
Potential
Emission
Factor
(lb/10^6 scf)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)ReferenceCO2 (mass basis)1 120,000 69 50
Methane (mass basis)25 2.3 0.00 0.00N2O (mass basis)298 2.2 0.00 0.00
CO2e 50
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
2-Methylnaphthalene 2.40E-05 1.39E-08 9.98E-09
3-Methylchloranthrene 1.80E-06 1.04E-09 7.48E-10
7,12-Dimethylbenz(a)anthracene 1.60E-05 9.24E-09 6.65E-09
Acenaphthene 1.80E-06 1.04E-09 7.48E-10
Acenaphthylene 1.80E-06 1.04E-09 7.48E-10
Anthracene 2.40E-06 1.39E-09 9.98E-10
Benz(a)anthracene 1.80E-06 1.04E-09 7.48E-10
Benzene 2.10E-03 1.21E-06 8.73E-07
Benzo(a)pyrene 1.20E-06 6.93E-10 4.99E-10
Benzo(b)fluoranthene 1.80E-06 1.04E-09 7.48E-10
Benzo(g,h,i)perylene 1.20E-06 6.93E-10 4.99E-10
Benzo(k)fluoranthene 1.80E-06 1.04E-09 7.48E-10
Chrysene 1.80E-06 1.04E-09 7.48E-10
Dibenzo(a,h)anthracene 1.20E-06 6.93E-10 4.99E-10
Dichlorobenzene 1.20E-03 6.93E-07 4.99E-07
Fluoranthene 3.00E-06 1.73E-09 1.25E-09
Fluorene 2.80E-06 1.62E-09 1.16E-09
Formaldehyde 7.50E-02 4.33E-05 3.12E-05
Hexane 1.80E+00 1.04E-03 7.48E-04
Indeno(1,2,3-cd)pyrene 1.80E-06 1.04E-09 7.48E-10
Naphthalene 6.10E-04 3.52E-07 2.54E-07
Phenanathrene 1.70E-05 9.82E-09 7.07E-09
Pyrene 5.00E-06 2.89E-09 2.08E-09
Toluene 3.40E-03 1.96E-06 1.41E-06
Arsenic 2.00E-04 1.15E-07 8.32E-08
Beryllium 1.20E-05 6.93E-09 4.99E-09
Cadmium 1.10E-03 6.35E-07 4.57E-07
Chromium 1.40E-03 8.08E-07 5.82E-07
Cobalt 8.40E-05 4.85E-08 3.49E-08
Manganese 3.80E-04 2.19E-07 1.58E-07
Mercury 2.60E-04 1.50E-07 1.08E-07
Nickel 2.10E-03 1.21E-06 8.73E-07
Selenium 2.40E-05 1.39E-08 9.98E-09
AP-42 Table 1.4-3
AP-42 Table 1.4-4
Natural Gas-Fired Boilers & Heaters
Manufacturer Data
or AP-42 Table 1.4-1
AP-42 Table 1.4-2
AP-42 Table 1.4-2
&
Table A-1 to
Subpart A of Part 98
Emission Factor
(lb/10^6 scf)
Page 1 of Version 1.0 November 29, 2018
Dylan Frederick (Jan 23, 2024 10:24 MST)
4
1/10/2024