DAQ-2024-010540

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DAQC-CI104350002-24
Site ID 10435 (B1)

MEMORANDUM

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

THROUGH: Chad Gilgen, Minor Source Compliance Section Manager

FROM: Connor Kijowski, Environmental Scientist

DATE: June 21, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County

INSPECTION DATE: April 25, 2024

SOURCE LOCATION: 5725 West Harold Gatty Drive
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: Joseph Jeppson, General Manager, Salt Lake City
801-328-9901

OPERATING STATUS: Operating normally at the time of inspection

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 eleven sterilizer chambers for
sterilization with Ethylene Oxide (EtO). A source tank scale
controls the volume of EtO pumped into the chambers. After a
proscribed 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.

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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
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 5725 West Harold Gatty Drive
Oak Brook, IL 60523 Salt Lake City, UT 84116

SIC Code: 7389: (Business Services, NEC)

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Section I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the
UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to
those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions
covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request. Unless
otherwise specified in this AO or in other applicable state and federal rules, records shall be kept
for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall,
to the extent practicable, maintain and operate any equipment approved under this AO, including
associated air pollution control equipment, in a manner consistent with good air pollution control
practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director
which may include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source. All maintenance performed
on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

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. Each condition of Section I was reviewed with source at the time of
inspection and appeared to be in compliance. This site has not been directed to submit an
Emission Inventory at this time. The AAT wet scrubber broke down and was reported as
required. No excess emissions occurred as the process emissions were routed to the dry bed
scrubber. A startup notification for Chamber 11 (item II.A.12) was submitted on
August 25, 2023. A new AO was issued on April 30, 2024, after the inspection occurred
(DAQE-AN104350031-24). While some equipment and requirements from the new AO
were reviewed with the source during the site visit, the source was evaluated based on AO
DAQE-AN104350030-21, dated March 25, 2021.

Section II: SPECIAL PROVISIONS

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

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)

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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 (AAT)
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

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.14 through II.A.17 - EtO Sterilizer Chambers 13 through 16 - have not yet
been installed.

II.A.22 - Nitrogen Dioxide Sterilizer - has been permanently removed.

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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. This equipment is included
on the recently issued AO.

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
April 2023 through March 2024 was reported as 124.6815 tons (249,363 pounds).

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. 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.

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. Monitoring devices are in place but used solely to measure
ethylene oxide for 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.

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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 stated that the Ceilcote scrubber can be properly
rerouted through the Ceilcote stack during an 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 source stated that the AAT adsorber system will be used as
described in the event of a breakdown of the Ceilcote system.
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. No Ceilcote scrubber breakdowns occurred during the previous 12 months. The source 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. The source is aware of the record requirements of any scrubber breakdowns. The AAT wet scrubber broke down during the previous 12 months and was recorded. Records of breakdowns are kept indefinitely. Refer to the Semi-Annual Subpart O Report in the attachments for more details.
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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: In Compliance. The AAT wet scrubber broke down and was reported according to
this condition. No excess emissions occurred as the process emissions were routed to the dry
bed scrubber.

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 Sterigenics Work Order, Sequence 10, as an example.

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 Sterigenics Work Order
record as an example.

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 2.0 or less with a target pH less than 1.0. Weekly preventive
maintenance is performed for the scrubber. Each aspect of maintenance is recorded on a
Sterigenics Work Order. Sequence 50 checks the pH of the scrubber solution and records
the value. All reviewed records indicated pH values were under 2.0.

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
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the following items:

A. Date

B. pH. [R307-401-8]

Status: In Compliance. See the attached Sterigenics Work Order as an example of record
keeping. Sequence 50 records the date, the equipment number, the site personnel, and the
pH value.

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
delta T was consistently greater than 5 degrees Fahrenheit. The delta T at the time of
inspection was 15 degrees Fahrenheit. An alarm system has been installed to ensure 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
was reviewed on site. The recordings provide the date, time, and delta T. 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.

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 scrubbers are conducted
for all periods that the systems are in operation. The glycol concentrations are addressed
by Sequence 100 and 110.

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

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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 Sterigenics Work Order addresses the scrubber liquor storage
tank level on Sequence 30. The glycol concentration is addressed on Sequence 100. The
reviewed weekly orders indicated that the liquor levels and ethylene glycol concentrations
remained within the limits required by this condition.

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 attached Sterigenics Work Order; see also the Semi-
Annual Subpart O Report submitted for the applicable time periods, submitted
January 26, 2024.

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 previous 12-months.

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. A previous inspection memo (DAQC-1543-21) provided
information indicating that the stack heights had met this requirement. The SLC Facility
Manager, Joseph Jeppson, stated that both A. (the Chamber Room ventilation) and C. (the
Ceilcote scrubber) has been rerouted to B. (the AAT and dry bed system stack), which is
now 60 feet from the ground surface. This condition has been updated in the newly issued
AO.

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
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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 startup of combined
scrubber system. [R307-165-2]

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

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]

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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]

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]

Status: In Compliance.

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. The most recent stack test was performed
October 5, 2023, and reviewed and approved on March 6, 2024. The stack test report
indicates a 99.9% reduction efficiency for EtO emissions (DAQC-222-24).

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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.
This generator engine is included on the recently issued AO.

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 report.

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. 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. This generator engine is
included on the recently issued AO.

AREA SOURCE RULES EVALUATION:

The following Area Source Rules were evaluated during this inspection:

Stationary Sources [R307-210]

Status: In Compliance. This area source rule is satisfied through compliance with NSPS Subpart
JJJJ listed above. Refer to the Federal Requirements section for more details.

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

Status: In Compliance. This area source rule is satisfied through compliance with MACT
Subpart ZZZZ and Subpart O. Refer to the Federal Requirements section for more details.

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.

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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

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

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN104350030-21,
dated March 25, 2021: 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. After the inspection, a new AO was issued
(DAQE-AN104350031-24) addressing this issue. No additional
compliance actions are currently recommended. This facility is
compliant with the other conditions of the AO at the time of
inspection.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Schedule inspection as this is a secured site.

NSR RECOMMENDATIONS: None at this time.

ATTACHMENTS: VEO Form, EtO Emission Totals, Sterigenics Work Orders,
Semi-Annual Subpart O Report
STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
Page_of_
EPA METHOD 9-VISIBLE EMISSION OBSERVATION FORM
~ource Name: SJ~ie,,s US
I
UC,.
Street Address: S'1'2-5 IJ,} \:\aold Gt\:\_j ~r
City/County: c-, ,. / C'
~11...-l ✓ 00 I:\: Ll\\C.C.,
Phone: <gt:)\_ 3 Z-€" _ a.qo\
Site ID: \04~
Facility: E6 O S::\er,,,:24\;o/\
Equipment/Process: 5': 'I ,,:: ,-
s.J.U' !W'S, vfV\"3et<:j 91"(,,
Control Equipment: cS'Cru~CS'
Emission Point: "~-1, c-\ u C..C.,J , kcls
Sky Conditions: Clear [ ) Partly Cloudy [ ] Overcast [ ]
Precipitation: No [ ) Yes [ )
Wind: Direction: ___ Speed: __ _ mph
Ambient Temp: °F RH: % ---
Height Relative to Observer: ---
Distance From Observer: ---
Condensed Water Vapor Present: No [ ] Yes [ ]
Attached [ ] Detached [ ]
Length of Condensed Water Vapor Plume: _____ _
Background: --------------
Sketch process unit: indicate observer position relative to
source; indicate potential emission points and/or actual
emission points.
0
DIJIN ,-,..1r1h Jfffi~
• observer
Sun ♦ Wind ► Emission Point with Plume (_)_
Observer Position x
Observer's Signature: ~ ~~---
Distrib: white-file; ca~, p=w~er/operator
oasERVATION DATE: ~ Jis I z.~
Start time: ___ Stop time: __ _
~
c
min 0 15 30 45
1
A I J.'c ....
2 /') ,LL
/ V 'J ii;;, I I . ,
3
4 ~M1S~ ~) ,
5
6
7
8
9
10
11
12
iolt1"" \v nil\-\1.A Per-,o~ ', A~r; I z,oz,:~-Mart:'1 202.t.!
COMMENTS:
/:tt:.&.1-a •, JC?f'\,S GW 5as. , ,sed
~,B2-f3 ', Suvl:br \1tp1d £\ow rgk&
-b~t , Sicu!,hcL l:i ?' 1 Row Rak
/:tt 6 2.b : (.e~l Gt•L '-~Jitrt 9 1~'-ul ,, H
~.~1., ~ AAT bv1ta. T
\/11:e.i-J ·, ScN\btr t◄fvcr 'M,\ +: ~VD< J1¥"c.l (c<t:.
v1fe,2.1,: t:60 Co/\C<•1trnM.t
I have received a copy of these observations:
SIGNATURE: 2-¥-----
Printed Name: Jo -c., ~:::f f SA'"'
R5S4119
Version STEROOO I
Location Item Number UOM --
CHAMBER II EO LB
CHAMBER! EO LB
CHAMBER2 EO LB
CHAMBER3 EO LB
CHAMBER4 EO LB
CHAMBERS EO LB
CHAMBER6 EO LB
CHAMBER7 EO LB
CHAMBERS EO LB
CHAMBER9 EO LB
CHAMBER_I0 EO LB
Sterigenics International, lnc
Gas Usage Report
Business Unit 129 Salt Lake City
Date From 3/28/2023 Date Thru 3/28/2024
Unit Of Measure Description
Pounds
Pounds
Pounds
Pounds
Pounds
Pounds
Pounds
Pounds
Pounds
Pounds
Pounds
Total Usace
Pr0"}-<--c) '?'f
Quantity
87-
20,224-
22,739-
22,454-
21,626-
JSS-
24,490-
21,762-
27.223-
4,695-
83•908•
249.,)_~
f ~AyrZOZY
4/23/2024
Page-
22:55:02 GMT
of I
~ Sterigenics.
A Sotera Health company
Sterigenics Work
Order ~ Sterigenics.
A Sotera Health company
Work Order
Work Order: 852370 (SLCEO)
WEEKLY PM-ACID SCRUBBER-NO DOWNTIME REQ'D
Status: PM Closed
Date Completed: 17/APR/2024 21:56
Completed By: OGRADY
WO Type: Preventive Maintenance
Department: MAINTENANCE
PM Code: PM-NAEO-1245
Standard WO:
Route:
Downtime Hours:
Equipment: AS001 (SLCEO)
AA T Acid Scrubber
Equipment
Activities
Task Plan Task Plan Description
Scheduled Start Date: 13/APR/2024
Scheduled End Date: 19/APR/2024
Date Started: 17/APR/2024
Date/Time Performed: 17/APR/2024 21:56
Performed By: KCOLAIZZI
Date/Time Reviewed: 24/APR/2024 17:08
Reviewed By: OGRADY
Parent Work Order:
Class: SCHMAINT
Priority:
Problem Code: PM
Assigned To:
Manufacturer:
Model:
Serial Number:
Activity
10 G-F-EO-MNT -048-WEEKLY PREVENTIVE MAINTENANCE -ACID SCRUBBERS (ALL
Trade
MAINT NA TYPES)
Checklist
Seq Description Date Updated Equipment Result Note Follow-
Updated By up WO
10 Check and record flow rate to Absorption 17/APR/
Tower 2024
21 :56
20 Perform alarm light test. 17/APR/
I
KCOLAIZZI I AS001
I I
I
KCOLAIZZI [ AS001
Value: 1500 GPM
.J.
Finding: Ok
j"---1-'--J
I
J
2024
21:56
30 Check the scrubber liquor and record the 17/APR/ KCOLAIZZI AS001
I Storage Tank level 2024
21:56
40 If liquor is shipped for recycling, record 17/APR/ KCOLAIZZI AS001
amount shipped. 2024
21:56
50 Check the scrubber liquor and record the pH 17/APR/ KCOLAIZZI AS001
(TAR GET pH 1.0 or less) 2024
21:56 -----
60 Record Inlet Temperature if the system 17/APR/ KCOLAIZZI AS001 I monitors this parameter 2024
I 21:56
Sterigenics Work
Order Run On: Apr 24, 2024 5:09:13 PM
Value: 154 INH
I I
Value: 0 GAL
j
Value: .12 pH
Value: 80 DEGF
l -l
Page: 1 of 2
.ti#WSf
'<f/j Sterigenics. Sterigenics Work
Order
~ Sterigenics® ~ A Sotera Health company
A Sotera Health company
Seq Description Date Updated Equipment Result Note
70 Record oulet Temperature if the sys I em
monitors this parameter
80 Check all pumps, pipes, seals, and rings for
leaks.
90 Check pressure relief valve for leaks or
discharge.
100 Record Glycol concentration
110 1 Ensure concentration does NOT exce;d
permit conditions
120 (Line inserted for translation requirements)
130 Record Wet scrubber outleVdry bed inlet EO
Levels (High flow system only)
140 Record Dry bed outlet EO Levels
150 Record static pressure drop across Scrubber
160 Deoxx only, validate reactor emptying cycle,
insp. correct open/close of valves
Updated By
17/APR/
2024
21:56
17/APR/
2024
21:56
17/APR/
2024
21:56
I 17/APR/
2024
I 21:56
17/APR/
1
2024
21:56
1
17/APR/
2024
21:56
17/APR/
2024 I 21:56
T I 17/APR/
2024
21:56
17/APR/
2024
21:56
17/APR/
2024
21:56
KCOLAIZZI AS001
I KCOLAIZZI / AS001
I I
KCOLAIZZI I AS001
KCOLAIZZI I AS001
I
KCOLAIZZI I AS001
KCOLAIZZI I AS001
KCOLAIZZI AS001
I
t KCOLAIZZI AS001
I
KCOLAIZZI AS001
KCOLAIZZI AS001
Print Booked Hours Labels
Sterigenics Work
Order
/Employee / Date / Total Time /
KCOLAIZZI 17/APR/2024
Run On: Apr 24, 2024 5:09:13 PM
I
Value: 95 DEGF
' Finding: Ok
T Finding: Not
1 applicable to
equipment --
I Value: 26 pct
l
Finding: Ok
I
T Completed
Value: 0 ppm
Value: 0 ppm
Value: 4 lnH20
Finding: Not
applicable to
equipment
Page: 2 of 2
t
Follow-
up WO
I
~ Sterigenicse
A Setera Health company
Sterigenics Work
Order
Work Order
Work Order: 816635 (SLCEO)
WEEKLY PM-ACID SCRUBBER-NO DOWNTIME REC'D
Status: PM Closed
Date Completed: 10/JAN/2024 22:53
Completed By: OGRADY
WO Type: Preventive Maintenance
Department: MAINTENANCE
PM Code: PM-NAEO-1245
Standard WO:
Route:
Downtime Hours:
Equipment: AS002 (SLCEO)
Ceilcote Scrubber
Equipment
Activities
Task Plan Task Plan Description
~ Sterigenics®
Y:(/ A Sotera Health company
Scheduled Start Date: 06/JAN/2024
Scheduled End Date: 12/JAN/2024
Date Started: 10/JAN/2024
Date/Time Performed: 10/JAN/2024 22:53
Performed By: KCOLAIZZI
Date/Time Reviewed: 16/JAN/2024 14:26
Reviewed By: OGRADY
Parent Work Order:
Class: SCHMAINT
Priority:
Problem Code: PM
Assigned To:
Manufacturer: CEILCOTE
Model: SPT-48-240
Serial Number: N/A
Activity
10 G-F-EO-MNT --048-WEEKLY PREVENTIVE MAINTENANCE -ACID SCRUBBERS (ALL
Trade
MAINT NA TYPES)
Checklist
Seq Description Date Updated Equipment
Updated By
10 Check and record flow rate to Absorption 110/JAN/ I KCOLAIZZI I AS002
Tower 2024
22:53
20 Perform alarm light test. 10/JAN/ KCOLAIZZI AS002
2024
22:53
30 Check the scrubber liquor and record the 10/JAN/ KCOLAIZZI AS002
Storage Tank level 2024
22:53
40 If liquor is shipped for recycling, record amount 10/JAN/ KCOLAIZZI AS002
shipped. 2024
22:53
50 Check the scrubber liquor and record the pH 10/JAN/ KCOLAIZZI AS002
(TAR GET pH 1.0 or less) 2024
22:53
60 Record Inlet Temperature if the system 10/JAN/ KCOLAIZZI I AS002
monitors this parameter 2024
22:53 1
Sterigenics Work
Order Run On: Apr 24, 2024 5:21 :53 PM
Result Note Follow-
up WO
Value: 131.7 GPM
Finding: Ok
Value: 76 INH
Value: 5000 GAL
----Value: 1.4 pH
I 1 -
I Value: 68 DEGF I 1
Page: 1 of 2
'fl) Sterigenics~
A Setera Health company
Sterigenics Work
Order 1f/) Sterigenics~
A Setera Health company
Description Date Updated Equipment Result Note Follow-
70 Record oulet Temperature if the system
monitors this parameter
80 Check all pumps, pipes, seals, and rings for
leaks.
90 Check pressure relief valve for leaks or
discharge.
100 Record Glycol concentration
110 Ensure concentration does NOT exceed
permit conditions
120 (line inserted for translation requirements)
130 Record Wet scrubber outlet/dry bed inlet EO
Levels (High flow system only)
140 Record Dry bed outlet EO Levels
150 Record static pressure drop across Scrubber
160 Deoxx only, validate reactor emptying cycle,
insp. correct open/close of valves
Updated
10/JAN/
2024
22:53
10/JAN/
2024
22:53
10/JAN/
2024 I 22:53
10/JAN/
2024
22:53
10/JAN/
2024
22:53
10/JAN/
12024
22:53
10/JAN/
2024 I 22:53
1
10/JAN/
2024
22:53
10/JAN/
2024
I 22:53
10/JAN/
2024
22:53
By
KCOLAIZZI AS002
1 KCOLAIZZI AS002
KCOLAIZZI AS002
I KCOlAIUI 1 AS002
KCOlAIUI l AS002
KCOlAIUI j AS002
KCOLAIZZI AS002
KCOLAIZZI l AS002
I
KCOlAIZZI I AS002
KCOLAIZZI AS002
1
Print Booked Hours Labels
Sterigenics Work
Order
Employee I Date I Total Time j
KCOLAIZZI 10/JAN/2024 1
Run On: Apr 24, 2024 5:21:53 PM
Value: 66 DEGF
Finding: Ok
=~~~i~~~,~~~ t j
equipment
I --f Value: 50 pct
I
I
l Finding: Ok -
j_
Completed
J --I Value: 0 ppm
Value: 0 ppm
Value: 2.4 lnH20
Finding: Not
applicable to
equipment
Page: 2 of 2
up WO
vlHHgli"f;
January 26,2024
Director, Air and Toxics Technical Enforcement program
Office of Enforcement, Compliance and Environmentat Justice
EPA Region Vlll
MailCode SENF-AT
1595 Wynkoop Sheet
Denver, CO 80202-1129
RE: 9-ummary Report- Gaseous and Opacity Excess Emission and Continuoua
f,lonitoring System Perforrnarre
Sterigenics Salt Lake City Facility - tftah Permit # DAeE-AN-i0{t50030.21
For the Period: July 1 - December g1,2D2g
Dear Director:
Per the requirements of 40 CFR $ 63. 10(eX3[vi), please accept this semi-annual Summary
Report for our Salt Lake City, Utah facility.
As provided in 40 CFR S 63.10(eX3[vii), we are submitting only the Summary Report for our
Salt Lake City facility because:
a) The total duration of excess emissions, or process or control system parameter
exceedances during the reporting period was less than 1 perc6nt of tire total operating
time, and
b) CMS downtime during the reporting period was tess than 5'percent of the totat
operating time.
In this reporting period, the Salt Lake City facility experienced a breakdown of its Advanced Air
Technologies (AAT) wet scrubber control device system. However, during the breakdown,
Process emissions were treated with the facility's dry bed conbol device Jystem as alowedbythefacility's operating permit.
Sterigenics US, LLC has reviewed applicable prwisions of the operating permit. The following
information is submitted as required in g63.10(eX3Xvi):
A) Qgmpanv Name and Address of the Affected Source:
Sterigenics US, LLC
UTAH DEPABTMENT OF
E}wl RONMENTAL OI..I,AUTY
FEB - 1 2024
DIVISION OF AIR QUAUTY
REVIEWED
Initiats: CG o^,,7' -27-?4
compriancc r,^u*fr-5ffi1 rt t ql r?/o/ ?
5725 West Harold Getty Dr.
Salt Lake City, UT 84116-3763
B) ldentificatlon of Hazardous Air pollutant:
Ethylene Oxide
2015 Spring Rd., Oak Brook, tL 50523
63G928'170O I sterigenics.com
0,,,u (cTJ.; f '^)
C) Reoortino Period Dates:
Beginning: July 01 ,2023
Ending: December 31, 2A23
D) Descriotion of Process Units:.,@ionchambersofvarioussizestosterilizemedicaldevicesand
other products'using ethylene oxide in gaseous form. Process emissions are exhausted
from tire sterilizatiori chambers through vacuum pumps to a Ceilcote acid-water scrubber
system for treatment. Process emissions from chamber backvents and aeration rooms for
dlgassing ethylene oxide from products following sterilization are treated in an AAT wet
scrubber with a dry bed catalyst system.
1E1 Emission and Ooeratino Parameter Limitations Soecified in Relevant Standards:
Control Unit Control Parameter LimitationsrSta ndards
Ceilote Scrubber Glycol liquor leveltank #2
Scrubber liquid flow rate
avg.)
Scrubber qlycol solution PH
Level<181.5 inches
80 GPM
pH < 2.0
AAT Wet Scrubber/
Dry Bed System
Glycol concentration
Scrubber liquid flow rate
avg.)
Heat exchanger temp
differential
EO conc. in dry bed exhaust
Concentration < 26.7 o/o
1500 GPM
50F
5.415 ppmv during normal
operation
Monitorino Eouipment Manufacturer and Model Number
SRI Gas Chromatograph ; Model 8610C
Date of Latest CMS Certification or Audit:
Calibrations occur weekly
TotalOoeratinq Time of Affected Source durino Reoortino Period:
4344 hours
F)
G)
H)
t)
J) CMS Performance Summarv:
2015 Spring Rd., Oak Brook, lL 60523
630-928.f700 | ,t*rigcnrcs.cor.
Emission Data Summarv:
Control Unit
Total
Duration
of Excess
Emissions
Excess
Emission
Duration
as o/o of
Total
Hours
Excess Emission Duration bY Cause
Startupl
Shutdown
Control
Equipmen
t
Problems
Process
Problems
Other
Known
Causes
Other
Unknown
Causes
AAT 0hr 0o/o 0 0 0 0 0
Ceilcote 0hr 0o/o 0 0 0 0 0
There were no CMS outages of the emission oontrolsystems during the period'
K) Descfiption of chanqes in cMS. Process€s or contrcls since Last Reoortino Period:
No changes to rePort.
L) ResDonsibleOfficid qertificali:on:i
Based on the information and belief formed after reasonable inquiry, the statements and
information in this report are tue, accurate, and complete'
Wagner
Vice President - Environmentral Health & Safety
M) Pate of Reoort:
January 2A,2024
lf you have any questions regarding this repor! please contract me at [phone] or
soeorgacoo@Sterioenics. com
Sincerely,
Stelgia GeorgacoPoulos
Maniger, Environmental Health & Safety
Cc: Mr. BrYce Bird, Director
UDEQ Division of AirQualitY
195 North 1950West
P.O. Box'1448120
Salt Lake CitY, UT 84.114-48,20
Joseph Jeppson - SLC Facility General Manager
2015 Spring Rd.. Oak Brook, lL 60523
63&928-1700 | sterig€nics.com