DAQ-2025-001846

DAQE-AN116440010-25

{{$d1 }}

Pedro Villarreal
ICU Medical, Inc.
4455 South Atherton Drive
Taylorsville, UT 84123
[e-mail]

Dear Mr. Villarreal:

Re: Approval Order: Modification to Approval Order DAQE-AN116440009-23 to Increase the VOC
and HAP Emissions Limits for the Medical Device Manufacturing Process
Project Number: N116440010

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on October
3, 2024. ICU Medical, Inc. must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Mr. Tim DeJulis, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as the
DAQE number shown on the upper right-hand corner of this letter. No public comments were received on
this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:TD:jg

cc: Salt Lake County Health Department

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

Tim Davis
Interim Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

April 3, 2025

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN116440010-25
Modification to Approval Order DAQE-AN116440009-23 to
Increase the VOC and HAP Emissions Limits for the Medical
Device Manufacturing Process

Prepared By
Mr. Tim DeJulis, Engineer
[phone]
[e-mail]

Issued to
ICU Medical, Inc. - Salt Lake Medical Products Manufacturing

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

April 3, 2025
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 4
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-AN116440010-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
ICU Medical, Inc. ICU Medical, Inc. - Salt Lake Medical Products Manufacturing

Mailing Address Physical Address
4455 South Atherton Drive 4455 South Atherton Drive
Taylorsville, UT 84123 Taylorsville, UT 84123

Source Contact UTM Coordinates
Name: Pedro Villarreal 422,045 m Easting
Phone: [phone],503,020 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3841 (Surgical & Medical Instruments & Apparatus)

SOURCE INFORMATION
General Description
ICU Medical, Inc. (ICU) manufactures critical care medical products. Solvent bonding, cleaning,
injection molding, and final assembly are used in the manufacturing processes. As parts are assembled,
small amounts of solvent are used to bond pieces together. The solvent is stored and dispensed in small,
vapor-tight containers that dispense small droplets of solvent onto the items to be bonded. Small amounts
of VOC-containing solvent are used to clean various manufactured plastic products and equipment.
Generally, solvents are applied to rags and wiped on the products or equipment. Raw plastic products are
formed by injection molding. Plastic granules are stored in storage silos until they are pneumatically
piped to an injection mold machine storage device. The raw products include polyvinyl chloride,
polycarbonate, polypropylene, and other plastics. The VOC content of the plastic pellets is very small.
The plastic pellets are heated in the injection-molding machine and extruded into molds. Once the parts
are set and stable, they are pulled from the machine and allowed to cool before being transferred to
another part of the facility or packaged. Many of the parts are assembled into ready-to-use systems and
shipped to medical supply vendors for sale and further dispensing to hospitals.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2
NAA
Salt Lake County
Airs Source Size: B

DAQE-AN116440010-25
Page 4

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

Project Description
ICU requested a modification to Condition II.B.4.b of the AO DAQE-AN116440009-23, dated November
2, 2023, to increase the VOC emission limitations from 17.66 tpy to 26.02 tpy. ICU is also requesting to
increase the HAPs emissions limitation from evaporative activities from 0.87 tpy to 7.36 tpy, with the
overall HAPs emissions being 7.46 tpy. No other changes to the equipment list will result from this
change in VOC and HAP production.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
Ammonia 0 0.19
CO2 Equivalent 0 7041.00
Carbon Monoxide 0 4.98
Nitrogen Oxides 0 5.99
Particulate Matter - PM10 0 0.80
Particulate Matter - PM2.5 0 0.80
Sulfur Dioxide 0 0.06
Volatile Organic Compounds 8.36 26.35

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Cyanide Compounds (CAS #143339) 5 11
Ethyl Benzene (CAS #100414) 0 4
Ethylene Glycol (CAS #107211) 17 26
Formaldehyde (CAS #50000) 0 9
Generic HAPs (CAS #GHAPS) 422
Glycol Ethers (CAS #EDF109) 0 47
Hexane (CAS #110543) 39 540
Methanol (CAS #67561) 12704 12756
Methylene Chloride (Dichloromethane) (CAS #75092) 47 707
Toluene (CAS #108883) 4 138
Xylenes (Isomers And Mixture) (CAS #1330207) 114 268
Change (TPY) Total (TPY)
Total HAPs 6.46 7.46

DAQE-AN116440010-25
Page 5

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]

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 ICU Medical, Inc. Salt Lake Medical Products Manufacturing
II.A.2 Various Boilers
Capacity: <5MMBtu/hr each Fuel: natural gas

For informational purposes only
II.A.3 Emergency Generator One (1) Emergency generator Capacity: 200 kW (268 hp) Fuel: diesel Manufactured: 2023
DAQE-AN116440010-25
Page 6

II.A.4 Various Comfort Heaters Comfort heaters, gas packs, sun units, or humidifiers Capacity: <5MMBtu/hr each Fuel: natural gas For information purposes only II.A.5 Mold Cleaning Equipment Resin Residual Removal Furnace
Various solvent bonding, solvent cleaning, injection molding, and residual plastic resins removal chemicals used in the medical device manufacturing process.

SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Limitations and Requirements
II.B.1.a Visible emissions from the following emission points shall not exceed the following values:
A. Electric resin residual removal furnace - 10% opacity

B. All natural gas-fired heater/boiler exhausts - 10% opacity
C. Diesel engine exhaust - 20% opacity.
[R307-401-8]

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.1.b The owner/operator shall not burn more than five (5) pounds of resin per day in the resin residual
removal furnace. [R307-401-8]
II.B.1.b.1 To determine compliance, the owner/operator shall keep a record of the weight of resin remaining in each residual mold per day put into the resin residual removal furnace for all periods when the plant is in operation. Weight of the resin combusted in each mold shall be the total weight of the resin plus the mold minus the weight of each mold, measured with a mass balance. [R307-401-8]
II.B.2 Fuel Requirements
II.B.2.a The owner/operator shall use only natural gas as fuel in all the boilers and heaters. [R307-401-8]
II.B.2.b The owner/operator shall only use diesel fuel (fuel oil #1, #2, or diesel fuel oil additives) in the emergency generator engine. All diesel burned shall meet the definition of ultra-low sulfur diesel
(ULSD) and contain no more than 15 ppm sulfur. [R307-401-8] II.B.2.b.1 To demonstrate compliance with the diesel fuel requirements for any diesel fuel purchased, the owner/operator shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements, or the owner/operator shall obtain certification of sulfur content from the fuel supplier. [R307-401-8]
II.B.3 Engine Requirements II.B.3.a The owner/operator shall not operate the emergency generator engine on-site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]
DAQE-AN116440010-25
Page 7

II.B.3.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [R307-401-8] II.B.4 Volatile Organic Compound (VOC) Limitations
II.B.4.a The VOC content of the solvent bonding, solvent cleaning, injection molding, and residual plastic resins removal chemicals as used shall not exceed the density limits established by R307-353. High solids (low VOC content) chemicals shall not be thinned or otherwise reduced beyond manufacturers recommendations. These parameters shall be tested by using the appropriate ASTM method or another method approved by the Director. [R307-353]
II.B.4.b The owner/operator shall not emit more than the following from evaporative sources (solvent
bonding, solvent cleaning, injection molding, residual plastic resin removal, etc.) on-site:
26.02 tons of VOC per rolling 12-month period
6.38 tons of methanol per rolling 12-month period

0.35 tons of methylene chloride per rolling 12-month period
0.16 tons of hexane per rolling 12-month period
0.13 tons of xylene per rolling 12-month period

0.34 tons of acrylic acid, benzene, cumene, cyanide compounds, diethanolamine, ethyl benzene, ethylene dichloride, ethylene glycol, formaldehyde, glycol ethers, isophorone, methyl
methacrylate, naphthalene, nickel compounds, propylene oxide, toluene, and combined per
rolling 12-month period
This does not include the emissions from the natural gas and diesel combustion sources.
[R307-401-8]

II.B.4.b.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed] [R307-401-8]
II.B.4.b.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs
reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the
quantities calculated above to provide the monthly total emissions of VOCs and HAPs.
[R307-401-8]

DAQE-AN116440010-25
Page 8

II.B.4.b.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material B. The maximum percent by weight of VOCs and each HAP in each material used C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN116440009-23 dated November 2, 2023 Is Derived From NOI dated October 3, 2024 Incorporates Additional information dated December 11, 2024

DAQE-AN116440010-25
Page 9

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

The Salt Lake Tribune
Publication Name:
The Salt Lake Tribune
Publication URL:
Publication City and State:
Salt Lake City, UT
Publication County:
Salt Lake
Notice Popular Keyword Category:
Notice Keywords:
ICU medical
Notice Authentication Number:
202502241044294957791
2892905420
Notice URL:
Back
Notice Publish Date:
Sunday, February 23, 2025
Notice Content
NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been
received for consideration by the Director: Company Name: ICU Medical, Inc. Location: ICU Medical, Inc. - Salt Lake Medical Products
Manufacturing – 4455 South Atherton Drive, Taylorsville, UT Project Description: ICU Medical, Inc. (ICU) requested a modification to
Condition II.B.4.b of the Approval Order DAQE-AN116440009-23, dated November 2, 2023, to increase the VOC emission limitations from
17.66 tpy to 26.02 tpy. ICU is also requesting to increase the HAPs emissions limitation from evaporative sources 0.88 tpy to 7.37 tpy with
the overall HAPs emissions being 7.48 tpy. No other changes to the equipment list will result from this change in VOC and HAP production.
The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air
quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period.
The project proposal, estimate of the effect on local air quality, and draft Approval Order are available for public inspection and comment at
the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same
address on or before March 25, 2025, will be considered in making the final decision on the approval/disapproval of the proposed project.
Email comments will also be accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of publication of
this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a
Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and
was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the
issue. Date of Notice: February 23, 2025 SLT0031647
Back

DAQE-IN116440010-25

February 20, 2025

Pedro Villarreal
ICU Medical, Inc.
4455 South Atherton Drive
Taylorsville, UT 84123
[e-mail]

Dear Mr. Villarreal:

Re: Intent to Approve: Modification to Approval Order DAQE-AN116440009-23 to Increase the
VOC and HAP Emissions Limits for the Medical Device Manufacturing Process
Project Number: N116440010

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, Mr. Tim DeJulis, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Mr. Tim DeJulis, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:TD:jg

cc: Salt Lake County Health Department

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

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN116440010-25
Modification to Approval Order DAQE-AN116440009-23 to
Increase the VOC and HAP Emissions Limits for the
Medical Device Manufacturing Process

Prepared By
Mr. Tim DeJulis, Engineer
[phone]
[e-mail]

Issued to
ICU Medical, Inc. - Salt Lake Medical Products Manufacturing

Issued On
February 20, 2025

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#s=Sig_es_:signer1:signature}}

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 4
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 9
ACRONYMS ............................................................................................................................... 10

DAQE-IN116440010-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
ICU Medical, Inc. ICU Medical, Inc. - Salt Lake Medical Products Manufacturing

Mailing Address Physical Address
4455 South Atherton Drive 4455 South Atherton Drive
Taylorsville, UT 84123 Taylorsville, UT 84123

Source Contact UTM Coordinates
Name: Pedro Villarreal 422,045 m Easting
Phone: [phone],503,020 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3841 (Surgical & Medical Instruments & Apparatus)

SOURCE INFORMATION
General Description
ICU Medical, Inc. (ICU) manufactures critical care medical products. Solvent bonding, cleaning,
injection molding, and final assembly are used in the manufacturing processes. As parts are assembled,
small amounts of solvent are used to bond pieces together. The solvent is stored and dispensed in small,
vapor-tight containers that dispense small droplets of solvent onto the items to be bonded. Small amounts
of VOC-containing solvent are used to clean various manufactured plastic products and equipment.
Generally, solvents are applied to rags and wiped on the products or equipment. Raw plastic products are
formed by injection molding. Plastic granules are stored in storage silos until they are pneumatically
piped to an injection mold machine storage device. The raw products include polyvinyl chloride,
polycarbonate, polypropylene, and other plastics. The VOC content of the plastic pellets is very small.
The plastic pellets are heated in the injection-molding machine and extruded into molds. Once the parts
are set and stable, they are pulled from the machine and allowed to cool before being transferred to
another part of the facility or packaged. Many of the parts are assembled into ready-to-use systems and
shipped to medical supply vendors for sale and further dispensing to hospitals.
NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County SO2
NAA
Salt Lake County
Airs Source Size: B

DAQE-IN116440010-25
Page 4

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

Project Description
ICU requested a modification to Condition II.B.4.b of the AO DAQE-AN116440009-23, dated November
2, 2023, to increase the VOC emission limitations from 17.66 tpy to 26.02 tpy. ICU is also requesting to
increase the HAPs emissions limitation from evaporative activities from 0.88 tpy to 7.37 tpy with the
overall HAPs emissions being 7.48 tpy. No other changes to the equipment list will result from this
change in VOC and HAP production.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
Ammonia 0 0.19
CO2 Equivalent 0 7041.00
Carbon Monoxide 0 4.98
Nitrogen Oxides 0 5.99
Particulate Matter - PM10 0 0.80
Particulate Matter - PM2.5 0 0.80
Sulfur Dioxide 0 0.06
Volatile Organic Compounds 8.36 26.35

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Cyanide Compounds (CAS #143339) 5 11
Ethyl Benzene (CAS #100414) 0 4
Ethylene Glycol (CAS #107211) 11 20
Formaldehyde (CAS #50000) 0 9
Generic HAPs (CAS #GHAPS) 480
Glycol Ethers (CAS #EDF109) 0 47
Hexane (CAS #110543) 39 540
Methanol (CAS #67561) 12708 12760
Methylene Chloride (Dichloromethane) (CAS #75092) 40 700
Toluene (CAS #108883) 6 140
Xylenes (Isomers And Mixture) (CAS #1330207) 106 260
Change (TPY) Total (TPY)
Total HAPs 6.49 7.49

DAQE-IN116440010-25
Page 5

PUBLIC NOTICE STATEMENT
The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the intent to approve will be published in the Salt Lake Tribune and Deseret News on February 23, 2025. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

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]
DAQE-IN116440010-25
Page 6

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.
II.A THE APPROVED EQUIPMENT II.A.1 ICU Medical, Inc. Salt Lake Medical Products Manufacturing
II.A.2 Various Boilers Capacity: <5MMBtu/hr each Fuel: natural gas For informational purposes only II.A.3 Emergency Generator One (1) Emergency generator Capacity: 200 kW (268 hp) Fuel: diesel Manufactured: 2023
II.A.4 Various Comfort Heaters Comfort heaters, gas packs, sun units, or humidifiers Capacity: <5MMBtu/hr each Fuel: natural gas For information purposes only II.A.5 Mold Cleaning Equipment Resin Residual Removal Furnace Various solvent bonding, solvent cleaning, injection molding, and residual plastic resins removal chemicals used in the medical device manufacturing process.

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS II.B.1 Limitations and Requirements
II.B.1.a Visible emissions from the following emission points shall not exceed the following values: A. Electric resin residual removal furnace - 10% opacity B. All natural gas-fired heater/boiler exhausts - 10% opacity C. Diesel engine exhaust - 20% opacity. [R307-401-8]
DAQE-IN116440010-25
Page 7

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b The owner/operator shall not burn more than five (5) pounds of resin per day in the resin residual removal furnace. [R307-401-8]

II.B.1.b.1 To determine compliance, the owner/operator shall keep a record of the weight of resin remaining in each residual mold per day put into the resin residual removal furnace, for all periods when the plant is in operation. Weight of the resin combusted in each mold shall be the total weight of the resin plus the mold minus the weight of each mold, measured with a mass balance. [R307-401-8]
II.B.2 Fuel Requirements
II.B.2.a The owner/operator shall use only natural gas as fuel in all the boilers and heaters. [R307-401-8]
II.B.2.b The owner/operator shall only use diesel fuel (fuel oil #1, #2, or diesel fuel oil additives) in the
emergency generator engine. All diesel burned shall meet the definition of ultra-low sulfur diesel (ULSD) and contain no more than 15 ppm sulfur. [R307-401-8]

II.B.2.b.1 To demonstrate compliance with the diesel fuel requirements for any diesel fuel purchased, the owner/operator shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements, or the owner/operator shall obtain certification of sulfur content from the fuel supplier. [R307-401-8] II.B.3 Engine Requirements
II.B.3.a The owner/operator shall not operate the emergency generator engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]
II.B.3.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall include the
following:
A. The date the emergency engine was used

B. The duration of operation in hours
C. The reason for the emergency engine usage.
[R307-401-8]

II.B.4 Volatile Organic Compound (VOC) Limitations
II.B.4.a The VOC content of the solvent bonding, solvent cleaning, injection molding, and residual plastic resins removal chemicals as used shall not exceed the density limits established by
R307-353. High solids (low VOC content) chemicals shall not be thinned or otherwise reduced
beyond manufacturers recommendations. These parameters shall be tested by using the
appropriate ASTM method or another method approved by the Director. [R307-353]

DAQE-IN116440010-25
Page 8

II.B.4.b The owner/operator shall not emit more than the following from evaporative sources (solvent bonding, solvent cleaning, injection molding, residual plastic resins removal, etc.) on site: 26.02 tons of VOC per rolling 12-month period 6.38 tons methanol per rolling 12-month period 0.35 tons of methylene chloride per rolling 12-month period 0.27 tons of hexane per rolling 12-month period 0.13 tons of xylene per rolling 12-month period 0.24 tons of chloride, cyanide compounds, ethyl benzene, ethylene dichloride, ethylene glycol, formaldehyde, glycol ethers, isophorone, methyl methacrylate, nickel compounds, propylene oxide, toluene, and xylene combined per rolling 12-month period. This does not include the emissions from the natural gas and diesel combustion sources. [R307-401-8] II.B.4.b.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months. The owner/operator shall use a mass-balance method to
calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method:

VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]
HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]
[R307-401-8]

II.B.4.b.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8] II.B.4.b.3 The owner/operator shall keep records each month of the following:

A. The name (as per SDS) of the VOC- and HAP-emitting material
B. The maximum percent by weight of VOCs and each HAP in each material used
C. The density of each material used

D. The volume of each VOC- and HAP-emitting material used

E. The amount of VOCs and the amount of each HAP emitted from each material

F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from
each material

G. The total amount of VOCs, the total amount of each HAP, and the total amount of all
HAPs combined emitted from all materials (in tons).

[R307-401-8]

DAQE-IN116440010-25
Page 9

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN116440009-23 dated November 2, 2023 Is Derived From NOI dated October 3, 2024 Incorporates Additional information dated December 11, 2024

DAQE-IN116440010-25
Page 10

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-NN116440010-25

February 20, 2025

Salt Lake Tribune and Deseret News
Legal Advertising Dept.
P.O. Box 704055
West Valley City, UT 84170
Acct #9001399880

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Salt Lake Tribune and
Deseret News on February 23, 2025.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Wasatch Front Regional Council
cc: Salt Lake County

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

DAQE-NN116440010-25
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: ICU Medical, Inc.
Location: ICU Medical, Inc. - Salt Lake Medical Products Manufacturing – 4455 South
Atherton Drive, Taylorsville, UT
Project Description: ICU Medical, Inc. (ICU) requested a modification to Condition II.B.4.b of the
Approval Order DAQE-AN116440009-23, dated November 2, 2023, to increase
the VOC emission limitations from 17.66 tpy to 26.02 tpy. ICU is also requesting
to increase the HAPs emissions limitation from evaporative sources 0.88 tpy to
7.37 tpy with the overall HAPs emissions being 7.48 tpy. No other changes to the
equipment list will result from this change in VOC and HAP production.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality, and draft Approval Order are available for public inspection and comment at
the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before March 25, 2025, will be considered in making
the final decision on the approval/disapproval of the proposed project. Email comments will also be
accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: February 23, 2025

{{#s=Sig_es_:signer1:signature}}

DAQE-

RN116440010 February 13, 2025 Pedro Villarreal ICU Medical, Inc. 4455 South Atherton Drive
Taylorsville, UT 84123 [e-mail]
Dear Pedro Villarreal, Re: Engineer Review:
Modification to DAQE-AN116440009-23 to Increase the VOC and HAP Emissions Limits for the Medical Device Manufacturing Process Project Number: N116440010 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review permitting program. ICU Medical, Inc. should complete this review within 10 business days of receipt. ICU Medical, Inc. should contact Mr. Tim DeJulis at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Mr. Tim DeJulis at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ
will prepare an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director.
If ICU Medical, Inc. does not respond to this letter within 10 business days, the project will move forward without source concurrence. If ICU Medical, Inc. has concerns that cannot be resolved and the
project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________
(Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N116440010: ICU Medical, Inc.- Salt Lake Medical Products Manufacturing February 13, 2025 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N116440010 Owner Name ICU Medical, Inc. Mailing Address 4455 South Atherton Drive
Taylorsville, UT, 84123 Source Name ICU Medical, Inc.- Salt Lake Medical Products Manufacturing
Source Location 4455 South Atherton Drive Taylorsville, UT 84123
UTM Projection 422,045 m Easting, 4,503,020 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 3841 (Surgical & Medical Instruments & Apparatus) Source Contact Pedro Villarreal Phone Number [phone] Email [e-mail] Billing Contact Pedro Villarreal Phone Number [phone]
Email [e-mail] Project Engineer Mr. Tim DeJulis, Engineer
Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted October 3, 2024 Date of Accepted Application October 15, 2024

Engineer Review N116440010: ICU Medical, Inc.- Salt Lake Medical Products Manufacturing February 13, 2025 Page 2
SOURCE DESCRIPTION General Description
ICU Medical, Inc. (ICU) manufactures critical care medical products. Solvent bonding, cleaning, injection molding, and final assembly are used in the manufacturing processes. As parts are assembled, small amounts of solvent are used to bond pieces together. The solvent is stored and
dispensed in small vapor tight containers that dispense small droplets of solvent onto the items to be bonded. Small amounts of VOC-containing solvent are used to clean various manufactured plastic products and equipment. Generally, solvents are applied to rags and wiped on the products or equipment. Raw plastic products are formed by injection molding. Plastic granules are stored in storage silos until they are pneumatically piped to an injection mold machine storage device. The raw products include polyvinyl chloride, polycarbonate, polypropylene and other plastics. The VOC content of the plastic pellets is very small. The plastic pellets are heated in the injection-molding machine and extruded into molds. Once the parts are set and stable, they are pulled from the machine and allowed to cool before being transferred to another part of the facility or packaged. Many of the parts are assembled into ready-to-use systems and shipped to medical supply vendors for sale and further dispensing to hospitals.
NSR Classification: Minor Modification at Minor Source
Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA, Salt Lake County
SO2 NAA Salt Lake County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Project Proposal Modification to DAQE-AN116440009-23 to Increase the VOC and HAP Emissions Limits for
the Medical Device Manufacturing Process Project Description
ICU requested a modification to Condition II.B.4.b of the AO DAQE-AN116440009-23, dated November 2, 2023 to increase the VOC emission limitations from 17.66 tpy to 26.02 tpy. ICU is also requesting to increase the HAPs emissions limitation from evaporative activities from 0.88
tpy to 7.37 tpy with the overall HAPs emissions being 7.48 tpy. No other changes to the equipment list will result from this change in VOC and HAP production. EMISSION IMPACT ANALYSIS All criteria pollutants are below the modeling thresholds contained in R307-410-4. All HAP emissions are below their respective emission threshold values in R307-410-5. Therefore, no modeling is required from this
source. [Last updated October 3, 2024]

Engineer Review N116440010: ICU Medical, Inc.- Salt Lake Medical Products Manufacturing February 13, 2025 Page 3
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY) Ammonia 0 0.19 CO2 Equivalent 0 7041.00
Carbon Monoxide 0 4.98
Nitrogen Oxides 0 5.99
Particulate Matter - PM10 0 0.80
Particulate Matter - PM2.5 0 0.80
Sulfur Dioxide 0 0.06 Volatile Organic Compounds 8.36 26.35 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Cyanide Compounds (CAS #143339) 5 11
Ethyl Benzene (CAS #100414) 0 4
Ethylene Glycol (CAS #107211) 11 20
Formaldehyde (CAS #50000) 0 9 Generic HAPs (CAS #GHAPS) 480 Glycol Ethers (CAS #EDF109) 0 47
Hexane (CAS #110543) 39 540
Methanol (CAS #67561) 12708 12760
Methylene Chloride (Dichloromethane) (CAS #75092) 40 700
Toluene (CAS #108883) 6 140 Xylenes (Isomers And Mixture) (CAS #1330207) 106 260 Change (TPY) Total (TPY)
Total HAPs 6.49 7.49

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N116440010: ICU Medical, Inc.- Salt Lake Medical Products Manufacturing February 13, 2025 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding Process Equipment
This BACT analysis is for the increase in VOC and HAP emissions from the production process. VOCs emissions will increase from 17.13 tpy to 26.02 tpy and HAPs will increase from 0.88 tpy to 7.37 tpy. The controls for this increase in emissions could be a thermal oxidizer, a regenerative
thermal oxidizer, or a flare device. Use of these technologies are economically infeasible to implement. The process equipment will remain the same; therefore, maintaining visible emissions below 10% opacity and complying with all applicable requirements of R307-353 is BACT.
[Last updated February 13, 2025]
SECTION I: GENERAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

Engineer Review N116440010: ICU Medical, Inc.- Salt Lake Medical Products Manufacturing February 13, 2025 Page 5
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT II.A.1 ICU Medical, Inc. Salt Lake Medical Products Manufacturing

II.A.2 Various Boilers Capacity: <5MMBtu/hr each Fuel: natural gas For informational purposes only
II.A.3 Emergency Generator
One (1) Emergency generator Capacity: 200 kW (268 hp) Fuel: diesel
Manufactured: 2023 II.A.4 Various Comfort Heaters Comfort heaters, gas packs, sun units, or humidifiers
Capacity; <5MMBtu/hr each Fuel: natural gas For information purposes only

II.A.5 Mold Cleaning Equipment Resin Residual Removal Furnace Various solvent bonding, solvent cleaning, injection molding, and residual plastic resins removal chemicals used in the medical device manufacturing process.

Engineer Review N116440010: ICU Medical, Inc.- Salt Lake Medical Products Manufacturing February 13, 2025 Page 6
SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Limitations and Requirements
II.B.1.a Visible emissions from the following emission points shall not exceed the following values:
A. Electric resin residual removal furnace - 10% opacity B. All natural gas-fired heater/boiler exhausts - 10% opacity C. Diesel engine exhaust - 20% opacity. [R307-401-8]
II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.1.b The owner/operator shall not burn more than five (5) pounds of resin per day in the resin residual removal furnace. [R307-401-8]
II.B.1.b.1 To determine compliance, the owner/operator shall keep a record of the weight of resin
remaining in each residual mold per day put into the resin residual removal furnace, for all periods when the plant is in operation. Weight of the resin combusted in each mold shall be the total weight of the resin plus the mold minus the weight of each mold, measured with a
mass balance. [R307-401-8] II.B.2 Fuel Requirements II.B.2.a The owner/operator shall use only natural gas as fuel in all the boilers and heaters. [R307-401-8]
II.B.2.b The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the
emergency generator engine. All diesel burned shall meet the definition of ultra-low sulfur diesel (ULSD), and contain no more than 15 ppm sulfur. [R307-401-8]
II.B.2.b.1 To demonstrate compliance with the diesel fuel requirements for any diesel fuel purchased, the owner/operator shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements, or the owner/operator shall obtain certification of sulfur content from the fuel supplier. [R307-401-8]
II.B.3 Engine Requirements
II.B.3.a The owner/operator shall not operate the emergency generator engine on site for more than
100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]

Engineer Review N116440010: ICU Medical, Inc.- Salt Lake Medical Products Manufacturing February 13, 2025 Page 7
II.B.3.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall
include the following:
A. The date the emergency engine was used
B. The duration of operation in hours
C. The reason for the emergency engine usage. [R307-401-8]
II.B.4 Volatile Organic Compound (VOC) Limitations
II.B.4.a NEW The VOC content of the solvent bonding, solvent cleaning, injection molding, and residual plastic resins removal chemicals as used shall not exceed the density limits established by R307-353. High solids (low VOC content) chemicals shall not be thinned or otherwise reduced beyond manufacturers recommendations. These parameters shall be tested by using
the appropriate ASTM method or another method approved by the Director. [R307-353] II.B.4.b NEW The owner/operator shall not emit more than the following from evaporative sources (solvent bonding, solvent cleaning, injection molding, residual plastic resins removal, etc.) on site: 26.02 tons of VOC per rolling 12-month period 6.38 tons methanol per rolling 12-month period
0.35 tons of methylene chloride per rolling 12-month period 0.27 tons of hexane per rolling 12-month period 0.13 tons of xylene per rolling 12-month period 0.24 tons of chloride, cyanide compounds, ethyl benzene, ethylene dichloride, ethylene glycol, formaldehyde, glycol ethers, isophorone, methyl methacrylate, nickel compounds, propylene oxide, toluene, and xylene combined per rolling 12-month period This does not include the emissions from the natural gas and diesel combustion sources. [R307-401-8]
II.B.4.b.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]
HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8]
II.B.4.b.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and
HAPs. [R307-401-8]

Engineer Review N116440010: ICU Medical, Inc.- Salt Lake Medical Products Manufacturing February 13, 2025 Page 8
II.B.4.b.3 The owner/operator shall keep records each month of the following:
A. The name (as per SDS) of the VOC- and HAP-emitting material
B. The maximum percent by weight of VOCs and each HAP in each material used C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8]

PERMIT HISTORY
When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN116440009-23 dated November 2, 2023 Is Derived From NOI dated October 3, 2024
Incorporates Additional information dated December 11, 2024
REVIEWER COMMENTS
1. Comment regarding Emissions Estimates: Based on a review of the VOC and HAP emissions by a mass balance methodology, the DAQ determined an increase in both VOC and HAP. [Last updated February 13, 2025] 2. Comment regarding NSPS and MACT Review: The plant is subject to 40 CFR 60 (NSPS) (Subpart A and Subpart IIII) and 40 CFR 63 (MACT) regulations (Subpart A and Subpart ZZZZ). 40 CFR 60 Subpart Dc applies to owners and operators of steam generating units (boilers) sized between 100 MMBtu/hr and 10 MMBtu/hr. All boilers are less than 5 MMBtu/hr on site, therefore this subpart doesn't apply to this plant.
40 CFR 60 Subpart IIII applies to owners and operators of stationary CI ICE that commence
construction after July 11, 2005, where the stationary CI ICE are manufactured on or after July 11, 2005, for engines with a maximum engine power greater than 50 hp. The source has an emergency generator engine rated at 200 kW (268 hp). The engine was purchased after July 11, 2005 therefore, this subpart applies to this plant. 40 CFR 63 Subpart ZZZZ applies to owners and operators of stationary RICE at a major or area source of HAP emissions. Since this source will have a stationary RICE at an area source of HAP

Engineer Review N116440010: ICU Medical, Inc.- Salt Lake Medical Products Manufacturing February 13, 2025 Page 9
emissions, Subpart ZZZZ applies to this plant. 40 CFR 63 Subpart JJJJJJ applies to owners and operators of boilers at an area source of HAPs emissions that use coal, biomass, or oil to fire them. Since this source will have boilers at an area source of HAP emissions, but use natural gas as fuel, this subpart will not apply to this plant . [Last updated February 13, 2025]
3. Comment regarding Title V Requirements: Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act,
Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants. 4. Any Title IV affected source.
This facility is not a major source and is not a Title IV source. The facility is not subject to 40 CFR 61 (NESHAP) regulations. This facility is subject to 40 CFR 60 and 40 CFR 63 (MACT) regulations. However, Title V does not apply because NSPS Subpart IIII and MACT Subpart ZZZZ exempt sources from the obligation to obtain a permit under 40 CFR part 70 (Title V permit) if the source is not otherwise required by law to obtain a permit. There are no other reasons why this source would be required to obtain a part 70 permit; therefore, Title V does not apply to this facility.
[Last updated November 6, 2024]

Engineer Review N116440010: ICU Medical, Inc.- Salt Lake Medical Products Manufacturing February 13, 2025 Page 10
ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology
CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency
FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units
NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit
R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year
UAC Utah Administrative Code VOC Volatile organic compounds
Tim Dejulis <[e-mail]>
ICU Medical's Engineering Review
18 messages
Tim Dejulis <[e-mail]>Mon, Jul 17, 2023 at 3:19 PM
To: Pedro Villarreal <[e-mail]>
Pedro,
Here is ICU Medical's engineering review for your inspection. Please look this over carefully. If it is acceptable, sign the
first page and return it to me by email. Otherwise, we can discuss anything. Thank you.
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
RN116440009-23.v 7.ICU Medical.docx
150K
Pedro Villarreal <[e-mail]>Wed, Aug 16, 2023 at 2:45 PM
To: Tim Dejulis <[e-mail]>
Hi Tim-

Just wanted to follow up, the engineer review was sent to Riley Jenkins (AECOM consultant) and suggested some
changes. I wanted to ensure they got to you. I believe it was 7/27/2023 when they sent me a copy and hope they sent it to
you as well.

Below are the changes as a reference:
Currently, the source contact is Steve Stauffer. We’d like to ask them to update that to be you.
On Page 3, it erroneously lists the horsepower of the replaced engine as 264hp , it should be 268hp.
It is correct in the rest of the document.
On page 6, under Section II: Permitted Equipment, II.A.3: it states that the manufacture year for the
200 kW emergency generator as 2023. I don’t believe this is the correct manufacture date since the
engine was installed in 2020. Double check the year that engine was manufactured and we’d like to
ask them to update that section as well.

Page Update Type Information to be updated
1 Source Contact Update Update information to be Pedro
Villarreal (currently Steve Stauffer)
12/30/24, 11:44 AM State of Utah Mail - ICU Medical's Engineering Review
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-a:r-1746650635288213335&simpl=msg-a:r-8204317799754…1/15
3 200 kW (268 hp) emergency
generator
Lists the generator hp as 264, should
be 268hp
6 200 kW emergency generator
manufacture year
Provide the updated date of
manufacture (currently listed as 2023)

Best Regards,

Pedro Villarreal
EHS Manager
4455 Atherton Drive
Salt Lake City, UT 84123
Phone: [phone]
www.icumed.com

From: Tim Dejulis <[e-mail]>
Sent: Monday, July 17, 2023 3:20 PM
To: Pedro Villarreal <[e-mail]>
Subject: ICU Medical's Engineering Review

CAUTION: This message has originated from an EXTERNAL SOURCE. Please use proper judgment and caution when
opening attachments, clicking links, or responding to this email.

[Quoted text hidden]
RN116440009-23.v 7.ICU Medical_AECOM changes.docx
161K
Tim Dejulis <[e-mail]>Fri, Aug 25, 2023 at 10:49 AM
To: Pedro Villarreal <[e-mail]>
Pedro,
Here is the updated engineering review for ICU Medical. Let me know if there are any other changes. Again, sign the first
page and return this to me by email if possible.
12/30/24, 11:44 AM State of Utah Mail - ICU Medical's Engineering Review
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-a:r-1746650635288213335&simpl=msg-a:r-8204317799754…2/15
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
RN116440009-23.v 8.ICU Medical.docx
150K
Tim Dejulis <[e-mail]>Thu, Sep 7, 2023 at 10:45 AM
To: Pedro Villarreal <[e-mail]>, "Steve Stauffer ([e-mail])" <[e-mail]>
Pedro,
Did you have any questions for me regarding the engineering review? If not, please have Steve Stauffer sign the front
page and return it to my attention. Thank you.
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
Mail Delivery Subsystem <[e-mail]>Thu, Sep 7, 2023 at 10:46 AM
To: [e-mail]
The original message was received at Thu, 7 Sep 2023 16:46:28 GMT
from m0113504.ppops.net [127.0.0.1]
----- The following addresses had permanent fatal errors -----
<[e-mail]>
(reason: 550 5.4.1 Recipient address rejected: Access denied. [CY4PEPF0000E9D9.namprd05.prod.outlook.com
2023-09-07T16:46:29.316Z 08DBACEA4A42B397])
----- Transcript of session follows -----
... while talking to icumed-com.mail.protection.outlook.com.:
>>> DATA
<<< 550 5.4.1 Recipient address rejected: Access denied. [CY4PEPF0000E9D9.namprd05.prod.outlook.com 2023-09-
07T16:46:29.316Z 08DBACEA4A42B397]
550 5.1.1 <[e-mail]>... User unknown
<<< 503 5.5.2 Need rcpt command [CY4PEPF0000E9D9.namprd05.prod.outlook.com 2023-09-07T16:46:29.316Z
08DBACEA4A42B397]
Final-Recipient: RFC822; [e-mail]
X-Actual-Recipient: rfc822; [e-mail]
Action: failed
Status: 5.4.1
12/30/24, 11:44 AM State of Utah Mail - ICU Medical's Engineering Review
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-a:r-1746650635288213335&simpl=msg-a:r-8204317799754…3/15
Remote-MTA: DNS; icumed-com.mail.protection.outlook.com
Diagnostic-Code: SMTP; 550 5.4.1 Recipient address rejected: Access denied. [CY4PEPF0000E9D9.namprd05.
prod.outlook.com 2023-09-07T16:46:29.316Z 08DBACEA4A42B397]
Last-Attempt-Date: Thu, 7 Sep 2023 16:46:29 GMT
---------- Forwarded message ----------
From: Tim Dejulis <[e-mail]>
To: Pedro Villarreal <[e-mail]>, "Steve Stauffer ([e-mail])" <[e-mail]>
Cc:
Bcc:
Date: Thu, 7 Sep 2023 10:45:42 -0600
Subject: Re: ICU Medical's Engineering Review
CAUTION: This message has originated from an EXTERNAL SOURCE. Please use proper judgment and cauon when opening
aachments, clicking links, or responding to this email.
Pedro,
Did you have any questions for me regarding the engineering review? If not, please have Steve Stauffer sign the front
page and return it to my attention. Thank you.
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
On Fri, Aug 25, 2023 at 10:49 AM Tim Dejulis <[e-mail]> wrote:
Pedro,
Here is the updated engineering review for ICU Medical. Let me know if there are any other changes. Again, sign the
first page and return this to me by email if possible.
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
On Wed, Aug 16, 2023 at 2:46 PM Pedro Villarreal <[e-mail]> wrote:
Hi Tim-

Just wanted to follow up, the engineer review was sent to Riley Jenkins (AECOM consultant) and suggested some
changes. I wanted to ensure they got to you. I believe it was 7/27/2023 when they sent me a copy and hope they
sent it to you as well.

Below are the changes as a reference:
12/30/24, 11:44 AM State of Utah Mail - ICU Medical's Engineering Review
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-a:r-1746650635288213335&simpl=msg-a:r-8204317799754…4/15
Currently, the source contact is Steve Stauffer. We’d like to ask them to update that to be you.
On Page 3, it erroneously lists the horsepower of the replaced engine as 264hp , it should be
268hp. It is correct in the rest of the document.
On page 6, under Section II: Permitted Equipment, II.A.3: it states that the manufacture year for
the 200 kW emergency generator as 2023. I don’t believe this is the correct manufacture date
since the engine was installed in 2020. Double check the year that engine was manufactured and
we’d like to ask them to update that section as well.

Page Update Type Information to be updated
1 Source Contact Update Update information to be Pedro
Villarreal (currently Steve Stauffer)
3 200 kW (268 hp) emergency
generator
Lists the generator hp as 264, should
be 268hp
6 200 kW emergency generator
manufacture year
Provide the updated date of
manufacture (currently listed as
2023)

Best Regards,

Pedro Villarreal
EHS Manager
4455 Atherton Drive
Salt Lake City, UT 84123
Phone: [phone]
www.icumed.com

From: Tim Dejulis <[e-mail]>
Sent: Monday, July 17, 2023 3:20 PM
To: Pedro Villarreal <[e-mail]>
Subject: ICU Medical's Engineering Review

CAUTION: This message has originated from an EXTERNAL SOURCE. Please use proper judgment and caution
when opening attachments, clicking links, or responding to this email.
12/30/24, 11:44 AM State of Utah Mail - ICU Medical's Engineering Review
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-a:r-1746650635288213335&simpl=msg-a:r-8204317799754…5/15

Pedro,

Here is ICU Medical's engineering review for your inspection. Please look this over carefully. If it is acceptable, sign
the first page and return it to me by email. Otherwise, we can discuss anything. Thank you.

Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Pedro Villarreal <[e-mail]>Thu, Sep 7, 2023 at 10:51 AM
To: Tim Dejulis <[e-mail]>
Cc: "Jenkins, Riley" <[e-mail]>
Good Morning-, Tim-

I am having our consultant review the engineering review. I will reach out to them to see if they have any questions.

Also, Steve Stauffer is not longer with the company, ICU Medical, I replaced him.
[Quoted text hidden]
Jenkins, Riley <[e-mail]>Thu, Sep 7, 2023 at 11:00 AM
To: Pedro Villarreal <[e-mail]>, Tim Dejulis <[e-mail]>
Hi Pedro,

I’ve attached the document with ‘Track Changes’ with the updates that are still requested for the AO.

These are the following items we suggest be updated before we sign the cover letter and get it into the
comment period.

Currently, the source contact is Steve Stauffer. We’d like to ask them to update that to be you. See
attached document for changes.
12/30/24, 11:44 AM State of Utah Mail - ICU Medical's Engineering Review
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-a:r-1746650635288213335&simpl=msg-a:r-8204317799754…6/15
On Page 3, it erroneously lists the horsepower of the replaced engine as 264hp , it should be 268hp.
It is correct in the rest of the document.

Thanks.

Riley J. Jenkins, EIT
Environmental Engineer
Central Region Air Permitting and Measurements
D [phone]
[e-mail]
AECOM
756 E Winchester Street, Suite 400
Salt Lake City, Utah 84107, USA
T [phone]
aecom.com
Imagine it. Delivered.
LinkedIn Twitter Facebook Instagram

From: Pedro Villarreal <[e-mail]>
Sent: Thursday, September 7, 2023 10:51 AM
To: Tim Dejulis <[e-mail]>
Cc: Jenkins, Riley <[e-mail]>
Subject: RE: ICU Medical's Engineering Review

Good Morning-, Tim- I am having our consultant review the engineering review. I will reach out to them to see if they have any questions. Also, Steve Stauffer is not longer with the company, ICU Medical, I replaced him. Best Regards, Pedro
[Quoted text hidden]
RN116440009-23.v 8.ICU Medical_AECOM changes.docx
158K
Tim Dejulis <[e-mail]>Fri, Sep 22, 2023 at 11:39 AM
To: "Jenkins, Riley" <[e-mail]>
Cc: Pedro Villarreal <[e-mail]>
Pedro,
The engineering review for ICU Medical was changed, as you requested. Please sign this and we will prepare it for the
public comment period, lasting 30-days. I will let ICU Medical know if any comments are received. Thank you.
12/30/24, 11:44 AM State of Utah Mail - ICU Medical's Engineering Review
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-a:r-1746650635288213335&simpl=msg-a:r-8204317799754…7/15
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
3 attachments
image001.png
19K
image001.png
19K
image001.png
19K
Pedro Villarreal <[e-mail]>Fri, Sep 22, 2023 at 1:07 PM
To: Tim Dejulis <[e-mail]>, "Jenkins, Riley" <[e-mail]>
Hi Tim-

I didn’t see an attachment for me to sign.
[Quoted text hidden]
Tim Dejulis <[e-mail]>Fri, Sep 22, 2023 at 3:15 PM
To: Pedro Villarreal <[e-mail]>
Cc: "Jenkins, Riley" <[e-mail]>
First page, near the bottom.
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
2 attachments
image001.png
19K
12/30/24, 11:44 AM State of Utah Mail - ICU Medical's Engineering Review
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-a:r-1746650635288213335&simpl=msg-a:r-8204317799754…8/15
image001.png
19K
Jenkins, Riley <[e-mail]>Mon, Sep 25, 2023 at 12:20 PM
To: Tim Dejulis <[e-mail]>, Pedro Villarreal <[e-mail]>
Hi Tim,

Would you mind please resending the engineering review document attachment? It wasn’t attached to the email sent at
11:39am on 9/22/2023 or the follow-up at 3:15pm the same day.

Thanks!

Riley J. Jenkins, EIT
Environmental Engineer
Central Region Air Permitting and Measurements
D [phone]
[e-mail]
AECOM
756 E Winchester Street, Suite 400
Salt Lake City, Utah 84107, USA
T [phone]
aecom.com
Imagine it. Delivered.
LinkedIn Twitter Facebook Instagram

From: Tim Dejulis <[e-mail]>
Sent: Friday, September 22, 2023 3:15 PM
To: Pedro Villarreal <[e-mail]>
Cc: Jenkins, Riley <[e-mail]>
Subject: Re: ICU Medical's Engineering Review

First page, near the bottom. Timothy DeJulis, PE Environmental Engineer | Minor NSR Section P: [phone] airquality. utah. gov On Fri, Sep 22, 2023 at 1: 07 PM Pedro Villarreal <Pedro. Villarreal@ icumed. com> wrote: Hi Tim- I didn’t see
[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
Pedro Villarreal
12/30/24, 11:44 AM State of Utah Mail - ICU Medical's Engineering Review
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-a:r-1746650635288213335&simpl=msg-a:r-8204317799754…9/15
[Quoted text hidden]
[Quoted text hidden]
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[Quoted text hidden]
[Quoted text hidden]
Pedro Villarreal
[Quoted text hidden]
Tim Dejulis <[e-mail]>Tue, Sep 26, 2023 at 9:12 AM
To: "Jenkins, Riley" <[e-mail]>
Cc: Pedro Villarreal <[e-mail]>
Just sent.
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
RN116440009-23.v 9.ICU Medical.docx
146K
Jenkins, Riley <[e-mail]>Tue, Sep 26, 2023 at 9:27 AM
To: Pedro Villarreal <[e-mail]>, Tim Dejulis <[e-mail]>
Hi Pedro and Tim,

I just looked through the engineering review that Tim sent over. There is still one update that needs to be made.

The horsepower of the diesel-fuel engine still needs to be updated from 264 to 268. I’ve taken a screenshot of the change
need and attached it below. I’ve also included the word document with this change. The paragraph is located, on page 4
of the word document.

12/30/24, 11:44 AM State of Utah Mail - ICU Medical's Engineering Review
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-a:r-1746650635288213335&simpl=msg-a:r-820431779975…10/15

Please let me know if you have any questions.

Thanks.

Riley J. Jenkins, EIT
Environmental Engineer
Central Region Air Permitting and Measurements
D [phone]
[e-mail]
AECOM
756 E Winchester Street, Suite 400
Salt Lake City, Utah 84107, USA
T [phone]
aecom.com
Imagine it. Delivered.
LinkedIn Twitter Facebook Instagram

From: Tim Dejulis <[e-mail]>
Sent: Tuesday, September 26, 2023 9:13 AM
To: Jenkins, Riley <[e-mail]>
Cc: Pedro Villarreal <[e-mail]>
Subject: Re: ICU Medical's Engineering Review

Just sent. Timothy DeJulis, PE Environmental Engineer | Minor NSR Section P: [phone] airquality. utah. gov On Mon, Sep 25, 2023 at 12: 20 PM Jenkins, Riley <riley. jenkins@ aecom. com> wrote: Hi Tim, Would you mind please resending the
[Quoted text hidden]
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12/30/24, 11:44 AM State of Utah Mail - ICU Medical's Engineering Review
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-a:r-1746650635288213335&simpl=msg-a:r-820431779975…11/15
[Quoted text hidden]
[Quoted text hidden]
Pedro Villarreal
[Quoted text hidden]
RN116440009-23.v 9.ICU Medical_AECOM Changes.docx
155K
Tim Dejulis <[e-mail]>Tue, Sep 26, 2023 at 9:36 AM
To: "Jenkins, Riley" <[e-mail]>
Cc: Pedro Villarreal <[e-mail]>
I've made the change indicated.
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
3 attachments
image001.png
30K
image001.png
30K
RN116440009-23.v 9.ICU Medical.docx
148K
Pedro Villarreal <[e-mail]>Tue, Sep 26, 2023 at 10:00 AM
To: Tim Dejulis <[e-mail]>, "Jenkins, Riley" <[e-mail]>
Hi Tim-

Attached is the signed document.

Best Regards,
12/30/24, 11:44 AM State of Utah Mail - ICU Medical's Engineering Review
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-a:r-1746650635288213335&simpl=msg-a:r-820431779975…12/15

[Quoted text hidden]
[Untitled].pdf
318K
Tim Dejulis <[e-mail]>Tue, Nov 19, 2024 at 1:15 PM
To: Pedro Villarreal <[e-mail]>
Cc: "Jenkins, Riley" <[e-mail]>, "West, Emily" <[e-mail]>
Bcc: Christine Bodell <[e-mail]>
Pedro,
I have ICU Medical's engineering review reviewed by the peer engineer. She has brought one question for me that ICU
Medical must answer.
In the NOI, the increase in VOC emissions was 17.99 tpy with an increase in emissions of 8.36 tpy leading to a total of
26.35 tpy. We should be increasing the solvent use VOC and HAPs accordingly. The VOC emissions should be 17.13 tpy
changing to 26.02 tpy as described in the project description on page 7 of the NOI. The difference in the VOC emissions
in this calculation is 8.89 tpy, not 8.36 tpy. This 0.52 tpy difference needs to be explained to us. Please explain this
difference in the emissions of the VOC to us.
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
Jenkins, Riley <[e-mail]>Mon, Dec 9, 2024 at 8:51 AM
To: Tim Dejulis <[e-mail]>, Pedro Villarreal <[e-mail]>
Cc: "West, Emily" <[e-mail]>
Hi Tim,

On behalf of ICU Medical, please find the response below.

During the 2023 AO Modification the overall facility emissions were increased from 17.49 tpy VOC to 17.99
tpy VOC. During the 2023 modification, condition II.B.4.b should have also been updated to reflect the new
emission limits from 17.13 tpy non-combustion VOC to 17.66 tpy non-combustion VOC (increased by 0.53
tpy VOC). Therefore, the non-combustion emission increase difference of 0.53 tpy VOC is not reflected in
the overall facility total increase for the 2024 modification because it had already been accounted for in the
2023 modification.

12/30/24, 11:44 AM State of Utah Mail - ICU Medical's Engineering Review
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-a:r-1746650635288213335&simpl=msg-a:r-820431779975…13/15
Thanks.

Riley J. Jenkins, EIT
Environmental Engineer
Central Region Air Permitting and Measurements
D [phone]
[e-mail]
AECOM
756 E Winchester Street, Suite 400
Salt Lake City, Utah 84107, USA
T [phone]
aecom.com
Imagine it. Delivered.
LinkedIn Twitter Facebook Instagram

From: Tim Dejulis <[e-mail]>
Sent: Tuesday, November 19, 2024 1:16 PM
To: Pedro Villarreal <[e-mail]>
Cc: Jenkins, Riley <[e-mail]>; West, Emily <[e-mail]>
Subject: Re: ICU Medical's Engineering Review

Pedro, I have ICU Medical's engineering review reviewed by the peer engineer. She has brought one question for me that ICU Medical must answer. In the NOI, the increase in VOC emissions was 17. 99 tpy with an increase in emissions of 8. 36
[Quoted text hidden]
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Please let me know if you have any questions.
[Quoted text hidden]
Tim Dejulis <[e-mail]>Tue, Dec 10, 2024 at 2:04 PM
To: Pedro Villarreal <[e-mail]>
Cc: "West, Emily" <[e-mail]>, "Jenkins, Riley" <[e-mail]>
Pedro,
I will make the change to the engineering review document based on this email. Thank you.
12/30/24, 11:44 AM State of Utah Mail - ICU Medical's Engineering Review
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-a:r-1746650635288213335&simpl=msg-a:r-820431779975…14/15
Timothy DeJulis, PE
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
12/30/24, 11:44 AM State of Utah Mail - ICU Medical's Engineering Review
https://mail.google.com/mail/u/0/?ik=67721adfe9&view=pt&search=all&permthid=thread-a:r-1746650635288213335&simpl=msg-a:r-820431779975…15/15