DAQ-2024-011076

DAQE-AN162020001-24

{{$d1 }}

Kyle Emmett
Life Technologies Corp.
1726 Hyclone Drive
Logan, UT 84321
[e-mail]

Dear Mr. Emmett:

Re: Approval Order: New Bioprocess Container Plant
Project Number: N162020001

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on June 30,
2022. Life Technologies Corp. must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Dylan Frederick, 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:DF:jg

cc: Bear River 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

September 11, 2024

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-AN162020001-24
New Bioprocess Container Plant

Prepared By
Dylan Frederick, Engineer
[phone]
[e-mail]

Issued to
Life Technologies Corp. - BioProcess Container Plant

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

September 11, 2024
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 ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 7
ACRONYMS ................................................................................................................................. 8

DAQE-AN162020001-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Life Technologies Corp. Life Technologies Corp. - BioProcess Container Plant

Mailing Address Physical Address
1726 Hyclone Drive 1726 Hyclone Drive
Logan, UT 84321 Logan, UT 84321

Source Contact UTM Coordinates
Name: Kyle Emmett 428,863 m Easting
Phone: [phone],617,037 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 2836 (Biological Products, Except Diagnostic Substances)

SOURCE INFORMATION
General Description
Life Technologies Corp., owned and operated by Thermo Fisher Scientific Inc., owns and operates a
bioprocess facility in Cache County that manufactures and supplies single-use bioprocess containers,
flexible containers, and liquid handling applications for the biopharmaceutical industry. The facility will
utilize isopropyl alcohol for cleanroom operations and operate an emergency generator engine.

NSR Classification
New Minor Source

Source Classification
Located in Logan UT-ID PM2.5 NAA
Cache 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
DAQE-AN162020001-24
Page 4

Project Description
Life Technologies Corp. has requested an approval order for a bioprocessing facility. The facility will
operate a 118 kW emergency generator and conduct cleaning operations with isopropyl alcohol (IPA).
The facility will be limited to 19.5 tons of IPA per rolling 12-month period. Emissions for small natural
gas-fired HVAC units have also been estimated and incorporated into the permit. This facility is a new
distinct source from Hyclone Labs, which operates at 925 West 1800 South in Logan. The sources are
operated and owned by two different companies.

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)
CO2 Equivalent 3378.00
Carbon Monoxide 2.40
Nitrogen Oxides 2.84
Particulate Matter - PM10 0.21
Particulate Matter - PM2.5 0.21
Sulfur Dioxide 0.02
Volatile Organic Compounds 19.67

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Formaldehyde (CAS #50000) 4
Hexane (CAS #110543) 100
Change (TPY) Total (TPY)
Total HAPs 0.05

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]
DAQE-AN162020001-24
Page 5

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]

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT
II.A.1 Life Technologies Research Laboratory II.A.2 One (1) Emergency Generator Rating: 118 kW (158 hp) Tier 3 certified Fuel: Diesel Fuel Installation Date: 2021
II.A.3 Various Comfort Heating Systems Rating: less than 5 MMBtu/hr each Fuel: Natural Gas II.A.4 Cleaning Operations IPA used for cleaning operations at the facility

DAQE-AN162020001-24
Page 6

SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Source-wide Requirements
II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:

A. The diesel-fired generator engine - 20% opacity.

B. All other points - 10% opacity.

[R307-401-8]

II.B.1.b Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3, R307-401-8]
II.B.2 Process Emissions
II.B.2.a The owner/operator shall store VOC and/or HAP containing materials and rags in covered containers except when in use. [R307-401-8]
II.B.2.b The owner/operator shall not consume more than 19.5 tons of isopropanol per rolling 12-month
period. [R307-401-8]

II.B.2.b.1 The owner/operator shall: A. Calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. B. Determine isopropanol consumption from company records. C. Record consumption on a monthly basis. D. Keep consumption records for all periods the plant is in operation. [R307-401-8]
II.B.2.c The owner/operator shall comply with the applicable VOC content limits in R307-304, "Solvent
Cleaning." [R307-304]

II.B.3 Emergency Engine Requirements
II.B.3.a The owner/operator shall install an emergency generator engine that is certified to meet a NOx
emission rate of 3.0 g/hp-hr or less. [R307-401-8]

II.B.3.a.1 To demonstrate compliance with the emission rate, the owner/operator shall keep a record of the manufacturer's certification of the emission rate. The record shall be kept for the life of the equipment. [R307-401-8]
II.B.3.b The owner/operator shall not operate the emergency 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 engine during emergencies. [40 CFR 60 Subpart ZZZZ, R307-401-8]
DAQE-AN162020001-24
Page 7

II.B.3.b.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 the 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. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.3.b.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for the emergency engine. [40 CFR 60 Subpart ZZZZ, R307-401-8]
II.B.3.c The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in the emergency engine. [R307-401-8] II.B.3.c.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]

II.B.3.c.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Is Derived From NOI dated June 30, 2022 Incorporates Additional Information dated November 14, 2022 Incorporates Additional Information dated November 17, 2022 Incorporates Additional Information dated February 8, 2023 Incorporates Additional Information dated December 21, 2023 Incorporates Additional Information dated February 14, 2024 Incorporates Additional Information dated February 28, 2024 Incorporates Additional Information dated April 16, 2024 Incorporates Additional Information dated May 1, 2024

DAQE-AN162020001-24
Page 8

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-IN162020001-24

August 8, 2024

Kyle Emmett
Life Technologies Corp.
1726 Hyclone Drive
Logan, UT 84321
[e-mail]

Dear Mr. Emmett:

Re: Intent to Approve: New Bioprocess Container Plant
Project Number: N162020001

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, Dylan Frederick, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Dylan Frederick, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:DF:jg

cc: Bear River 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-IN162020001-24
New Bioprocess Container Plant

Prepared By
Dylan Frederick, Engineer
[phone]
[e-mail]

Issued to
Life Technologies Corp. - BioProcess Container Plant

Issued On
August 8, 2024

{{$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 ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 7
ACRONYMS ................................................................................................................................. 9

DAQE-IN162020001-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Life Technologies Corp. Life Technologies Corp. - BioProcess Container Plant

Mailing Address Physical Address
1726 Hyclone Drive 1726 Hyclone Drive
Logan, UT 84321 Logan, UT 84321

Source Contact UTM Coordinates
Name: Kyle Emmett 428,863 m Easting
Phone: [phone],617,037 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 2836 (Biological Products, Except Diagnostic Substances)

SOURCE INFORMATION
General Description
Life Technologies Corp., owned and operated by Thermo Fisher Scientific Inc., owns and operates a
bioprocess facility in Cache County that manufactures and supplies single-use bioprocess containers,
flexible containers, and liquid handling applications for the biopharmaceutical industry. The facility will
utilize isopropyl alcohol for cleanroom operations and operate an emergency generator engine.
NSR Classification
New Minor Source

Source Classification
Located in Logan UT-ID PM2.5 NAA
Cache 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

DAQE-IN162020001-24
Page 4

Project Description
Life Technologies Corp. has requested an approval order for a bioprocessing facility. The facility will
operate a 118-kW emergency generator and conduct cleaning operations with isopropyl alcohol (IPA).
The facility will be limited to 19.5 tons of IPA per rolling 12-month period. Emissions for small natural
gas fired HVAC units have also been estimated and incorporated into the permit. This facility is a new
distinct source from Hyclone Labs, which operates at 925 West 1800 South in Logan. The sources are
operated and owned by two (2) different companies.

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)
CO2 Equivalent 3378.00
Carbon Monoxide 2.40
Nitrogen Oxides 2.84
Particulate Matter - PM10 0.21
Particulate Matter - PM2.5 0.21
Sulfur Dioxide 0.02
Volatile Organic Compounds 19.67

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Formaldehyde (CAS #50000) 4
Hexane (CAS #110543) 100
Change (TPY) Total (TPY)
Total HAPs 0.05

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 Herald Journal on August 10, 2024. 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.

DAQE-IN162020001-24
Page 5

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]
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]

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 Life Technologies Research Laboratory
DAQE-IN162020001-24
Page 6

II.A.2 One (1) Emergency Generator Rating: 118 kW (158 hp) Tier 3 certified Fuel: Diesel Fuel Installation Date: 2021 II.A.3 Various Comfort Heating Systems Rating: less than 5 MMBtu/hr each
Fuel: Natural Gas
II.A.4 Cleaning Operations IPA used for cleaning operations at the facility

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 Source-wide Requirements II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. The diesel-fired generator engine - 20% opacity. B. All other points - 10% opacity. [R307-401-8]
II.B.1.b Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3, R307-401-8] II.B.2 Process Emissions
II.B.2.a The owner/operator shall store VOC and/or HAP containing materials and rags in covered containers, except when in use. [R307-401-8] II.B.2.b The owner/operator shall not consume more than 19.5 tons of isopropanol per rolling 12-month period. [R307-401-8]
II.B.2.b.1 The owner/operator shall: A. Calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. B. Determine isopropanol consumption from company records. C. Record consumption on a monthly basis. D. Keep consumption records for all periods the plant is in operation. [R307-401-8]
DAQE-IN162020001-24
Page 7

II.B.2.d The owner/operator shall comply with the applicable VOC content limits in R307-304, "Solvent Cleaning." [R307-304] II.B.3 Emergency Engine Requirements
II.B.3.a The owner/operator shall install an emergency generator engine that is certified to meet a NOx emission rate of 3.0 g/hp-hr or less. [R307-401-8] II.B.3.a.1 To demonstrate compliance with the emission rate, the owner/operator shall keep a record of the manufacturer's certification of the emission rate. The record shall be kept for the life of the
equipment. [R307-401-8]
II.B.3.b The owner/operator shall not operate the emergency 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 engine during emergencies. [40 CFR 60 Subpart ZZZZ, R307-401-8]
II.B.3.b.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 the 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.
[40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.3.b.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for the emergency engine. [40 CFR 60 Subpart ZZZZ, R307-401-8]
II.B.3.c The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as
fuel in the emergency engine. [R307-401-8]
II.B.3.c.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8] II.B.3.c.2 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN150810002-15 dated October 5, 2015 Is Derived From NOI dated June 30, 2022 Incorporates Additional Information dated November 14, 2022 Incorporates Additional Information dated November 17, 2022 Incorporates Additional Information dated February 8, 2023 Incorporates Additional Information dated December 21, 2023
DAQE-IN162020001-24
Page 8
Incorporates Additional Information dated February 14, 2024
Incorporates Additional Information dated February 28, 2024 Incorporates Additional Information dated April 16, 2024 Incorporates Additional Information dated May 1, 2024

DAQE-IN162020001-24
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

Herald Journal
Publication Name:
Herald Journal
Publication URL:
Publication City and State:
Logan, UT
Publication County:
Cache
Notice Popular Keyword Category:
Notice Keywords:
life technologies
Notice Authentication Number:
202408121158449905472
1761527914
Notice URL:
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Notice File:Notice Publish Date:
THJ-0810-ClassAd-546262-1.pdf Saturday, August 10, 2024
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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: Life Technologies Corporation Location: Life Technologies Corp. - BioProcess
Container Plant – 1726 Hyclone Drive,Logan, UT Project Description: Life Technologies Corp., owned and operated by Thermo Fisher Scientific
Inc., has requested a new approval order for a bioprocess facility in Cache County. The facility will manufacture and supply single use
bioprocess containers and other products. The facility will operate a new emergency generator engine and conduct cleaning operations with
isopropyl alcohol. 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 Dir
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DAQE-NN162020001-24

August 8, 2024

The Herald Journal
Legal Advertising Dept
1068 W 130 S
Logan, UT 84321

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in The Herald Journal on
August 10, 2024.

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: Bear River Association of Governments
cc: Cache 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-NN162020001-24
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: Life Technologies Corporation
Location: Life Technologies Corp. - BioProcess Container Plant – 1726 Hyclone Drive,
Logan, UT
Project Description: Life Technologies Corp., owned and operated by Thermo Fisher Scientific Inc.,
has requested a new approval order for a bioprocess facility in Cache County.
The facility will manufacture and supply single use bioprocess containers and
other products. The facility will operate a new emergency generator engine and
conduct cleaning operations with isopropyl alcohol.

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 September 9, 2024, 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: August 10, 2024

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

DAQE-

RN162020001
July 19, 2024

Kyle Emmett
Life Technologies Corporation
1726 Hyclone Drive
Logan, UT 84321
[e-mail]

Dear Kyle Emmett,

Re: Engineer Review:
New Bioprocess Container Plant
Project Number: N162020001

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. Life Technologies
Corporation should complete this review within 10 business days of receipt.

Life Technologies Corporation should contact Dylan Frederick at [phone] if there are questions
or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email
Dylan Frederick 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 Life Technologies Corporation does not respond to this letter within 10 business days, the project will
move forward without source concurrence. If Life Technologies Corporation 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

01 AUG 2024

Engineer Review N162020001: Life Technologies Corp- BioProcess Container Plant
July 19, 2024
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N162020001
Owner Name Life Technologies Corporation
Mailing Address 1726 Hyclone Drive
Logan, UT, 84321

Source Name Life Technologies Corp- BioProcess Container Plant
Source Location 1726 Hyclone Drive
Logan, UT 84321

UTM Projection 428,863 m Easting, 4,617,037 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 2836 (Biological Products, Except Diagnostic Substances)

Source Contact Kyle Emmett
Phone Number [phone]
Email [e-mail]

Billing Contact Kyle Emmett
Phone Number [phone]
Email [e-mail]

Project Engineer Dylan Frederick, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted June 30, 2022
Date of Accepted Application December 21, 2023

Engineer Review N162020001: Life Technologies Corp- BioProcess Container Plant
July 19, 2024
Page 2
SOURCE DESCRIPTION

General Description
Life Technologies Corp, owned and operated by Thermo Fisher Scientific Inc, owns and operates
a bioprocess facility in Cache County that manufacturers and supplies single use bioprocess
containers, flexible containers and liquid handling applications for the biopharmaceutical
industry. The facility will utilize isopropyl alcohol for cleanroom operations and operate an
emergency generator engine.

NSR Classification:
New Minor Source

Source Classification
Located in Logan UT-ID PM2.5 NAA
Cache 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
New Bioprocess Container Plant

Project Description
Life Technologies Corp has requested an approval order for a bioprocessing facility. The facility
will operate a 118 kW emergency generator and conduct cleaning operations with isopropyl
alcohol (IPA). The facility will be limited to 19.5 tons of IPA per rolling 12-month period.
Emissions for small natural gas fired HVAC units have also been estimated and incorporated into
the permit. This facility is a new distinct source from Hyclone Labs, which operates at 925 West
1800 South, in Logan. The sources are operated and owned by two different companies.

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 for this
modification. [Last updated March 12, 2024]

Engineer Review N162020001: Life Technologies Corp- BioProcess Container Plant
July 19, 2024
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)
CO2 Equivalent 3378.00
Carbon Monoxide 2.40
Nitrogen Oxides 2.84
Particulate Matter - PM10 0.21
Particulate Matter - PM2.5 0.21
Sulfur Dioxide 0.02
Volatile Organic Compounds 19.67

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Formaldehyde (CAS #50000) 4
Hexane (CAS #110543) 100
Change (TPY) Total (TPY)
Total HAPs 0.05

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

Engineer Review N162020001: Life Technologies Corp- BioProcess Container Plant
July 19, 2024
Page 4
Review of BACT for New/Modified Emission Units

1. BACT review regarding Emergency Generator
Life Technologies Corp has requested to add a 118 kW emergency generator to the facility. The
generator will add emissions consisting primarily of NOx and CO, with small amounts of HAPs,
PM10, PM2.5, and VOCs.

The proposed emergency generator is a tier 3 certified engine. Potential control options for
generators include add-on controls such as SCR, oxidation catalysts, and diesel particulate filters.
The source could also purchase an upgraded tier 4 engine. Annual emissions from the engine
include 0.05 tons per year NOx, and 0.06 tons per year of CO. These emissions are from 100 hours
of operation due to maintenance and testing. Due to the low amount of emissions annually from
the engine, the benefit of further emission reductions would be minimal, and the cost of either
purchasing add-on controls or an upgraded, lower-emitting engine would not be cost effective. For
that reason, it is considered economically infeasible to implement more stringent controls.

Additional measures can be taken to reduce emissions from the engine. The source can operate the
engine according to manufacturer recommendations to ensure proper combustion and engine
maintenance. The engine is diesel fueled, and the engine can use ultra-low sulfur diesel fuel to
reduce emissions. Other good combustion practices such as avoiding idling and ensuring proper
operation according to manufacturer specifications can also be implemented. These measures are
feasible to implement and are accepted as BACT.

BACT for control of the emergency generator will be the installation of an engine certified to tier 3
diesel engine standards, including 3.0 g/hp-hr NOx, use of ultra-low sulfur diesel fuel, good
combustion practices, and a 20% opacity limit.
[Last updated June 19, 2024]

2. BACT review regarding Isopropanol
Life Technologies Corp is requesting an annual limit of 19.5 tons of isopropanol use per year. This
activity will result in emissions of fugitive VOCs as isopropanol is used for cleaning surfaces and
bioprocess container components. An alternative is not possible without altering the quality and
nature of the products being produced. Add-on controls for this process are not feasible to
implement. VOC control devices would require installation of a VOC capture device that would
send captured VOCs to a control device such as a scrubber. These systems are not compatible with
the process at Life Technologies Corp and would be economically infeasible to implement due to
the high cost of add-on air systems and control devices. These systems additionally are not
compatible with processes that release fugitive emissions at irregular intervals. For all these
reasons, add on controls are not considered further.

The facility can control VOC emissions by using best practices including using closed IPA
containers to reduce evaporation, using pre-wetted IPA wipers for cleaning, and disposing of IPA
rags into closed containers, and keeping containers closed when not in use. These practices are
considered BACT for IPA use at the facility. [Last updated June 19, 2024]

SECTION I: GENERAL PROVISIONS

Engineer Review N162020001: Life Technologies Corp- BioProcess Container Plant
July 19, 2024
Page 5
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]

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]

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

Engineer Review N162020001: Life Technologies Corp- BioProcess Container Plant
July 19, 2024
Page 6
II.A.1
NEW
Life Technologies Research Laboratory

II.A.2
NEW
One (1) Emergency Generator
Rating: 118 kW (158 hp)
Tier 3 certified
Fuel: Diesel Fuel
Installation Date: 2021

II.A.3
NEW
Various Comfort Heating Systems
Rating: less than 5 MMBtu/hr each
Fuel: Natural Gas

II.A.4
NEW
Cleaning Operations
IPA used for cleaning operations at the facility

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
NEW
Source-wide Requirements
II.B.1.a
NEW
The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:

A. The diesel-fired generator engine - 20% opacity

B. All other points - 10% opacity. [R307-401-8]

II.B.1.b
NEW
Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-201-3, R307-401-8]

II.B.2
NEW
Process Emissions
II.B.2.a
NEW
The owner/operator shall store VOC and/or HAP containing materials and rags in covered
containers except when in use. [R307-401-8]

II.B.2.b
NEW
The owner/operator shall not consume more than 19.5 tons of isopropanol per rolling 12-
month period. [R307-401-8]

Engineer Review N162020001: Life Technologies Corp- BioProcess Container Plant
July 19, 2024
Page 7
II.B.2.b.1
NEW
The owner/operator shall:

A. Calculate a new 12-month total by the 20th day of each month using data from the
previous 12 months

B. Determine isopropanol consumption from company records

C. Record consumption on a monthly basis

D. Keep consumption records for all periods the plant is in operation. [R307-401-8]

II.B.2.d
NEW
The owner/operator shall comply with the applicable VOC content limits in R307-304
"Solvent Cleaning". [R307-304]

II.B.3
NEW
Emergency Engine Requirements
II.B.3.a
NEW
The owner/operator shall install an emergency generator engine that is certified to meet a NOx
emission rate of 3.0 g/hp-hr or less. [R307-401-8]

II.B.3.a.1
NEW
To demonstrate compliance with the emission rate, the owner/operator shall keep a record of
the manufacturer's certification of the emission rate. The record shall be kept for the life of
the equipment. [R307-401-8]

II.B.3.b
NEW
The owner/operator shall not operate the emergency 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 engine during emergencies. [40 CFR 60 Subpart ZZZZ, R307-401-8]

II.B.3.b.1
NEW
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 the 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. [40 CFR 63 Subpart ZZZZ, R307-401-8]

II.B.3.b.2
NEW
To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for the emergency engine. [40 CFR 60 Subpart ZZZZ, R307-401-8]

II.B.3.c
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in the emergency engine. [R307-401-8]

II.B.3.c.1
NEW
The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]

Engineer Review N162020001: Life Technologies Corp- BioProcess Container Plant
July 19, 2024
Page 8
II.B.3.c.2
NEW
To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel
meets the ULSD requirements. [R307-401-8]

Engineer Review N162020001: Life Technologies Corp- BioProcess Container Plant
July 19, 2024
Page 9
PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Is Derived From NOI dated June 30, 2022
Incorporates Additional Information dated November 14, 2022
Incorporates Additional Information dated November 17, 2022
Incorporates Additional Information dated February 8, 2023
Incorporates Additional Information dated December 21, 2023
Incorporates Additional Information dated February 14, 2024
Incorporates Additional Information dated February 28, 2024
Incorporates Additional Information dated April 16, 2024
Incorporates Additional Information dated May 1, 2024

REVIEWER COMMENTS

1. Comment regarding Emission Calculations:
Emission changes in this modification were calculated with the following methods:

Isopropanol - Life Technologies Corp currently utilizes isopropanol that is emitted as fugitive VOCs.
All isopropanol is assumed to evaporate to the atmosphere. Actual emissions from recent year data
are at about 8.6 tons per year, and an IPA limit of 19.5 TPY is requested to be maintained to allow
operational flexibility.

Comfort Air Systems - Life Technologies Corp operates multiple HVAC units with varying ratings
under 5 MMBtu/hr per year. To account for emissions from these sources, the total heat input of all
HVAC units was added up and calculated like they were a single boiler/heater unit. An input of 6.5
MMBtu/hr and 8760 hours per year was used to account for all HVAC units. AP-42 Chapter 1.4,
Tables 1.4-1 through 1.4-4 were used for emission factors for criteria pollutants and HAPs. CO2e
emission factors were taken from AP-42 Table 1.4-2 and Table A-1 to Subpart A of Part 98.

Generator Emissions - The new 118 kW emergency generator will operate up to 100 hours per year
for maintenance and testing purposes. An input of 158 hp and 100 hours of operation per year were
used, and emission factors were taken from AP-42 chapters 3.3 and 3.4, Tables 3.3-1, 3.3-2 and 3.4-
1 through 3.4-4.
[Last updated June 20, 2024]

2. Comment regarding NSPS and MACT Review:
40 CFR 60 (NSPS) 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 after April 1, 2006.
The facility will operate a proposed new emergency diesel generator that was manufactured after the
applicability dates in this subpart. Therefore, this subpart is applicable to the emergency generator.

40 CFR 63 (MACT) Subpart ZZZZ applies to owners and operators of stationary RICE at a major or
area source of HAP emissions. The emergency generator at the facility meets the definition of a
stationary RICE according to this subpart, and the facility is an area source of HAP emissions. The
emergency engine applicable to this subpart. Compliance with this subpart is met with compliance to
NSPS Subpart IIII.

Engineer Review N162020001: Life Technologies Corp- BioProcess Container Plant
July 19, 2024
Page 10
[Last updated May 20, 2024]

3. Comment regarding Title V:
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 subject to 40 CFR 60
(NSPS) and 40 CFR 63 (MACT) regulations. It is not subject to 40 CFR 61 (NESHAP) regulations.
NSPS Subparts IIII, and MACT subpart ZZZZ exempt sources from the obligation to obtain a permit
under a 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 April 17, 2024]

4. Comment regarding Life Technologies/HyClone Laboratories ownership:
Up to 2014, Thermo Fisher Scientific owned and operated HyClone Laboratories LLC, which
included the bioprocess container manufacturing facility that is being permitted in this approval
order. That same year, Thermo Fisher Scientific purchased Life Technologies Corporation,
headquartered out of Carlsbad, CA and is mainly involved in the manufacturing of cell culture media
for the biopharmaceutical industry. The US Trade Commission required Thermo Fisher Scientific
either cancel the purchase or sell the cell culture media manufacturing portion of Hyclone
Laboratories LLC located at 925 W 1800 S, Logan, UT (directly across the street to the process
being permitted in this approval order) due to monopoly concerns. Hyclone's Cell Culture business
was sold to GE Healthcare in 2014 and then to Cytiva (parent company Danaher) in 2019 and is no
longer associated with the facility being permitted in this approval order. The facility under site ID
16202 is owned and operated under Life Technologies Corp. The facility under site ID 15081 owned
and operated by Hyclone Labs currently operates under approval order DAQE-AN150810002-15.
[Last updated July 18, 2024]

Engineer Review N162020001: Life Technologies Corp- BioProcess Container Plant
July 19, 2024
Page 11
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

Dylan Frederick <[e-mail]>
Source Review 150810004
Emmett, Kyle <[e-mail]>Tue, Apr 16, 2024 at 4:59 PM
To: Dylan Frederick <[e-mail]>
Hey Sir-
My Site
Thermo Fisher Scientific/Life Technologies Corp
1726 HyClone Drive
Logan UT 84321
The other facility not associated with us
HyClone Laboratories/Cytiva
925 West 1800 South
Logan UT 84321
Let me know if you need anything else.
Take care- Kyle
Sent from my iPhone
On Apr 16, 2024, at 4:32 PM, Dylan Frederick <[e-mail]> wrote:
[Quoted text hidden]
6/25/24, 10:21 AM State of Utah Mail - Source Review 150810004
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1796534023225287848&simpl=msg-f:1796534023225287848 1/1
Life Technologies Corp Summary
Pollutants NOX CO PM10 PM2.5 SO2 VOC
Heaters 2.79 2.34 0.21 0.21 0.02 0.15
Emergency Engine 0.05 0.06 0 0 0 0.02
IPA Use 0 0 0 0 0 19.5
Total 2.84 2.4 0.21 0.21 0.02 19.67
CO2e HAP
3369 0.05
9 0
0 0
3378 0.05
4/7/24, 10:55 PM State of Utah Mail - Source Review 150810004
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r-3452212417711336783&simpl=msg-a:r-40619789952507…1/3
Dylan Frederick <[e-mail]>
Source Review 150810004
4 messages
Dylan Frederick <[e-mail]>Sat, Feb 24, 2024 at 5:46 PM
To: "Emmett, Kyle" <[e-mail]>
Kyle,
Please see the attached permit, and let me know if there are any issues that need to be addressed before the final draft
goes out to public comment.
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
RN150810004-24.rtf
1548K
Emmett, Kyle <[e-mail]>Mon, Feb 26, 2024 at 2:24 PM
To: Dylan Frederick <[e-mail]>
Hi Dylan-

Thanks for sending this. Doing a quick glance at it, this appears to be modification to an existing Approval Order for
Hyclone Labs/Cytiva (Not part of our business Life Technologies Corp) which is directly south of our facility and not the
New Source Registration/Initial Approval Order I submitted. What tipped me off was Section II that lists multiple dust
collectors, multiple generators and boilers, which we don’t have at our facility but I know Hyclone Labs across the street
has all that equipment. I know they are going through a large expansion, did they submit permit modification paperwork?

The Life Technologies Corporation/Thermo Fisher Scientific site I submitted for Initial Approval for only has 1 diesel
generator, comfort air systems, and IPA as emissions sources. There are no dust collectors/generation or boilers on-site

I know our address has Hyclone in our street address, but we are not associated with them and sometimes that causes
confusion.

If we need to have a call to discuss please let me know but from what I am reviewing the information on the attached is for
Hyclone Labs/Cytiva, not my facility Life Technologies/Thermo Fisher located at 1726 Hyclone Drive.

4/7/24, 10:55 PM State of Utah Mail - Source Review 150810004
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r-3452212417711336783&simpl=msg-a:r-40619789952507…2/3
Thanks-

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Saturday, February 24, 2024 5:46 PM
To: Emmett, Kyle <[e-mail]>
Subject: Source Review 150810004

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious, report
using the Report Phish button in Outlook or send to [e-mail].
[Quoted text hidden]
RN150810004-24.rtf
1548K
Dylan Frederick <[e-mail]>Wed, Feb 28, 2024 at 10:10 AM
To: "Emmett, Kyle" <[e-mail]>
Kyle,
Thanks for letting me know about this. Back when I got this project reassigned to me I had assumed they had the right
site IDs. So this facility never had an approval order before?
[Quoted text hidden]
Emmett, Kyle <[e-mail]>Wed, Feb 28, 2024 at 3:50 PM
To: Dylan Frederick <[e-mail]>
Thanks Dylan-

Correct this facility has not had an approval order previously.
4/7/24, 10:55 PM State of Utah Mail - Source Review 150810004
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-a:r-3452212417711336783&simpl=msg-a:r-40619789952507…3/3

Let me know if you have any questions.

Take care-

-Kyle
[Quoted text hidden]
2/15/24, 2:34 PM State of Utah Mail - Project Update Hyclone Labs
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-a:r-6570950840459348287&dsqt=1&simpl=msg-a:r-6570950…1/8
Dylan Frederick <[e-mail]>
Project Update Hyclone Labs
Dylan Frederick <[e-mail]>Thu, Feb 15, 2024 at 2:15 PM
To: "Emmett, Kyle" <[e-mail]>
Thanks Kyle, glad I asked, because I thought the 19,500 in this form represented lbs of IPA, not tons. I will keep the limit
at 19.5
On Wed, Feb 14, 2024 at 5:17 PM Emmett, Kyle <[e-mail]> wrote:
Hey Sir-

Correct we want to maintain 19.5 tpy. See attached Form 5 of when we initially requested 20 tpy but after discussion
didn’t want to push the limit that would put us in Title IV danger.

We hopefully can stay well below that (in the near term), but as we pick back up production demand, may increase IPA
usage close to that 19.5 tpy. We do have some projects in the works to further decrease our IPA usage….but it will be a
couple years.

Thanks for following up.

Take care-

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Wednesday, February 14, 2024 10:58 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Project Update Hyclone Labs
2/15/24, 2:34 PM State of Utah Mail - Project Update Hyclone Labs
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-a:r-6570950840459348287&dsqt=1&simpl=msg-a:r-6570950…2/8

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious, report
using the Report Phish button in Outlook or send to [e-mail].

Hey Kyle,

I have one more question for you that was brought up during management's review of the permit. Are you sure about
the 9.5 tpy limit on Isopropanol for this approval order? The previous AO was at 19.5. We wanted to be sure to avoid a
situation where you need to have the limit raised again in a few years.

On Wed, Feb 7, 2024 at 4:00 PM Emmett, Kyle <[e-mail]> wrote:
You bet. See attached, along with the initial Form 2 initially submitted.

Let me know if you need anything else.

Take care-

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Wednesday, February 7, 2024 1:41 PM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Project Update Hyclone Labs

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious,
2/15/24, 2:34 PM State of Utah Mail - Project Update Hyclone Labs
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-a:r-6570950840459348287&dsqt=1&simpl=msg-a:r-6570950…3/8
report using the Report Phish button in Outlook or send to [e-mail].

Kyle,

I'm realizing I forgot to address the email you had sent to me on the 25th. Is it possible for you to fill this form out for
me to confirm the correct ownership of the facility?

On Tue, Feb 6, 2024 at 4:33 PM Dylan Frederick <[e-mail]> wrote:
I think I have that spec sheet, I'm not sure if the reviewer saw that part or not. If you can find a separate sheet
from the EPA that would be great but I think you're fine for now.

On Tue, Feb 6, 2024 at 4:26 PM Emmett, Kyle <[e-mail]> wrote:
Hey Dylan-

Thanks for the update. I will need to do some looking to see if I can get that certificate of conformity. Only thing I
have in my records is the attached Spec Sheet. Will that work or do you need an actual certificate?

Take care- Kyle

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, February 6, 2024 12:13 PM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Project Update Hyclone Labs

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious,
report using the Report Phish button in Outlook or send to [e-mail].

Kyle,

I have gotten the compliance review done for the permit, you should see the permit after the management
review is done in the next week. I had a question, did you ever get an EPA sheet for the emergency engine that
is listed as a "certificate of conformity"?

On Thu, Jan 25, 2024 at 3:13 PM Emmett, Kyle <[e-mail]> wrote:
Hey Sir-

2/7/24, 1:32 PM State of Utah Mail - Project Update Hyclone Labs
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permmsgid=msg-f:1789102202307070978&simpl=msg-f:1789102202307070978 1/1
Dylan Frederick <[e-mail]>
Project Update Hyclone Labs
Emmett, Kyle <[e-mail]>Thu, Jan 25, 2024 at 3:13 PM
To: Dylan Frederick <[e-mail]>
Hey Sir-
Our Owner is Life Technologies Corp which is a Thermo Fisher Scientific fully owned subsidiary. Please use Life
Technologies Corp on all official documentation as that is our legal name and entity.
A little bit of background- Back in 2014 Thermo Fisher Scientific owned HyClone Labs, which consisted of the facility I’m
at and the remaining HyClone Labs facility across the street. In that year Thermo Fisher then bought Life Technologies,
which is a lot bigger than HyClone and due to having a monopoly on the market in our industry, the US Trade Commission
required that Thermo Fisher either call of the purchase of Life Technologies or sell HyClone Labs. Thermo Fisher made
the decision to sell HyClone Labs which was purchased by GE Healthcare and has since been purchased by Danaher
Corporation and rebranded as Cytiva. They are a competitor and customer of our but we have no affiliation with them.
So in short- HyClone Labs is no longer associated with Life Technologies or Thermo Fisher Scientific.
Hope this helps. Please let me know if you have any other questions.
Take care- Kyle
On Jan 25, 2024, at 2:59 PM, Dylan Frederick <[e-mail]> wrote:
[Quoted text hidden]
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:1739998426551608…1/87
Dylan Frederick <[e-mail]>
Re: Air Quality Notices Received
16 messages
Rita Trick <[e-mail]>Mon, Aug 1, 2022 at 4:06 PM
To: "Emmett, Kyle" <[e-mail]>, Dylan Frederick <[e-mail]>
Thank you for the update. I have added my coworker to this email ([e-mail]), he will be taking over the
project from here.
Best Regards,
Rita
On Thu, Jul 28, 2022 at 2:59 PM Emmett, Kyle <[e-mail]> wrote:
Hi Rita-

Talking to our Engineering Team we are estimating consuming 8 million lbs of film in 2022. If we were to run all
equipment at 100% capacity we could run up to an estimated 12 million lbs in a 12 month period. For business
continuity and redundancy capacity in the event one of our sister sites across the globe has issues, we want to keep
below 80% capacity in our regular schedule.

Please let me know if you need anything else.

Take care-

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Wednesday, July 27, 2022 1:04 PM
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:1739998426551608…2/87
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious, report
using the Report Phish button in Outlook or send to [e-mail].

Hello Kyle,
Do you have an estimate of how much plastic will be consumed at the facility over a rolling 12-month period?

On Wed, Jul 20, 2022 at 11:20 AM Emmett, Kyle <[e-mail]> wrote:
HI Rita.

Hope your surgery went well and you are healing quick!

1. 19,500 is lbs/year? The attached calculations are PDFs and I cannot see how it was calculated. Would it be
possible to attach written or excel calculations?
a. I have attached the excel spreadsheet used to calculate the usage YTD. As I mentioned in an earlier
message our usage got out of hand in 2021 due to using isopropanol for general cleaning during the
COVID Pandemic. Our expansion projects were not completed till the end of 2021 and we have usage
back in control in 2022 and expect to use less than 16-17k lbs/site by year end.
2. "Eaches" is not a unit I am familiar with. The material listed is BioProcess Container Assemblies at an annual
quantity of 1,200,000. Is that 1,200,000 bag/tube assemblies? Could you estimate the plastic needed (in lbs)
to produce those?
a. The “Eaches” refers to a single BioProcess Container Assembly, so we would consider each Bag/Tube
assembly an “Each” and we produce 1.2mil/yr.
b. As far as estimating lbs of plastic to produce these, that might get a little tricky, but I will see what I can
find out. Some of our bags are 10k Liters and others are 2 Liters made of the same material. I’ll ask our
procurement team how many rolls of plastic film they purchased and used in 2021 and 2022YTD.
3. For the 650 North 870 West location are there any generators, boilers, spray bottles, or plastic melters?
a. At this location we do not have any generators, boilers or anything to melt plastic. The only thing they
have is bottles of 70% and 90% isopropanol for cleaning and lubrication. At this facility all they do is
attached tubing and components to bags or lines. This facility will take chambers that were built at the
1726 Hyclone Site or from some of our sister sites located in Tennessee, Pennsylvania, England, or
Singapore, and do the final assembly based on demand.

Please let me know if you need anything else and I’ll see if I can get a gauge on our plastic film used in 2021 and
2022YTD in lbs.

Take care,

Kyle D. Emmett, CIH, CSP
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:1739998426551608…3/87
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Wednesday, July 20, 2022 10:05 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious,
report using the Report Phish button in Outlook or send to [e-mail].

Just to clarify,
1. 19,500 is lbs/year? The attached calculations are PDFs and I cannot see how it was calculated. Would it be
possible to attach written or excel calculations?
2. "Eaches" is not a unit I am familiar with. The material listed is BioProcess Container Assemblies at an annual
quantity of 1,200,000. Is that 1,200,000 bag/tube assemblies? Could you estimate the plastic needed (in lbs) to
produce those?
3. For the 650 North 870 West location are there any generators, boilers, spray bottles, or plastic melters?

On Tue, Jul 12, 2022 at 12:41 PM Emmett, Kyle <[e-mail]> wrote:
Hi Rita-

Hope your surgery went well and your recovery is quick.
1. Calculations for the emissions information: See attached for Alcohol Usage Information for both the 1726
Hyclone and 650 North Locations in 2021 and 2022. As mentioned earlier, this Isopropyl Alcohol is used literally by
spray bottle or wipe to clean surfaces in our cleanrooms or lubrication for putting parts together. We shouldn’t get
above 16,000 lbs of IPA used at either site by year end, but I put a max of 19,500 on the NOI at the
recommendation of a consultant.
2. Units on Form 3 for maximum hourly production and maximum annual production: The units would be “eaches”.
I have included in the attached “Product Examples” PPT some examples of some of the products that we make so
you have a visual of what we make. These containers range in size from 10mL to 10,000L depending on the
customer needs.
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:1739998426551608…4/87
3. Emitting units in each of the facilities. The NOI for the 650 North 870 West location does not list any specific
equipment: All the emissions are coming through comfort air HVAC systems for our building cleanrooms and/or
through general building air loss. Each of the HVAC Units are fitted w/ exhaust fans, but the fans are rarely
running because we maintain a positive pressure in the cleanrooms and the air losses are mainly through the
airlock and man-door accesses. We also recirculate greater than 80% or our air. Attached is the Air Handling Unit
info to these air handling systems for each site along w/ a screenshot from the control software showing that the
exhaust fans are not running.
Please let me know if you need any further info or if you would like to have a call to discuss in more detail. We
want to make sure we do this right.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Tuesday, July 5, 2022 1:55 PM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious,
report using the Report Phish button in Outlook or send to [e-mail].

Emmett, I am so sorry about the accident! Thank you for getting back to me. I am getting ACL surgery on
Thursday and should be back to review the data late next week. I will look it over and email you with questions /
set up a video call.

Thanks for working on this!

On Tue, Jul 5, 2022 at 12:28 PM Emmett, Kyle <[e-mail]> wrote:
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:1739998426551608…5/87
Hi Rita-

Thanks for the quick response. I’m looking forward to working with you on this. If it’s ok w/ you I will have the
requested info to you for both the 1726 HyClone Drive and 650 North Locations by the end of the week. I was
in a auto accident the first part of June that busted me up pretty good and I was out of office till last week. I
have the info you are asking for, just need to organize it so it makes sense and get the latest usage data from
our production team.

Just a little background, at the end of 2021 we went through a massive expansion and that led us to do a
regulatory review and we realize we no longer fall under the Small Source Exemption. With that said, due to
COVID we also started to use a lot of Isopropanol for general cleaning which increased our site usage and
inflated our numbers. We got that back under control and now know that our VOC usage (Isopropanol) is only
for use in our FDA regulated cleanroom for cleaning and lubrication of our products and we will be above the 5
tons but below the 10 tons for large generators.

I apologize for not submitting everything you need. We are in a weird situation where our IPA emissions is
literally from spray bottles and wipers. We make the assumption that it all volatilizes and thus is an emission. It
is generally just lost to atmosphere through comfort air systems from our cleanroom or through building air
losses because the clean rooms are kept under positive pressure.

I’ll send you all the requested info and then if there are still questions I would enjoy a video call to make sure we
are on the same page.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Tuesday, July 5, 2022 9:59 AM
To: Emmett, Kyle <[e-mail]>
Subject: Air Quality Notices Received

1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:1739998426551608…6/87
CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious,
report using the Report Phish button in Outlook or send to [e-mail].

Hello Mr. Emmett,
The Utah Department of Air Quality (DAQ) has received two Notice of Intents (NOIs) for Life Technologies Corp.
It appears that the majority of the information is the same/similar on both NOIs. I was hoping you could provide
the following:
1. Calculations for the emissions information. To have the potential to emit 19,500 tons per year of VOCS is
extremely high.
2. Units on Form 3 for maximum hourly production and maximum annual production.
3. Emitting units in each of the facilities. The NOI for the 650 North 870 West location does not list any specific
equipment. The NOI for the 1726 Hyclone Drive location does not list any specific equipment but there is an
attachment for an emergency generator. ,

Please let me know if you have any questions. I would be happy to set up a video-call to better discuss what is
needed from both of these applications.

Thank you.
--
Rita Trick
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--
Rita
[phone]

--
Rita
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:1739998426551608…7/87
[phone]

--
Rita
[phone]
--
Rita
[phone]
Emmett, Kyle <[e-mail]>Thu, Sep 8, 2022 at 11:20 AM
To: Dylan Frederick <[e-mail]>
Hi Dylan-

Hope things are going well. Just reaching out to see if you need anything more from me on our NOI Applications for the
two separate sites in Logan Utah?

Thanks,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
[Quoted text hidden]
Dylan Frederick <[e-mail]>Tue, Oct 18, 2022 at 11:02 AM
To: "Emmett, Kyle" <[e-mail]>
Hello Kyle,
I'm so sorry for taking a while to get back to you, I lost track of this email for a while and have been prioritizing some other
projects I've had. I've had a chance to look at the project and what Rita had gotten from you so far, and I do have some
more information I'd like to request.
1. Are there any emission sources at the facility besides the IPA use? Any combustion based heating units, or plastic
melting?
2. I've attached the emission information I have received, and based on the correspondence I saw with Rita, these
calculations do not match the total VOC's requested in the application. The eventual permit will have a limit on the total
VOCs you can emit and will require you track your sources of IPA use to make sure you do not exceed that limit. Can you
give me an estimate of what the maximum total IPA use would be at the facility in a year? By using your potential
maximum, we can set the limit at that number and you shouldn't have much trouble staying under the limit.
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:1739998426551608…8/87
3. For all increases in emissions and newly permitted sources, we need a "Best Available Control Technology" or BACT
analysis submitted. This essentially is evaluating what control options there are to potentially reduce emissions at the
facility. Please send me an analysis that shows you've evaluated potential controls at the facility, including potential add-
on controls that could capture and dispose of the VOCs. If it is not possible to have a VOC capture system with a control,
your analysis can simply explain why it is not possible to include a capture system or controls. It helps us out a lot if you
can include a cost estimate of some kind as well.
I hope this isn't too much at once, please feel free to call me or contact me with any questions you may have about the
information requested above, thank you.
[Quoted text hidden]
--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
2 attachments
VOC Usage Calculated 2022 11JUL2022.xlsx
17K
2021 Alcohol Usage.pdf
230K
Emmett, Kyle <[e-mail]>Mon, Oct 31, 2022 at 10:24 AM
To: Dylan Frederick <[e-mail]>
Hi Dylan-

My apologies for the late response, I’ve been on PTO (hunting season….) and just getting around to my earlier emails. I
will get you responses to your requests here in the next couple of days.

Thanks-
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1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:1739998426551608…9/87
[Quoted text hidden]
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--
Rita Trick
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--
Rita
[phone]

--
Rita
[phone]

--
Rita
[phone]

--
Rita
[phone]

--
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…10/87
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
[Quoted text hidden]
Emmett, Kyle <[e-mail]>Mon, Nov 14, 2022 at 2:15 PM
To: Dylan Frederick <[e-mail]>
Hi Dylan-

Again, apologies for the late response, busy time…..

See below in blue for responses to your questions.

1. Are there any emission sources at the facility besides the IPA use? Any combustion based heating units, or plastic
melting?
a. At the BioCenter location at 1726 Hyclone Drive we have one emergency generator. No boilers, or plastic
melting. The Comfort Air Systems are natural gas, but no industrial heating units are on-site. Let me know if
you require anything for the Comfort Air Systems.
b. At the Assembly Center location at 650 N 870 West there are no other emissions sources besides the IPA.
The Comfort Air Systems are natural gas fired. but no industrial heating units are on-site. Let me know if you
require anything for the Comfort Air Systems.

2. I've attached the emission information I have received, and based on the correspondence I saw with Rita, these
calculations do not match the total VOC's requested in the application. The eventual permit will have a limit on the
total VOCs you can emit and will require you track your sources of IPA use to make sure you do not exceed that
limit. Can you give me an estimate of what the maximum total IPA use would be at the facility in a year? By using
your potential maximum, we can set the limit at that number and you shouldn't have much trouble staying under
the limit.
a. On the Application Form 5 I had put “Permitted Emissions” at 20,000 lbs and “Proposed Emissions” at
19,500lbs at the advice of a consultant to give us some wiggle room in the event of a process upset or need
for extra cleaning of our controlled room. With that said below is the projected emissions for 2022.
b. We can easily track monthly the amount of IPA consumed on-site
c. At the BioCenter we are currently on track to use ~17,250 lbs of IPA by year end
d. At the Assembly Center we are currently on tract to use ~15,500 lbs of IPA by year end

3. For all increases in emissions and newly permitted sources, we need a "Best Available Control Technology" or
BACT analysis submitted. This essentially is evaluating what control options there are to potentially reduce
emissions at the facility. Please send me an analysis that shows you've evaluated potential controls at the facility,
including potential add-on controls that could capture and dispose of the VOCs. If it is not possible to have a VOC
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…11/87
capture system with a control, your analysis can simply explain why it is not possible to include a capture system
or controls. It helps us out a lot if you can include a cost estimate of some kind as well.
a. I kinda figured you’d be asking for something like this. See attached for a brief summary I started putting
together awhile ago. If this isn’t what you need and you require more technical data please let me know and
I will see what I can track down.

Thanks and please let me know if you need anything else.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

[Quoted text hidden]
VOC Best Available Control Technology Analysis.pptx
1109K
Dylan Frederick <[e-mail]>Tue, Nov 15, 2022 at 10:28 AM
To: "Emmett, Kyle" <[e-mail]>
Kyle,
Thanks for getting back to me. I do have some more questions based on your responses.
1. Can I please get emission calculations for the comfort air systems? If they are natural gas powered there should be
associated combustion emissions.
2. The emergency generator needs calculations submitted as well, but only for 100 hours of operation. This is the
standard way we permit emergency use generators, the 100 hours is just for testing and maintenance purposes and does
not include any actual emergency use situations.
3. For the IPA use, having some breathing room is fine, I just want to confirm here that you are requesting an annual VOC
limit of 9.5 tons per year for both facilities (specifically to limit IPA). If there is a different limit you are requesting to set for
each facility, please let me know.
4. The BACT analysis you sent me is pretty close to what I'm looking for, but is this intended to apply to both facilities?
Additionally, if you can provide any more specific information or technical data for my write up, I'll happily take it, the more
quantifiable information I can put in the better.
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…12/87
5. Unfortunately I also need a BACT analysis for the generator and air systems assuming they are contributing to
emissions at each site. My expectation is that emissions from the generator will be too low to add controls at 100 hours of
operation per year, but I'm supposed to get a BACT analysis anyways. Same is true for the air systems, there probably
aren't many upgrades that are feasible for a natural gas system, especially if its a small unit. If the AC systems are under
5 MMBtu/hr for each unit, disregard my request for a BACT analysis as that would make it exempt from the requirement to
provide a BACT analysis.
Hopefully these requests are straight forward, please feel free to call or contact me if you have any questions. Thanks for
all your help,
Dylan
[Quoted text hidden]
Emmett, Kyle <[e-mail]>Thu, Nov 17, 2022 at 10:19 AM
To: Dylan Frederick <[e-mail]>
Hi Dylan-

Thanks for working through this with me. My apologies if I’m making this more difficult for you than is necessary. Definitely
a good learning experience for me. I’m working with a consultant on this but for my personal/professional development I’m
trying to do most of the work on my own. Please see below in blue my responses. I will work on getting you more detail in
the next couple of weeks.

1. Can I please get emission calculations for the comfort air systems? If they are natural gas powered there should
be associated combustion emissions.
a. Please give me a couple weeks to gather all this information. We are in the process of implementing a new
Maintenance Management System and this info isn’t readily accessible and we will need to go to each unit.

2. The emergency generator needs calculations submitted as well, but only for 100 hours of operation. This is the
standard way we permit emergency use generators, the 100 hours is just for testing and maintenance purposes
and does not include any actual emergency use situations.
a. Please let me know if the attached data sheet titled “A15 Emergency Generator Emissions” meets the
needs for this.

3. For the IPA use, having some breathing room is fine, I just want to confirm here that you are requesting an annual
VOC limit of 9.5 tons per year for both facilities (specifically to limit IPA). If there is a different limit you are
requesting to set for each facility, please let me know.
a. Correct, each site we would like to have a limit of 9.5 tons/yr/each site specifically for IPA (VOCs).

4. The BACT analysis you sent me is pretty close to what I'm looking for, but is this intended to apply to both
facilities? Additionally, if you can provide any more specific information or technical data for my write up, I'll happily
take it, the more quantifiable information I can put in the better.
a. Yes the BACT provided is the same for both facilities. Same type of processes occur at both facilities.

5. Unfortunately I also need a BACT analysis for the generator and air systems assuming they are contributing to
emissions at each site. My expectation is that emissions from the generator will be too low to add controls at 100
hours of operation per year, but I'm supposed to get a BACT analysis anyways. Same is true for the air systems,
there probably aren't many upgrades that are feasible for a natural gas system, especially if its a small unit. If the
AC systems are under 5 MMBtu/hr for each unit, disregard my request for a BACT analysis as that would make it
exempt from the requirement to provide a BACT analysis.
a. The same for Question 1- Please give me a couple weeks to gather all this information. We are in the
process of implementing a new Maintenance Management System and this info isn’t readily accessible and
we will need to go to each unit.
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…13/87
[Quoted text hidden]
A15 Emergency Generator Emissions.pdf
20K
Emmett, Kyle <[e-mail]>Thu, Dec 15, 2022 at 3:54 PM
To: Dylan Frederick <[e-mail]>
Hi Dylan-

Hope things are going well. I have looked at all our HVAC Heaters/AC and the highest Btu/hr units we have are
350,000btu/hr units. I’ve attached a couple pictures of the spec tags for the most common larger units we have. Let me
know if you think I’m not looking at the right info.

If this is the case do you need any further info for questions 1 and 5 below or are we good to go?
[Quoted text hidden]
HVAC Units.pptx
2830K
Dylan Frederick <[e-mail]>Thu, Dec 22, 2022 at 1:42 PM
To: "Emmett, Kyle" <[e-mail]>
Kyle,
Thanks for getting this to me. I will send a quick calculation to you for the HVAC units to account for their emissions, but
otherwise I think that is all the information I need for these. Once I get your go ahead for the calculations I'll work on
getting these projects done once the new year is started. Hope you have a good holiday,
Dylan
[Quoted text hidden]
Emmett, Kyle <[e-mail]>Wed, Jan 11, 2023 at 1:47 PM
To: Dylan Frederick <[e-mail]>
Hey Dylan-

Hope you had a good holiday break! Just following up on the below email and if I still need to send you calculations for
our HVAC emissions and if you have a tool I can use to get that back to you?
[Quoted text hidden]
Dylan Frederick <[e-mail]>Tue, Jan 31, 2023 at 9:30 AM
To: "Emmett, Kyle" <[e-mail]>
Kyle,
Sorry for taking a while to get back to you,
I've looked over the last submissions I got from you, here are the emission estimates for the generator. For the comfort air
systems, I assumed there were 3 units at 350,000 Btu each, but to be accurate I would need to know how many units
there are. I could also calculate it if you simply knew the total natural gas used at the facilities on an annual basis. Finally,
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…14/87
I never got a best available control technology (BACT) analysis for the emergency generator. Could you provide a small
write-up explaining whether further emission controls are possible, and what is already applied to the engine? If not, state
that further controls are not possible due to either economic, environmental, or energy impact concerns. In this case it
would most likely be cost, as emissions from the generator are low enough that adding controls would most likely not be
cost effective.
Thank you for your help, feel free to reach out to me with any questions you have, thanks.
[Quoted text hidden]
2 attachments
Hyclone and Thermo Fisher emergency generator.xlsx
76K
Comfort Air Systems emissions Hyclone and Thermo Fisher.xlsx
80K
Emmett, Kyle <[e-mail]>Wed, Feb 8, 2023 at 5:42 PM
To: Dylan Frederick <[e-mail]>
Hi Dylan-

Thanks for all your help and guidance with all this. Here is what I have for you.

1726 Hyclone Drive Facility
1. Attached is the updated version of the emissions estimates you provided for the comfort air systems. I added a
second tab to the Excel File that includes an inventory of all the gas fired systems on-site so you can check my
work, and updated the Rating on the calculations tab.
2. Reviewed the emissions estimates for the emergency generator and agree with it.
3. See attached BACT review for the emergency generator.

650 North 870 West Facility
1. Attached is emissions estimate for the comfort air systems. I added a second tab to the Excel File that includes an
inventory of all the gas fired systems on-site and updated the Rating on the calculations tab.

Please let me know if you need anything else.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…15/87
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, January 31, 2023 9:30 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious, report
using the Report Phish button in Outlook or send to [e-mail].

Kyle,

Sorry for taking a while to get back to you,

I've looked over the last submissions I got from you, here are the emission estimates for the generator. For the comfort air
systems, I assumed there were 3 units at 350,000 Btu each, but to be accurate I would need to know how many units
there are. I could also calculate it if you simply knew the total natural gas used at the facilities on an annual basis. Finally,
I never got a best available control technology (BACT) analysis for the emergency generator. Could you provide a small
write-up explaining whether further emission controls are possible, and what is already applied to the engine? If not, state
that further controls are not possible due to either economic, environmental, or energy impact concerns. In this case it
would most likely be cost, as emissions from the generator are low enough that adding controls would most likely not be
cost effective.

Thank you for your help, feel free to reach out to me with any questions you have, thanks.

On Wed, Jan 11, 2023 at 1:48 PM Emmett, Kyle <[e-mail]> wrote:
Hey Dylan-

Hope you had a good holiday break! Just following up on the below email and if I still need to send you calculations for
our HVAC emissions and if you have a tool I can use to get that back to you?

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…16/87

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Thursday, December 22, 2022 1:43 PM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious, report
using the Report Phish button in Outlook or send to [e-mail].

Kyle,

Thanks for getting this to me. I will send a quick calculation to you for the HVAC units to account for their emissions, but
otherwise I think that is all the information I need for these. Once I get your go ahead for the calculations I'll work on
getting these projects done once the new year is started. Hope you have a good holiday,

Dylan

On Thu, Dec 15, 2022 at 3:54 PM Emmett, Kyle <[e-mail]> wrote:
Hi Dylan-

Hope things are going well. I have looked at all our HVAC Heaters/AC and the highest Btu/hr units we have are
350,000btu/hr units. I’ve attached a couple pictures of the spec tags for the most common larger units we have. Let
me know if you think I’m not looking at the right info.

If this is the case do you need any further info for questions 1 and 5 below or are we good to go?

Thanks,

1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…17/87
Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Emmett, Kyle
Sent: Thursday, November 17, 2022 10:20 AM
To: Dylan Frederick <[e-mail]>
Subject: RE: Air Quality Notices Received

Hi Dylan-

Thanks for working through this with me. My apologies if I’m making this more difficult for you than is necessary.
Definitely a good learning experience for me. I’m working with a consultant on this but for my personal/professional
development I’m trying to do most of the work on my own. Please see below in blue my responses. I will work on
getting you more detail in the next couple of weeks.

1. Can I please get emission calculations for the comfort air systems? If they are natural gas powered there
should be associated combustion emissions.
a. Please give me a couple weeks to gather all this information. We are in the process of implementing a
new Maintenance Management System and this info isn’t readily accessible and we will need to go to
each unit.

2. The emergency generator needs calculations submitted as well, but only for 100 hours of operation. This is
the standard way we permit emergency use generators, the 100 hours is just for testing and maintenance
purposes and does not include any actual emergency use situations.
a. Please let me know if the attached data sheet titled “A15 Emergency Generator Emissions” meets the
needs for this.

3. For the IPA use, having some breathing room is fine, I just want to confirm here that you are requesting an
annual VOC limit of 9.5 tons per year for both facilities (specifically to limit IPA). If there is a different limit you
are requesting to set for each facility, please let me know.
a. Correct, each site we would like to have a limit of 9.5 tons/yr/each site specifically for IPA (VOCs).

1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…18/87
4. The BACT analysis you sent me is pretty close to what I'm looking for, but is this intended to apply to both
facilities? Additionally, if you can provide any more specific information or technical data for my write up, I'll
happily take it, the more quantifiable information I can put in the better.
a. Yes the BACT provided is the same for both facilities. Same type of processes occur at both facilities.

5. Unfortunately I also need a BACT analysis for the generator and air systems assuming they are contributing
to emissions at each site. My expectation is that emissions from the generator will be too low to add controls
at 100 hours of operation per year, but I'm supposed to get a BACT analysis anyways. Same is true for the air
systems, there probably aren't many upgrades that are feasible for a natural gas system, especially if its a
small unit. If the AC systems are under 5 MMBtu/hr for each unit, disregard my request for a BACT analysis
as that would make it exempt from the requirement to provide a BACT analysis.
a. The same for Question 1- Please give me a couple weeks to gather all this information. We are in the
process of implementing a new Maintenance Management System and this info isn’t readily
accessible and we will need to go to each unit.
Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, November 15, 2022 10:28 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious,
report using the Report Phish button in Outlook or send to [e-mail].

Kyle,

Thanks for getting back to me. I do have some more questions based on your responses.
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…19/87

1. Can I please get emission calculations for the comfort air systems? If they are natural gas powered there should
be associated combustion emissions.

2. The emergency generator needs calculations submitted as well, but only for 100 hours of operation. This is the
standard way we permit emergency use generators, the 100 hours is just for testing and maintenance purposes and
does not include any actual emergency use situations.

3. For the IPA use, having some breathing room is fine, I just want to confirm here that you are requesting an annual
VOC limit of 9.5 tons per year for both facilities (specifically to limit IPA). If there is a different limit you are requesting
to set for each facility, please let me know.

4. The BACT analysis you sent me is pretty close to what I'm looking for, but is this intended to apply to both
facilities? Additionally, if you can provide any more specific information or technical data for my write up, I'll happily
take it, the more quantifiable information I can put in the better.

5. Unfortunately I also need a BACT analysis for the generator and air systems assuming they are contributing to
emissions at each site. My expectation is that emissions from the generator will be too low to add controls at 100
hours of operation per year, but I'm supposed to get a BACT analysis anyways. Same is true for the air systems,
there probably aren't many upgrades that are feasible for a natural gas system, especially if its a small unit. If the AC
systems are under 5 MMBtu/hr for each unit, disregard my request for a BACT analysis as that would make it
exempt from the requirement to provide a BACT analysis.

Hopefully these requests are straight forward, please feel free to call or contact me if you have any questions.
Thanks for all your help,

Dylan

On Mon, Nov 14, 2022 at 2:15 PM Emmett, Kyle <[e-mail]> wrote:
Hi Dylan-

Again, apologies for the late response, busy time…..

See below in blue for responses to your questions.

1. Are there any emission sources at the facility besides the IPA use? Any combustion based heating units, or
plastic melting?
a. At the BioCenter location at 1726 Hyclone Drive we have one emergency generator. No boilers, or
plastic melting. The Comfort Air Systems are natural gas, but no industrial heating units are on-site.
Let me know if you require anything for the Comfort Air Systems.
b. At the Assembly Center location at 650 N 870 West there are no other emissions sources besides
the IPA. The Comfort Air Systems are natural gas fired. but no industrial heating units are on-site.
Let me know if you require anything for the Comfort Air Systems.

1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…20/87
2. I've attached the emission information I have received, and based on the correspondence I saw with Rita,
these calculations do not match the total VOC's requested in the application. The eventual permit will have
a limit on the total VOCs you can emit and will require you track your sources of IPA use to make sure you
do not exceed that limit. Can you give me an estimate of what the maximum total IPA use would be at the
facility in a year? By using your potential maximum, we can set the limit at that number and you shouldn't
have much trouble staying under the limit.
a. On the Application Form 5 I had put “Permitted Emissions” at 20,000 lbs and “Proposed Emissions”
at 19,500lbs at the advice of a consultant to give us some wiggle room in the event of a process
upset or need for extra cleaning of our controlled room. With that said below is the projected
emissions for 2022.
b. We can easily track monthly the amount of IPA consumed on-site
c. At the BioCenter we are currently on track to use ~17,250 lbs of IPA by year end
d. At the Assembly Center we are currently on tract to use ~15,500 lbs of IPA by year end

3. For all increases in emissions and newly permitted sources, we need a "Best Available Control
Technology" or BACT analysis submitted. This essentially is evaluating what control options there are to
potentially reduce emissions at the facility. Please send me an analysis that shows you've evaluated
potential controls at the facility, including potential add-on controls that could capture and dispose of the
VOCs. If it is not possible to have a VOC capture system with a control, your analysis can simply explain
why it is not possible to include a capture system or controls. It helps us out a lot if you can include a cost
estimate of some kind as well.
a. I kinda figured you’d be asking for something like this. See attached for a brief summary I started
putting together awhile ago. If this isn’t what you need and you require more technical data please
let me know and I will see what I can track down.

Thanks and please let me know if you need anything else.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, October 18, 2022 11:03 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…21/87
CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious,
report using the Report Phish button in Outlook or send to [e-mail].

Hello Kyle,

I'm so sorry for taking a while to get back to you, I lost track of this email for a while and have been prioritizing
some other projects I've had. I've had a chance to look at the project and what Rita had gotten from you so far,
and I do have some more information I'd like to request.

1. Are there any emission sources at the facility besides the IPA use? Any combustion based heating units, or
plastic melting?

2. I've attached the emission information I have received, and based on the correspondence I saw with Rita,
these calculations do not match the total VOC's requested in the application. The eventual permit will have a limit
on the total VOCs you can emit and will require you track your sources of IPA use to make sure you do not
exceed that limit. Can you give me an estimate of what the maximum total IPA use would be at the facility in a
year? By using your potential maximum, we can set the limit at that number and you shouldn't have much trouble
staying under the limit.

3. For all increases in emissions and newly permitted sources, we need a "Best Available Control Technology" or
BACT analysis submitted. This essentially is evaluating what control options there are to potentially reduce
emissions at the facility. Please send me an analysis that shows you've evaluated potential controls at the facility,
including potential add-on controls that could capture and dispose of the VOCs. If it is not possible to have a VOC
capture system with a control, your analysis can simply explain why it is not possible to include a capture system
or controls. It helps us out a lot if you can include a cost estimate of some kind as well.

I hope this isn't too much at once, please feel free to call me or contact me with any questions you may have
about the information requested above, thank you.

On Thu, Sep 8, 2022 at 11:20 AM Emmett, Kyle <[e-mail]> wrote:
Hi Dylan-

Hope things are going well. Just reaching out to see if you need anything more from me on our NOI
Applications for the two separate sites in Logan Utah?

Thanks,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…22/87

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Monday, August 1, 2022 4:06 PM
To: Emmett, Kyle <[e-mail]>; Dylan Frederick <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious,
report using the Report Phish button in Outlook or send to [e-mail].

Thank you for the update. I have added my coworker to this email ([e-mail]), he will be taking over
the project from here.

Best Regards,
Rita

On Thu, Jul 28, 2022 at 2:59 PM Emmett, Kyle <[e-mail]> wrote:
Hi Rita-

Talking to our Engineering Team we are estimating consuming 8 million lbs of film in 2022. If we were to run
all equipment at 100% capacity we could run up to an estimated 12 million lbs in a 12 month period. For
business continuity and redundancy capacity in the event one of our sister sites across the globe has issues,
we want to keep below 80% capacity in our regular schedule.

Please let me know if you need anything else.

Take care-

Kyle D. Emmett, CIH, CSP
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…23/87
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Wednesday, July 27, 2022 1:04 PM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be
suspicious, report using the Report Phish button in Outlook or send to [e-mail].

Hello Kyle,
Do you have an estimate of how much plastic will be consumed at the facility over a rolling 12-month
period?

On Wed, Jul 20, 2022 at 11:20 AM Emmett, Kyle <[e-mail]> wrote:
HI Rita.

Hope your surgery went well and you are healing quick!

1. 19,500 is lbs/year? The attached calculations are PDFs and I cannot see how it was calculated.
Would it be possible to attach written or excel calculations?
a. I have attached the excel spreadsheet used to calculate the usage YTD. As I mentioned in
an earlier message our usage got out of hand in 2021 due to using isopropanol for general
cleaning during the COVID Pandemic. Our expansion projects were not completed till the
end of 2021 and we have usage back in control in 2022 and expect to use less than 16-17k
lbs/site by year end.
2. "Eaches" is not a unit I am familiar with. The material listed is BioProcess Container Assemblies at
an annual quantity of 1,200,000. Is that 1,200,000 bag/tube assemblies? Could you estimate the
plastic needed (in lbs) to produce those?
a. The “Eaches” refers to a single BioProcess Container Assembly, so we would consider
each Bag/Tube assembly an “Each” and we produce 1.2mil/yr.
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…24/87
b. As far as estimating lbs of plastic to produce these, that might get a little tricky, but I will see
what I can find out. Some of our bags are 10k Liters and others are 2 Liters made of the
same material. I’ll ask our procurement team how many rolls of plastic film they purchased
and used in 2021 and 2022YTD.
3. For the 650 North 870 West location are there any generators, boilers, spray bottles, or plastic
melters?
a. At this location we do not have any generators, boilers or anything to melt plastic. The only
thing they have is bottles of 70% and 90% isopropanol for cleaning and lubrication. At this
facility all they do is attached tubing and components to bags or lines. This facility will take
chambers that were built at the 1726 Hyclone Site or from some of our sister sites located in
Tennessee, Pennsylvania, England, or Singapore, and do the final assembly based on
demand.

Please let me know if you need anything else and I’ll see if I can get a gauge on our plastic film used in
2021 and 2022YTD in lbs.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Wednesday, July 20, 2022 10:05 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be
suspicious, report using the Report Phish button in Outlook or send to [e-mail].

Just to clarify,
1. 19,500 is lbs/year? The attached calculations are PDFs and I cannot see how it was calculated. Would
it be possible to attach written or excel calculations?
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…25/87
2. "Eaches" is not a unit I am familiar with. The material listed is BioProcess Container Assemblies at an
annual quantity of 1,200,000. Is that 1,200,000 bag/tube assemblies? Could you estimate the plastic
needed (in lbs) to produce those?
3. For the 650 North 870 West location are there any generators, boilers, spray bottles, or plastic melters?

On Tue, Jul 12, 2022 at 12:41 PM Emmett, Kyle <[e-mail]> wrote:
Hi Rita-

Hope your surgery went well and your recovery is quick.
1. Calculations for the emissions information: See attached for Alcohol Usage Information for both the
1726 Hyclone and 650 North Locations in 2021 and 2022. As mentioned earlier, this Isopropyl Alcohol
is used literally by spray bottle or wipe to clean surfaces in our cleanrooms or lubrication for putting
parts together. We shouldn’t get above 16,000 lbs of IPA used at either site by year end, but I put a
max of 19,500 on the NOI at the recommendation of a consultant.
2. Units on Form 3 for maximum hourly production and maximum annual production: The units would
be “eaches”. I have included in the attached “Product Examples” PPT some examples of some of the
products that we make so you have a visual of what we make. These containers range in size from
10mL to 10,000L depending on the customer needs.
3. Emitting units in each of the facilities. The NOI for the 650 North 870 West location does not list any
specific equipment: All the emissions are coming through comfort air HVAC systems for our building
cleanrooms and/or through general building air loss. Each of the HVAC Units are fitted w/ exhaust fans,
but the fans are rarely running because we maintain a positive pressure in the cleanrooms and the air
losses are mainly through the airlock and man-door accesses. We also recirculate greater than 80% or
our air. Attached is the Air Handling Unit info to these air handling systems for each site along w/ a
screenshot from the control software showing that the exhaust fans are not running.
Please let me know if you need any further info or if you would like to have a call to discuss in more
detail. We want to make sure we do this right.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…26/87

From: Rita Trick <[e-mail]>
Sent: Tuesday, July 5, 2022 1:55 PM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be
suspicious, report using the Report Phish button in Outlook or send to [e-mail].

Emmett, I am so sorry about the accident! Thank you for getting back to me. I am getting ACL
surgery on Thursday and should be back to review the data late next week. I will look it over and email
you with questions / set up a video call.

Thanks for working on this!

On Tue, Jul 5, 2022 at 12:28 PM Emmett, Kyle <[e-mail]> wrote:
Hi Rita-

Thanks for the quick response. I’m looking forward to working with you on this. If it’s ok w/ you I will
have the requested info to you for both the 1726 HyClone Drive and 650 North Locations by the end
of the week. I was in a auto accident the first part of June that busted me up pretty good and I was
out of office till last week. I have the info you are asking for, just need to organize it so it makes
sense and get the latest usage data from our production team.

Just a little background, at the end of 2021 we went through a massive expansion and that led us to
do a regulatory review and we realize we no longer fall under the Small Source Exemption. With that
said, due to COVID we also started to use a lot of Isopropanol for general cleaning which increased
our site usage and inflated our numbers. We got that back under control and now know that our
VOC usage (Isopropanol) is only for use in our FDA regulated cleanroom for cleaning and lubrication
of our products and we will be above the 5 tons but below the 10 tons for large generators.

I apologize for not submitting everything you need. We are in a weird situation where our IPA
emissions is literally from spray bottles and wipers. We make the assumption that it all volatilizes
and thus is an emission. It is generally just lost to atmosphere through comfort air systems from our
cleanroom or through building air losses because the clean rooms are kept under positive pressure.

I’ll send you all the requested info and then if there are still questions I would enjoy a video call to
make sure we are on the same page.

Take care,

1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…27/87
Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Tuesday, July 5, 2022 9:59 AM
To: Emmett, Kyle <[e-mail]>
Subject: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be
suspicious, report using the Report Phish button in Outlook or send to [e-mail].

Hello Mr. Emmett,
The Utah Department of Air Quality (DAQ) has received two Notice of Intents (NOIs) for Life
Technologies Corp. It appears that the majority of the information is the same/similar on both NOIs. I
was hoping you could provide the following:
1. Calculations for the emissions information. To have the potential to emit 19,500 tons per year of
VOCS is extremely high.
2. Units on Form 3 for maximum hourly production and maximum annual production.
3. Emitting units in each of the facilities. The NOI for the 650 North 870 West location does not list
any specific equipment. The NOI for the 1726 Hyclone Drive location does not list any specific
equipment but there is an attachment for an emergency generator. ,

Please let me know if you have any questions. I would be happy to set up a video-call to better
discuss what is needed from both of these applications.

Thank you.
--
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…28/87
Rita Trick
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--
Rita
[phone]

--
Rita
[phone]

--
Rita
[phone]

--
Rita
[phone]

--
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…29/87
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…30/87

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…31/87
4 attachments
Comfort Air Systems Emissions Thermo Fisher- 1726 Hyclone Drive.xlsx
83K
Comfort Air Systems Emissions Thermo Fisher- 650 North 870 West.xlsx
81K
Emergency Generator Emissions Thermo Fisher- 1726 Hyclone Drive.xlsx
76K
Emergency Generator Best Available Control Technology Analysis.pptx
448K
Emmett, Kyle <[e-mail]>Thu, Apr 6, 2023 at 8:53 AM
To: Dylan Frederick <[e-mail]>
Hi Dylan-

Hope all is well. Just following up to see if any further info is needed for our Air Approval Order?

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Emmett, Kyle
Sent: Wednesday, February 8, 2023 5:42 PM
To: Dylan Frederick <[e-mail]>
Subject: RE: Air Quality Notices Received

Hi Dylan-

Thanks for all your help and guidance with all this. Here is what I have for you.
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…32/87

1726 Hyclone Drive Facility
1. Attached is the updated version of the emissions estimates you provided for the comfort air systems. I added a
second tab to the Excel File that includes an inventory of all the gas fired systems on-site so you can check my
work, and updated the Rating on the calculations tab.
2. Reviewed the emissions estimates for the emergency generator and agree with it.
3. See attached BACT review for the emergency generator.

650 North 870 West Facility
1. Attached is emissions estimate for the comfort air systems. I added a second tab to the Excel File that includes an
inventory of all the gas fired systems on-site and updated the Rating on the calculations tab.

Please let me know if you need anything else.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, January 31, 2023 9:30 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious, report
using the Report Phish button in Outlook or send to [e-mail].

Kyle,
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…33/87

Sorry for taking a while to get back to you,

I've looked over the last submissions I got from you, here are the emission estimates for the generator. For the comfort air
systems, I assumed there were 3 units at 350,000 Btu each, but to be accurate I would need to know how many units
there are. I could also calculate it if you simply knew the total natural gas used at the facilities on an annual basis. Finally,
I never got a best available control technology (BACT) analysis for the emergency generator. Could you provide a small
write-up explaining whether further emission controls are possible, and what is already applied to the engine? If not, state
that further controls are not possible due to either economic, environmental, or energy impact concerns. In this case it
would most likely be cost, as emissions from the generator are low enough that adding controls would most likely not be
cost effective.

Thank you for your help, feel free to reach out to me with any questions you have, thanks.

On Wed, Jan 11, 2023 at 1:48 PM Emmett, Kyle <[e-mail]> wrote:
Hey Dylan-

Hope you had a good holiday break! Just following up on the below email and if I still need to send you calculations for
our HVAC emissions and if you have a tool I can use to get that back to you?

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Thursday, December 22, 2022 1:43 PM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…34/87
CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious, report
using the Report Phish button in Outlook or send to [e-mail].

Kyle,

Thanks for getting this to me. I will send a quick calculation to you for the HVAC units to account for their emissions, but
otherwise I think that is all the information I need for these. Once I get your go ahead for the calculations I'll work on
getting these projects done once the new year is started. Hope you have a good holiday,

Dylan

On Thu, Dec 15, 2022 at 3:54 PM Emmett, Kyle <[e-mail]> wrote:
Hi Dylan-

Hope things are going well. I have looked at all our HVAC Heaters/AC and the highest Btu/hr units we have are
350,000btu/hr units. I’ve attached a couple pictures of the spec tags for the most common larger units we have. Let
me know if you think I’m not looking at the right info.

If this is the case do you need any further info for questions 1 and 5 below or are we good to go?

Thanks,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Emmett, Kyle
Sent: Thursday, November 17, 2022 10:20 AM
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…35/87
To: Dylan Frederick <[e-mail]>
Subject: RE: Air Quality Notices Received

Hi Dylan-

Thanks for working through this with me. My apologies if I’m making this more difficult for you than is necessary.
Definitely a good learning experience for me. I’m working with a consultant on this but for my personal/professional
development I’m trying to do most of the work on my own. Please see below in blue my responses. I will work on
getting you more detail in the next couple of weeks.

1. Can I please get emission calculations for the comfort air systems? If they are natural gas powered there
should be associated combustion emissions.
a. Please give me a couple weeks to gather all this information. We are in the process of implementing a
new Maintenance Management System and this info isn’t readily accessible and we will need to go to
each unit.

2. The emergency generator needs calculations submitted as well, but only for 100 hours of operation. This is
the standard way we permit emergency use generators, the 100 hours is just for testing and maintenance
purposes and does not include any actual emergency use situations.
a. Please let me know if the attached data sheet titled “A15 Emergency Generator Emissions” meets the
needs for this.

3. For the IPA use, having some breathing room is fine, I just want to confirm here that you are requesting an
annual VOC limit of 9.5 tons per year for both facilities (specifically to limit IPA). If there is a different limit you
are requesting to set for each facility, please let me know.
a. Correct, each site we would like to have a limit of 9.5 tons/yr/each site specifically for IPA (VOCs).

4. The BACT analysis you sent me is pretty close to what I'm looking for, but is this intended to apply to both
facilities? Additionally, if you can provide any more specific information or technical data for my write up, I'll
happily take it, the more quantifiable information I can put in the better.
a. Yes the BACT provided is the same for both facilities. Same type of processes occur at both facilities.

5. Unfortunately I also need a BACT analysis for the generator and air systems assuming they are contributing
to emissions at each site. My expectation is that emissions from the generator will be too low to add controls
at 100 hours of operation per year, but I'm supposed to get a BACT analysis anyways. Same is true for the air
systems, there probably aren't many upgrades that are feasible for a natural gas system, especially if its a
small unit. If the AC systems are under 5 MMBtu/hr for each unit, disregard my request for a BACT analysis
as that would make it exempt from the requirement to provide a BACT analysis.
a. The same for Question 1- Please give me a couple weeks to gather all this information. We are in the
process of implementing a new Maintenance Management System and this info isn’t readily
accessible and we will need to go to each unit.
Take care,

Kyle D. Emmett, CIH, CSP
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…36/87
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, November 15, 2022 10:28 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious,
report using the Report Phish button in Outlook or send to [e-mail].

Kyle,

Thanks for getting back to me. I do have some more questions based on your responses.

1. Can I please get emission calculations for the comfort air systems? If they are natural gas powered there should
be associated combustion emissions.

2. The emergency generator needs calculations submitted as well, but only for 100 hours of operation. This is the
standard way we permit emergency use generators, the 100 hours is just for testing and maintenance purposes and
does not include any actual emergency use situations.

3. For the IPA use, having some breathing room is fine, I just want to confirm here that you are requesting an annual
VOC limit of 9.5 tons per year for both facilities (specifically to limit IPA). If there is a different limit you are requesting
to set for each facility, please let me know.

4. The BACT analysis you sent me is pretty close to what I'm looking for, but is this intended to apply to both
facilities? Additionally, if you can provide any more specific information or technical data for my write up, I'll happily
take it, the more quantifiable information I can put in the better.

5. Unfortunately I also need a BACT analysis for the generator and air systems assuming they are contributing to
emissions at each site. My expectation is that emissions from the generator will be too low to add controls at 100
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…37/87
hours of operation per year, but I'm supposed to get a BACT analysis anyways. Same is true for the air systems,
there probably aren't many upgrades that are feasible for a natural gas system, especially if its a small unit. If the AC
systems are under 5 MMBtu/hr for each unit, disregard my request for a BACT analysis as that would make it
exempt from the requirement to provide a BACT analysis.

Hopefully these requests are straight forward, please feel free to call or contact me if you have any questions.
Thanks for all your help,

Dylan

On Mon, Nov 14, 2022 at 2:15 PM Emmett, Kyle <[e-mail]> wrote:
Hi Dylan-

Again, apologies for the late response, busy time…..

See below in blue for responses to your questions.

1. Are there any emission sources at the facility besides the IPA use? Any combustion based heating units, or
plastic melting?
a. At the BioCenter location at 1726 Hyclone Drive we have one emergency generator. No boilers, or
plastic melting. The Comfort Air Systems are natural gas, but no industrial heating units are on-site.
Let me know if you require anything for the Comfort Air Systems.
b. At the Assembly Center location at 650 N 870 West there are no other emissions sources besides
the IPA. The Comfort Air Systems are natural gas fired. but no industrial heating units are on-site.
Let me know if you require anything for the Comfort Air Systems.

2. I've attached the emission information I have received, and based on the correspondence I saw with Rita,
these calculations do not match the total VOC's requested in the application. The eventual permit will have
a limit on the total VOCs you can emit and will require you track your sources of IPA use to make sure you
do not exceed that limit. Can you give me an estimate of what the maximum total IPA use would be at the
facility in a year? By using your potential maximum, we can set the limit at that number and you shouldn't
have much trouble staying under the limit.
a. On the Application Form 5 I had put “Permitted Emissions” at 20,000 lbs and “Proposed Emissions”
at 19,500lbs at the advice of a consultant to give us some wiggle room in the event of a process
upset or need for extra cleaning of our controlled room. With that said below is the projected
emissions for 2022.
b. We can easily track monthly the amount of IPA consumed on-site
c. At the BioCenter we are currently on track to use ~17,250 lbs of IPA by year end
d. At the Assembly Center we are currently on tract to use ~15,500 lbs of IPA by year end

3. For all increases in emissions and newly permitted sources, we need a "Best Available Control
Technology" or BACT analysis submitted. This essentially is evaluating what control options there are to
potentially reduce emissions at the facility. Please send me an analysis that shows you've evaluated
potential controls at the facility, including potential add-on controls that could capture and dispose of the
VOCs. If it is not possible to have a VOC capture system with a control, your analysis can simply explain
why it is not possible to include a capture system or controls. It helps us out a lot if you can include a cost
estimate of some kind as well.
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…38/87
a. I kinda figured you’d be asking for something like this. See attached for a brief summary I started
putting together awhile ago. If this isn’t what you need and you require more technical data please
let me know and I will see what I can track down.

Thanks and please let me know if you need anything else.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, October 18, 2022 11:03 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious,
report using the Report Phish button in Outlook or send to [e-mail].

Hello Kyle,

I'm so sorry for taking a while to get back to you, I lost track of this email for a while and have been prioritizing
some other projects I've had. I've had a chance to look at the project and what Rita had gotten from you so far,
and I do have some more information I'd like to request.

1. Are there any emission sources at the facility besides the IPA use? Any combustion based heating units, or
plastic melting?

2. I've attached the emission information I have received, and based on the correspondence I saw with Rita,
these calculations do not match the total VOC's requested in the application. The eventual permit will have a limit
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…39/87
on the total VOCs you can emit and will require you track your sources of IPA use to make sure you do not
exceed that limit. Can you give me an estimate of what the maximum total IPA use would be at the facility in a
year? By using your potential maximum, we can set the limit at that number and you shouldn't have much trouble
staying under the limit.

3. For all increases in emissions and newly permitted sources, we need a "Best Available Control Technology" or
BACT analysis submitted. This essentially is evaluating what control options there are to potentially reduce
emissions at the facility. Please send me an analysis that shows you've evaluated potential controls at the facility,
including potential add-on controls that could capture and dispose of the VOCs. If it is not possible to have a VOC
capture system with a control, your analysis can simply explain why it is not possible to include a capture system
or controls. It helps us out a lot if you can include a cost estimate of some kind as well.

I hope this isn't too much at once, please feel free to call me or contact me with any questions you may have
about the information requested above, thank you.

On Thu, Sep 8, 2022 at 11:20 AM Emmett, Kyle <[e-mail]> wrote:
Hi Dylan-

Hope things are going well. Just reaching out to see if you need anything more from me on our NOI
Applications for the two separate sites in Logan Utah?

Thanks,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Monday, August 1, 2022 4:06 PM
To: Emmett, Kyle <[e-mail]>; Dylan Frederick <[e-mail]>
Subject: Re: Air Quality Notices Received
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…40/87

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious,
report using the Report Phish button in Outlook or send to [e-mail].

Thank you for the update. I have added my coworker to this email ([e-mail]), he will be taking over
the project from here.

Best Regards,
Rita

On Thu, Jul 28, 2022 at 2:59 PM Emmett, Kyle <[e-mail]> wrote:
Hi Rita-

Talking to our Engineering Team we are estimating consuming 8 million lbs of film in 2022. If we were to run
all equipment at 100% capacity we could run up to an estimated 12 million lbs in a 12 month period. For
business continuity and redundancy capacity in the event one of our sister sites across the globe has issues,
we want to keep below 80% capacity in our regular schedule.

Please let me know if you need anything else.

Take care-

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Wednesday, July 27, 2022 1:04 PM
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…41/87
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be
suspicious, report using the Report Phish button in Outlook or send to [e-mail].

Hello Kyle,
Do you have an estimate of how much plastic will be consumed at the facility over a rolling 12-month
period?

On Wed, Jul 20, 2022 at 11:20 AM Emmett, Kyle <[e-mail]> wrote:
HI Rita.

Hope your surgery went well and you are healing quick!

1. 19,500 is lbs/year? The attached calculations are PDFs and I cannot see how it was calculated.
Would it be possible to attach written or excel calculations?
a. I have attached the excel spreadsheet used to calculate the usage YTD. As I mentioned in
an earlier message our usage got out of hand in 2021 due to using isopropanol for general
cleaning during the COVID Pandemic. Our expansion projects were not completed till the
end of 2021 and we have usage back in control in 2022 and expect to use less than 16-17k
lbs/site by year end.
2. "Eaches" is not a unit I am familiar with. The material listed is BioProcess Container Assemblies at
an annual quantity of 1,200,000. Is that 1,200,000 bag/tube assemblies? Could you estimate the
plastic needed (in lbs) to produce those?
a. The “Eaches” refers to a single BioProcess Container Assembly, so we would consider
each Bag/Tube assembly an “Each” and we produce 1.2mil/yr.
b. As far as estimating lbs of plastic to produce these, that might get a little tricky, but I will see
what I can find out. Some of our bags are 10k Liters and others are 2 Liters made of the
same material. I’ll ask our procurement team how many rolls of plastic film they purchased
and used in 2021 and 2022YTD.
3. For the 650 North 870 West location are there any generators, boilers, spray bottles, or plastic
melters?
a. At this location we do not have any generators, boilers or anything to melt plastic. The only
thing they have is bottles of 70% and 90% isopropanol for cleaning and lubrication. At this
facility all they do is attached tubing and components to bags or lines. This facility will take
chambers that were built at the 1726 Hyclone Site or from some of our sister sites located in
Tennessee, Pennsylvania, England, or Singapore, and do the final assembly based on
demand.

Please let me know if you need anything else and I’ll see if I can get a gauge on our plastic film used in
2021 and 2022YTD in lbs.

Take care,
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…42/87

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Wednesday, July 20, 2022 10:05 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be
suspicious, report using the Report Phish button in Outlook or send to [e-mail].

Just to clarify,
1. 19,500 is lbs/year? The attached calculations are PDFs and I cannot see how it was calculated. Would
it be possible to attach written or excel calculations?
2. "Eaches" is not a unit I am familiar with. The material listed is BioProcess Container Assemblies at an
annual quantity of 1,200,000. Is that 1,200,000 bag/tube assemblies? Could you estimate the plastic
needed (in lbs) to produce those?
3. For the 650 North 870 West location are there any generators, boilers, spray bottles, or plastic melters?

On Tue, Jul 12, 2022 at 12:41 PM Emmett, Kyle <[e-mail]> wrote:
Hi Rita-

Hope your surgery went well and your recovery is quick.
1. Calculations for the emissions information: See attached for Alcohol Usage Information for both the
1726 Hyclone and 650 North Locations in 2021 and 2022. As mentioned earlier, this Isopropyl Alcohol
is used literally by spray bottle or wipe to clean surfaces in our cleanrooms or lubrication for putting
parts together. We shouldn’t get above 16,000 lbs of IPA used at either site by year end, but I put a
max of 19,500 on the NOI at the recommendation of a consultant.
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…43/87
2. Units on Form 3 for maximum hourly production and maximum annual production: The units would
be “eaches”. I have included in the attached “Product Examples” PPT some examples of some of the
products that we make so you have a visual of what we make. These containers range in size from
10mL to 10,000L depending on the customer needs.
3. Emitting units in each of the facilities. The NOI for the 650 North 870 West location does not list any
specific equipment: All the emissions are coming through comfort air HVAC systems for our building
cleanrooms and/or through general building air loss. Each of the HVAC Units are fitted w/ exhaust fans,
but the fans are rarely running because we maintain a positive pressure in the cleanrooms and the air
losses are mainly through the airlock and man-door accesses. We also recirculate greater than 80% or
our air. Attached is the Air Handling Unit info to these air handling systems for each site along w/ a
screenshot from the control software showing that the exhaust fans are not running.
Please let me know if you need any further info or if you would like to have a call to discuss in more
detail. We want to make sure we do this right.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Tuesday, July 5, 2022 1:55 PM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be
suspicious, report using the Report Phish button in Outlook or send to [e-mail].

Emmett, I am so sorry about the accident! Thank you for getting back to me. I am getting ACL
surgery on Thursday and should be back to review the data late next week. I will look it over and email
you with questions / set up a video call.

Thanks for working on this!
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…44/87

On Tue, Jul 5, 2022 at 12:28 PM Emmett, Kyle <[e-mail]> wrote:
Hi Rita-

Thanks for the quick response. I’m looking forward to working with you on this. If it’s ok w/ you I will
have the requested info to you for both the 1726 HyClone Drive and 650 North Locations by the end
of the week. I was in a auto accident the first part of June that busted me up pretty good and I was
out of office till last week. I have the info you are asking for, just need to organize it so it makes
sense and get the latest usage data from our production team.

Just a little background, at the end of 2021 we went through a massive expansion and that led us to
do a regulatory review and we realize we no longer fall under the Small Source Exemption. With that
said, due to COVID we also started to use a lot of Isopropanol for general cleaning which increased
our site usage and inflated our numbers. We got that back under control and now know that our
VOC usage (Isopropanol) is only for use in our FDA regulated cleanroom for cleaning and lubrication
of our products and we will be above the 5 tons but below the 10 tons for large generators.

I apologize for not submitting everything you need. We are in a weird situation where our IPA
emissions is literally from spray bottles and wipers. We make the assumption that it all volatilizes
and thus is an emission. It is generally just lost to atmosphere through comfort air systems from our
cleanroom or through building air losses because the clean rooms are kept under positive pressure.

I’ll send you all the requested info and then if there are still questions I would enjoy a video call to
make sure we are on the same page.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Tuesday, July 5, 2022 9:59 AM
To: Emmett, Kyle <[e-mail]>
Subject: Air Quality Notices Received
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…45/87

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be
suspicious, report using the Report Phish button in Outlook or send to [e-mail].

Hello Mr. Emmett,
The Utah Department of Air Quality (DAQ) has received two Notice of Intents (NOIs) for Life
Technologies Corp. It appears that the majority of the information is the same/similar on both NOIs. I
was hoping you could provide the following:
1. Calculations for the emissions information. To have the potential to emit 19,500 tons per year of
VOCS is extremely high.
2. Units on Form 3 for maximum hourly production and maximum annual production.
3. Emitting units in each of the facilities. The NOI for the 650 North 870 West location does not list
any specific equipment. The NOI for the 1726 Hyclone Drive location does not list any specific
equipment but there is an attachment for an emergency generator. ,

Please let me know if you have any questions. I would be happy to set up a video-call to better
discuss what is needed from both of these applications.

Thank you.
--
Rita Trick
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--
Rita
[phone]

--
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…46/87
Rita
[phone]

--
Rita
[phone]

--
Rita
[phone]

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…47/87
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…48/87

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

Emmett, Kyle <[e-mail]>Thu, May 18, 2023 at 8:40 AM
To: Dylan Frederick <[e-mail]>
Hello Dylan-

Just checking in to see if you need any info to move forward with our air approval order. Want to make sure we are
supporting you if anything else is needed.

Take care-

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…49/87

From: Emmett, Kyle
Sent: Thursday, April 6, 2023 8:54 AM
To: 'Dylan Frederick' <[e-mail]>
Subject: RE: Air Quality Notices Received

Hi Dylan-

Hope all is well. Just following up to see if any further info is needed for our Air Approval Order?

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Emmett, Kyle
Sent: Wednesday, February 8, 2023 5:42 PM
To: Dylan Frederick <[e-mail]>
Subject: RE: Air Quality Notices Received

Hi Dylan-

Thanks for all your help and guidance with all this. Here is what I have for you.

1726 Hyclone Drive Facility
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…50/87
1. Attached is the updated version of the emissions estimates you provided for the comfort air systems. I added a
second tab to the Excel File that includes an inventory of all the gas fired systems on-site so you can check my
work, and updated the Rating on the calculations tab.
2. Reviewed the emissions estimates for the emergency generator and agree with it.
3. See attached BACT review for the emergency generator.

650 North 870 West Facility
1. Attached is emissions estimate for the comfort air systems. I added a second tab to the Excel File that includes an
inventory of all the gas fired systems on-site and updated the Rating on the calculations tab.

Please let me know if you need anything else.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, January 31, 2023 9:30 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious, report
using the Report Phish button in Outlook or send to [e-mail].

Kyle,

Sorry for taking a while to get back to you,
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…51/87

I've looked over the last submissions I got from you, here are the emission estimates for the generator. For the comfort air
systems, I assumed there were 3 units at 350,000 Btu each, but to be accurate I would need to know how many units
there are. I could also calculate it if you simply knew the total natural gas used at the facilities on an annual basis. Finally,
I never got a best available control technology (BACT) analysis for the emergency generator. Could you provide a small
write-up explaining whether further emission controls are possible, and what is already applied to the engine? If not, state
that further controls are not possible due to either economic, environmental, or energy impact concerns. In this case it
would most likely be cost, as emissions from the generator are low enough that adding controls would most likely not be
cost effective.

Thank you for your help, feel free to reach out to me with any questions you have, thanks.

On Wed, Jan 11, 2023 at 1:48 PM Emmett, Kyle <[e-mail]> wrote:
Hey Dylan-

Hope you had a good holiday break! Just following up on the below email and if I still need to send you calculations for
our HVAC emissions and if you have a tool I can use to get that back to you?

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Thursday, December 22, 2022 1:43 PM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious, report
using the Report Phish button in Outlook or send to [e-mail].
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…52/87

Kyle,

Thanks for getting this to me. I will send a quick calculation to you for the HVAC units to account for their emissions, but
otherwise I think that is all the information I need for these. Once I get your go ahead for the calculations I'll work on
getting these projects done once the new year is started. Hope you have a good holiday,

Dylan

On Thu, Dec 15, 2022 at 3:54 PM Emmett, Kyle <[e-mail]> wrote:
Hi Dylan-

Hope things are going well. I have looked at all our HVAC Heaters/AC and the highest Btu/hr units we have are
350,000btu/hr units. I’ve attached a couple pictures of the spec tags for the most common larger units we have. Let
me know if you think I’m not looking at the right info.

If this is the case do you need any further info for questions 1 and 5 below or are we good to go?

Thanks,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Emmett, Kyle
Sent: Thursday, November 17, 2022 10:20 AM
To: Dylan Frederick <[e-mail]>
Subject: RE: Air Quality Notices Received

Hi Dylan-
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…53/87

Thanks for working through this with me. My apologies if I’m making this more difficult for you than is necessary.
Definitely a good learning experience for me. I’m working with a consultant on this but for my personal/professional
development I’m trying to do most of the work on my own. Please see below in blue my responses. I will work on
getting you more detail in the next couple of weeks.

1. Can I please get emission calculations for the comfort air systems? If they are natural gas powered there
should be associated combustion emissions.
a. Please give me a couple weeks to gather all this information. We are in the process of implementing a
new Maintenance Management System and this info isn’t readily accessible and we will need to go to
each unit.

2. The emergency generator needs calculations submitted as well, but only for 100 hours of operation. This is
the standard way we permit emergency use generators, the 100 hours is just for testing and maintenance
purposes and does not include any actual emergency use situations.
a. Please let me know if the attached data sheet titled “A15 Emergency Generator Emissions” meets the
needs for this.

3. For the IPA use, having some breathing room is fine, I just want to confirm here that you are requesting an
annual VOC limit of 9.5 tons per year for both facilities (specifically to limit IPA). If there is a different limit you
are requesting to set for each facility, please let me know.
a. Correct, each site we would like to have a limit of 9.5 tons/yr/each site specifically for IPA (VOCs).

4. The BACT analysis you sent me is pretty close to what I'm looking for, but is this intended to apply to both
facilities? Additionally, if you can provide any more specific information or technical data for my write up, I'll
happily take it, the more quantifiable information I can put in the better.
a. Yes the BACT provided is the same for both facilities. Same type of processes occur at both facilities.

5. Unfortunately I also need a BACT analysis for the generator and air systems assuming they are contributing
to emissions at each site. My expectation is that emissions from the generator will be too low to add controls
at 100 hours of operation per year, but I'm supposed to get a BACT analysis anyways. Same is true for the air
systems, there probably aren't many upgrades that are feasible for a natural gas system, especially if its a
small unit. If the AC systems are under 5 MMBtu/hr for each unit, disregard my request for a BACT analysis
as that would make it exempt from the requirement to provide a BACT analysis.
a. The same for Question 1- Please give me a couple weeks to gather all this information. We are in the
process of implementing a new Maintenance Management System and this info isn’t readily
accessible and we will need to go to each unit.
Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…54/87
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, November 15, 2022 10:28 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious,
report using the Report Phish button in Outlook or send to [e-mail].

Kyle,

Thanks for getting back to me. I do have some more questions based on your responses.

1. Can I please get emission calculations for the comfort air systems? If they are natural gas powered there should
be associated combustion emissions.

2. The emergency generator needs calculations submitted as well, but only for 100 hours of operation. This is the
standard way we permit emergency use generators, the 100 hours is just for testing and maintenance purposes and
does not include any actual emergency use situations.

3. For the IPA use, having some breathing room is fine, I just want to confirm here that you are requesting an annual
VOC limit of 9.5 tons per year for both facilities (specifically to limit IPA). If there is a different limit you are requesting
to set for each facility, please let me know.

4. The BACT analysis you sent me is pretty close to what I'm looking for, but is this intended to apply to both
facilities? Additionally, if you can provide any more specific information or technical data for my write up, I'll happily
take it, the more quantifiable information I can put in the better.

5. Unfortunately I also need a BACT analysis for the generator and air systems assuming they are contributing to
emissions at each site. My expectation is that emissions from the generator will be too low to add controls at 100
hours of operation per year, but I'm supposed to get a BACT analysis anyways. Same is true for the air systems,
there probably aren't many upgrades that are feasible for a natural gas system, especially if its a small unit. If the AC
systems are under 5 MMBtu/hr for each unit, disregard my request for a BACT analysis as that would make it
exempt from the requirement to provide a BACT analysis.

1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…55/87
Hopefully these requests are straight forward, please feel free to call or contact me if you have any questions.
Thanks for all your help,

Dylan

On Mon, Nov 14, 2022 at 2:15 PM Emmett, Kyle <[e-mail]> wrote:
Hi Dylan-

Again, apologies for the late response, busy time…..

See below in blue for responses to your questions.

1. Are there any emission sources at the facility besides the IPA use? Any combustion based heating units, or
plastic melting?
a. At the BioCenter location at 1726 Hyclone Drive we have one emergency generator. No boilers, or
plastic melting. The Comfort Air Systems are natural gas, but no industrial heating units are on-site.
Let me know if you require anything for the Comfort Air Systems.
b. At the Assembly Center location at 650 N 870 West there are no other emissions sources besides
the IPA. The Comfort Air Systems are natural gas fired. but no industrial heating units are on-site.
Let me know if you require anything for the Comfort Air Systems.

2. I've attached the emission information I have received, and based on the correspondence I saw with Rita,
these calculations do not match the total VOC's requested in the application. The eventual permit will have
a limit on the total VOCs you can emit and will require you track your sources of IPA use to make sure you
do not exceed that limit. Can you give me an estimate of what the maximum total IPA use would be at the
facility in a year? By using your potential maximum, we can set the limit at that number and you shouldn't
have much trouble staying under the limit.
a. On the Application Form 5 I had put “Permitted Emissions” at 20,000 lbs and “Proposed Emissions”
at 19,500lbs at the advice of a consultant to give us some wiggle room in the event of a process
upset or need for extra cleaning of our controlled room. With that said below is the projected
emissions for 2022.
b. We can easily track monthly the amount of IPA consumed on-site
c. At the BioCenter we are currently on track to use ~17,250 lbs of IPA by year end
d. At the Assembly Center we are currently on tract to use ~15,500 lbs of IPA by year end

3. For all increases in emissions and newly permitted sources, we need a "Best Available Control
Technology" or BACT analysis submitted. This essentially is evaluating what control options there are to
potentially reduce emissions at the facility. Please send me an analysis that shows you've evaluated
potential controls at the facility, including potential add-on controls that could capture and dispose of the
VOCs. If it is not possible to have a VOC capture system with a control, your analysis can simply explain
why it is not possible to include a capture system or controls. It helps us out a lot if you can include a cost
estimate of some kind as well.
a. I kinda figured you’d be asking for something like this. See attached for a brief summary I started
putting together awhile ago. If this isn’t what you need and you require more technical data please
let me know and I will see what I can track down.

Thanks and please let me know if you need anything else.
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…56/87

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, October 18, 2022 11:03 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious,
report using the Report Phish button in Outlook or send to [e-mail].

Hello Kyle,

I'm so sorry for taking a while to get back to you, I lost track of this email for a while and have been prioritizing
some other projects I've had. I've had a chance to look at the project and what Rita had gotten from you so far,
and I do have some more information I'd like to request.

1. Are there any emission sources at the facility besides the IPA use? Any combustion based heating units, or
plastic melting?

2. I've attached the emission information I have received, and based on the correspondence I saw with Rita,
these calculations do not match the total VOC's requested in the application. The eventual permit will have a limit
on the total VOCs you can emit and will require you track your sources of IPA use to make sure you do not
exceed that limit. Can you give me an estimate of what the maximum total IPA use would be at the facility in a
year? By using your potential maximum, we can set the limit at that number and you shouldn't have much trouble
staying under the limit.

1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…57/87
3. For all increases in emissions and newly permitted sources, we need a "Best Available Control Technology" or
BACT analysis submitted. This essentially is evaluating what control options there are to potentially reduce
emissions at the facility. Please send me an analysis that shows you've evaluated potential controls at the facility,
including potential add-on controls that could capture and dispose of the VOCs. If it is not possible to have a VOC
capture system with a control, your analysis can simply explain why it is not possible to include a capture system
or controls. It helps us out a lot if you can include a cost estimate of some kind as well.

I hope this isn't too much at once, please feel free to call me or contact me with any questions you may have
about the information requested above, thank you.

On Thu, Sep 8, 2022 at 11:20 AM Emmett, Kyle <[e-mail]> wrote:
Hi Dylan-

Hope things are going well. Just reaching out to see if you need anything more from me on our NOI
Applications for the two separate sites in Logan Utah?

Thanks,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Monday, August 1, 2022 4:06 PM
To: Emmett, Kyle <[e-mail]>; Dylan Frederick <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious,
report using the Report Phish button in Outlook or send to [e-mail].
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…58/87

Thank you for the update. I have added my coworker to this email ([e-mail]), he will be taking over
the project from here.

Best Regards,
Rita

On Thu, Jul 28, 2022 at 2:59 PM Emmett, Kyle <[e-mail]> wrote:
Hi Rita-

Talking to our Engineering Team we are estimating consuming 8 million lbs of film in 2022. If we were to run
all equipment at 100% capacity we could run up to an estimated 12 million lbs in a 12 month period. For
business continuity and redundancy capacity in the event one of our sister sites across the globe has issues,
we want to keep below 80% capacity in our regular schedule.

Please let me know if you need anything else.

Take care-

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Wednesday, July 27, 2022 1:04 PM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…59/87
CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be
suspicious, report using the Report Phish button in Outlook or send to [e-mail].

Hello Kyle,
Do you have an estimate of how much plastic will be consumed at the facility over a rolling 12-month
period?

On Wed, Jul 20, 2022 at 11:20 AM Emmett, Kyle <[e-mail]> wrote:
HI Rita.

Hope your surgery went well and you are healing quick!

1. 19,500 is lbs/year? The attached calculations are PDFs and I cannot see how it was calculated.
Would it be possible to attach written or excel calculations?
a. I have attached the excel spreadsheet used to calculate the usage YTD. As I mentioned in
an earlier message our usage got out of hand in 2021 due to using isopropanol for general
cleaning during the COVID Pandemic. Our expansion projects were not completed till the
end of 2021 and we have usage back in control in 2022 and expect to use less than 16-17k
lbs/site by year end.
2. "Eaches" is not a unit I am familiar with. The material listed is BioProcess Container Assemblies at
an annual quantity of 1,200,000. Is that 1,200,000 bag/tube assemblies? Could you estimate the
plastic needed (in lbs) to produce those?
a. The “Eaches” refers to a single BioProcess Container Assembly, so we would consider
each Bag/Tube assembly an “Each” and we produce 1.2mil/yr.
b. As far as estimating lbs of plastic to produce these, that might get a little tricky, but I will see
what I can find out. Some of our bags are 10k Liters and others are 2 Liters made of the
same material. I’ll ask our procurement team how many rolls of plastic film they purchased
and used in 2021 and 2022YTD.
3. For the 650 North 870 West location are there any generators, boilers, spray bottles, or plastic
melters?
a. At this location we do not have any generators, boilers or anything to melt plastic. The only
thing they have is bottles of 70% and 90% isopropanol for cleaning and lubrication. At this
facility all they do is attached tubing and components to bags or lines. This facility will take
chambers that were built at the 1726 Hyclone Site or from some of our sister sites located in
Tennessee, Pennsylvania, England, or Singapore, and do the final assembly based on
demand.

Please let me know if you need anything else and I’ll see if I can get a gauge on our plastic film used in
2021 and 2022YTD in lbs.

Take care,

1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…60/87
Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Wednesday, July 20, 2022 10:05 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be
suspicious, report using the Report Phish button in Outlook or send to [e-mail].

Just to clarify,
1. 19,500 is lbs/year? The attached calculations are PDFs and I cannot see how it was calculated. Would
it be possible to attach written or excel calculations?
2. "Eaches" is not a unit I am familiar with. The material listed is BioProcess Container Assemblies at an
annual quantity of 1,200,000. Is that 1,200,000 bag/tube assemblies? Could you estimate the plastic
needed (in lbs) to produce those?
3. For the 650 North 870 West location are there any generators, boilers, spray bottles, or plastic melters?

On Tue, Jul 12, 2022 at 12:41 PM Emmett, Kyle <[e-mail]> wrote:
Hi Rita-

Hope your surgery went well and your recovery is quick.
1. Calculations for the emissions information: See attached for Alcohol Usage Information for both the
1726 Hyclone and 650 North Locations in 2021 and 2022. As mentioned earlier, this Isopropyl Alcohol
is used literally by spray bottle or wipe to clean surfaces in our cleanrooms or lubrication for putting
parts together. We shouldn’t get above 16,000 lbs of IPA used at either site by year end, but I put a
max of 19,500 on the NOI at the recommendation of a consultant.
2. Units on Form 3 for maximum hourly production and maximum annual production: The units would
be “eaches”. I have included in the attached “Product Examples” PPT some examples of some of the
products that we make so you have a visual of what we make. These containers range in size from
10mL to 10,000L depending on the customer needs.
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…61/87
3. Emitting units in each of the facilities. The NOI for the 650 North 870 West location does not list any
specific equipment: All the emissions are coming through comfort air HVAC systems for our building
cleanrooms and/or through general building air loss. Each of the HVAC Units are fitted w/ exhaust fans,
but the fans are rarely running because we maintain a positive pressure in the cleanrooms and the air
losses are mainly through the airlock and man-door accesses. We also recirculate greater than 80% or
our air. Attached is the Air Handling Unit info to these air handling systems for each site along w/ a
screenshot from the control software showing that the exhaust fans are not running.
Please let me know if you need any further info or if you would like to have a call to discuss in more
detail. We want to make sure we do this right.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Tuesday, July 5, 2022 1:55 PM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be
suspicious, report using the Report Phish button in Outlook or send to [e-mail].

Emmett, I am so sorry about the accident! Thank you for getting back to me. I am getting ACL
surgery on Thursday and should be back to review the data late next week. I will look it over and email
you with questions / set up a video call.

Thanks for working on this!

On Tue, Jul 5, 2022 at 12:28 PM Emmett, Kyle <[e-mail]> wrote:
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…62/87
Hi Rita-

Thanks for the quick response. I’m looking forward to working with you on this. If it’s ok w/ you I will
have the requested info to you for both the 1726 HyClone Drive and 650 North Locations by the end
of the week. I was in a auto accident the first part of June that busted me up pretty good and I was
out of office till last week. I have the info you are asking for, just need to organize it so it makes
sense and get the latest usage data from our production team.

Just a little background, at the end of 2021 we went through a massive expansion and that led us to
do a regulatory review and we realize we no longer fall under the Small Source Exemption. With that
said, due to COVID we also started to use a lot of Isopropanol for general cleaning which increased
our site usage and inflated our numbers. We got that back under control and now know that our
VOC usage (Isopropanol) is only for use in our FDA regulated cleanroom for cleaning and lubrication
of our products and we will be above the 5 tons but below the 10 tons for large generators.

I apologize for not submitting everything you need. We are in a weird situation where our IPA
emissions is literally from spray bottles and wipers. We make the assumption that it all volatilizes
and thus is an emission. It is generally just lost to atmosphere through comfort air systems from our
cleanroom or through building air losses because the clean rooms are kept under positive pressure.

I’ll send you all the requested info and then if there are still questions I would enjoy a video call to
make sure we are on the same page.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Tuesday, July 5, 2022 9:59 AM
To: Emmett, Kyle <[e-mail]>
Subject: Air Quality Notices Received

1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…63/87
CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be
suspicious, report using the Report Phish button in Outlook or send to [e-mail].

Hello Mr. Emmett,
The Utah Department of Air Quality (DAQ) has received two Notice of Intents (NOIs) for Life
Technologies Corp. It appears that the majority of the information is the same/similar on both NOIs. I
was hoping you could provide the following:
1. Calculations for the emissions information. To have the potential to emit 19,500 tons per year of
VOCS is extremely high.
2. Units on Form 3 for maximum hourly production and maximum annual production.
3. Emitting units in each of the facilities. The NOI for the 650 North 870 West location does not list
any specific equipment. The NOI for the 1726 Hyclone Drive location does not list any specific
equipment but there is an attachment for an emergency generator. ,

Please let me know if you have any questions. I would be happy to set up a video-call to better
discuss what is needed from both of these applications.

Thank you.
--
Rita Trick
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--
Rita
[phone]

--
Rita
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…64/87
[phone]

--
Rita
[phone]

--
Rita
[phone]

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…65/87
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

1/9/24, 2:46 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…66/87

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

Dylan Frederick <[e-mail]>Thu, May 18, 2023 at 8:45 AM
To: "Emmett, Kyle" <[e-mail]>
Kyle,
Sorry about the delay in getting back to you, I've had a lot of different projects I've been balancing as of late. As far as I'm
aware I have all the information I need, the projects are under internal review and if something comes up I'll reach out to
you. Thanks for checking in with me.
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1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…67/87
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Hello Mr. Emmett,
The Utah Department of Air Quality (DAQ) has received two Notice of Intents (NOIs) for Life
Technologies Corp. It appears that the majority of the information is the same/similar on both
NOIs. I was hoping you could provide the following:
1. Calculations for the emissions information. To have the potential to emit 19,500 tons per year of
VOCS is extremely high.
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--
Rita
[phone]

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Rita
[phone]

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Rita
[phone]

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Rita
[phone]
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Emmett, Kyle <[e-mail]>Thu, May 18, 2023 at 9:40 AM
To: Dylan Frederick <[e-mail]>
1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…68/87
Thanks Dylan. No worries, just wanted to make sure you weren’t waiting on me. I can only imagine how many projects
you guys have so completely understand. Nothing like doing more with less😊.

Take care- Kyle

From: Dylan Frederick <[e-mail]>
Sent: Thursday, May 18, 2023 8:46 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious, report
using the Report Phish button in Outlook or send to [e-mail].

Kyle,

Sorry about the delay in getting back to you, I've had a lot of different projects I've been balancing as of late. As far as I'm
aware I have all the information I need, the projects are under internal review and if something comes up I'll reach out to
you. Thanks for checking in with me.

On Thu, May 18, 2023 at 8:40 AM Emmett, Kyle <[e-mail]> wrote:
Hello Dylan-

Just checking in to see if you need any info to move forward with our air approval order. Want to make sure we are
supporting you if anything else is needed.

Take care-

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]
1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…69/87

From: Emmett, Kyle
Sent: Thursday, April 6, 2023 8:54 AM
To: 'Dylan Frederick' <[e-mail]>
Subject: RE: Air Quality Notices Received

Hi Dylan-

Hope all is well. Just following up to see if any further info is needed for our Air Approval Order?

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Emmett, Kyle
Sent: Wednesday, February 8, 2023 5:42 PM
To: Dylan Frederick <[e-mail]>
Subject: RE: Air Quality Notices Received

Hi Dylan-

Thanks for all your help and guidance with all this. Here is what I have for you.

1726 Hyclone Drive Facility
1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…70/87
1. Attached is the updated version of the emissions estimates you provided for the comfort air systems. I added a
second tab to the Excel File that includes an inventory of all the gas fired systems on-site so you can check my
work, and updated the Rating on the calculations tab.
2. Reviewed the emissions estimates for the emergency generator and agree with it.
3. See attached BACT review for the emergency generator.

650 North 870 West Facility
1. Attached is emissions estimate for the comfort air systems. I added a second tab to the Excel File that includes
an inventory of all the gas fired systems on-site and updated the Rating on the calculations tab.

Please let me know if you need anything else.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, January 31, 2023 9:30 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious, report
using the Report Phish button in Outlook or send to [e-mail].

Kyle,

Sorry for taking a while to get back to you,
1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…71/87

I've looked over the last submissions I got from you, here are the emission estimates for the generator. For the comfort
air systems, I assumed there were 3 units at 350,000 Btu each, but to be accurate I would need to know how many
units there are. I could also calculate it if you simply knew the total natural gas used at the facilities on an annual basis.
Finally, I never got a best available control technology (BACT) analysis for the emergency generator. Could you provide
a small write-up explaining whether further emission controls are possible, and what is already applied to the engine? If
not, state that further controls are not possible due to either economic, environmental, or energy impact concerns. In
this case it would most likely be cost, as emissions from the generator are low enough that adding controls would most
likely not be cost effective.

Thank you for your help, feel free to reach out to me with any questions you have, thanks.

On Wed, Jan 11, 2023 at 1:48 PM Emmett, Kyle <[e-mail]> wrote:
Hey Dylan-

Hope you had a good holiday break! Just following up on the below email and if I still need to send you calculations
for our HVAC emissions and if you have a tool I can use to get that back to you?

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Thursday, December 22, 2022 1:43 PM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious,
report using the Report Phish button in Outlook or send to [e-mail].
1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…72/87

Kyle,

Thanks for getting this to me. I will send a quick calculation to you for the HVAC units to account for their emissions,
but otherwise I think that is all the information I need for these. Once I get your go ahead for the calculations I'll work
on getting these projects done once the new year is started. Hope you have a good holiday,

Dylan

On Thu, Dec 15, 2022 at 3:54 PM Emmett, Kyle <[e-mail]> wrote:
Hi Dylan-

Hope things are going well. I have looked at all our HVAC Heaters/AC and the highest Btu/hr units we have are
350,000btu/hr units. I’ve attached a couple pictures of the spec tags for the most common larger units we have.
Let me know if you think I’m not looking at the right info.

If this is the case do you need any further info for questions 1 and 5 below or are we good to go?

Thanks,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Emmett, Kyle
Sent: Thursday, November 17, 2022 10:20 AM
To: Dylan Frederick <[e-mail]>
Subject: RE: Air Quality Notices Received

Hi Dylan-
1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…73/87

Thanks for working through this with me. My apologies if I’m making this more difficult for you than is necessary.
Definitely a good learning experience for me. I’m working with a consultant on this but for my
personal/professional development I’m trying to do most of the work on my own. Please see below in blue my
responses. I will work on getting you more detail in the next couple of weeks.

1. Can I please get emission calculations for the comfort air systems? If they are natural gas powered there
should be associated combustion emissions.
a. Please give me a couple weeks to gather all this information. We are in the process of implementing
a new Maintenance Management System and this info isn’t readily accessible and we will need to
go to each unit.

2. The emergency generator needs calculations submitted as well, but only for 100 hours of operation. This is
the standard way we permit emergency use generators, the 100 hours is just for testing and maintenance
purposes and does not include any actual emergency use situations.
a. Please let me know if the attached data sheet titled “A15 Emergency Generator Emissions” meets
the needs for this.

3. For the IPA use, having some breathing room is fine, I just want to confirm here that you are requesting an
annual VOC limit of 9.5 tons per year for both facilities (specifically to limit IPA). If there is a different limit
you are requesting to set for each facility, please let me know.
a. Correct, each site we would like to have a limit of 9.5 tons/yr/each site specifically for IPA (VOCs).

4. The BACT analysis you sent me is pretty close to what I'm looking for, but is this intended to apply to both
facilities? Additionally, if you can provide any more specific information or technical data for my write up, I'll
happily take it, the more quantifiable information I can put in the better.
a. Yes the BACT provided is the same for both facilities. Same type of processes occur at both
facilities.

5. Unfortunately I also need a BACT analysis for the generator and air systems assuming they are
contributing to emissions at each site. My expectation is that emissions from the generator will be too low
to add controls at 100 hours of operation per year, but I'm supposed to get a BACT analysis anyways.
Same is true for the air systems, there probably aren't many upgrades that are feasible for a natural gas
system, especially if its a small unit. If the AC systems are under 5 MMBtu/hr for each unit, disregard my
request for a BACT analysis as that would make it exempt from the requirement to provide a BACT
analysis.
a. The same for Question 1- Please give me a couple weeks to gather all this information. We are in
the process of implementing a new Maintenance Management System and this info isn’t readily
accessible and we will need to go to each unit.
Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…74/87
Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, November 15, 2022 10:28 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious,
report using the Report Phish button in Outlook or send to [e-mail].

Kyle,

Thanks for getting back to me. I do have some more questions based on your responses.

1. Can I please get emission calculations for the comfort air systems? If they are natural gas powered there
should be associated combustion emissions.

2. The emergency generator needs calculations submitted as well, but only for 100 hours of operation. This is the
standard way we permit emergency use generators, the 100 hours is just for testing and maintenance purposes
and does not include any actual emergency use situations.

3. For the IPA use, having some breathing room is fine, I just want to confirm here that you are requesting an
annual VOC limit of 9.5 tons per year for both facilities (specifically to limit IPA). If there is a different limit you are
requesting to set for each facility, please let me know.

4. The BACT analysis you sent me is pretty close to what I'm looking for, but is this intended to apply to both
facilities? Additionally, if you can provide any more specific information or technical data for my write up, I'll
happily take it, the more quantifiable information I can put in the better.

5. Unfortunately I also need a BACT analysis for the generator and air systems assuming they are contributing to
emissions at each site. My expectation is that emissions from the generator will be too low to add controls at 100
hours of operation per year, but I'm supposed to get a BACT analysis anyways. Same is true for the air systems,
there probably aren't many upgrades that are feasible for a natural gas system, especially if its a small unit. If the
AC systems are under 5 MMBtu/hr for each unit, disregard my request for a BACT analysis as that would make it
exempt from the requirement to provide a BACT analysis.
1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…75/87

Hopefully these requests are straight forward, please feel free to call or contact me if you have any questions.
Thanks for all your help,

Dylan

On Mon, Nov 14, 2022 at 2:15 PM Emmett, Kyle <[e-mail]> wrote:
Hi Dylan-

Again, apologies for the late response, busy time…..

See below in blue for responses to your questions.

1. Are there any emission sources at the facility besides the IPA use? Any combustion based heating units,
or plastic melting?
a. At the BioCenter location at 1726 Hyclone Drive we have one emergency generator. No boilers,
or plastic melting. The Comfort Air Systems are natural gas, but no industrial heating units are
on-site. Let me know if you require anything for the Comfort Air Systems.
b. At the Assembly Center location at 650 N 870 West there are no other emissions sources
besides the IPA. The Comfort Air Systems are natural gas fired. but no industrial heating units
are on-site. Let me know if you require anything for the Comfort Air Systems.

2. I've attached the emission information I have received, and based on the correspondence I saw with
Rita, these calculations do not match the total VOC's requested in the application. The eventual permit
will have a limit on the total VOCs you can emit and will require you track your sources of IPA use to
make sure you do not exceed that limit. Can you give me an estimate of what the maximum total IPA
use would be at the facility in a year? By using your potential maximum, we can set the limit at that
number and you shouldn't have much trouble staying under the limit.
a. On the Application Form 5 I had put “Permitted Emissions” at 20,000 lbs and “Proposed
Emissions” at 19,500lbs at the advice of a consultant to give us some wiggle room in the event of
a process upset or need for extra cleaning of our controlled room. With that said below is the
projected emissions for 2022.
b. We can easily track monthly the amount of IPA consumed on-site
c. At the BioCenter we are currently on track to use ~17,250 lbs of IPA by year end
d. At the Assembly Center we are currently on tract to use ~15,500 lbs of IPA by year end

3. For all increases in emissions and newly permitted sources, we need a "Best Available Control
Technology" or BACT analysis submitted. This essentially is evaluating what control options there are to
potentially reduce emissions at the facility. Please send me an analysis that shows you've evaluated
potential controls at the facility, including potential add-on controls that could capture and dispose of the
VOCs. If it is not possible to have a VOC capture system with a control, your analysis can simply explain
why it is not possible to include a capture system or controls. It helps us out a lot if you can include a
cost estimate of some kind as well.
a. I kinda figured you’d be asking for something like this. See attached for a brief summary I started
putting together awhile ago. If this isn’t what you need and you require more technical data
please let me know and I will see what I can track down.

1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…76/87
Thanks and please let me know if you need anything else.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Dylan Frederick <[e-mail]>
Sent: Tuesday, October 18, 2022 11:03 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be suspicious,
report using the Report Phish button in Outlook or send to [e-mail].

Hello Kyle,

I'm so sorry for taking a while to get back to you, I lost track of this email for a while and have been prioritizing
some other projects I've had. I've had a chance to look at the project and what Rita had gotten from you so far,
and I do have some more information I'd like to request.

1. Are there any emission sources at the facility besides the IPA use? Any combustion based heating units, or
plastic melting?

2. I've attached the emission information I have received, and based on the correspondence I saw with Rita,
these calculations do not match the total VOC's requested in the application. The eventual permit will have a
limit on the total VOCs you can emit and will require you track your sources of IPA use to make sure you do not
exceed that limit. Can you give me an estimate of what the maximum total IPA use would be at the facility in a
year? By using your potential maximum, we can set the limit at that number and you shouldn't have much
trouble staying under the limit.

1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…77/87
3. For all increases in emissions and newly permitted sources, we need a "Best Available Control Technology"
or BACT analysis submitted. This essentially is evaluating what control options there are to potentially reduce
emissions at the facility. Please send me an analysis that shows you've evaluated potential controls at the
facility, including potential add-on controls that could capture and dispose of the VOCs. If it is not possible to
have a VOC capture system with a control, your analysis can simply explain why it is not possible to include a
capture system or controls. It helps us out a lot if you can include a cost estimate of some kind as well.

I hope this isn't too much at once, please feel free to call me or contact me with any questions you may have
about the information requested above, thank you.

On Thu, Sep 8, 2022 at 11:20 AM Emmett, Kyle <[e-mail]> wrote:
Hi Dylan-

Hope things are going well. Just reaching out to see if you need anything more from me on our NOI
Applications for the two separate sites in Logan Utah?

Thanks,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Monday, August 1, 2022 4:06 PM
To: Emmett, Kyle <[e-mail]>; Dylan Frederick <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be
suspicious, report using the Report Phish button in Outlook or send to [e-mail].
1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…78/87

Thank you for the update. I have added my coworker to this email ([e-mail]), he will be taking
over the project from here.

Best Regards,
Rita

On Thu, Jul 28, 2022 at 2:59 PM Emmett, Kyle <[e-mail]> wrote:
Hi Rita-

Talking to our Engineering Team we are estimating consuming 8 million lbs of film in 2022. If we were to
run all equipment at 100% capacity we could run up to an estimated 12 million lbs in a 12 month period.
For business continuity and redundancy capacity in the event one of our sister sites across the globe has
issues, we want to keep below 80% capacity in our regular schedule.

Please let me know if you need anything else.

Take care-

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Wednesday, July 27, 2022 1:04 PM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…79/87
CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be
suspicious, report using the Report Phish button in Outlook or send to [e-mail].

Hello Kyle,
Do you have an estimate of how much plastic will be consumed at the facility over a rolling 12-month
period?

On Wed, Jul 20, 2022 at 11:20 AM Emmett, Kyle <[e-mail]> wrote:
HI Rita.

Hope your surgery went well and you are healing quick!

1. 19,500 is lbs/year? The attached calculations are PDFs and I cannot see how it was calculated.
Would it be possible to attach written or excel calculations?
a. I have attached the excel spreadsheet used to calculate the usage YTD. As I mentioned
in an earlier message our usage got out of hand in 2021 due to using isopropanol for
general cleaning during the COVID Pandemic. Our expansion projects were not
completed till the end of 2021 and we have usage back in control in 2022 and expect to
use less than 16-17k lbs/site by year end.
2. "Eaches" is not a unit I am familiar with. The material listed is BioProcess Container Assemblies
at an annual quantity of 1,200,000. Is that 1,200,000 bag/tube assemblies? Could you estimate
the plastic needed (in lbs) to produce those?
a. The “Eaches” refers to a single BioProcess Container Assembly, so we would consider
each Bag/Tube assembly an “Each” and we produce 1.2mil/yr.
b. As far as estimating lbs of plastic to produce these, that might get a little tricky, but I will
see what I can find out. Some of our bags are 10k Liters and others are 2 Liters made of
the same material. I’ll ask our procurement team how many rolls of plastic film they
purchased and used in 2021 and 2022YTD.
3. For the 650 North 870 West location are there any generators, boilers, spray bottles, or plastic
melters?
a. At this location we do not have any generators, boilers or anything to melt plastic. The
only thing they have is bottles of 70% and 90% isopropanol for cleaning and lubrication.
At this facility all they do is attached tubing and components to bags or lines. This facility
will take chambers that were built at the 1726 Hyclone Site or from some of our sister
sites located in Tennessee, Pennsylvania, England, or Singapore, and do the final
assembly based on demand.

Please let me know if you need anything else and I’ll see if I can get a gauge on our plastic film used in
2021 and 2022YTD in lbs.

Take care,

1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…80/87
Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Wednesday, July 20, 2022 10:05 AM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be
suspicious, report using the Report Phish button in Outlook or send to [e-mail].

Just to clarify,
1. 19,500 is lbs/year? The attached calculations are PDFs and I cannot see how it was calculated.
Would it be possible to attach written or excel calculations?
2. "Eaches" is not a unit I am familiar with. The material listed is BioProcess Container Assemblies at
an annual quantity of 1,200,000. Is that 1,200,000 bag/tube assemblies? Could you estimate the
plastic needed (in lbs) to produce those?
3. For the 650 North 870 West location are there any generators, boilers, spray bottles, or plastic
melters?

On Tue, Jul 12, 2022 at 12:41 PM Emmett, Kyle <[e-mail]> wrote:
Hi Rita-

Hope your surgery went well and your recovery is quick.
1. Calculations for the emissions information: See attached for Alcohol Usage Information for both
the 1726 Hyclone and 650 North Locations in 2021 and 2022. As mentioned earlier, this Isopropyl
Alcohol is used literally by spray bottle or wipe to clean surfaces in our cleanrooms or lubrication for
putting parts together. We shouldn’t get above 16,000 lbs of IPA used at either site by year end, but I
put a max of 19,500 on the NOI at the recommendation of a consultant.
2. Units on Form 3 for maximum hourly production and maximum annual production: The units
would be “eaches”. I have included in the attached “Product Examples” PPT some examples of
1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…81/87
some of the products that we make so you have a visual of what we make. These containers range
in size from 10mL to 10,000L depending on the customer needs.
3. Emitting units in each of the facilities. The NOI for the 650 North 870 West location does not list
any specific equipment: All the emissions are coming through comfort air HVAC systems for our
building cleanrooms and/or through general building air loss. Each of the HVAC Units are fitted w/
exhaust fans, but the fans are rarely running because we maintain a positive pressure in the
cleanrooms and the air losses are mainly through the airlock and man-door accesses. We also
recirculate greater than 80% or our air. Attached is the Air Handling Unit info to these air handling
systems for each site along w/ a screenshot from the control software showing that the exhaust fans
are not running.
Please let me know if you need any further info or if you would like to have a call to discuss in more
detail. We want to make sure we do this right.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Tuesday, July 5, 2022 1:55 PM
To: Emmett, Kyle <[e-mail]>
Subject: Re: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to be
suspicious, report using the Report Phish button in Outlook or send to [e-mail].

Emmett, I am so sorry about the accident! Thank you for getting back to me. I am getting ACL
surgery on Thursday and should be back to review the data late next week. I will look it over and
email you with questions / set up a video call.

Thanks for working on this!
1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…82/87

On Tue, Jul 5, 2022 at 12:28 PM Emmett, Kyle <[e-mail]> wrote:
Hi Rita-

Thanks for the quick response. I’m looking forward to working with you on this. If it’s ok w/ you I
will have the requested info to you for both the 1726 HyClone Drive and 650 North Locations by
the end of the week. I was in a auto accident the first part of June that busted me up pretty good
and I was out of office till last week. I have the info you are asking for, just need to organize it so it
makes sense and get the latest usage data from our production team.

Just a little background, at the end of 2021 we went through a massive expansion and that led us
to do a regulatory review and we realize we no longer fall under the Small Source Exemption.
With that said, due to COVID we also started to use a lot of Isopropanol for general cleaning
which increased our site usage and inflated our numbers. We got that back under control and
now know that our VOC usage (Isopropanol) is only for use in our FDA regulated cleanroom for
cleaning and lubrication of our products and we will be above the 5 tons but below the 10 tons for
large generators.

I apologize for not submitting everything you need. We are in a weird situation where our IPA
emissions is literally from spray bottles and wipers. We make the assumption that it all volatilizes
and thus is an emission. It is generally just lost to atmosphere through comfort air systems from
our cleanroom or through building air losses because the clean rooms are kept under positive
pressure.

I’ll send you all the requested info and then if there are still questions I would enjoy a video call to
make sure we are on the same page.

Take care,

Kyle D. Emmett, CIH, CSP
Sr. Manager, EHS & Sustainability

Thermo Fisher Scientific
1726 Hyclone Drive Logan, Utah 84321
Office: 435-792-8862
Mobile: [phone]
[e-mail]

From: Rita Trick <[e-mail]>
Sent: Tuesday, July 5, 2022 9:59 AM
1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…83/87
To: Emmett, Kyle <[e-mail]>
Subject: Air Quality Notices Received

CAUTION: This email originated from outside of Thermo Fisher Scientific. If you believe it to
be suspicious, report using the Report Phish button in Outlook or send to
[e-mail].

Hello Mr. Emmett,
The Utah Department of Air Quality (DAQ) has received two Notice of Intents (NOIs) for Life
Technologies Corp. It appears that the majority of the information is the same/similar on both
NOIs. I was hoping you could provide the following:
1. Calculations for the emissions information. To have the potential to emit 19,500 tons per year of
VOCS is extremely high.
2. Units on Form 3 for maximum hourly production and maximum annual production.
3. Emitting units in each of the facilities. The NOI for the 650 North 870 West location does not list
any specific equipment. The NOI for the 1726 Hyclone Drive location does not list any specific
equipment but there is an attachment for an emergency generator. ,

Please let me know if you have any questions. I would be happy to set up a video-call to better
discuss what is needed from both of these applications.

Thank you.
--
Rita Trick
Environmental Engineer | Minor NSR Section
M: [phone]
airquality.utah.gov

--
Rita
[phone]
1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…84/87

--
Rita
[phone]

--
Rita
[phone]

--
Rita
[phone]

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…85/87
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…86/87

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
Dylan Frederick
Environmental Engineer | Minor NSR Section
P: [phone]
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

1/9/24, 2:47 PM State of Utah Mail - Re: Air Quality Notices Received
https://mail.google.com/mail/u/0/?ik=8010e5eaf2&view=pt&search=all&permthid=thread-f:1739998426551608773&simpl=msg-f:173999842655160…87/87
Equipment Details
Rating 158 hp = (118 kw)
Operational Hours 100 hours/year
Sulfur Content 15 ppm or 0.0015%
Criteria Pollutant
Emission
Standards
(g/hp-hr)
Emission Factor
(lb/hp-hr)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
NOX 3 1.04 0.05
CO 3.7 1.29 0.06
PM10 0.22 0.08 0.00
PM2.5 0.22 0.08 0.00
VOC 2.51E-03 0.40 0.02SO21.21E-05 0.00 0.00 AP-42 Table 3.4-1HAP0.00 0.00 See Below
Green House Gas Pollutant
Global
Warming
Potential
Emission Factor
(lb/hp-hr)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)ReferenceCO2 (mass basis)1 1.15E+00 182 9
Methane (mass basis)25 0 0CO2e9
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
Benzene 9.33E-04 1.03E-03 5.16E-05Toluene4.09E-04 4.52E-04 2.26E-05Xylenes2.85E-04 3.15E-04 1.58E-05
1,3-Butadiene 3.91E-05 4.32E-05 2.16E-06
Formaldehyde 1.18E-03 1.31E-03 6.53E-05
Acetaldehyde 7.67E-04 8.48E-04 4.24E-05
Acrolein 9.25E-05 1.02E-04 5.12E-06
Naphthalene 8.48E-05 9.38E-05 4.69E-06Acenaphthylene5.06E-06 5.60E-06 2.80E-07Acenaphthene1.42E-06 1.57E-06 7.85E-08Fluorene2.92E-05 3.23E-05 1.61E-06
Phenanthrene 2.94E-05 3.25E-05 1.63E-06
Anthracene 1.87E-06 2.07E-06 1.03E-07
Fluoranthene 7.61E-06 8.42E-06 4.21E-07
Pyrene 4.78E-06 5.29E-06 2.64E-07
Benz(a)anthracene 1.68E-06 1.86E-06 9.29E-08Chrysene3.53E-07 3.90E-07 1.95E-08Benzo(b)fluoranthene 9.91E-08 1.10E-07 5.48E-09Benzo(k)fluoranthene 1.55E-07 1.71E-07 8.57E-09
Benzo(a)pyrene 1.88E-07 2.08E-07 1.04E-08
Indeno(1,2,3-cd)pyrene 3.75E-07 4.15E-07 2.07E-08
Dibenz(a,h)anthracene 5.83E-07 6.45E-07 3.22E-08
Benzo(g,h,l)perylene 4.89E-07 5.41E-07 2.70E-08
AP-42 Table 3.3-1
& Table 3.4-1
Emission Factor
(lb/MMBtu)
AP-42 Table 3.3-2,
Table 3.4-3, &
Table 3.4-4
(1,3-Butadiene will
not popluate if the
engine size is greater
than 600 hp. AP-42
does not list 1,3-
Butadiene for engines
greater than 600 hp.)
Diesel-Fired Engines
Emergency Engines should
equal 100 hours of
operation per year
Manufacturer Data,
AP-42 Table 3.3-1,
& Table 3.4-1
Page 1 of Version 1.1 February 21, 2019
Model:100REOZJD
Kohler Co. provides one-source responsibility for the
generating system and accessories.
The generator set and its components are
prototype-tested, factory-built, and production-tested.
The 60 Hz generator set offers a UL 2200 listing.
The generator set accepts rated load in one step.
The 60 Hz generator set meets NFPA 110, Level 1,
when equipped with the necessary accessories and
installed per NFPA standards.
The generator set complies with ISO 8528-5,
Class G2, requirements for transient performance in
all generator set configurations. Select the
Decision-Maker 550 controller for improved voltage
regulation and ISO 8528-5, Class G3, compliance.
The 60 Hz generator set engine is certified by the
Environmental Protection Agency (EPA) to conform to
Tier 3 nonroad emissions regulations.
A one-year limited warranty covers all systems and
components. Two-, five-, and ten-year extended
warranties are also available.
Alternator features:
The unique Fast-Response II excitation system
delivers excellent voltage response and short-circuit
capability using a permanent magnet (PM)-excited
alternator.
The brushless, rotating-field alternator has
broadrange reconnectability.
Other features:
Controllers are available for all applications. See
controller features inside.
The low coolant level shutdown prevents
overheating (standard on radiator models only).
Integral vibration isolation eliminates the need for
under-unit vibration spring isolators.
Diesel208--600 V
Standard Features
Ratings Range
60 Hz
Standby: kW 80--100
kVA 80--125
Prime: kW 71--92
kVA 71--115
G5-299 (100REOZJD) 9/08d
Generator Set Ratings
130 CRise
Standby Rating
105 CRise
Prime Rating
Alternator Voltage Ph Hz kW/kVA Amps kW/kVA Amps
4S9
120/208 3 60 100/125 347 90/113 312
127/220 3 60 100/125 328 90/113 295
120/240 3 60 100/125 301 90/113 271
120/240 1 60 80/80 333 71/71 296
139/240 3 60 100/125 301 91/114 274
220/380 3 60 88/110 167 90/113 171
277/480 3 60 100/125 150 91/114 137
347/600 3 60 100/125 120 91/114 109
4S11
120/208 3 60 100/125 347 91/114 316
127/220 3 60 100/125 328 91/114 299
120/240 3 60 100/125 301 91/114 274
120/240 1 60 95/95 396 86/86 358
139/240 3 60 100/125 301 92/115 277
220/380 3 60 100/125 190 91/114 173
277/480 3 60 100/125 150 92/115 138
347/600 3 60 100/125 120 92/115 111
4V11 120/240 1 60 95/95 396 86/86 358
RATINGS: Allthree-phaseunitsareratedat 0.8power factor. Allsingle-phaseunits arerated at 1.0 power factor.Standby Ratings:Standby ratings apply toinstallations servedby areliable utility source. The
standbyratingisapplicabletovaryingloadsforthedurationofapoweroutage. Thereisnooverloadcapabilityforthisrating. RatingsareinaccordancewithISO-3046/1,BS5514,AS2789,andDIN 6271.Prime
Power Ratings:Prime power ratings apply to installations where utility power is unavailable or unreliable. At varying load, the number of generator set operating hours is unlimited. A 10% overload capacity is
available for one hour in twelve. Ratings are in accordance with ISO-8528/1, overload power in accordance with ISO-3046/1, BS 5514, AS 2789, and DIN 6271. For limited running time and base load ratings,
consult the factory. Obtain the technical information bulletin (TIB-101) on ratings guidelines for the complete ratings definitions. The generator set manufacturer reserves the right to change the design or
specifications without notice and without any obligation or liability whatsoever. GENERAL GUIDELINES FOR DERATION:Altitude:Derate 1.3% per 100 m (328 ft.) elevation above 2500 m (8200 ft.).
Temperature:Derate 1.0% per 10 C(18 F) temperature above 25 C(77 F).
G5-299 (100REOZJD) 9/08d
Alternator Specifications
Specifications Alternator
Manufacturer Kohler
Type 4-Pole, Rotating-Field
Exciter type Brushless,
Permanent-Magnet
Leads: quantity, type 12, Reconnectable
Voltage regulator Solid State, Volts/Hz
Insulation: NEMA MG1
Material Class H
Temperature rise 130 C, Standby
Bearing: quantity, type 1, Sealed
Coupling Flexible Disc
Amortisseur windings Full
Voltage regulation, no-load to full-load
Permanent magnet (PM) alternator ±2% Average
550 controller (with 0.5% drift
due to temperature variation)3-Phase Sensing,±0.25%
Unbalanced load capability 100% of Rated
Standby Current
One-step load acceptance 100% of Rating
Peak motor starting kVA: (35% dip for voltages below)
480 V 4S9 (12 lead) 315
480 V 4S11 (12 lead) 460
480 V 4V11 (12 lead) —
NEMA MG1, IEEE, and ANSI standards compliance for
temperature rise and motor starting.
Sustained short-circuit current of up to 300% of the rated
current for up to 10 seconds.
Sustained short-circuit current enabling downstream circuit
breakers to trip without collapsing the alternator field.
Self-ventilated and dripproof construction.
Vacuum-impregnated windings with fungus-resistant epoxy
varnish for dependability and long life.
Superior voltage waveform from a two-thirds pitch stator and
skewed rotor.
Fast-Response II brushless alternator with brushless
exciter for excellent load response.
Application Data
Engine
Engine Specifications
Manufacturer John Deere
Engine model 4045HF285I
Engine type 4-Cycle, Turbocharged,
Charge Air-Cooled
Cylinder arrangement 4 Inline
Displacement, L (cu. in.) 4.5 (276)
Bore and stroke, mm (in.) 106 x 127 (4.19 x 5.00)
Compression ratio 19:1
Piston speed,m/min. (ft./min.) 457 (1500)
Main bearings: quantity, type 5, Replaceable Insert
Rated rpm 1800
Max. power at rated rpm, kWm (BHP) 118 (158)
Cylinder head material Cast Iron
Crankshaft material Forged Steel
Valve material:
Intake Chromium-Silicon Steel
Exhaust Stainless Steel
Governor: type, make/model JDEC Electronic L16
Denso HP3
Frequency regulation, no-load to full-load Isochronous
Frequency regulation, steady state ±0.25%
Frequency Fixed
Air cleaner type, all models Dry
Exhaust
Exhaust System
Exhaust manifold type Dry
Exhaust flow at rated kW, m
3/min. (cfm) 22.8 (805)
Exhaust temperature at rated kW, dry
exhaust,C(F)580 (1076)
Maximum allowable back pressure,
kPa (in. Hg)7.5 (2.2)
Exhaust outlet size at engine hookup,
mm (in.)98 (3.86)
Engine Electrical
Engine Electrical System (12/24 Volt*)
Battery charging alternator:12 Volt/24 Volt
Ground (negative/positive) Negative
Volts (DC) 12/24
Ampere rating 65/45
Starter motor rated voltage (DC) 12/24
Battery, recommended cold cranking
amps (CCA):12 Volt/24 Volt
Quantity, CCA rating each One, 640/Two, 570
Battery voltage (DC) 12
*12-volt or 24-volt engine electrical systems are available.
G5-299 (100REOZJD) 9/08d
Application Data
Fuel
Fuel System
Fuel supply line, min. ID, mm (in.)11.0 (0.44)
Fuel return line, min. ID, mm (in.) 6.0 (0.25)
Max. lift, fuel pump: type, m (ft.) Engine-Driven, 1.8 (6.0)
Max. fuel flow, Lph (gph) 74.6 (19.7)
Fuel prime pump Manual
Fuel filter
Secondary 2 Microns @ 98% Efficiency
Primary 30 Microns
Water Separator Yes
Recommended fuel #2 Diesel
Lubrication
Lubricating System
Type Full Pressure
Oil pan capacity, L (qt.) 14.7 (15.5)
Oil pan capacity with filter, L (qt.) 15.6 (16.5)
Oil filter: quantity, type 1, Cartridge
Oil cooler Water-Cooled
Cooling
Radiator System
Ambient temperature,C(F)*50 (122)
Engine jacket water capacity, L (gal.) 8.5 (2.25)
Radiator system capacity, including
engine, L (gal.)20.1 (5.3)
Engine jacket water flow, Lpm (gpm) 182 (48)
Heat rejected to cooling water at rated
kW, dry exhaust, kW (Btu/min.)62 (3544)
Heat rejected to air charge cooler at
rated kW, dry exhaust, kW (Btu/min.)20 (1127)
Water pump type Centrifugal
Fan diameter, including blades, mm (in.) 600 (23.6)
Fan, kWm (HP) 5.7 (7.6)
Max. restriction of cooling air, intake and
discharge side of radiator, kPa (in. H2O)0.125 (0.5)
* Enclosure with enclosed silencer reduces ambient
temperature capability by 5°C(9°F).
Operation Requirements
Air Requirements
Radiator-cooled cooling air,
m3/min. (scfm)161 (5700)
Combustion air, m
3/min. (cfm) 8.2 (288)
Heat rejected to ambient air:
Engine, kW (Btu/min.) 25.0 (1420)
Alternator, kW (Btu/min.) 11.6 (660)
Air density = 1.20 kg/m
3 (0.075 lbm/ft
3)
Fuel Consumption
Diesel, Lph (gph) at % load Standby Rating
100%31.0 (8.2)
75% 25.0 (6.6)
50% 17.8 (4.7)
25% 9.5 (2.5)
Diesel, Lph (gph) at % load Prime Rating
100%27.6 (7.3)
75% 22.7 (6.0)
50% 14.4 (3.8)
25% 7.6 (2.0)
Controllers
Decision-Maker 550 Controller
Audiovisual annunciation with NFPA 110 Level 1 capability.
Programmable microprocessor logic and digital display features.
Alternator safeguard circuit protection.
12- or 24-volt engine electrical system capability.
Remote start, remote annunciation, and remote communication options.
Refer to G6-46 for additional controller features and accessories.
Decision-Maker 3+, 16-Light Controller
Audiovisual annunciation with NFPA 110 Level 1 capability.
Microprocessor logic, AC meters, and engine gauge features.
12- or 24-volt engine electrical system capability.
Remote start, prime power, and remote annunciation options.
Refer to G6-30 for additional controller features and accessories.
Overall Size, L x W x H, mm (in.):
Wide Skid: 2400 x 1040 x 1274 (94.49 x 40.94 x 50.15)
Narrow Skid: 2400 x 864 x 1274 (94.49 x 34.02 x 50.15)
Weight (radiator model), wet, kg (lb.): 1234 (2720)
©2006, 2007, 2008, 2009 by Kohler Co. All rights reserved.
DISTRIBUTED BY:
Dimensions and Weights
NOTE: This drawing is provided for reference only and should not be used for planning
installation. Contact your local distributor for more detailed information.
H
WL
G5-299 (100REOZJD) 9/08d
Additional Standard Features
Alternator Protection (standard with 550 controller)
Battery Rack and Cables
Emission Compliant Engine
Integral Vibration Isolation
Oil Drain Extension
Operation and Installation Literature
Available Options
Approvals and Listings
CSA Approval
IBC Seismic Certification
UL 2200 Listing
Enclosed Unit
Sound Enclosure (with enclosed critical silencer)
Weather Enclosure (with enclosed critical silencer)
Weather Housing (with roof-mounted critical silencer)
Open Unit
Exhaust Silencer, Critical (kit: PA-354809)
Exhaust Silencer, Hospital (kit: PA-365349)
Flexible Exhaust Connector, Stainless Steel
Fuel System
Auxiliary Fuel Pump
Flexible Fuel Lines
Fuel Pressure Gauge
Subbase Fuel Tanks
Subbase Fuel Tank with Day Tank
Controller
Common Failure Relay
Communication Products and PC Software (550 controller only)
Customer Connection
Dry Contact (isolated alarm)
Prime Power Switch (550 controller only)
Remote Annunciator Panel
Remote Audiovisual Alarm Panel
Remote Emergency Stop
Remote Mounting Cable
Run Relay
Cooling System
Block Heater
(recommended for ambient temperatures below 0°C[32°F])
Radiator Duct Flange
Electrical System
Alternator Strip Heater
Battery
Battery Charger, Equalize/Float Type
Battery Heater
Line Circuit Breaker (NEMA type 1 enclosure)
Line Circuit Breaker with Shunt Trip (NEMA type 1 enclosure)
Optional Alternators
Safeguard Breaker (16-light controller)
Paralleling System
Reactive Droop Compensator
Voltage Adjust Control
Voltage Regulator Relocation
Miscellaneous
Air Cleaner, Heavy Duty
Air Cleaner Restriction Indicator
Crankcase Emissions Canister
Engine Fluids (oil and coolant) Added
Rated Power Factor Testing
Rodent Guards
Skid End Caps
Literature
General Maintenance
NFPA 110
Overhaul
Production
Warranty
2-Year Basic
2-Year Prime
5-Year Basic
5-Year Comprehensive
10-Year Major Components
Other Options
_______________________________________________
_______________________________________________
_______________________________________________
_______________________________________________
Kohler Power Systems
Asia Pacific Headquarters
7 Jurong Pier Road
Singapore 619159
Phone [phone], Fax [phone]
KOHLER CO., Kohler, Wisconsin 53044 USA
Phone [phone], Fax [phone]
For the nearest sales and service outlet in the
US and Canada, phone [phone]
KohlerPower.com
The world leader in serving scienceProprietary & Confidential
Thermo Fisher Scientific, Logan, UT
Emergency Generator BACT Analysis Prepared By
Kyle D. Emmett, CIH, CSP
Sr. Manager EHS
February, 2023
2 Proprietary & Confidential
Summary
Thermo Fisher Scientific has submitted a Notice Of Intent (NOI) due to the use and emission of VOCs (Isopropyl Alcohol) in its cleanroom environments during the manufacture and assembly of Bio-Process Containers in Logan Utah in support of the Biopharmaceutical and Research Industry. The manufacture and assembly process requires the use of Sterile Isopropyl Alcohol CAS# 67-63-0 to clean components and surfaces and serve as sterile lubrication during assembly.
The Logan Utah facilities are part of the legal entity “Life Technologies Corporation” owned and operated by Thermo Fisher Scientific. Life Technologies Corporation maintains compliance with applicable FDA regulations, specifically 21CFR820.
The Logan Utah facilities are part of the Single Use Division of Life Technologies Corp and manufactures Bio-Process Containers (BPCs) for sale. BPCs are used as liquid management systems for large and small volumes of liquids produces for further manufacturing. They are also provided empty as mixing containers, holding containers, downstream processing containers or waste collection containers. They are single use, disposable containers.
As requested by The Utah Dept of Environmental Quality, Thermo Fisher Scientific Logan submits this analysis of current and potential control technologies or methods that will reduce emissions from it’s Emergency Generator located at 1726 HycloneDrive.
Table 1 and 2 provide summaries of each BACT determination for Emergency Generator Emissions.
3 Proprietary & Confidential
Table 1. Summary of Current BACT
Process Current Used BACT
Emergency Generator Operate Engine Meeting Tier Nonroad Regulatory Requirements
All new engines manufactured in the United States are required to meet emission limits specified in “Tiers,” based upon date
of manufacture. A review of the EPA’s RBLC indicates that the use of Tier-compliant engines is BACT for emergency engines.
The Emergency Generator at 1726 Hyclone Drive has a Tier III engine.
Combust only ultra-low sulfur diesel (ULSD) in emergency generator engine and utilize good combustion practices.
Comply with specified maintenance schedules (crankcase oil, belts and hoses, etc.), and minimize time at idle.
Summary of BACT
4 Proprietary & Confidential
Summary of BACT
Table 2. Summary of Potential BACT
Process Potential BACT Elimination/Infeasibility of Options
Emergency Generator Replace Engine for Emergency Generator A review of the EPA’s RBLC database for emergency diesel engines
indicates that the use of Tier III engines has been considered BACT1.
As noted above, the site currently utilizes good combustion practices, ULSD Fuel, and routine maintenance for Emergency Diesel Engines.
This represents the only technically feasible control option for Tier III
emergency diesel engines.
As part of the BACT evaluation, for the emergency generator engine,
the side believes it is meeting Federal regulatory standards and
operating with good combustion practices are the most appropriate
requirements for this engine.
Emissions generated by the emergency generator are low enough that
adding controls would most likely not be cost effective.
1. chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.epa.gov/sites/default/files/2020-07/documents/nonroad_ria_final-nonroad-diesel-engines_2004-05.pdf
Equipment Details
Rating 7 MMBtu/hour
Operational Hours 8,760 hours/yearFiringNormal
Criteria Pollutant
Concentration
(ppm)
Emission
Factor
(lb/10^6 scf)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
NOX 100 0.64 2.79
CO 84 0.54 2.34
PM10 7.6 0.05 0.21
PM2.5 7.6 0.05 0.21
SO2 0.6 0.00 0.02
VOC 5.5 0.04 0.15Lead0.0005 0.00 0.00
HAP 0.01 0.05 See Below
Green House Gas Pollutant
Global
Warming
Potential
Emission
Factor
(lb/10^6 scf)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
CO2 (mass basis)1 120,000 765 3,349
Methane (mass basis)25 2.3 0.01 0.06
N2O (mass basis)298 2.2 0.01 0.06
CO2e 3,369
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference
2-Methylnaphthalene 2.40E-05 1.53E-07 6.70E-073-Methylchloranthrene 1.80E-06 1.15E-08 5.02E-08
7,12-Dimethylbenz(a)anthracene 1.60E-05 1.02E-07 4.47E-07Acenaphthene1.80E-06 1.15E-08 5.02E-08
Acenaphthylene 1.80E-06 1.15E-08 5.02E-08
Anthracene 2.40E-06 1.53E-08 6.70E-08
Benz(a)anthracene 1.80E-06 1.15E-08 5.02E-08
Benzene 2.10E-03 1.34E-05 5.86E-05
Benzo(a)pyrene 1.20E-06 7.65E-09 3.35E-08
Benzo(b)fluoranthene 1.80E-06 1.15E-08 5.02E-08Benzo(g,h,i)perylene 1.20E-06 7.65E-09 3.35E-08
Benzo(k)fluoranthene 1.80E-06 1.15E-08 5.02E-08
Chrysene 1.80E-06 1.15E-08 5.02E-08
Dibenzo(a,h)anthracene 1.20E-06 7.65E-09 3.35E-08
Dichlorobenzene 1.20E-03 7.65E-06 3.35E-05
Fluoranthene 3.00E-06 1.91E-08 8.37E-08
Fluorene 2.80E-06 1.78E-08 7.82E-08Formaldehyde7.50E-02 4.78E-04 2.09E-03
Hexane 1.80E+00 1.15E-02 5.02E-02
Indeno(1,2,3-cd)pyrene 1.80E-06 1.15E-08 5.02E-08
Naphthalene 6.10E-04 3.89E-06 1.70E-05
Phenanathrene 1.70E-05 1.08E-07 4.75E-07
Pyrene 5.00E-06 3.19E-08 1.40E-07
Toluene 3.40E-03 2.17E-05 9.49E-05
Arsenic 2.00E-04 1.27E-06 5.58E-06
Beryllium 1.20E-05 7.65E-08 3.35E-07
Cadmium 1.10E-03 7.01E-06 3.07E-05
Chromium 1.40E-03 8.92E-06 3.91E-05
Cobalt 8.40E-05 5.35E-07 2.34E-06
Manganese 3.80E-04 2.42E-06 1.06E-05
Mercury 2.60E-04 1.66E-06 7.26E-06
Nickel 2.10E-03 1.34E-05 5.86E-05
Selenium 2.40E-05 1.53E-07 6.70E-07
AP-42 Table 1.4-4
Manufacturer Data
or AP-42 Table 1.4-1
AP-42 Table 1.4-2
Natural Gas-Fired Boilers & Heaters
AP-42 Table 1.4-2
&
Table A-1 to
Subpart A of Part 98
AP-42 Table 1.4-3
Emission Factor
(lb/10^6 scf)
Page 1 of 3 Version 1.0
November 29, 2018
Asset Description Location Make Serial Number
015562 AHU-4, Make-Up Air A15-401 TRANE F08B31725
26722 Air Handler A16-205 REZNOR BTC3053017256
26721 Air Handler A16-205 REZNOR BTC3053017255
016555 AIR HANDLER UNIT (RTU-1)A15-ROOF TRANE 806101016D
016552 AIR HANDLER UNIT (RTU-4)A15-ROOF TRANE 806101098D
016554 AIR HANDLER UNIT (RTU-5)A15-ROOF TRANE 806101104D
016551 AIR HANDLER UNIT (RTU-3)A15-ROOF TRANE 806101111D
021163 AIR HANDLER UNIT (RTU-2)A15-ROOF TRANE 164311564L
016686 AIR HANDLER UNIT (RTU-7)A15-ROOF TRANE 407101870L
016687 AIR HANDLER UNIT (RTU-10)A15-ROOF TRANE 407101892L
016530 AIR HANDLER UNIT (RTU-6)A15-ROOF TRANE 733101758L
017375 AIR HANDLER UNIT,YORK (RTU-8)A15-ROOF York N1H0199779
021093 Air Handler, Division Offices (RTU) A15-ROOF York N1K5038761
019549 AIR HANDLER UNIT,YORK (RTU-15)A15-ROOF York N1L2234763
017376 AIR HANDLER UNIT,YORK (RTU-9)A15-ROOF York N1H0281080
019521 AIR HANDLER UNIT,YORK (RTU-12)A15-ROOF York N1L2226060
N/A Roof Top Unit A15-ROOF York N1F9014072
026746 Roof Top Unit (RTU-8)A16-ROOF York N2B0600316
026741 Roof Top Unit (RTU-3)A16-ROOF York N2B0600317
026743 Roof Top Unit (RTU-5)A16-ROOF York N2B0600340
026744 Roof Top Unit (RTU-6)A16-ROOF York N2B0600339
019520 AIR HANDLER UNIT,YORK (RTU-11)A15-ROOF York N1K2154536
026739 Roof Top Unit (RTU-1)A16-ROOF York N2B0601494
026740 Roof Top Unit (RTU-2)A16-ROOF York N2B0601495
026742 Roof Top Unit (RTU-4)A16-ROOF York N2B0601496
026745 Roof Top Unit (RTU-7)A16-ROOF York N2B0601497
026747 Roof Top Unit (RTU-9)A16-ROOF York N2B0601498
026753 Roof Top Unit (RTU-15)A16-ROOF York N2B1697414
026749 Roof Top Unit (RTU-11)A16-ROOF York N2B1697415
026750 Roof Top Unit (RTU-12)A16-ROOF York N2B1697416
026756 Roof Top Unit (RTU-18)A16-ROOF York N2B1697417
026748 Roof Top Unit (RTU-10)A16-ROOF York N2B1686327
026752 Roof Top Unit (RTU-14)A16-ROOF York N2B1686328
026755 Roof Top Unit (RTU-17)A16-ROOF York N2B1697411
026751 Roof Top Unit (RTU-13)A16-ROOF York N2B1697425
026754 Roof Top Unit (RTU-16)A16-ROOF York N2B1697418
Model Number BTU/Hr
GXAA35PFMF0L1BN304U0ADEP5 292000
SDH-350 315000
SDH-350 315000
YCD181C4HBCA 350000
YCD181C4HBCA 350000
YCD181C4HBCA 350000
YCD181C4HBCA 350000
YHC092FRHA0DH00C0A1A100070000D 160000
YSC060A4RHA1CC000A10002A0B 160000
YSC060A4RHA1CC000A10002A0B 160000
YSCO36A4RLA2K000000000000A 160000
ZF048N10N4AA1 A 125000
ZF048N10N4AAA4A 125000
ZF048N10N4AAAZ 125000
ZF072N10N4AAA 125000
ZF090N15N4AAA5A 180000
ZF090N18R4A1AAA1A2 180000
ZF090N18R4D1ACA3A2 180000
ZF090N18R4D1ACA3A2 180000
ZF090N18R4D1ACA3A2 180000
ZF102N18R4D1ACA3A2 180000
ZF120N20N4AAA5A 240000
ZF120N24R401ACA3A3 240000
ZF120N24R401ACA3A3 240000
ZF120N24R401ACA3A3 240000
ZH049N12B4D1ACA3A2 120000
ZH049N12B4D1ACA3A2 120000
ZJ037N06D4D1ACA1A3 60000
ZJ037N06D4D1ACA1A3 60000
ZJ037NO6D4D1ACA1A3 60000
ZJ037NO6D4D1ACA1A3 60000
ZJ049N06D4A1ACA1A2 60000
ZJ049N06D4A1ACA1A2 60000
ZJ049N12D4D1ACA1A2 120000
ZJ061N08D4A1ACA1A3 80000
ZJ102N18D4D1ACA1A2 180000
6482000
1 of 1
Form 2 Date ____________
Company Information/Notice of Intent (NOI)
Utah Division of Air Quality
New Source Review Section
Application for: □ Initial Approval Order □Approval Order Modification
General Owner and Source Information
1.Company name and mailing address:
____________________________
____________________________
____________________________
Phone No.: ( )
Fax No.: ( )
2.Company** contact for environmental matters:
____________________________
Phone no.: ( )
Email: _______________________
** Company contact only; consultant or independent contractor contact information can be provided in a cover letter
3.Source name and physical address (if different from
above):____________________________
____________________________
____________________________
Phone no.: ( )
Fax no.: ( )
4.Source Property Universal Transverse Mercator
coordinates (UTM), including System and Datum:
UTM:_________________________
X:____________________________
Y:____________________________
5.The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC)
__ __ __ __
7.If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____
8.Brief (50 words or less) description of process.
Electronic NOI
9.A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black ([e-mail]) or Alan
Humpherys ([e-mail]) can expedite review process. Please mark application type.
Hard Copy Submittal Electronic Copy Submittal □ Both
Authorization/Signature
I hereby certify that the information and data submitted in and with this application is completely true, accurate and
complete, based on reasonable inquiry made by me and to the best of my knowledge and belief.
Signature: Title:
_______________________________________
Name (Type or print)
Telephone Number:
( )
Email:
Date:
30JUN2022
4
Life Technologies Corp
1726 Hyclone Drive
Logan, UT 84321
[phone]
Kyle Emmett
[phone]
[e-mail]
Thermo Fisher Scientific BioCenter
1726 Hyclone Drive
Logan, UT
[phone]
Cache
12
428863
4617037
2673
Thermo Fisher Scientific manufacturers single-use BioProcess Containers (BPCs), ready-to-use
flexible containers, critical to sterile liquid handling applications in the biopharmaceutical industry.
BPCs are produced and assembled in ISO-7 cleanrooms.
4
Sr. Manager EHS
Kyle D. Emmett [phone]
[e-mail]
30JUN2022
Kyle D. EmmettDigitally signed by Kyle D. Emmett Date: 2022.06.30 14:24:08 -06'00'
DAO 2018 002272
Page 1 of 1
Form 3 Company____________________
Process Information Site________________________
Utah Division of Air Quality
New Source Review Section
Process Information - For New Permit ONLY
1.Name of process:2.End product of this process:
3.Process Description*:
Operating Data
4.Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year
5.Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall _______
6.Maximum Hourly production (indicate units.):
_____________
7.Maximum annual production (indicate units):
________________
8.Type of operation:
Continuous Batch Intermittent
9.If batch, indicate minutes per cycle ________
Minutes between cycles ________
10. Materials and quantities used in process.*
Material Maximum Annual Quantity (indicate units)
11.Process-Emitting Units with pollution control equipment*
Emitting Unit(s) Capacity(s) Manufacture Date(s)
*If additional space is required, please create a spreadsheet or Word processing document and attach to form.
Life Technologies Corp
Thermo Fisher Scientific BioCenter
BioProccss Container
Manufacturing and Assembly
Single-Use BioProcess
Containers
Rolls of multilayer plastic film, made up of a polyester elastomer, ethyl vinyl alcohol and
low-density polyethylene, are introduced into a production ISO-7 cleanroom where it is
cut and heat sealed (<300F) on semi-auto and automatic bag manufacturing lines into
containers called BioProcess Containers (BPCs) ranging in sizes from ~20mL to
10,000L. The BPC is then fitted/assembled with connectors, tubing, filters, manifolds, pH
probes, mixers, etc. The process involves the use of Sterile Isopropyl Alcohol CAS#
67-63-0 (70-99% concentration) to clean components and surfaces and serve as sterile
lubrication during assembly.
24
7
50
25%
25%
25%
25%
3,474 29,927,007
4
BioProcess Container Assemblies 2,927,007.00
N/A N/A
Docuitiunl Dale;: 02/28,;2018
DAQ 2018
II002273
Page 1 of 1
Company___________________________
Site _____________________________
Form 5
Emissions Information
Criteria/GHGs/ HAP’s
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
Life Technologies Corp
Thermo Fisher Scientific BioCenter
20,000.00 0.00 19,500.00
Jccumonl Dcjlc: 02/28/2018
Utah Division of Air Quality
New Source Review Section Company: ___________________
Site/Source: _________________ Form 17 Date: _______________________
Diesel Powered Standby Generator

Company Information
1. Company Name and Address:
____________________________________________
____________________________________________
____________________________________________
____________________________________________
Phone Number: _______________________________
Fax Number: _______________________________
2. Company Contact:
____________________________________________
____________________________________________
____________________________________________
____________________________________________
Phone Number: _______________________________
Fax Number: _______________________________
3. Installation Address:
____________________________________________ County where facility is located: __________________
____________________________________________
____________________________________________ Latitude, Longitude and UTM Coordinates of Facility
____________________________________________ __________________________________________
Phone Number: _______________________________ __________________________________________
Fax Number: _______________________________
Standby Generator Information
4. Engines:
Maximum Maximum Emission Rate Date the engine
Manufacturer Model Rated Hours of Rate of NOx was constructed Horsepower or Kilowatts Operation grams/BHP-HR or reconstructed
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
Attach Manufacturer-supplied information
5. Calculated emissions for this equipment:
PM10____________ Lbs/hr _____________Tons/yr PM2.5____________ Lbs/hr _____________Tons/yr
NOx_____________Lbs/hr______________Tons/yr SOx ____________ Lbs/hr______________Tons/yr
CO _____________Lbs/hr______________Tons/yr VOC ____________Lbs/hr______________Tons/yr
CO2 ____________Tons/yr CH4 ____________ Tons/yr
N2O ____________Tons/yr
HAPs___________ Lbs/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.
Life Technologies Corp
Thermo Fisher Scientific- BioCenter
24MAY2022
Life Technologies Corp
1726 Hyclone Drive
Logan, UT, 84321
[phone]
Kyle D. Emmett
Sr. Manager EHS
1726 Hyclone Drive
Logan, UT, 84321
[phone]
Thermo Fisher Scientific BioCenter
1726 Hyclone Drive
Logan, UT, 84321
[phone]
Cache
UTM 12
X: 428863 Y: 4617037
John Deere 100REOZJD April 2008118 kW 26 2.77
0.000304 0.000004
0.006192 0.00008
0.002995 0.00004

Instructions Form 17 - Diesel Powered Standby Generator

Call the Division of Air Quality (DAQ) at [phone] if you have problems or questions in filling out
this form. Ask to speak with a New Source Review engineer. We will be glad to help!
Lines 1 Fill in the name, address, phone number, and fax number of the business applying for the and 2: permit exemption.
Line 3 Fill in the address where the equipment will be located. Directions to business if needed for remote locations,
i.e., five miles south of Deseret on highway 101, turn left at farmhouse, go 1.5 miles. Identify the county the
equipment will be located. Also enter the latitude, longitude and UTM coordinates of the facility. Line 4 Fill in the manufacturer, model, maximum rated horsepower or kilowatts, maximum hours of operation, emission
rate for NOx in grams/BHP-hr, and the date the engine was constructed or reconstructed. Attach manufacturer
emission information. Note: Maximum rated horsepower not to exceed 1000hp or 750 kilowatts. Also maximum hours not to exceed
300 hours. Line 5 Supply calculations for all criteria pollutants, greenhouse gases and hazardous air pollutants. Use EPA AP-42
or manufacturers’ data to complete your calculations. Fill in the name, address, phone number, and fax number
of the business applying for the
U:\aq\ENGINEER\GENERIC\Forms 2010\Form17 Diesel-fired Standby Generators.doc
Revised 12/20/10
Rating Specific Emissions Data - John Deere Power Systems
Rating Data
Rating
Spec Rated Power (kW)
Rated Speed
Vehicle Model Number
4045HF285I
118
1800
OEM (Gen Set)
Certificate Data
Model Year
EPA Family Name
EPA JD Name
EPA Certificate Number
2008
8JDXL06.8105
350HAC
JDX-NRCI-08-04
CARB Certificate Number
Label Part Number
U-R-004-0313
R527066
Emissions Data *
Units
CO
Pm
NOx
HC
NOx + HC
Test Engine
g/kW-hr
1.8
0.182
3.72
0.12
3.83
g/hp-hr
1.34
0.136
2.77
0.089
2.86
PE4045X000979
* The emission data listed is measured from the calibration
engine under laboratory test conditions. It is intended to
represent an "average" engine but is not a guarantee that all
engines meet these values.
JDPS 2/21/2008 Page 1
1 of 1
Form 2 Date ____________
Company Information/Notice of Intent (NOI)
Utah Division of Air Quality
New Source Review Section
Application for: □ Initial Approval Order □Approval Order Modification
General Owner and Source Information
1.Company name and mailing address:
____________________________
____________________________
____________________________
Phone No.: ( )
Fax No.: ( )
2.Company** contact for environmental matters:
____________________________
Phone no.: ( )
Email: _______________________
** Company contact only; consultant or independent contractor contact information can be provided in a cover letter
3.Source name and physical address (if different from
above):____________________________
____________________________
____________________________
Phone no.: ( )
Fax no.: ( )
4.Source Property Universal Transverse Mercator
coordinates (UTM), including System and Datum:
UTM:_________________________
X:____________________________
Y:____________________________
5.The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC)
__ __ __ __
7.If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____
8.Brief (50 words or less) description of process.
Electronic NOI
9.A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black ([e-mail]) or Alan
Humpherys ([e-mail]) can expedite review process. Please mark application type.
Hard Copy Submittal Electronic Copy Submittal □ Both
Authorization/Signature
I hereby certify that the information and data submitted in and with this application is completely true, accurate and
complete, based on reasonable inquiry made by me and to the best of my knowledge and belief.
Signature: Title:
_______________________________________
Name (Type or print)
Telephone Number:
( )
Email:
Date:
30JUN2022
4
Life Technologies Corp
1726 Hyclone Drive
Logan, UT 84321
[phone]
Kyle Emmett
[phone]
[e-mail]
Thermo Fisher Scientific BioCenter
1726 Hyclone Drive
Logan, UT
[phone]
Cache
12
428863
4617037
2673
Thermo Fisher Scientific manufacturers single-use BioProcess Containers (BPCs), ready-to-use
flexible containers, critical to sterile liquid handling applications in the biopharmaceutical industry.
BPCs are produced and assembled in ISO-7 cleanrooms.
4
Sr. Manager EHS
Kyle D. Emmett [phone]
[e-mail]
30JUN2022
Kyle D. EmmettDigitally signed by Kyle D. Emmett Date: 2022.06.30 14:24:08 -06'00'
DAO 2018 002272
Page 1 of 1
Form 3 Company____________________
Process Information Site________________________
Utah Division of Air Quality
New Source Review Section
Process Information - For New Permit ONLY
1.Name of process:2.End product of this process:
3.Process Description*:
Operating Data
4.Maximum operating schedule:
__________ hrs/day
__________days/week
__________weeks/year
5.Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall _______
6.Maximum Hourly production (indicate units.):
_____________
7.Maximum annual production (indicate units):
________________
8.Type of operation:
Continuous Batch Intermittent
9.If batch, indicate minutes per cycle ________
Minutes between cycles ________
10. Materials and quantities used in process.*
Material Maximum Annual Quantity (indicate units)
11.Process-Emitting Units with pollution control equipment*
Emitting Unit(s) Capacity(s) Manufacture Date(s)
*If additional space is required, please create a spreadsheet or Word processing document and attach to form.
Life Technologies Corp
Thermo Fisher Scientific BioCenter
BioProccss Container
Manufacturing and Assembly
Single-Use BioProcess
Containers
Rolls of multilayer plastic film, made up of a polyester elastomer, ethyl vinyl alcohol and
low-density polyethylene, are introduced into a production ISO-7 cleanroom where it is
cut and heat sealed (<300F) on semi-auto and automatic bag manufacturing lines into
containers called BioProcess Containers (BPCs) ranging in sizes from ~20mL to
10,000L. The BPC is then fitted/assembled with connectors, tubing, filters, manifolds, pH
probes, mixers, etc. The process involves the use of Sterile Isopropyl Alcohol CAS#
67-63-0 (70-99% concentration) to clean components and surfaces and serve as sterile
lubrication during assembly.
24
7
50
25%
25%
25%
25%
3,474 29,927,007
4
BioProcess Container Assemblies 2,927,007.00
N/A N/A
Docuitiunl Dale;: 02/28,;2018
DAQ 2018
II002273
Page 1 of 1
Company___________________________
Site _____________________________
Form 5
Emissions Information
Criteria/GHGs/ HAP’s
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
Life Technologies Corp
Thermo Fisher Scientific BioCenter
20,000.00 0.00 19,500.00
Jccumonl Dcjlc: 02/28/2018
Utah Division of Air Quality
New Source Review Section Company: ___________________
Site/Source: _________________ Form 17 Date: _______________________
Diesel Powered Standby Generator

Company Information
1. Company Name and Address:
____________________________________________
____________________________________________
____________________________________________
____________________________________________
Phone Number: _______________________________
Fax Number: _______________________________
2. Company Contact:
____________________________________________
____________________________________________
____________________________________________
____________________________________________
Phone Number: _______________________________
Fax Number: _______________________________
3. Installation Address:
____________________________________________ County where facility is located: __________________
____________________________________________
____________________________________________ Latitude, Longitude and UTM Coordinates of Facility
____________________________________________ __________________________________________
Phone Number: _______________________________ __________________________________________
Fax Number: _______________________________
Standby Generator Information
4. Engines:
Maximum Maximum Emission Rate Date the engine
Manufacturer Model Rated Hours of Rate of NOx was constructed Horsepower or Kilowatts Operation grams/BHP-HR or reconstructed
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
Attach Manufacturer-supplied information
5. Calculated emissions for this equipment:
PM10____________ Lbs/hr _____________Tons/yr PM2.5____________ Lbs/hr _____________Tons/yr
NOx_____________Lbs/hr______________Tons/yr SOx ____________ Lbs/hr______________Tons/yr
CO _____________Lbs/hr______________Tons/yr VOC ____________Lbs/hr______________Tons/yr
CO2 ____________Tons/yr CH4 ____________ Tons/yr
N2O ____________Tons/yr
HAPs___________ Lbs/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.
Life Technologies Corp
Thermo Fisher Scientific- BioCenter
24MAY2022
Life Technologies Corp
1726 Hyclone Drive
Logan, UT, 84321
[phone]
Kyle D. Emmett
Sr. Manager EHS
1726 Hyclone Drive
Logan, UT, 84321
[phone]
Thermo Fisher Scientific BioCenter
1726 Hyclone Drive
Logan, UT, 84321
[phone]
Cache
UTM 12
X: 428863 Y: 4617037
John Deere 100REOZJD April 2008118 kW 26 2.77
0.000304 0.000004
0.006192 0.00008
0.002995 0.00004

Instructions Form 17 - Diesel Powered Standby Generator

Call the Division of Air Quality (DAQ) at [phone] if you have problems or questions in filling out
this form. Ask to speak with a New Source Review engineer. We will be glad to help!
Lines 1 Fill in the name, address, phone number, and fax number of the business applying for the and 2: permit exemption.
Line 3 Fill in the address where the equipment will be located. Directions to business if needed for remote locations,
i.e., five miles south of Deseret on highway 101, turn left at farmhouse, go 1.5 miles. Identify the county the
equipment will be located. Also enter the latitude, longitude and UTM coordinates of the facility. Line 4 Fill in the manufacturer, model, maximum rated horsepower or kilowatts, maximum hours of operation, emission
rate for NOx in grams/BHP-hr, and the date the engine was constructed or reconstructed. Attach manufacturer
emission information. Note: Maximum rated horsepower not to exceed 1000hp or 750 kilowatts. Also maximum hours not to exceed
300 hours. Line 5 Supply calculations for all criteria pollutants, greenhouse gases and hazardous air pollutants. Use EPA AP-42
or manufacturers’ data to complete your calculations. Fill in the name, address, phone number, and fax number
of the business applying for the
U:\aq\ENGINEER\GENERIC\Forms 2010\Form17 Diesel-fired Standby Generators.doc
Revised 12/20/10
Rating Specific Emissions Data - John Deere Power Systems
Rating Data
Rating
Spec Rated Power (kW)
Rated Speed
Vehicle Model Number
4045HF285I
118
1800
OEM (Gen Set)
Certificate Data
Model Year
EPA Family Name
EPA JD Name
EPA Certificate Number
2008
8JDXL06.8105
350HAC
JDX-NRCI-08-04
CARB Certificate Number
Label Part Number
U-R-004-0313
R527066
Emissions Data *
Units
CO
Pm
NOx
HC
NOx + HC
Test Engine
g/kW-hr
1.8
0.182
3.72
0.12
3.83
g/hp-hr
1.34
0.136
2.77
0.089
2.86
PE4045X000979
* The emission data listed is measured from the calibration
engine under laboratory test conditions. It is intended to
represent an "average" engine but is not a guarantee that all
engines meet these values.
JDPS 2/21/2008 Page 1