DAQ-2024-011119

DAQE-AN159810003-24

{{$d1 }}

Prachi Kalla
Amazon Services, LLC
P.O. Box 80842
Seattle, WA 98108
[e-mail]

Dear Ms. Kalla:

Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN159810001-19 to
Replace Existing Sublimation Printers with New Direct-To-Film (DTF) Printers under UAC
R307-401-12
Project Number: N159810003

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on
September 4, 2024. Amazon Services, LLC must comply with the requirements of this AO, all applicable
state requirements (R307), and Federal Standards.

The project engineer for this action is Christine Bodell, 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.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:CB:jg

cc: Salt Lake County Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

October 7, 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-AN159810003-24
Administrative Amendment to Approval Order
DAQE-AN159810001-19 to Replace Existing Sublimation Printers
with New Direct-To-Film (DTF) Printers under UAC R307-401-12

Prepared By
Christine Bodell, Engineer
[phone]
[e-mail]

Issued to
Amazon Services, LLC - Salt Lake Digital Printing Facility

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

October 7, 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 .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 7
ACRONYMS ................................................................................................................................. 8

DAQE-AN159810003-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Amazon Services, LLC Amazon Services, LLC - Salt Lake Digital Printing Facility

Mailing Address Physical Address
P.O. Box 80842 770 South Gladiola, Suite 500
Seattle, WA 98108 Salt Lake City, UT 84104

Source Contact UTM Coordinates
Name: Prachi Kalla 417,858 m Easting
Phone: [phone],511,865 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 2759 (Commercial Printing, NEC)

SOURCE INFORMATION
General Description
Amazon Services, LLC (Amazon Services) owns and operates a digital printing plant located in Salt Lake
City, Salt Lake County. Amazon Services prints on t-shirts, mugs, cell phone ring stand holders, and cell
phone cases, on an as-ordered basis. These items are packaged individually at the plant and delivered to
customers.

NSR Classification
Administrative Amendment

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

Applicable Federal Standards
None

DAQE-AN159810003-24
Page 4

Project Description
Amazon Services has requested an update to Approval Order DAQE-AN159810001-19 with the
following changes:

1- Updates to existing apparel printing hazardous air pollutant (HAP) and volatile organic compound
(VOC) emission rates, according to maximum stack test results from stack testing conducted at a similar
Amazon facility on December 17, 2020.

2- Removal of twenty (20) existing sublimation printers (Equipment ID# II.A.4 in AO
DAQE-AN159810001-19) and replace with six (6) direct-to-film (DTF) apparel printers.

Emissions from the existing twenty (20) sublimation printers were estimated to be 4.70 tpy of VOCs and
0.86 tpy of HAPs. Replacing the sublimation printers with six (6) new direct-to-film (DTF) printers
results in 3.95 tpy of VOCs and 0.19 tpy of HAPs (a reduction of 0.75 tpy of VOCs and 0.67 tpy of
HAPs).

Additionally, the annual VOC and HAPs emissions were updated using the new stack testing emission
factors and updated production rates. The side-wide reduction in VOCs and HAPs is 5.82 tpy of 0.88 tpy,
respectively. This project meets the requirements of UAC R307-401-12 Reduction in Air Pollutants and
does not require a public comment period.

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 0 1659.00
Carbon Monoxide 0 1.16
Nitrogen Oxides 0 1.38
Particulate Matter - PM10 0 0.10
Particulate Matter - PM2.5 0 0.10
Sulfur Dioxide 0 0.01
Volatile Organic Compounds -5.82 10.41

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 60
Glycol Ethers (CAS #EDF109) -100 1920
Triethylene Glycol (CAS #112276) -1720 0
Change (TPY) Total (TPY)
Total HAPs -0.88 0.99

DAQE-AN159810003-24
Page 5

SECTION I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] 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 Amazon Services, LLC
Digital Printing Plant
II.A.2 Twenty-four (24) Digital Apparel Printers
II.A.3 Six (6) Direct-To-Film (DTF) Apparel Printers *New*

II.A.4 Twelve (12) Ultra-Violet (UV) Non-Apparel Printers
DAQE-AN159810003-24
Page 6

II.A.5 Eight (8) Apparel Dryers Fuel: Natural Gas Capacity: 0.4 MMBtu/hr each

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements and Limitations
II.B.1.a The owner/operator shall use only natural gas as fuel in the stationary equipment on site. [R307-401-8]
II.B.1.b The owner/operator shall not allow visible emissions on site to exceed 10% opacity.
[R307-401-8]
II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.1.c The owner/operator shall route all emissions from the 24 Digital Apparel Printers through the Apparel Dryer burners before the emissions are vented to the atmosphere. [R307-401-8]

II.B.1.d The owner/operator shall not exceed the solvent VOC content limits established in R307-304 for any solvents. [R307-304, R307-401-8]
II.B.1.e The owner/operator shall comply with all applicable requirements of UAC R307-304 (Solvent
Cleaning) and UAC R307-325 (Ozone Nonattainment and Maintenance Areas: General Requirements). [R307-304, R307-325, R307-401-8]

II.B.1.f The owner/operator shall: A. Not use any ink that contains greater than 42.80% VOCs by weight or contains greater than 12.40% HAPs by weight for digital apparel printing applications. B. Not use any ink that contains greater than 70% VOCs by weight or contains greater than 5% HAPs by weight for all DTF apparel printing applications. C. Not use any ink that contains greater than 27.6% VOCs by weight or contains any HAPs for all UV non-apparel printing applications. D. Not use any ink or solvent that contains any HAPs except for glycol ethers. [R307-401-8]
II.B.1.f.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records
of the Safety Data Sheet (SDS) for each ink and solvent. [R307-401-8]
DAQE-AN159810003-24
Page 7

II.B.1.g The owner/operator shall not emit more than the following from evaporative sources (printing, coating, and/or cleaning) on site: A. 10.34 tons per rolling 12-month period of VOCs. B. 0.96 tons per rolling 12-month period of ethylene glycol. [R307-401-8] II.B.1.g.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method for each
material in use to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method:
VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed].
HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed].
[R307-401-8]

II.B.1.g.2 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material. B. The maximum percent by weight of VOCs and each HAP in each material used. C. The density of each material used. D. The volume of each VOC- and HAP-emitting printing operation. E. The amount of VOCs and the amount of each HAP emitted from each material. F. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8]
PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN159810001-19 dated September 5, 2019 Incorporates NOI dated September 4, 2024

DAQE-AN159810003-24
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-

RN159810003
September 23, 2024

Prachi Kalla
Amazon Services, LLC.
P.O. Box 80842
Seattle, WA 98108
[e-mail]

Dear Prachi Kalla,

Re: Engineer Review - Administrative Amendment:
Administrative Amendment to Approval Order DAQE-AN159810001-19 to Replace Existing
Sublimation Printers with New Direct-To-Film (DTF) Printers under UAC R307-401-12
Project Number: N159810003

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 (NSR) permitting program. Amazon
Services, LLC. should complete this review within 10 business days of receipt.

Amazon Services, LLC. should contact Christine Bodell at [phone] if there are questions or
concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email
Christine Bodell at [e-mail] the signed cover letter. Upon receipt of the signed cover letter,
the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director.

If Amazon Services, LLC. does not respond to this letter within 10 business days, the project will move
forward without source concurrence. If Amazon Services, LLC. has concerns that cannot be resolved and
the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction.

Approval Signature Prachi Kalla 9/24/2024
(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
Lieutenant Governor

Engineer Review N159810003: Amazon Services, LLC. - Salt Lake Digital Printing Facility
September 23, 2024
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N159810003
Owner Name Amazon Services, LLC.
Mailing Address P.O. Box 80842
Seattle, WA, 98108

Source Name Amazon Services, LLC. - Salt Lake Digital Printing Facility
Source Location 770 South Gladiola, Suite 500
Salt Lake City, UT 84104

UTM Projection 417,858 m Easting, 4,511,865 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 2759 (Commercial Printing, NEC)

Source Contact Prachi Kalla
Phone Number [phone]
Email [e-mail]

Billing Contact Prachi Kalla
Phone Number [phone]
Email [e-mail]

Project Engineer Christine Bodell, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted September 4, 2024
Date of Accepted Application September 5, 2024

Engineer Review N159810003: Amazon Services, LLC. - Salt Lake Digital Printing Facility
September 23, 2024
Page 2
SOURCE DESCRIPTION

General Description
Amazon Services, LLC. (Amazon Services) owns and operates a digital printing plant located in
Salt Lake City, Salt Lake County. Amazon Services prints on t-shirts, mugs, cell phone ring stand
holders, and cell phone cases, on an as-ordered basis. These items are packaged individually at
the plant and delivered to customers.

NSR Classification:
Administrative Amendment

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

Applicable Federal Standards
None

Project Proposal
Administrative Amendment to Approval Order DAQE-AN159810001-19 to Replace Existing
Sublimation Printers with New Direct-To-Film (DTF) Printers under UAC R307-401-12

Project Description
Amazon Services, LLC. (Amazon Services) has requested an update to Approval Order DAQE-
AN159810001-19 with the following changes:

- Updates to existing apparel printing hazardous air pollutant (HAP) and volatile organic
compound (VOC) emission rates, according to maximum stack test results from stack testing
conducted at a similar Amazon facility on December 17, 2020.

- Removal of twenty (20) existing sublimation printers (Equipment ID# II.A.4 in AO DAQE-
AN159810001-19) and replace with six (6) direct-to-film (DTF) apparel printer.

Emissions from the existing twenty (20) sublimation printers were estimated to be 4.70 tpy of
VOCs and 0.86 tpy of HAPs. Replacing the sublimation printers with six (6) new direct-to-film
(DTF) printers results in 3.95 tpy of VOCs and 0.19 tpy of HAPs (a reduction of 0.75 tpy of
VOCs and 0.67 tpy of HAPs).

Additionally, the annual VOC and HAPs emissions were updated using the new stack testing
emission factors and updated production rates. The side-wide reduction in VOCs and HAPs is
5.82 tpy of 0.88 tpy, respectively. This project meets the requirements of UAC R307-401-12
Reduction in Air Pollutants and does not require a public comment period.

EMISSION IMPACT ANALYSIS
This is an administrative amendment under R307-401-12. No actual emissions are increasing at this time.
Therefore, modeling is not required. [Last updated September 4, 2024]

Engineer Review N159810003: Amazon Services, LLC. - Salt Lake Digital Printing Facility
September 23, 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 0 1659.00
Carbon Monoxide 0 1.16
Nitrogen Oxides 0 1.38
Particulate Matter - PM10 0 0.10
Particulate Matter - PM2.5 0 0.10
Sulfur Dioxide 0 0.01
Volatile Organic Compounds -5.82 10.41

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 60
Glycol Ethers (CAS #EDF109) -100 1920
Triethylene Glycol (CAS #112276) -1720 0
Change (TPY) Total (TPY)
Total HAPs -0.88 0.99

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

Engineer Review N159810003: Amazon Services, LLC. - Salt Lake Digital Printing Facility
September 23, 2024
Page 4
Review of BACT for New/Modified Emission Units

1. BACT review regarding New Six (6) Direct-To-Film (DTF) Apparel Printers
This is an administrative amendment under R307-401-12. No actual emissions are increasing at
this time. Therefore, a BACT analysis is not required. [Last updated September 4, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

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

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

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

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

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

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

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

Engineer Review N159810003: Amazon Services, LLC. - Salt Lake Digital Printing Facility
September 23, 2024
Page 5
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

II.A.1 Amazon Services, LLC.
Digital Printing Plant

II.A.2 Twenty-four (24) Digital Apparel Printers

II.A.3 Six (6) Direct-To-Film (DTF) Apparel Printers
*New*

II.A.4 Twelve (12) Ultra-Violet (UV) Non-Apparel Printers

II.A.5 Eight (8) Apparel Dryers
Fuel: Natural Gas
Capacity: 0.4 MMBtu/hr each

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 Requirements and Limitations
II.B.1.a The owner/operator shall use only natural gas as fuel in the stationary equipment on site.
[R307-401-8]

II.B.1.b The owner/operator shall not allow visible emissions on-site to exceed 10% opacity. [R307-
401-8]

II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted in accordance
with 40 CFR 60, Appendix A, Method 9. [R307-401-8]

Engineer Review N159810003: Amazon Services, LLC. - Salt Lake Digital Printing Facility
September 23, 2024
Page 6
II.B.1.c The owner/operator shall route all emissions from the 24 Digital Apparel Printers through the
Apparel Dryer burners before the emissions are vented to the atmosphere. [R307-401-8]

II.B.1.d The owner/operator shall not exceed the solvent VOC content limits established in R307-304
for any solvents. [R307-304, R307-401-8]

II.B.1.e The owner/operator shall comply with all applicable requirements of UAC R307-304 (Solvent
Cleaning) and UAC R307-325 (Ozone Nonattainment and Maintenance Areas: General
Requirements). [R307-304, R307-325, R307-401-8]

II.B.1.f
NEW
The owner/operator shall:

A. Not use any ink that contains greater than 42.80% VOCs by weight or
contains greater than 12.40% HAPs by weight for digital apparel printing
applications

B. Not use any ink that contains greater than 70% VOCs by weight or
contains greater than 5% HAPs by weight for all DTF apparel printing
applications

C. Not use any ink that contains greater than 27.6% VOCs by weight or
contains any HAPs for all UV non-apparel printing applications

D. Not use any ink or solvent that contains any HAPs except for glycol ethers.

[R307-401-8]

II.B.1.f.1 To demonstrate compliance with the above condition, the owner/operator shall maintain
records of the Safety Data Sheet (SDS) for each ink and solvent. [R307-401-8]

II.B.1.g
NEW
The owner/operator shall not emit more than the following from evaporative sources (printing,
coating, and/or cleaning) on site:

A. 10.34 tons per rolling 12-month period of VOCs

B. 0.96 tons per rolling 12-month period of ethylene glycol

[R307-401-8]

II.B.1.g.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using
data from the previous 12 months. The owner/operator shall use a mass-balance method for
each material in use to calculate emissions from evaporative sources. The owner/operator
may use the following equations with applicable units to comply with the mass-balance
method:

VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed]

HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]

[R307-401-8]

Engineer Review N159810003: Amazon Services, LLC. - Salt Lake Digital Printing Facility
September 23, 2024
Page 7
II.B.1.g.2 The owner/operator shall keep records each month of the following:

A. The name (as per SDS) of the VOC- and HAP-emitting material

B. The maximum percent by weight of VOCs and each HAP in each material used

C. The density of each material used

D. The volume of each VOC- and HAP-emitting printing operation

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

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

[R307-401-8]

Engineer Review N159810003: Amazon Services, LLC. - Salt Lake Digital Printing Facility
September 23, 2024
Page 8
PERMIT HISTORY

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

Supersedes AO DAQE-AN159810001-19 dated September 5, 2019
Incorporates NOI dated September 4, 2024

REVIEWER COMMENTS

1. Comment regarding Source Emission Estimates and UAC R307-401-12 Applicability:
Amazon re-evaluated its PTE based on updated hours of operation and production throughputs.
Emissions from the printers and printer solvent cleanup are generated through the evaporation of
VOCs and HAPs from the inks. Replacing the existing sublimation printers with new DTF printers
results in a net decrease in VOCs and total HAPs. Therefore, this project qualifies as a Reduction in
Air Pollutants under UAC R307-401-12.

The 2019 AO specified a PTE of 3.86 tpy of glycol ethers and 0.72 tpy of triethylene glycol.
Amazon has indicated that no triethylene glycol and a maximum of 0.96 tpy of glycol ethers will be
emitted as a result of the printer replacement and operational changes. Condition II.B.1.c of the 2019
AO has been updated to reflect the new values.

The 2019 AO did not include HAPs emissions from the natural gas-fired boilers. The PTE has been
updated to include the 0.03 tpy of generic HAPs emitted from the boilers. This does not represent an
increase in actual HAPs emissions as the boiler operations are not changing.

Apparel Printing
VOC emissions from the 24 digital apparel printers are based on maximum stack test results from
stack testing conducted at a similar facility (Amazon DFW5) on December 17, 2020. The VOC
emission rate is 1.41 lb/hr. HAPs emissions are based on VOC Emissions and the maximum weight
percent of HAP in the inks and are equivalent to 0.18 lb/hr. The maximum VOC and HAP weight
content of the inks used during the stack test and used at the Salt Lake City Facility in the digital
apparel printing applications are 42.80% and 12.40%, respectively.

Bases on the stack testing, a maximum of 95% of the VOC and HAPs emissions are captured and
routed to the natural gas-fired dryers to be combusted. 5% of the VOC ad HAPs emissions are
fugitive from handling.

VOC and HAPs emissions from the DTF apparel printers are based on the ink SDS sheets and
manufacturer data. The source estimated emissions from the inks using mass-balance and assumed
the highest VOC and/or HAP content associated with each ink for a conservative estimate.

Apparel Printing Solvent Cleaning
VOCs are emitted from the cleanup solvent for the 24 digital apparel printers. The consumption rate
of solvent is 1,440 gals, annually. The solvent has a density of 8.43 lb/gal and a VOC content of
2.0% by weight. The solvent contains no HAPs.

VOCs are also emitted from the cleanup solvent for the 6 new DTF apparel printers. The
consumption rate of solvent is 230 gals, annually. The solvent has a density of 8.35 lb/gal and a
VOC content of 6.0% by weight. The solvent contains no HAPs.

Engineer Review N159810003: Amazon Services, LLC. - Salt Lake Digital Printing Facility
September 23, 2024
Page 9

Non-Apparel Printing
VOC and HAPs emissions from the 12 UV printers and new DTF printers are based on the ink SDS
sheets and manufacturer data. The source estimated emissions from the inks using mass-balance and
assumed the highest VOC and/or HAP content associated with each ink for a conservative estimate.

Non-Apparel Printing Solvent Cleaning
The UV printers are cleaned using solvent. The consumption rate of solvent is 12 gals, annually. The
solvent has a density of 8.45 lb/gal and a VOC content of 100% by weight. The solvent contains no
HAPs.

8 Natural Gas-Fired Dryers
The eight (8) apparel dryers' emissions were estimated with AP-42 Section 1.4 (Natural Gas
Combustion). [Last updated September 20, 2024]

2. Comment regarding NSPS and MACT Applicability:
This plant has no applicability to 40 CFR 60 (NSPS) or 40 CFR 63 (MACT) standards.

Subparts that might apply are NSPS Subparts QQ and FFF and MACT Subparts KK and OOOO.

NSPS Subpart QQ (Standards of Performance for the Graphic Arts Industry: Publication
Rotogravure Printing) does not apply due to the printing process not taking place on a gravure
cylinder.

NSPS Subpart FFF (Standards of Performance for Flexible Vinyl and Urethane Coating and
Printing) does not apply due there being to no coating the materials with vinyl or urethane.

MACT Subpart KK (National Emission Standards for the Printing and Publishing Industry) do not
apply as this is a minor source of HAP emissions and also that there isn't any rotogravure or
flexographic processes taking place.

MACT Subpart OOOO (National Emission Standards for Hazardous Air Pollutants: Printing,
Coating, and Dyeing of Fabrics and Other Textiles) does not apply as the operation does not coat t-
shirts or apparel with elastomers, polymers, or prepolymer materials. [Last updated September 4,
2024]

3. Comment regarding Title V Applicability:
Title V of the 1990 Clean Air Act (Title V) applies to the following:

1. Any major source
2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act,
Standards of Performance for New Stationary Sources;
3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants.
4. Any Title IV affected source.

This facility is not a major source and is not a Title IV source. The facility is not subject to 40 CFR
60 (NSPS), 40 CFR 61 (NESHAP), or 40 CFR 63 (MACT) regulations. 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 September 4, 2024]

Engineer Review N159810003: Amazon Services, LLC. - Salt Lake Digital Printing Facility
September 23, 2024
Page 10
4. Comment regarding Utah Administrative Code Rules:
UAC R307-351 (Graphic Arts)
Condition II.B.1.b of the 2019 AO states that "The owner/operator shall not exceed the VOC content
limits established by R307-351 for any inks".

In a 2020 Full Compliance Evaluation of the site (See memorandum DAQC-1470-20) indicated that
R307-351 did not apply to the source and that condition II.B.1.b. should be removed.

UAC R307-351 (Graphic Arts) applies to graphic arts printing operations located in Box Elder,
Cache, Davis, Salt Lake, Utah, Tooele and Weber counties. Per R307-351-4, "graphic arts printing"
means the application of words and images using the offset lithographic, letterpress, rotogravure, or
flexographic printing process. Digital printing is not included in the definition of graphic arts
printing in this rule. Therefore, UAC R307-351 does not apply to the source and condition II.B.1.b
has been removed.

UAC R307-304 (Solvents Cleaning)
R307-304 applies to solvent cleaning operations within Box Elder, Cache, Davis, Salt Lake, Tooele,
Utah or Weber counties to an owner or operator using 55 gallons or more a year of VOC containing
solvent products, minus exempt materials, for solvent cleaning operations. Per the NOI application,
Amazon will use up to 1,440 gallons annually of solvent for the digital apparel printing operations,
12 gallons annually for the cellphone ring stand operations, and 230 gallons annually for the DTF
apparel printing operations.

R307-304-5 establishes VOC content limits for solvent production. Amazon shall be subject to these
limits.

UAC R307-325 (Environmental Quality, Air Quality (R307-325)
R307-325 applies to all sources located in any nonattainment or maintenance area for ozone. The
source is located in an ozone nonattainment area. This rule applies to the source. [Last updated
September 4, 2024]

Engineer Review N159810003: Amazon Services, LLC. - Salt Lake Digital Printing Facility
September 23, 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

Apparel Printing UV Printer - Cell Phone Stands
VOCs 1.412 lb/hr Max production 135 units/hr
HAPs 0.1751 lb/hr Product Density 1.18 g/cm3
Print volume 0.02 cm3/unit
App rate 0.025 g/unit
fugitive 5 %Emission Rate 0.006 g/unit
collected-NG drye 95 %Max VOC content 27.6 %
Max HAP content 0 %
Total
VOC 6.18456 tpy
HAPs 0.766938 tpy
Printers 12 No.
Total Fugitive Print Production rate 135 unit/hr
VOC 0.31 tpy Site hourly 1620 unit/hr
HAPs 0.04 tpy EF 0.006 g/unit
EF 9.72 g/hr
Total Collected to NG Dryers EF 0.021384 lb/hr
VOC 5.88 tpy
HAPs 0.73 tpy VOCs 0.026 tpy
HAPs 0.000 tpy
Glycol Ethers 0.038
Triethylene Glycol 0
Natural Gas-Fired Boilers & Heaters
Equipment Details
Rating 3.2 MMBtu/hour
Operational Hours 8760 hours/year
NOX 1.37 tpy
CO 1.15 tpy
PM10 0.10 tpy
PM2.5 0.10 tpy
SO2 0.01 tpy
VOC 0.08 tpy
Lead 0.00 tpy
HAP 0.03 tpy
Sublimation Printer App Data DTF Apparel App
Product Density 1.1 g/cm3 Product Density 1.1 g/ml
Print volume 0.57 cm3/unit App rate 2.15 ml/unit
App rate 0.62 g/unit App rate 2.37 g/unit
Max VOC content 27.2 %Max VOC content 46 %
Max HAP content 5 %Max HAP content 5 %
Printers 20 No.Printers 6 No.
Print Production rate 144 unit/hr Print Production rate 60 unit/hr
Site hourly 2880 unit/hr Site hourly 360 unit/hr
EF 0.62 g/unit EF 1.54 g/unit
EF 1785.6 g/hr EF 554.4 g/hr
EF 3.92832 lb/hr EF 1.21968 lb/hr
VOCs 4.680 tpy VOCs 3.900 tpy
HAPs 0.860 tpy HAPs 0.267 tpy
Glycol Ethe 0.267
Triethylene 0
**all values are within tolerance to NOI
differences due to NOI being more accurate
Pollutant Current AO New PTE Difference NOI e
NOX 1.38 1.37 -0.01 1.37 -0.01
CO 1.16 1.15 -0.01 1.15 -0.01
PM10 0.10 0.10 0.00 0.1 0.00
PM2.5 0.10 0.10 0.00 0.1 0.00
VOC 35.66 10.40 -25.26 10.41 -25.25
SO2 0.01 0.01 0.00 0.01 0.00
HAP 4.58 1.02 -3.56 0.96 -3.62
Glycol Ethers 3.86 0.96 -2.9
Triethylene Glyco 0.72 0 -0.72
Total HAPs 4.58 0.96

Pollutant

Printing

Printing Change
Per New Calcs
VOC 4.697 3.9527 -0.7443
HAP 0.860 0.1916 -0.669
Apparel Solvent Cleaning
consumption rate 3.95 gal/day
consumption rate 1441.75 gal/yr
Product Density 8.43 lb/gal
consumption rate 33.2985 lb/day
consumption rate 12153.95 lb/yr
Max VOC content 2 %
Max HAP content 0 %
Total Fugitive
VOC 0.12 tpy
HAPs 0.00 tpy
Cell Phone Solvent Cleaning
consumption rate 1 gal/day
consumption rate 365 gal/yr
Product Density 8.43 lb/gal
consumption rate 8.43 lb/day
consumption rate 3076.95 lb/yr
Max VOC content 2 %
Max HAP content 0 %
Total Fugitive
VOC 0.03 tpy
HAPs 0.00 tpy
DTF Apparent Printing Cleanup
consumption rate 0.63 gal/day
consumption rate 230 gal/yr
Product Density 8.35 lb/gal
consumption rate 5.2605 lb/day
consumption rate 1920.083 lb/yr
Max VOC content 6 %
Max HAP content 0 %
Total Fugitive
VOC 0.06 tpy
HAPs 0.00 tpy
Page 1 of 1
Company___________________________
6LWH_____________________________
Form 
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
Amazon.com Services, LLC
Salt Lake City
0.10 0.00 0.10
0.10 0.00 0.10
0.10 0.00 0.10
1.38 0.00 1.37
0.01 0.00 0.01
1.16 0.00 1.15
35.66 0.00 10.41
4.46
0.00
0.03
0.00
0.00
0.00
0.00
1.67
Ethylene Glycol 3.86 0.00 0.96 0.00
Triethylene Glycol Monomethyl Ether 0.72 0.00 0.00 0.00
4.58 0.00 0.96 0.00
Amazon.com Services, LLC - Salt Lake City Facility
Emissions Summary
Hours of Operation (hr/day)24
Hours of Operation - Printers (hr/yr)8,760
Hours of Operation - Dryers (hr/yr)8,760
No. of Apparel Printers 24
Production per Apparel Printer (units/hr)60
Total Hourly Apparel Printer Production (units/hr)1,440
Total Apparel Printer Production (units/yr)12,614,400
No. of Dryers 8
Dryer Collection Efficiency (%) - Apparel Printing Operations 95%
Dryer Collection Efficiency (%) - Apparel Cleanup Operations 0%
Dryer Collection Efficiency (%) - Other Printing and Cleanup Operations 0%
Control Efficiency (%)0%
No. of UV Printers 12
Production per UV Printer (units/hr)135
Total Hourly UV Printer Production (units/hr)1,620
Total UV Printer Production (units/yr)14,191,200
No. of DTF Apparel Printers 6
Production per DTF Apparel Printer (units/hr)60
Total Hourly DTF Apparel Printer Production (units/hr)360
Total DTF Apparel Printer Production (units/yr)2,450,000
lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy
Building Fugitive Emissions - Apparel Printing (95% Collection Efficiency)0.0706 0.3092 0.0088 0.0383 ----0.0088 0.0383 ------------------------------------
Building Fugitive Emissions - Cell Phone Ring Stand Printing 0.0062 0.0270 ------------------------------------------------
Building Fugitive Emissions - DTF Apparel Printing 1.7419 3.8951 0.0939 0.1916 ----0.0939 0.1916 ------------------------------------
Building Fugitive Emissions - Apparel Printing Cleanup 0.6681 0.1219 ------------------------------------------------
Building Fugitive Emissions - Cell Phone Ring Stand Printing Cleanup 8.4455 0.0507 ------------------------------------------------
Building Fugitive Emissions - DTF Apparel Printing Cleanup 0.3155 0.0576 ------------------------------------------------
Building Fugitives Sum 11.2478 4.4615 0.1026 0.2300 ----0.1026 0.2300 ------------------------------------
Dryer Stack Emissions - Dryer Combustion 0.0173 0.0756 ------------0.3137 1.3741 0.2635 1.1543 0.0019 0.0082 0.0238 0.1044 0.0238 0.1044 0.0238 0.1044 0.0004 0.0016 0.0071 0.0309 0.0007 0.0031
Dryer Stack Emissions - Apparel Printing (95% Collection Efficiency)1.3414 5.8753 0.1663 0.7285 ----0.1663 0.7285 ------------------------------------
Dryer Stack Emissions Sum 1.3587 5.9509 0.1663 0.7285 ----0.1663 0.7285 0.3137 1.3741 0.2635 1.1543 0.0019 0.0082 0.0238 0.1044 0.0238 0.1044 0.0238 0.1044 0.0004 0.0016 0.0071 0.0309 0.0007 0.0031
12.61 10.41 0.27 0.96 0.00 0.00 0.27 0.96 0.31 1.37 0.26 1.15 0.002 0.01 0.02 0.10 0.02 0.10 0.02 0.10 0.0004 0.002 0.01 0.03 0.001 0.003
18.93 35.66 1.64 3.86 0.20 0.72 1.84 4.58 0.37 1.38 0.31 1.16 0.002 0.01 0.03 0.10 0.03 0.10 0.03 0.10 --0.003 --0.34 --0.05
-6.33 -25.25 -1.37 -2.90 -0.20 -0.72 -1.57 -3.62 -0.05 -3.18E-03 -0.04 -2.67E-03 -3.14E-04 -1.91E-05 -3.97E-03 -2.42E-04 -3.97E-03 -2.42E-04 -3.97E-03 -2.42E-04 ---1.36E-03 ---0.31 ---0.05
--100 --10 --10 --25 --100 --100 --100 --100 --100 --100 ------------
Notes:
*Proposed Emissions (lb/hr) & (tpy) = Sum all Activity - Building Fugitives Sum - Dryer Stack Emissions Sum
**Currently Permitted Emissions (lb/hr) & (tpy) include emissions from 20 Sublimation Printers that were never installed or operated at the facility. These printers are being replaced with the DTF Apparel Printers.
CO2 CH4 N2OPM2.5ActivityVOCTotal HAP NOX COEmissions
Release Point
SO2 PM PM10Ethylene Glycol Triethylene Glycol
Monomethyl Ether
Major Source/Title V Thresholds
Building
Fugitives
Dryer Stacks
Proposed Emissions*
Currently Permitted Emissions**
Change in Permitted Emissions
Amazon.com Services, LLC - Salt Lake City Facility
Emissions Summary
August 2024
Page 1 of 13
Amazon.com Services, LLC - Salt Lake City Facility
Consumption Estimates
Apparel Printing Emissions Data
Kornit Ink/Fixation VOC Emissions
(lb/hr)
HAP Emissions
(lb/hr)
Kornit EcoRapid Ink/Fixation 1.4120 0.1751
VOC Emissions are based on maximum stack test results from stack testing conducted at a similar facility (Amazon DFW5) on December 17, 2020.
HAP Emissions are based on VOC Emissions and the maximum weight percent of HAP in the inks.
PM emissions are not expected from these printing operations; therefore, the solids content of the inks is not evaluated.
A safety factor of 100% is applied to the hourly rates for conservatism.
UV Printer Application Data
Mimaki Ink Color Product Density
(g/ml) or (g/cm3)
Maximum
Production
(units/hr)
Print Volume
(cm3/unit)
Application
Rate*
(g/unit)
Emission
Rate**
(g/unit)
RTI Method
24 VOC
Content
HAP Content RTI Method
24 Sample ID
Cyan 1.09 22.50%0.00%S-32
Magenta 1.09 25.60%0.00%S-33
Yellow 1.09 27.60%0.00%S-35
Black 1.09 23.80%0.00%S-31
White 1.18 18.10%0.00%S-34
* A jig can hold up to 27 individual cell phone ring stand units. Each cell phone ring stand unit consumes 0.025 g of ink.
PM emissions are not expected from these printing operations; therefore, the solids content of the inks is not evaluated.
Max VOC and HAP content used for hourly and annual estimates.
DTF Apparel Printer Application Data
Consumable Product Density
(g/ml)
Application Rate*
(ml/unit)
Application Rate
(g/unit)
Max VOC
Content
Average VOC
Content
Max HAP
Content
Average HAP
Content
CMYK Ink 1.07 1.44 1.54 35.00%23.00%0.00%0.00%
White Ink 1.10 2.15 2.37 70.00%46.00%5.00%3.00%
Cleaning Solution 1.00 0.55 0.55 6.00%6.00%0.00%0.00%
* Based on R&D testing.
PM emissions are not expected from these printing operations; therefore, the solids content of the inks is not evaluated.
Except for the cleaning solution, max VOC/HAP content is used to estimate hourly emissions and average VOC/HAP content is used to estimate annual
emissions.
0.025135.00 0.02 0.006
** Per U.S. EPA Technical Bulletin: Ultraviolet and Electron Beam Cured Coatings, Inks, and Adhesives , virtually all components of a UV formulation become a solid part of a
cured coating, ink, or adhesive. Generally, only small amounts of VOC may be emitted. Therefore, it is conservatively assumed that 25% of the ink application rate is emitted to
the environment.
Amazon.com Services, LLC - Salt Lake City Facility
Consumption Estimates
August 2024
Page 2 of 13
Amazon.com Services, LLC - Salt Lake City Facility
Apparel Printing Emissions Calculations - 95% Collection
Hourly Emissions Products
Parameter Units of measurement Ink/Fixation
Uncollected
Uncontrolled
Hourly Emissions
(lb/hr)
Collection
Efficiency %
Collected
Uncontrolled
Hourly Emissions
(lb/hr)
Control Efficiency
%
Building Fugitive
Emissions
(lb/hr)
Collected Stack
Hourly Emissions
(lb/hr)
Total Building
Fugitive and
Collected Stack
Hourly Emissions
(lb/hr)
VOC hourly emissions lb/hr 1.4120 1.4120 95.00%1.3414 0.00%0.0706 1.3414 1.4120
HAP hourly emissions lb/hr 0.1751 0.1751 95.00%0.1663 0.00%0.0088 0.1663 0.1751
Annual Emissions Products
Parameter Units of measurement Ink/Fixation
Uncollected
Uncontrolled
Annual Emissions
(tpy)
Collection
Efficiency %
Collected
Uncontrolled
Annual Emissions
(tpy)
Control Efficiency
%
Building Fugitive
Emissions
(tpy)
Collected Stack
Annual Emissions
(tpy)
Total Building
Fugitive and
Collected Stack
Annual Emissions
(tpy)
operating schedule hr/yr 8,760
VOC annual emissions tpy 6.1846 6.1846 95.00%5.8753 0.00%0.3092 5.8753 6.1846
HAP annual emissions tpy 0.7669 0.7669 95.00%0.7285 0.00%0.0383 0.7285 0.7669
Cleanup Solvent (assumes all building fugitives as cleanup is at the printer)
Parameter Units of measurement Wiping Fluid
Uncollected
Uncontrolled
Emissions
(lb/hr)
Uncollected
Uncontrolled
Emissions
(tpy)
Building Fugitives
Emissions
(lb/hr)
Building Fugitives
Emissions
(tpy)
Stack Emissions
(lb/hr)
Stack Emissions
(tpy)
consumption rate per hour* gal/hr 3.95
consumption rate per day gal/day 3.95
consumption rate per year gal/yr 1,440
product density g/ml 1.01
product density lb/gal 8.43
consumption rate per hour lb/hr 33.25
consumption rate per day lb/day 33.25
consumption rate per year lb/yr 12,137.55
Estimated Collection Efficiency % 0.00%
Control Efficiency % 0.00%
%VOC from formulation [VOC emissions] % 2.0%0.6681 0.1219 0.6681 0.1219 ----
%HAP from formulation [HAP emissions] % 0.00%------------
*consumption rate per hour assumes that all daily usage can be utilized in one hour (worst case)
Amazon.com Services, LLC - Salt Lake City Facility
Apparel Printing Emissions Calculations - 95% Collection
August 2024
Page 3 of 13
Amazon.com Services, LLC - Salt Lake City Facility
Apparel Printing Emissions Calculations - 95% Collection
Printing Notes:
Hourly Emissions
VOC hourly emissions (lb/hr) = maximum stack test results from stack testing conducted on December 17, 2020
VOC hourly emissions: Uncollected Uncontrolled Hourly Emissions (lb/hr) = VOC hourly emissions (lb/hr)
VOC hourly emissions: Collected Uncontrolled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency %
VOC hourly emissions: Building Fugitive Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * (1 – Collection Efficiency %)
VOC hourly emissions: Collected Stack Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency % * (1 - Control Efficiency %)
VOC hourly emissions: Total Building Fugitive and Collected Stack Hourly Emissions (lb/hr) = Building Fugitive Emissions (lb/hr) + Collected Stack Hourly Emissions (lb/hr)
HAP hourly emissions (lb/hr) = VOC hourly emissions (lb/hr) * Maximum HAP Weight Percent of All Inks (%)
HAP hourly emissions: Uncollected Uncontrolled Hourly Emissions (lb/hr) = HAP hourly emissions (lb/hr)
HAP hourly emissions: Collected Uncontrolled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency %
HAP hourly emissions: Building Fugitive Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * (1 – Collection Efficiency %)
HAP hourly emissions: Collected Stack Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency % * (1 - Control Efficiency %)
HAP hourly emissions: Total Building Fugitive and Collected Stack Hourly Emissions (lb/hr) = Building Fugitive Emissions (lb/hr) + Collected Stack Hourly Emissions (lb/hr)
Annual Emissions
VOC annual emissions (tpy) = VOC hourly emissions (lb/hr) * 8,760 (hr/yr) / 2,000 (lb/ton)
VOC annual emissions (tpy): Uncollected Uncontrolled Annual Emissions (tpy) = Sum of VOC annual emissions (tpy)
VOC annual emissions (tpy): Collected Uncontrolled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency %
VOC annual emissions (tpy): Building Fugitive Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * (1 – Collection Efficiency %)
VOC annual emissions (tpy): collected stack Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency % * (1 - Control Efficiency %)
VOC annual emissions (tpy): Total Building Fugitive and Collected Stack Annual Emissions (tpy) = Building Fugitive Emissions (tpy) + Collected Stack Annual Emissions (tpy)
HAP annual emissions (tpy) = HAP hourly emissions (lb/hr) * 8,760 (hr/yr) / 2,000 (lb/ton)
HAP annual emissions (tpy): Uncollected Uncontrolled Annual Emissions (tpy) = Sum of HAP annual emissions (tpy)
HAP annual emissions (tpy): Collected Uncontrolled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency %
HAP annual emissions (tpy): Building Fugitive/Roof Stack Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * (1 – Collection Efficiency %)
HAP annual emissions (tpy): Collected Stack Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency % * (1 - Control Efficiency %)
HAP annual emissions (tpy): Total Building Fugitive and Collected Stack Annual Emissions (tpy) = Building Fugitive Emissions (tpy) + Collected Stack Annual Emissions (tpy)
Cleanup Solvent Notes:
Hourly Emissions
consumption rate per hour (gal/hr) = consumption rate per day (gal/day) [assumes that all daily usage can be utilized in one hour (worst case)]
consumption rate per day (gal/day) = consumption rate per year (gal/yr) / 365 (day/yr)
consumption rate per year (gal/yr) = conservative estimate
product density (g/ml) = per product SDS
product density (lb/gal) = product density (g/ml) * 8.3454
consumption rate per hour (lb/hr) = consumption rate (gal/hr) * product density (lb/gal)
consumption rate per day (lb/day) = consumption rate (gal/day) * product density (lb/gal)
consumption rate per year (lb/yr) = consumption rate (gal/yr) * product density (lb/gal)
VOC hourly emissions: Uncollected Uncontrolled Emissions (lb/hr) = consumption rate per hour (lb/hr) * %VOC from formulation
VOC hourly emissions: Building Fugitives (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * (1 - Collection Efficiency %)
VOC hourly emissions: Stack Emissions (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * Collection Efficiency % * (1 - Control Efficiency %)
HAP hourly emissions: Uncollected Uncontrolled Emissions (lb/hr) = consumption rate per hour (lb/hr) * %HAP from formulation
HAP hourly emissions: Building Fugitives (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * (1 - Collection Efficiency %)
HAP hourly emissions: Stack Emissions (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * Collection Efficiency % * (1 - Control Efficiency %)
Annual Emissions
consumption rate per year (lb/yr) = consumption rate per year (gal/yr) * product density (lb/gal)
VOC annual emissions: Uncollected Uncontrolled Emissions (tpy) = consumption rate per year (lb/yr) * %VOC from formulation / 2000 (lb/ton)
VOC annual emissions: Building Fugitives (tpy) = Uncollected Uncontrolled Emissions (tpy) * (1 - Collection Efficiency %)
VOC annual emissions: Stack Emissions (tpy) = Uncollected Uncontrolled Emissions (tpy) * Collection Efficiency % * (1 - Control Efficiency %)
HAP annual emissions: Uncollected Uncontrolled Emissions (tpy) = consumption rate per hour (tpy) * %HAP from formulation
HAP annual emissions: Building Fugitives (tpy) = Uncollected Uncontrolled Emissions (tpy) * (1 - Collection Efficiency %)
HAP annual emissions: Stack Emissions (tpy) = Uncollected Uncontrolled Emissions (tpy) * Collection Efficiency % * (1 - Control Efficiency %)
Amazon.com Services, LLC - Salt Lake City Facility
Apparel Printing Emissions Calculations - 95% Collection
August 2024
Page 4 of 13
Amazon.com Services, LLC - Salt Lake City Facility
Cell Phone Ring Stand Emissions Calculations
Hourly Emissions Products
Parameter Units of measurement Ink
Uncollected
Uncontrolled
Hourly Emissions
(lb/hr)
Collection
Efficiency %
Collected
Uncontrolled
Hourly Emissions
(lb/hr)
Control Efficiency
%
Building Fugitive
Emissions
(lb/hr)
Collected
Controlled Hourly
Emissions
(lb/hr)
Total Building
Fugitive and
Collected
Controlled Hourly
Emissions
(lb/hr)
operating printers printer 12
single printer production rate unit/hr per printer 135
site hourly production rate unit/hr 1620
emission rate per unit g/unit 0.006
emission rate per hour g/hr 10.13
emission rate per hour lb/hr 0.0223
Max %VOC from formulation %27.60%
VOC hourly emissions lb/hr 0.0062 0.0062 0.00%--0.00%0.0062 --0.0062
%HAP from formulation %0.00%
HAP hourly emissions lb/hr 0.0000 --0.00%--0.00%------
Annual Emissions Products
Parameter Units of measurement Ink
Uncollected
Uncontrolled
Annual Emissions
(tpy)
Collection
Efficiency %
Collected
Uncontrolled
Annual Emissions
(tpy)
Control Efficiency
%
Building Fugitive
Emissions
(tpy)
Collected
Controlled Annual
Emissions
(tpy)
Total Building
Fugitive and
Collected
Controlled Annual
Emissions
(tpy)
operating schedule day/yr 365
operating schedule hr/day 24
operating schedule hr/yr 8,760
production rate unit/yr 14,191,200
annual emission rate g/yr 88,695.0000
annual emission rate lb/yr 195.5388
total consumption tpy 0.0978
Collection Efficiency % 0.00%
Control Efficiency % 0.00%
Max %VOC from formulation %27.60%
VOC annual emissions tpy 0.0270 0.0270 0.00%--0.00%0.0270 --0.0270
Max %HAP from formulation %0.00%
HAP annual emissions tpy 0.0000 --0.00%--0.00%------
Amazon.com Services, LLC - Salt Lake City Facility
Cell Phone Ring Stand Emissions Calculations
August 2024
Page 5 of 13
Amazon.com Services, LLC - Salt Lake City Facility
Cell Phone Ring Stand Emissions Calculations
Cleanup Solvent (assumes all building fugitives as cleanup is at the printer)
Parameter Units of measurement Washing Fluid
Uncollected
Uncontrolled
Emissions
(lb/hr)
Uncollected
Uncontrolled
Emissions
(tpy)
Building Fugitives
Emissions
(lb/hr)
Building Fugitives
Emissions
(tpy)
Stack Emissions
(lb/hr)
Stack Emissions
(tpy)
consumption rate per hour* gal/hr 1.00
consumption rate per day gal/day 1.00
average monthly consumption rate gal/month 1.00
consumption rate per year gal/yr 12.00
product density g/ml 1.01
product density lb/gal 8.45
consumption rate per hour lb/hr 8.45
consumption rate per day lb/day 8.45
average monthly consumption rate lb/month 8.45
consumption rate per year lb/yr 101.35
Collection Efficiency % 0.00%
Control Efficiency % 0.00%
%VOC from formulation [VOC emissions] % 100.00%8.4455 0.0507 8.4455 0.0507 ----
%HAP from formulation [HAP emissions] % 0.00%------------
*consumption rate per hour assumes that all daily usage can be utilized in one hour (worst case)
Amazon.com Services, LLC - Salt Lake City Facility
Cell Phone Ring Stand Emissions Calculations
August 2024
Page 6 of 13
Amazon.com Services, LLC - Salt Lake City Facility
Cell Phone Ring Stand Emissions Calculations
Printing Notes:
Hourly Emissions
operating printers (printer) = number of printers installed
single printer production rate (unit/hr per printer) = number of units that can be printed per hour per printer
site hourly production rate (unit/hr) = operating printers (# printers) * single printer production rate (unit/hr per printer)
emission rate per hour (g/hr) = production rate (unit/hr) * emission rate per unit (g/unit) [refer to Consumption Estimates]
emission rate per hour (lb/hr) = emission rate (g/hr) * 0.00220462 (lb/g)
VOC hourly emissions (lb/hr) = emission rate per hour (lb/hr) * Max %VOC from formulation
VOC hourly emissions: Uncollected Uncontrolled Hourly Emissions (lb/hr) = VOC hourly emissions (lb/hr)
VOC hourly emissions: Collected Uncontrolled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency %
VOC hourly emissions: Building Fugitive Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * (1 – Collection Efficiency %)
VOC hourly emissions: Collected Controlled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency % * (1 - Control Efficiency %)
VOC hourly emissions: Total Building Fugitive and Collected Controlled Hourly Emissions (lb/hr) = Building Fugitive Emissions (lb/hr) + Collected Controlled Hourly Emissions (lb/hr)
HAP hourly emissions (lb/hr) = emission rate per hour (lb/hr) * %HAP from formulation
HAP hourly emissions: Uncollected Uncontrolled Hourly Emissions (lb/hr) = HAP hourly emissions (lb/hr)
HAP hourly emissions: Collected Uncontrolled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency %
HAP hourly emissions: Building Fugitive Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * (1 – Collection Efficiency %)
HAP hourly emissions: Collected Controlled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency % * (1 - Control Efficiency %)
HAP hourly emissions: Total Building Fugitive and Collected Controlled Hourly Emissions (lb/hr) = Building Fugitive Emissions (lb/hr) + Collected Controlled Hourly Emissions (lb/hr)
Annual Emissions
operating schedule (hr/yr) = operating schedule (day/yr) * operating schedule (hr/day)
production rate (unit/yr) = production rate (unit/hr) * operating schedule (hr/yr)
annual emission rate (g/yr) = emission rate per hour (g/hr) * operating schedule (hr/yr)
annual emission rate (lb/yr) = annual emission rate (g/yr) * 0.00220462 (lb/g)
total emission (tpy) = annual emission rate (lb/yr) / 2,000 (lb/ton)
VOC annual emissions (tpy) = total emission (tpy) * Max %VOC from formulation
VOC annual emissions (tpy): Uncollected Uncontrolled Annual Emissions (tpy) = VOC annual emissions (tpy)
VOC annual emissions (tpy): Collected Uncontrolled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency %
VOC annual emissions (tpy): Building Fugitive Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * (1 – Collection Efficiency %)
VOC annual emissions (tpy): Collected Controlled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency % (1 - Control Efficiency %)
VOC annual emissions (tpy): Total Building Fugitive and Collected Controlled Annual Emissions (tpy) = Building Fugitive Emissions (tpy) + Collected Controlled Annual Emissions (tpy)
HAP annual emissions (tpy) = total consumption (tpy) * Max %HAP from formulation
HAP annual emissions (tpy): Uncollected Uncontrolled Annual Emissions (tpy) = HAP annual emissions (tpy)
HAP annual emissions (tpy): Collected Uncontrolled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency %
HAP annual emissions (tpy): Building Fugitive Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * (1 – Collection Efficiency %)
HAP annual emissions (tpy): Collected Controlled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency % * (1 - Control Efficiency %)
HAP annual emissions (tpy): Total Building Fugitive and Collected Controlled Annual Emissions (tpy) = Building Fugitive Emissions (tpy) + Collected Controlled Annual Emissions (tpy)
Cleanup Solvent Notes:
Hourly Emissions
consumption rate per hour (gal/hr) = consumption rate per day (gal/day) [assumes that all daily usage can be utilized in one hour (worst case)]
consumption rate per day (gal/day) = consumption rate per month (gal/month) [assumes that all monthly usage can be utilized in one day (worst case)]
average monthly consumption rate (gal/month) = consumption rate per year (gal/yr) / 12 (month/yr)
consumption rate per year (gal/yr) = conservative estimate
product density (g/ml) = per product SDS
product density (lb/gal) = product density (g/ml) * 8.3454
consumption rate per hour (lb/hr) = consumption rate (gal/hr) * product density (lb/gal)
consumption rate per day (lb/day) = consumption rate (gal/day) * product density (lb/gal)
average monthly consumption rate (lb/month) = average monthly consumption rate (gal/month) * product density (lb/gal)
VOC hourly emissions: Uncollected Uncontrolled Emissions (lb/hr) = consumption rate per hour (lb/hr) * %VOC from formulation
VOC hourly emissions: Building Fugitives (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * (1 - Collection Efficiency %)
VOC hourly emissions: Stack Emissions (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * Collection Efficiency * (1 - Control Efficiency %)
HAP hourly emissions: Uncollected Uncontrolled Emissions (lb/hr) = consumption rate per hour (lb/hr) * %HAP from formulation
HAP hourly emissions: Building Fugitives (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * (1 - Collection Efficiency %)
HAP hourly emissions: Stack Emissions (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * Collection Efficiency * (1 - Control Efficiency %)
Annual Emissions
consumption rate per year (lb/yr) = consumption rate per year (gal/yr) * product density (lb/gal)
VOC annual emissions: Uncollected Uncontrolled Emissions (tpy) = consumption rate per year (lb/yr) * %VOC from formulation / 2000 (lb/ton)
VOC annual emissions: Building Fugitives (tpy) = Uncollected Uncontrolled Emissions (tpy) * (1 - Collection Efficiency %)
VOC annual emissions: Stack Emissions (tpy) = Uncollected Uncontrolled Emissions (tpy) * Collection Efficiency * (1 - Control Efficiency %)
HAP annual emissions: Uncollected Uncontrolled Emissions (tpy) = consumption rate per hour (tpy) * %HAP from formulation
HAP annual emissions: Building Fugitives (tpy) = Uncollected Uncontrolled Emissions (tpy) * (1 - Collection Efficiency %)
HAP annual emissions: Stack Emissions (tpy) = Uncollected Uncontrolled Emissions (tpy) * Collection Efficiency * (1 - Control Efficiency %)
Amazon.com Services, LLC - Salt Lake City Facility
Cell Phone Ring Stand Emissions Calculations
August 2024
Page 7 of 13
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
Hourly Emissions
Parameter Units of measurement Ink (Cyan, Magenta,
Yellow, Black)White Ink
Uncollected
Uncontrolled
Hourly Emissions
(lb/hr)
Collection
Efficiency (%)
Collected
Uncontrolled
Hourly Emissions
(lb/hr)
Control Efficiency
(%)
Building Fugitive
Emissions
(lb/hr)
Collected
Controlled Hourly
Emissions
(lb/hr)
Total Building
Fugitive and
Collected
Controlled Hourly
Emissions
(lb/hr)
operating printers printer 6 6
printer production rate unit/hr*printer 60 60
production rate unit/hr 360 360
consumption rate per unit* gr/unit 1.54 2.37
consumption rate per hour gr/hr 554.69 851.40
consumption rate per hour lb/hr 1.2229 1.8770
Max %VOC from formulation %35.00%70.00%
VOC hourly emissions lb/hr 0.4280 1.3139 1.7419 ------1.7419 --1.7419
Max %HAP from formulation %--5.00%
HAP hourly emissions lb/hr --0.0939 0.0939 ------0.0939 --0.0939
*hightest %VOC or %HAP in any single product
Products
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
August 2024
Page 8 of 13
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
Annual Emissions
Parameter Units of measurement Ink (Cyan, Magenta,
Yellow, Black)White Ink
Uncollected
Uncontrolled
Annual Emissions
(tpy)
Collection
Efficiency (%)
Collected
Uncontrolled
Annual Emissions
(tpy)
Control Efficiency
(%)
Building Fugitive
Emissions
(tpy)
Collected
Controlled Annual
Emissions
(tpy)
Total Building
Fugitive and
Collected
Controlled Annual
Emissions
(tpy)
operating printers printer 6 6
printer production rate unit/hr*printer 60 60
consumption rate per unit gr/unit 1.54 2.37
production rate unit/yr 2,450,000 2,450,000
annual consumption rate gr/yr 3,774,960 5,794,250
annual consumption rate lb/yr 8322.35 12774.12
average monthly consumption rate lb/mo 693.53 1,064.51
total consumption ton/year 4.161 6.387
Collection Efficiency %%----
Control Efficiency %%----
Average %VOC from formulation %23.00%46.00%
VOC annual emissions ton/year 0.9571 2.9380 3.8951 ------3.8951 --3.8951
VOC annual emissions (building fugitives)ton/year 0.9571 2.9380
VOC annual emissions (collected controlled)ton/year ----
VOC annual emissions (fug + controlled)ton/year 0.9571 2.9380
Average %HAP from formulation %--3.00%
HAP annual emissions ton/year --0.1916 0.1916 ------0.1916 --0.1916
HAP annual emissions (building fugitives)ton/year --0.1916
HAP annual emissions (collected controlled)ton/year ----
HAP annual emissions (fug + controlled)ton/year --0.1916
Average %PM from formulation %----
Products
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
August 2024
Page 9 of 13
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
Cleanup Solvent (assumes all building fugitives as cleanup is at the printer)
Parameter Units of measurement Cleaning Solution
Uncollected
Uncontrolled
Emissions
(lb/hr)
Uncollected
Uncontrolled
Emissions
(ton/mo)
Uncollected
Uncontrolled
Emissions
(tpy)
Building Fugitives
Emissions
(lb/hr)
Building Fugitives
Emissions
(ton/mo)
Building Fugitives
Emissions
(tpy)
Stack Emissions
(lb/hr)
Stack Emissions
(ton/mo)
Stack Emissions
(tpy)
consumption rate per hour* gal/hr 0.63
consumption rate per day gal/day 0.63
average monthly consumption rate gal/mo 19.17
consumption rate per year gal/yr 230.00
product density g/ml 1.00
product density lb/gal 8.35
consumption rate per hour lb/hr 5.26
consumption rate per day lb/day 5.26
average monthly consumption rate lb/mo 159.95
consumption rate per year lb/yr 1,919.44
Estimated Collection Efficiency % 0.00%
Control Efficiency % 0.00%
%VOC from formulation [VOC emissions] % 6.00%0.3155 0.0048 0.0576 0.3155 0.0048 0.0576 0.0000 0.0000 0.0000
%HAP from formulation [HAP emissions] % 0.00%0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
*consumption rate per hour assumes that all daily usage can be utilized in one hour (worst case)
Printing Notes:
Hourly Emissions
operating printers (printer) = maximum number of printers to be installed
printer production rate (unit/hr*printer) = maximum number of units that can be printed per hour per printer
production rate (unit/hr) = operating printers (printer) * printer production rate (unit/hr*printer)
consumption rate per hour (gr/hr) = production rate (unit/hr) * consumption rate per unit (gr/unit) [refer to Consumption Estimates]
consumption rate per hour (lb/hr) = consumption rate (gr/hr) * 0.00220462 (lb/gr)
VOC hourly emissions (lb/hr) = consumption rate per hour (lb/hr) * Max %VOC from formulation
VOC hourly emissions: Uncollected Uncontrolled Hourly Emissions (lb/hr) = Sum of VOC hourly emissions (lb/hr) [total ink and concentrate fixation]
VOC hourly emissions: Collected Uncontrolled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Estimated Collection Efficiency %
VOC hourly emissions: Building Fugitive Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * (1 – Estimated Collection Efficiency %)
VOC hourly emissions: Collected Controlled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Estimated Collection Efficiency % * (1 - Control Efficiency %)
VOC hourly emissions: Total Building Fugitive and Collected Controlled Hourly Emissions (lb/hr) = Building Fugitive Emissions (lb/hr) + Collected Controlled Hourly Emissions (lb/hr)
HAP hourly emissions (lb/hr) [per product] = consumption rate per hour (lb/hr) * %HAP from formulation
HAP hourly emissions: Uncollected Uncontrolled Hourly Emissions (lb/hr) = Sum of HAP hourly emissions (lb/hr) [total ink, no HAP contained in the fixation material]
HAP hourly emissions: Collected Uncontrolled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Estimated Collection Efficiency %
HAP hourly emissions: Building Fugitive Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * (1 – Estimated Collection Efficiency %)
HAP hourly emissions: Collected Controlled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Estimated Collection Efficiency % * (1 - Control Efficiency %)
HAP hourly emissions: Total Building Fugitive and Collected Controlled Hourly Emissions (lb/hr) = Building Fugitive Emissions (lb/hr) + Collected Controlled Hourly Emissions (lb/hr)
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
August 2024
Page 10 of 13
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
Annual Emissions
operating printers (printer) = maximum number of printers to be installed
printer production rate (unit/hr*printer) = maximum number of units that can be printed per hour per printer
production rate (unit/hr) = operating printers (printer) * printer production rate (unit/hr*printer)
consumption rate per hour (gr/hr) = production rate (unit/hr) * consumption rate per unit (gr/unit) [consumption rate per unit based on consumption rate process knowledge from a similar facility elsewhere in the United States or expected consumption rates for non-apparel products]
operating schedule (hr/yr) = operating schedule (day/yr) * operating schedule (hr/day)
production rate (unit/yr) = production rate (unit/hr) * operating schedule (hr/yr)
annual consumption rate (gr/yr) = consumption rate per hour (gr/hr) * operating schedule (hr/yr)
annual consumption rate (lb/yr) = annual consumption rate (gr/yr) * 0.00220462 (lb/gr)
average monthly consumption rate (lb/mo) = annual consumption rate (lb/yr) / 12 (mo/yr)
total consumption (ton/year) = annual consumption rate (lb/yr) / 2,000 (lb/ton)
VOC annual emissions (ton/year) [per product] = total consumption (ton/year) * Avg %VOC from formulation
VOC annual emissions (building fugitives) (ton/year) [per product] = VOC annual emissions (ton/year) [per product] * (1 – Estimated Collection Efficiency %)
VOC annual emissions (collected controlled) (ton/year) [per product] = VOC annual emissions (ton/year) [per product] * Estimated Collection Efficiency % * (1 - Control Efficiency %)
VOC annual emissions (fug + controlled) (ton/year) [per product] = VOC annual emissions (building fugitives) (ton/year) [per product] + VOC annual emissions (collected controlled) (ton/year) [per product]
VOC annual emissions (ton/year): Uncollected Uncontrolled Annual Emissions (tpy) = Sum of VOC annual emissions (ton/year) [per product]
VOC annual emissions (ton/year): Collected Uncontrolled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency %
VOC annual emissions (ton/year): Building Fugitive Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * (1 – Estimated Collection Efficiency %)
VOC annual emissions (ton/year): Collected Controlled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Estimated Collection Efficiency % (1 - Control Efficiency %)
VOC annual emissions (ton/year): Total Building Fugitive and Collected Controlled Annual Emissions (tpy) = Building Fugitive Emissions (tpy) + Collected Controlled Annual Emissions (tpy)
HAP annual emissions (ton/year) [per product] = total consumption (ton/year) * %HAP from formulation
HAP annual emissions (building fugitives) (ton/year) [per product] = HAP annual emissions (ton/year) [per product] * (1 – Estimated Collection Efficiency %)
HAP annual emissions (collected controlled) (ton/year) [per product] = HAP annual emissions (ton/year) [per product] * Estimated Collection Efficiency % * (1 - Control Efficiency %)
HAP annual emissions (fug + controlled) (ton/year) [per product] = HAP annual emissions (building fugitives) (ton/year) [per product] + HAP annual emissions (collected controlled) (ton/year) [per product]
HAP annual emissions (ton/year): Uncollected Uncontrolled Annual Emissions (tpy) = Sum of HAP annual emissions (ton/year) [per product]
HAP annual emissions (ton/year): Collected Uncontrolled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Estimated Collection Efficiency %
HAP annual emissions (ton/year): Building Fugitive Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * (1 – Estimated Collection Efficiency %)
HAP annual emissions (ton/year): Collected Controlled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Estimated Collection Efficiency % * (1 - Control Efficiency %)
HAP annual emissions (ton/year): Total Building Fugitive and Collected Controlled Annual Emissions (tpy) = Building Fugitive Emissions (tpy) + Collected Controlled Annual Emissions (tpy)
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
August 2024
Page 11 of 13
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
Cleanup Solvent Notes:
Hourly Emissions
consumption rate per hour (gal/hr) = consumption rate per day (gal/day) [assumes that all daily usage can be utilized in one hour (worst case)]
consumption rate per day (gal/day) = consumption rate per hour (gal/hr)
average monthly consumption rate (gal/mo) = consumption rate per day (gal/day) * 31 (day/mo)
consumption rate per year (gal/yr) = average monthly consumption rate (gal/mo) * 12 (mo/yr)
product density (g/ml) = per product SDS
product density (lb/gal) = product density (g/ml) * 8.3454
consumption rate per hour (lb/hr) = consumption rate (gal/hr) * product density (lb/gal)
consumption rate per day (lb/day) = consumption rate (gal/day) * product density (lb/gal)
average monthly consumption rate (lb/mo) = average monthly consumption rate (gal/mo) * product density (lb/gal)
VOC hourly emissions: Uncollected Uncontrolled Emissions (lb/hr) = consumption rate per hour (lb/hr) * %VOC from formulation
VOC hourly emissions: Building Fugitives (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * (1 - Estimated Collection Efficiency %)
VOC hourly emissions: Stack Emissions (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * Estimated Collection Efficiency * (1 - Control Efficiency %)
HAP hourly emissions: Uncollected Uncontrolled Emissions (lb/hr) = consumption rate per hour (lb/hr) * %HAP from formulation
HAP hourly emissions: Building Fugitives (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * (1 - Estimated Collection Efficiency %)
HAP hourly emissions: Stack Emissions (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * Estimated Collection Efficiency * (1 - Control Efficiency %)
Annual Emissions
consumption rate per year (lb/yr) = consumption rate per year (gal/yr) * product density (lb/gal)
VOC monthly emissions: Uncollected Uncontrolled Emissions (ton/mo) = consumption rate per month (lb/mo) * %VOC from formulation / 2000 (lb/ton)
VOC monthly emissions: Building Fugitives (ton/mo) = Uncollected Uncontrolled Emissions (ton/mo) * (1 - Estimated Collection Efficiency %)
VOC monthly emissions: Stack Emissions (ton/mo) = Uncollected Uncontrolled Emissions (ton/mo) * Estimated Collection Efficiency * (1 - Control Efficiency %)
HAP monthly emissions: Uncollected Uncontrolled Emissions (ton/mo) = consumption rate per hour (ton/mo) * %HAP from formulation
HAP monthly emissions: Building Fugitives (ton/mo) = Uncollected Uncontrolled Emissions (ton/mo) * (1 - Estimated Collection Efficiency %)
HAP monthly emissions: Stack Emissions (ton/mo) = Uncollected Uncontrolled Emissions (ton/mo) * Estimated Collection Efficiency * (1 - Control Efficiency %)
VOC annual emissions: Uncollected Uncontrolled Emissions (tpy) = consumption rate per year (lb/yr) * %VOC from formulation / 2000 (lb/ton)
VOC annual emissions: Building Fugitives (tpy) = Uncollected Uncontrolled Emissions (tpy) * (1 - Estimated Collection Efficiency %)
VOC annual emissions: Stack Emissions (tpy) = Uncollected Uncontrolled Emissions (tpy) * Estimated Collection Efficiency * (1 - Control Efficiency %)
HAP annual emissions: Uncollected Uncontrolled Emissions (tpy) = consumption rate per hour (tpy) * %HAP from formulation
HAP annual emissions: Building Fugitives (tpy) = Uncollected Uncontrolled Emissions (tpy) * (1 - Estimated Collection Efficiency %)
HAP annual emissions: Stack Emissions (tpy) = Uncollected Uncontrolled Emissions (tpy) * Estimated Collection Efficiency * (1 - Control Efficiency %)
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
August 2024
Page 12 of 13
Amazon.com Services, LLC - Salt Lake City Facility
Dryer Combustion Emissions Calculations
Digital Printing Dryers
Dryer Rating 0.4 MMBtu/hr
Maximum Operating Time 8,760 hr/yr
Maximum Number of Units 8
Fuel Natural Gas
Estimated Fuel Throughput 3,504.00 MMBtu/yr/dryer
35,048.41 Therms/yr/dryer
28,032.00 MMBtu/yr Total
280,387.28 Therms/yr Total
Individual Dryer
(lb/MMscf)(g/MMBtu)(lb/MMBtu)(lb/hr)(lb/hr)(tpy)
NOX 100.0 ----0.0392 0.3137 1.3741
VOC 5.5 ----0.0022 0.0173 0.0756
CO 84.0 ----0.0329 0.2635 1.1543
SO2 0.6 ----0.0002 0.0019 0.0082
PM/PM2.5/PM10 7.6 ----0.0030 0.0238 0.1044
CO2 --0.05 1.17E-04 4.68E-05 0.0004 0.0016
CH4 --1.00 2.20E-03 8.82E-04 0.0071 0.0309
N2O --0.10 2.20E-04 8.82E-05 0.0007 0.0031
Notes:
Criteria pollutant emission factors from U.S. Environmental Protection Agency AP-42 Section 1.4 Tables 1.4-1 and 1.4-2
GHG pollutant emission factors from U.S. Environmental Protection Agency 2024 GHG Emission Factors Hub.
Natural Gas Heat Value = 1,020 MMBtu/MMscf
Calculation Methodology:
Maximum Operating Time (hr/yr) = 8,760 (hr/yr)
Criteria Pollutant Individual Short-Term Emission Rate (lb/hr) = Dryer Rating (MMBtu/hr) * Emission Factor (lb/MMscf)) / 1,020 (MMBtu/MMscf)
Criteria Pollutant Combined Short-Term Emission Rate (lb/hr) = Dryer Rating (MMBtu/hr) * Emission Factor (lb/MMscf)) / 1,020 (MMBtu/MMscf) * Maximum Number of Units (#)
Criteria Pollutant Combined Annual Emission Rate (tpy) = Combined Short-Term Emission Rate (lb/hr) * Operating Time (hr/yr) / 2,000 (lb/ton)
GHG Individual Short-Term Emission Rate (lb/hr) = GHG Combined Short-Term Emission Rate (lb/hr) / Maximum Number of Units (#)
GHG Combined Short-Term Emission Rate (lb/hr) = GHG Combined Annual Emission Rate (tpy) * 2,000 (lb/ton) / Maximum Operating Time (hr/yr)
GHG Combined Annual Emission Rate (tpy) = Emission Factor (lb/MMBtu) * Total Estimated Fuel Throughput (MMBtu/yr) / 2,000 (lb/ton)
Digital Dryers Nos. 1 through 8
Combined Dryers
Annual
Emission Rate
Short-Term
Emission Rate Emission Source Contaminant Emission Factor Short-Term Emission
Rate Emission Factor Emission Factor
Amazon.com Services, LLC - Salt Lake City Facility
Dryer Combustion Emissions Calculations
August 2024
Page 13 of 13
Amazon.com Services, LLC – Salt Lake City Facility
Process Description
Amazon.com Services, LLC – Salt Lake City Facility August 2024
Process Description Page 1 of 4

Amazon.com Services, Inc. (Amazon) operates a digital printing facility in Salt Lake City, UT.
Production at the site includes apparel and other merchandise printing. The description that
follows includes both existing and proposed equipment and operations.
Existing Apparel Printing Operations
This digital printing operation consists of 24 digital printers and eight (8) natural gas fired dryers.

Blank apparel units (e.g. shirts, aprons, etc.) are manually inserted one at a time into one of the
digital printers. Each printer can accommodate two apparel units simultaneously and up to 60
apparel units per hour. Annual production will be limited to 12,614,400 apparel units per year.

A fixation agent or solution is applied to a unit on a maximum print area of 15” x 18” before inks
are applied. Immediately following the application of the fixation agent or solution, ink is applied
according to order specifications. Upon completion of the printing cycle, the apparel units are
manually transferred one at a time to a dryer. The printers and dryers are sources of Volatile
Organic Compound (VOC) emissions that include Hazardous Air Pollutants (HAP).

Emissions testing during operations at a similar facility has confirmed that no more than 5% of the
potential emissions from the apparel printing operations are fugitive in nature and the remaining
95% will be routed to natural gas fired dryers. Information regarding this emissions testing can be
provided upon request.

The following are the proposed usage rates for the digital printing operation:

Equipment ID Emission
Point No. Equipment Ink/Chemical
Hourly Usage
Rate
(lb/hr)
Annual Usage
Rate
(tpy)
DP1 through
DP24
FUG-1
and
DDV1
through
DDV8
Digital Printers
Nos. 1-24
Inks (CMYRGK) 4.5 19.3
White Ink 9.6 41.9
Concentrate
Fixation 56.8 248.9
*C-Cyan, M-Magenta, Y-Yellow, R-Red, G-Green, K-Black

The natural gas dryers are a source of products of combustion emissions. Combustion emissions
from the dryers will be routed to stacks. The following is a summary of dryer specifications:

Equipment
ID Emission Point No. Equipment
Individual Heat
Rating
(MMBtu/hr)
Operating
Schedule
(hr/yr)
DDV1
through
DDV8
DDV1 through DDV8 Digital Dryers
Nos. 1 through 8 0.40 8,760

A wiping fluid is used as a cleanup solvent for printing equipment. Cleanup activities are a source
of VOCs and are released as building fugitives. The following are the proposed usage rates for
cleanup:
Amazon.com Services, LLC – Salt Lake City Facility
Process Description
Amazon.com Services, LLC – Salt Lake City Facility August 2024
Process Description Page 2 of 4

Equipment
ID
Emission
Point
No.
Equipment
Hourly Usage
Rate
(gal/hr)
Daily Usage
Rate
(gal/day)
Annual Usage
Rate
(gal/yr)
D-CLEAN1 FUG-1 Digital Printing Area 1
Cleanup 2.05 2.1 750

Proposed Direct-to-Film (DTF) Apparel Printing
The proposed DTF apparel printing operations consist of six M&R Quatro printers. The printers
are self-contained systems each consisting of a wide format roll-fed inkjet printer, a thermoplastic
polyurethane (TPU) powder applicator, a high-efficiency infra-red dryer, and an electric heat press.
Each printer is capable of printing up to 60 units per hour.
The DTF process begins with the creation of a digital design. Once the design is finalized, it is
printed onto PET film with a digital inkjet printer using cyan, magenta, yellow, black, and white
pigmented aqueous inkjet inks. After printing is complete, and while the ink is still wet, the transfer
is prepared by applying a layer of TPU powder to the print area. Immediately after the TPU powder
has been applied, the final construction of film, ink, and TPU powder is prepared for the transfer
process by running it through the high-efficiency infra-red drying system to cure the ink, and to
fuse the TPU powder to achieve a strong bond between the ink and the fabric, ensuring a durable
and long-lasting print. After printing onto the PET film is complete, the film enters the high-
efficiency infra-red drying system to cure the ink. A garment is placed on a heat press and prepped
for the film transfer. The film transfer is then laid on top of the garment in the correct alignment.
The heat press is used to apply both heat and pressure and causes the design to transfer from the
film onto the fabric. The film remains intact throughout the process.
Materials used in the DTF apparel printing operations include polyethylene terephthalate (PET)
film, TPU powder, and water-based inks. No emissions are expected from the PET film or the TPU
powder based on the process description above (i.e., the PET film remains intact throughout the
process; the TPU powder is consumed in the process). Therefore, the DTF apparel printing
operations are a source of VOC and HAP emissions and are represented as building fugitives. It is
conservatively assumed that 100% of the VOC and HAP constituents in the inks are emitted.
The following table includes the proposed ink usage rates for the DTF apparel printing operations.
Equipment
ID
Emission
Point No. Equipment Ink/Material
Hourly Ink
Usage Rate
(lb/hr)
Annual Ink
Usage Rate
(tpy)
DTF1
through
DTF6
FUG-1 DTF Apparel
Printer Nos. 1-6
CMYK Ink 1.22 4.16
White Ink 1.88 6.39

A wiping fluid is used as a cleanup solution for the DTF apparel printing equipment. Cleanup activities are
a source of VOC emissions and are represented as building fugitives. The following table includes the
proposed usage rates for cleanup.
Amazon.com Services, LLC – Salt Lake City Facility
Process Description
Amazon.com Services, LLC – Salt Lake City Facility August 2024
Process Description Page 3 of 4

Equipment
ID
Emission
Point No. Equipment
Hourly Usage
Rate
(gal/hr)
Daily Usage
Rate
(gal/day)
Annual Usage
Rate
(gal/yr)
D-CLEAN3 FUG-1 Digital Printing Area
3 Cleanup 0.63 0.63 230

Existing Non-Apparel Printing Operations
The production area is open concept and consists of 12 flatbed UV printers. Emissions from
sources and operations in this area are released into the atmosphere as fugitives (EPN FUG-1).

Cell Phone Ring Stands
This digital printing operation consists of 12 UV printers. Up to 27 Blank cell phone ring stand
units are placed in pre-cut plastic sheets referred to as jigs. The jigs are manually inserted into one
of the 12 UV printers one at a time. Each printer can accommodate up to 5 jigs per hour. Ink is
dried and cured within the printers using UV LED lamps. The printers are a source of VOC
emissions. Annual production will be limited to 14,191,200 cell phone ring stand units per year.

The following are the proposed ink usage rates for this digital printing operation:

Equipment ID Emission
Point No. Equipment Ink/Chemical
Hourly Usage
Rate
(lb/hr)
Annual Usage
Rate
(tpy)
UV1 through
UV12 FUG-1 UV Printers Nos.
1-12 Total Inks 0.02 0.10

A wiping fluid is used as a cleanup solvent for printing equipment. Cleanup activities are a source
of VOCs and are released as building fugitives. The following are the proposed usage rates for
cleanup:

Equipment
ID
Emission
Point
No.
Equipment
Hourly Usage
Rate
(gal/hr)
Daily Usage
Rate
(gal/hr)
Annual Usage
Rate
(gal/yr)
D-CLEAN2 FUG-1 Digital Printing Area 2
Cleanup 1 1 12

Sublimation Printing and Curing – Miscellaneous Products
This digital printing operation was never installed or operated and is being removed from the
permit with this application.

Maintenance, Start-up and Shutdown (MSS) Activities

Prior to conducting production operations, each dryer will undergo a 10-minute start-up purge
period. The dryers will be a source of products of combustion.

The dryer stacks are each 12 inches in diameter and four (4) feet in height above the roof of the
building. Amazon will conduct the purge twice per day per dryer.

Amazon.com Services, LLC – Salt Lake City Facility
Process Description
Amazon.com Services, LLC – Salt Lake City Facility August 2024
Process Description Page 4 of 4

Equipment ID Emission Point
No. Equipment
Individual Heat
Rating
(MMBtu/hr)
Purge Frequency
Per Dryer
(#/day)
DDV1 through DDV8 DDV1 through
DDV8
Digital Dryers
Nos. 1 through 8 0.40 2

BSI America Professional Services Inc. T: 800.790.6236
7800 North MoPac Expwy bsigroup.com
Suite 325
Austin TX 78759
July 17, 2024
Bryce Bird
Director
Air Quality Division Utah Department of Environmental Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Re: Amazon.com Services, LLC – Salt Lake City Site (SLC4)
770 South Gladiola, Suite 500
Salt Lake City, UT 84104
Approval Order DAEQE-AN159810001-19
Minor Source Permit Modification – BSI Project No. 1190079
Dear Bryce Bird:
Amazon.com Services, LLC is seeking to modify the New Source Review (NSR) Minor Source Permit issued to its Salt Lake City Site (SLC4), located at 770 South Gladiola, Suite 500 in Salt Lake City, Utah. The
requested modifications are as follows:
•Updates to existing apparel printing hazardous air pollutant (HAP) and volatile organic compound(VOC) emission rates, according to maximum stack test results from stack testing conducted at a
similar Amazon facility on December 17, 2020.
•Modification of printing operations hours to 24 hours a day, 7 days a week, 365 days a year. As aresult, annual throughputs will increase for the existing apparel printing production, UV printing
production, and sublimation printing production.
•A decrease in the hourly production rate per UV printer, based on actual operations data.
•Addition of direct-to-film (DTF) apparel printing.
•Updates to green house gas (GHG) emission estimated for the apparel printing dryers.
Please find the NOI application forms and supporting documents for the requested modifications
attached.
Should you have any questions regarding this permit modification request, please contact Ryan Pickett at 870.833.1401 or via email at [e-mail].
Bryce Bird, Utah Department of Environmental Quality Page 2
BSI Project No. 1190079 Amazon SLC4 Air Permit Modification Application 071724
Regards, Reviewed by:
Loren Ladd Ryan Pickett
Loren Ladd Ryan Pickett, Manager
Consulting Technician Senior Consultant
cc: Michael Boese, Amazon.com Services, LLC – Seattle WA
Attachments
Form 1 – Notice of Intent (NOI) Application Checklist Form 2 – Company Information/ Notice of Intent (NOI)
Form 5 – Emissions Information
Area Map Plot Plan
Process Description
Process Flow Diagram State and Federal Regulatory Review
Best Available Control Technology (BACT) Review
Health Effects Review
Emissions Calculations
Emissions Summary Consumption Estimates
Apparel Printing Emissions at 95% Collection Efficiency
Cell Phone Ring Stand Printing Emissions Calculations Miscellaneous Products Printing Emissions
Dryer Combustion Emissions Calculations
DTF Apparel Printing Emission Calculations
Bryce Bird, Utah Department of Environmental Quality Attachments
BSI Project No. 1190079 Amazon SLC4 Air Permit Modification Application 071724
Attachments
Form 1 Date __________________
Notice of Intent (NOI) Application Checklist
Company __________________
Utah Division of Air Quality
New Source Review Section
Source Identification Information [R307-401-5]
1. Company name, mailing address, physical address and telephone number †
2. Company contact (Name, mailing address, and telephone number)†
3. Name and contact of person submitting NOI application (if different than 2)†
4. Source Universal Transverse Mercator (UTM) coordinates †
5. Source Standard Industrial Classification (SIC) code †
6. Area designation (attainment, maintenance, or nonattainment)†
7. Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.)†
8. Source size determination (Major, Minor, PSD)†
9. Current Approval Order(s) and/or Title V Permit numbers †
NOI Application Information:[R307-401]
†
†
†
†
†
†
†
†
†
†
†N/A †
†N/A †
A. Air quality analysis (air model, met data, background data, source impact analysis) †N/A †
Detailed description of the project and source process
Discussion of fuels, raw materials, and products consumed/produced
Description of equipment used in the process and operating schedule
Description of changes to the process, production rates, etc.
Site plan of source with building dimensions, stack parameters, etc.
Best Available Control Technology (BACT) Analysis [R307-401-8]
$BACT analysis for all new and modified equipment
Emissions Related Information: [R307-401-2(b)]
$Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5,NOx, SO2, CO, VOCs, HAPs, and GHGs)
%References/assumptions, SDS, for each calculation and pollutant
&All speciated HAP emissions (list in lbs/hr)
Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
$Composition and physical characteristics of effluent
(emission rates, temperature, volume, pollutant types and concentrations)
Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
$NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
%Alternative site analysis, Major source ownership compliance certification
Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
%Visibility impact analysis, Class I area impact
 6LJQDWXUHRQ$SSOLFDWLRQ
†N/A †
Note: The Division of Air Quality will not accept documents containing confidential information or data.
Documents containing confidential information will be returned to the Source submitting the application.
July 2024
Amazon.com Services, LLC
✔
✔
✔
✔
✔
✔
✔
✔
✔
✔
✔
✔
✔
✔
✔
✔
✔
✔
✔
✔
1of 1
Form 2 Date ____________
Company Information/Notice of Intent (NOI)
Utah Division of Air Quality
New Source Review Section
Application for: Ƒ Initial Approval Order Ƒ 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 Ƒ %RWK
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: 7/17/2024
July 2024
✔
Amazon.com Services, LLC
P.O. Box 80842
Seattle, WA 98108
[phone]
Ms. Prachi Kalla
[phone]
[e-mail]
Salt Lake Digital Printing Fa
770 South Gladiola, Ste 500
Salt Lake City, UT 84104
Salt Lake City
12
417,755 m Easting
4,511,713 m Northing
2759
AN159810001-19 09 05 2019
Amazon.com Services, LLC. (Amazon Services) operates a digital printing plant located in Salt Lake
City, Salt Lake City County. Amazon Services prints on t-shirts, mugs, cell phone ring stand holders,
and cell phone cases on an as-ordered basis. These items are packaged individually at the plant
location for delivery to the customers.
✔
Sr. Regional Environmental
Prachi Kalla
[phone]
[e-mail]
Page 1 of 1
Company___________________________
6LWH_____________________________
Form 
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
Amazon.com Services, LLC
Salt Lake City
0.10 0.00 0.10
0.10 0.00 0.10
0.10 0.00 0.10
1.38 0.00 1.37
0.01 0.00 0.01
1.16 0.00 1.15
35.66 0.00 16.23
10.28
0.00
0.89
0.82
0.00
0.00
0.00
1.67
Ethylene Glycol 3.86 0.00 1.01 0.00
Triethylene Glycol Monomethyl Ether 0.72 0.14 0.86 0.03
4.58 0.00 1.87 0.00
Text Source: ESRI World Imagery
Datum: WGS 1984
Text Amazon.com Services, LLC - Salt Lake City770 Gladiola Street, Suite 500Salt Lake City, UT 84104Area Map
Location:UTM Zone 12417754.87 m E4511712.58 m N
Text
July 2024
Esri, HERE, Garmin, (c) OpenStreetMap contributors, and the GIS user community, Source: Esri, Maxar,Earthstar Geographics, and the GIS User Community
Legend
Property Boundary
Building
Lease Area
±
7800 N. Mopac Expwy, Suite 325Austin, TX 78759
0 770 1,540385Feet
Text Source: ESRI World Imagery
Datum: WGS 1984
Text Amazon.com Services, LLC - Salt Lake City770 Gladiola Street, Suite 500Salt Lake City, UT 84104Plot Plan Map
Location:UTM Zone 12417754.87 m E4511712.58 m N
Text
July 2024
Esri, HERE, Garmin, (c) OpenStreetMap contributors, and the GIS user community, Source: Esri, Maxar,Earthstar Geographics, and the GIS User Community
Legend
Property Boundary
Building
Lease Area
±
7800 N. Mopac Expwy, Suite 325Austin, TX 78759
0 380 760190Feet
Stack parameters area as follows:
- 8 stacks (one stack per dryer) - Building Height: 30 ft - Stack Height: 34 ft - Diameter: 1 ft - Velocity: 24.4 fps - Temperature: 200 F (estimated)
690 ft
290 ft
330 ft
240 ft
360 ft
50 ft
Amazon.com Services, LLC – Salt Lake City Facility Process Description
Amazon.com Services, LLC – Salt Lake City Facility July 2024
Process Description Page 1 of 3
Amazon Services, Inc. (Amazon) is proposing to operate a digital printing facility in Salt Lake
City, UT. Production at the site will include apparel and other merchandise printing. The
description that follows includes equipment and operations proposed for site build out.
Apparel Printing Operations
This digital printing operation consists of 24 digital printers and eight (8) natural gas fired dryers. Blank apparel units (e.g. shirts, aprons, etc.) are manually inserted one at a time into one of the digital printers. Each printer can accommodate two apparel units simultaneously and up to 60 apparel units per hour. Annual production will be limited to 10,512,000 apparel units per year.
A fixation agent or solution is applied to a unit on a maximum print area of 15” x 18” before inks are applied. Immediately following the application of the fixation agent or solution, ink is applied according to order specifications. Upon completion of the printing cycle, the apparel units are manually transferred one at a time to a dryer. The printers and dryers are a source of Volatile
Organic Compound (VOC) emissions that include Hazardous Air Pollutants (HAP). Emissions testing during operations at a similar facility has confirmed that no more than 5% of the potential emissions from the apparel printing operations are fugitive in nature and the remaining 95% will be routed to natural gas fired dryers. Information regarding this emissions testing can be
provided upon request. The following are the proposed usage rates for the digital printing operation:
Equipment ID Emission Point No. Equipment Ink/Chemical Hourly Usage Rate (lb/hr)
Annual Usage Rate (tpy)
DP1 through DP24 FUG-1 Digital Printers Nos. 1-24
Inks (CMYRGK) 4.5 16.2
White Ink 9.6 35
Concentrate Fixation 56.8 207.5
*C-Cyan, M-Magenta, Y-Yellow, R-Red, G-Green, K-Black
The natural gas dryers are a source of products of combustion emissions. Combustion emissions
from the dryers will be routed to stacks. The following is a summary of dryer specifications:
Equipment ID EPN Equipment Individual Heat Rating (MMBtu/hr)
Operating Schedule (hr/yr)
DDV1 through DDV8 DDV1 through DDV8 Digital Dryers Nos. 1 through 8 0.40 8,760

Amazon.com Services, LLC – Salt Lake City Facility Process Description
Amazon.com Services, LLC – Salt Lake City Facility July 2024
Process Description Page 2 of 3
A wiping fluid is used as a cleanup solvent for printing equipment. Cleanup activities are a source of VOCs and are released as building fugitives. The following are the proposed usage rates for
cleanup:

Equipment ID EPN Equipment
Hourly Usage
Rate (gal/hr)
Daily Usage
Rate (gal/day)
Annual Usage
Rate (gal/yr)
D-CLEAN1 FUG-1 Digital Printing Area 1
Cleanup 2.05 2.1 750
Non-Apparel Printing Operations
The production area is open concept and consists of 12 flatbed UV printers, 20 dye sublimation
printers and 80 sublimation heat presses used for curing. Emissions from sources and operations in this area are released into the atmosphere as fugitives (EPN FUG-1). Cell Phone Ring Stands
This digital printing operation consists of 12 UV printers. Up to 191 Blank cell phone ring stand units are placed in pre-cut plastic sheets referred to as jigs. The jigs are manually inserted into one of the 12 UV printers one at a time. Each printer can accommodate up to 6 jigs per hour. Ink is dried and cured within the printers using UV LED lamps. The printers are a source of VOC emissions. Annual production will be limited to 100,389,600 cell phone ring stand units per year.
The following are the proposed ink usage rates for this digital printing operation:
Equipment ID EPN Equipment Ink/Chemical Hourly Usage Rate (lb/hr)
Annual Usage Rate (tpy)
UV1 through UV12 FUG-1 UV Printers Nos. 1-12 Total Inks 0.76 2.77

A wiping fluid is used as a cleanup solvent for printing equipment. Cleanup activities are a source
of VOCs and are released as building fugitives. The following are the proposed usage rates for cleanup:
Equipment ID EPN Equipment Hourly Usage Rate (gal/hr)
Daily Usage Rate (gal/hr)
Annual Usage Rate (gal/yr)
D-CLEAN2 FUG-1 Digital Printing Area 2 Cleanup 1 1 12

Sublimation Printing and Curing – Miscellaneous Products
This digital printing operation consists of 20 dye sublimation printers used for printing miscellaneous products designs. Blank units are inserted into one of 80 sublimation printers. Each printer can accommodate up to 144 prints per hour. Annual production will be limited to 21,024,000 merchandise units per year. The printers are a source of VOC emissions that include
HAPs.
Amazon.com Services, LLC – Salt Lake City Facility Process Description
Amazon.com Services, LLC – Salt Lake City Facility July 2024
Process Description Page 3 of 3
Upon completion of the printing cycle, the units are transferred to one of the 80 electric sublimation
heat presses for application on to miscellaneous products such as cell phone cases or mugs for
curing. This operation is a source of VOC emissions that include HAPs. However, for the purposes of the emissions calculations and modeling exercise, it is assumed that estimated potential emissions from the sublimation operations (printing and heat presses) are emitted during the printing phase.

The following are the proposed ink usage rates for the digital printing operation:
Equipment ID EPN Equipment Ink/Chemical Hourly Usage Rate (lb/hr)
Annual Usage Rate (tpy)
SUB1 through
SUB20, HP1 through HP80
FUG-1
Sublimation Printers Nos. 1-
20, Sublimation Heat Presses Nos. 1 through 80
Total Inks 3.95 14.39

Maintenance, Start-up and Shutdown (MSS) Activities Prior to conducting production operations, each dryer will undergo a 10-minute start-up purge period. The dryers will be a source of products of combustion.
The dryer stacks are each 12 inches in diameter and four (4) feet in height above the roof of the building. Amazon will conduct the purge twice per day per dryer.
Equipment ID EPN Equipment Individual Heat Rating (MMBtu/hr)
Purge Frequency Per Dryer (#/day)
DDV1 through DDV8
DDV1 through DDV8 Digital Dryers Nos. 1 through 8 0.40 2

Main Production Floor - Apparel
VOC, HAP
Digital Printers
(IDs DP1 – DP24)
Digital Dryers
(IDs DDV1 –
DDV8)
NOx, VOC, HAP, CO, PM, PM10, PM2.5, SO2
VOC
Cleanup Ops
(ID D-CLEAN1)
Finished
Apparel Units
Printed Apparel
Units
Blank Apparel
Units
Amazon.com Services, LLC – Salt Lake City Facility
Apparel Printing
Amazon.com Services, LLC – Salt Lake City Facility
Apparel Printing
July 2024
Page 1 of 1
Inks/Fixation
Agent
Digital Dryers
(IDs DDV1 – DDV8)
EPNs DDV1-S through DDV20-S
NOx, VOC, CO, PM, PM10, PM2.5, SO2
Natural Gas
Amazon.com Services, LLC – Salt Lake City Facility
Dryer Combustion
Amazon.com Services, LLC – Salt Lake City Facility
Dryer Combustion
July 2024
Page 1 of 1
VOC
UV Printers
(IDs UV1-UV12)
VOC
Cleanup Ops
(ID D-CLEAN2)
Finished Printed UnitsBlank Jigs
Amazon.com Services, LLC – Salt Lake City Facility
UV Printing
Amazon.com Services, LLC – Salt Lake City Facility
UV Printing
July 2024
Page 1 of 1
Inks
Amazon.com Services, LLC – Salt Lake City Facility
Sublimation Printing
Sublimation
Printers
(IDs SUB1-SUB20)
Sublimation Heat
Presses
(IDs HP1-HP80)
Finished Product Units
Printed
Product
Units
Blank Product
Units
EPN FUG-1
VOC, HAP
Amazon.com Services, LLC – Salt Lake City Facility
Sublimation Printing
July 2024
Page 1 of 1
Inks
Amazon.com Services, LLC – Salt Lake City Facility
DTF Apparel Printing
DTF Printers
(IDs DTF1-DTF6)Heat Presses
Finished Apparel Units
Printed
Apparel
Units
Blank Apparel
Units
VOC, HAP
Amazon.com Services, LLC – Salt Lake City Facility
DTF Apparel Printing
July 2024
Page 1 of 1
Inks
VOC
Cleanup Ops
(ID D-CLEAN3)
Amazon.com Services, LLC - Salt Lake City Facility
State and Federal Regulation Review
Federal Regulations - Code of Federal Regulations
Rule Reference Rule Title Applicability Applicability Justification
40 CFR Part 52.21 Prevention of Significant Deterioration (PSD) of Air Quality NO
This facility is not one of the listed stationary sources of air pollutants for which emissions of 100
tons per year (tpy) or more of a regulated NSR pollutant triggers the major source requirements in
40 CFR § 52.21(b)(1)(i)(a) or in 40 CFR § 52.21(b)(1)(iii)(t). This facility will not emit 250 tpy or
more of a regulated NSR pollutant; therefore, PSD permitting does not apply.
40 CFR Part 60 Standard of Performance for New Stationary Sources NO This facility will not operate sources subject to this rule.
40 CFR Part 61 National Standards for Hazardous Air Pollutants NO This facility will not operate sources subject to this rule.
40 CFR Part 63 Maximum Achievable Control Technology NO This facility will not be a major source or have the potential to emit at major source thresholds.
State Regulations - Utah Administrative Code Title 307. Environmental Quality, Air Quality
Rule Reference Rule Title Applicability Applicability Justification
R307-101 General Requirements YES This rule is administrative in nature and does not regulate the operation of the facility. Amazon
Services, Inc. (Amazon) will comply with the standards in this rule as necessary.
R307-102 General Requirements: Broadly Applicable Requirements YES This rule is administrative in nature and does not regulate the operations of the facility. Amazon
will comply with the standards in this rule as necessary.
R307-103 Administrative Procedures YES This rule is administrative in nature and does not regulate the operations of the facility. Amazon
will comply with the standards in this rule as necessary.
R307-104 Conflict of Interest YES This rule is administrative in nature and does not regulate the operations of the facility. Amazon
will comply with the standards in this rule as necessary.
R307-105 General Requirements: Emergency Controls YES Amazon will comply with the standards in this rule as necessary.
R307-107 General Requirements: Breakdowns YES Amazon will comply with the standards in this rule as necessary.
R307-110 General Requirements: State Implementation Plan YES Amazon will comply with the standards in this rule as necessary.
R307-115 General Conformity YES Amazon will comply with the standards in this rule as necessary.
R307-120 General Requirements: Tax Exemption for Air Pollution Control Equipment NO The applicant is not applying for the programs listed in this rule.
R307-121 General Requirements: Clean Air and Efficient Vehicle Tax Credit NO The applicant is not applying for the programs listed in this rule.
R307-122 General Requirements: Heavy Duty Vehicle Tax Credit NO The applicant is not applying for the programs listed in this rule.
R307-123 General Requirements: Clean Fuels and Vehicle Technology Grant and Loan Program NO The applicant is not applying for the programs listed in this rule.
R307-124 General Requirements: Conversion to Alternative Fuel Grant Program NO The applicant is not applying for the programs listed in this rule.
R307-125 Clean Air Retrofit, Replacement, and Off-Road Technology Program NO The applicant is not applying for the programs listed in this rule.
R307-130 General Penalty Policy YES Amazon will comply with the standards in this rule as necessary.
R307-135 Enforcement Response Policy for Asbestos Hazard Emergency Response Act NO The facility will not operate sources regulated by this rule.
R307-150 Emission Inventories YES Amazon will comply with the standards in this rule as necessary.
R307-165 Emission Testing NO The facility will not operate sources that include used oil burned for energy recovery and is not an
air stripper and soil venting project.
R307-170 Continuous Emission Monitoring Program NO The facility will not operate sources regulated by this rule.
R307-201 Emission Standards: General Emission Standards YES This facility will be located in a nonattainment area for PM10.
R307-202 Emission Standards: General Burning NO Amazon will not conduct burning operations at the site.
R307-203 Emission Standards: Sulfur Content of Fuels NO The facility will not operate sources regulated by this rule.
R307-204 Emission Standards: Smoke Management NO The facility will not conduct prescribed fire or wildland fire clearing or management activities.
R307-205 Emission Standards: Fugitive Emissions and Fugitive Dust NO This facility will not be a source of fugitive dust; therefore this rule does not apply.
R307-206 Emission Standards: Abrasive Blasting NO The facility will not operate sources regulated by this rule.
R307-207 Residential Fireplaces and Solid Fuel Burning Devices NO The facility will not operate sources regulated by this rule.
R307-208 Outdoor Wood Boilers NO The facility will not operate sources regulated by this rule.
R307-210 Standards of Performance for New Stationary Sources NO This facility will not operate sources subject to this rule.
R307-214 National Emission Standards for Hazardous Air Pollutants NO This facility will not operate sources subject to this rule. This facility will not be a major source or
have the potential to emit at major source thresholds.
R307-220 Emission Standards: Plan for Designated Facilities NO The facility will not operate sources regulated by this rule.
R307-221 Emission Standards: Emission Controls for Existing Municipal Solid Waste Landfills NO The facility will not operate sources regulated by this rule.
R307-222 Emission Standards: Existing Incinerators for Hospital, Medical, Infectious Waste NO The facility will not operate sources regulated by this rule.
R307-223 Emission Standards: Existing Small Municipal Waste Combustion Units NO The facility will not operate sources regulated by this rule.
R307-224 Mercury Emission Standards: Coal-Fired Electric Generating Units NO The facility will not operate sources regulated by this rule.
R307-230 NOx Emission Limits for Natural Gas-Fired Water Heaters NO There are no boilers at this site; therefore this regulation does not apply.
R307-250 Western Backstop Sulfur Dioxide Trading Program NO The applicant is not applying for the programs listed in this rule.
R307-301 Utah and Weber Counties: Oxygenated Gasoline Program As a Contingency Measure NO The applicant is not applying for the programs listed in this rule.
R307-302 Solid Fuel Burning Devices NO This facility will not operate a fireplace, wood stove or boiler; therefore this rule does not apply.
R307-303 Commercial Cooking NO This facility will not operate commercial cooking equipment; therefore this rule doe not apply.
R307-304 Solvent Cleaning NO Equipent cleaning solvents are circulated within the equipment. There will be no manual
application of solvents for equipment maintenance; therefore this rule does not apply.
R307-305 Nonattainment and Maintenance Areas for PM10: Emission Standards YES This facility will be located in a nonattainment area for PM10. Amazon will comply with the
standards in this rule as necessary.
R307-306 PM10 Nonattainment and Maintenance Areas: Abrasive Blasting NO This facility will not conduct abrasive blasting operations.
R307-307 Road Salting and Sanding NO This facility will not apply salt or abrasives such as crushed slag and sand to roads; therefore this
rule does not apply.
R307-309 Nonattainment and Maintenance Areas for PM10 and PM2.5: Fugitive Emissions and Fugitive Dust NO This facility will not handle aggregate materials and will not conduct mining or construction
operations.
Amazon.com Services, LLC - Salt Lake City Facility
State and Federal Regulation Review
July 2024
Page 1 of 3
Amazon.com Services, LLC - Salt Lake City Facility
State and Federal Regulation Review
State Regulations - Utah Administrative Code Title 307. Environmental Quality, Air Quality
Rule Reference Rule Title Applicability Applicability Justification
R307-310 Salt Lake County: Trading of Emission Budgets for Transportation Conformity NO The applicant is not applying for the programs listed in this rule.
R307-311 Utah County: Trading of Emission Budgets for Transportation Conformity NO The applicant is not applying for the programs listed in this rule.
R307-312 Aggregate Processing Operations for PM2.5 Nonattainment Areas NO
This facility will not operate sources in the aggregate processing industry, including aggregate
processing equipment, hot mix asphalt plants, and concrete batch plants; therefore this rule does
not apply.
R307-320 Ozone Maintenance Areas and Ogden City: Employer-Based Trip Reduction Program NO The applicant is not applying for the programs listed in this rule.
R307-325 Ozone Nonattainment and Maintenance Areas: General Requirements NO This facility will not be located in an ozone nonattainment area.
R307-326 Ozone Nonattainment and Maintenance Areas: Control of Hydrocarbon Emissions in Petroleum Refineries NO This facility will not be a petroleum refinery; therefore this rule does not apply.
R307-327 Ozone Nonattainment and Maintenance Areas: Petroleum Liquid Storage NO This facility is not a petroleum refinery or petroleum liquid storage facility located in an ozone
nonattainment or maintenance area; therefore this rule does not apply.
R307-328 Gasoline Transfer and Storage NO This facility will not operate gasoline cargo or storage tanks; therefore this rule does not apply.
R307-335 Degreasing NO This facility will not operate a degreaser or conduct degreasing operations; therefore this rule does
not apply.
R307-341 Ozone Nonattainment and Maintenance Areas: Cutback Asphalt NO This facility is not located in an ozone nonattainment or maintenance area and will not use or apply
cutback asphalt for the proposed operations; therefore this rule does not apply.
R307-342 Adhesives and Sealants NO The facility will not manufacture adhesives or sealants.
R307-343 Wood Furniture Manufacturing Operations NO This facility is not a wood furniture manufacturing operations; therefore this rule does not apply.
R307-344 Paper, Film, and Foil Coatings NO This facility is not a paper, film, and foil coatings operations; therefore this rule does not apply.
R307-345 Fabric and Vinyl Coatings NO This facility is not a fabric and vinyl coatings operations; therefore this rule does not apply.
R307-346 Metal Furniture Surface Coatings NO This facility is not a metal furniture surface coatings operations; therefore this rule dose not apply.
R307-347 Large Appliance Surface Coatings NO This facility is not a large appliance surface coatings facility; therefore this rule does not apply.
R307-348 Magnet Wire Coatings NO This facility is not a magnet wire coatings facility; therefore this rule does not apply.
R307-349 Flat Wood Paneling Coatings NO This facility is not a flat wood paneling coatings facility; therefore this rule does not apply.
R307-350 Miscellaneous Metal Parts and Products Coatings NO This facility is not a miscellaneous metal parts and products coatings facility; therefore this rule
does not apply.
R307-351 Graphic Arts NO
This facility will not utilize roll printing, lithographic, letterpress, rotogravure, or flexographic printing
processes or techniques; therefore this rule does not apply. Operations at this facility will include
digital printing.
R307-352 Metal Container, Closure, and Coil Coatings NO This facility is not a metal container, closure, and coil coatings operation; therefore this rule does
not apply.
R307-353 Plastic Parts Coatings NO This facility will not manufacture or extrude plastic materials; therefore this rule does not apply.
R307-354 Automotive Refinishing Coatings NO This facility is not an automotive refinishing coatings operation; therefore this rule does not apply.
R307-355 Aerospace Manufacture and Rework Facilities NO This facility is not an aerospace manufacturing and rework facility; therefore this rule does not
apply.
R307-356 Appliance Pilot Light NO This facility will not operate natural gas-fired fan-type central furnaces, gas fireplaces or gas
stoves; therefore this rule does not apply.
R307-357 Consumer Products NO
This facility will not sell, supply, offer for sale, distribute for sale or manufacture for sale chemically
formulated products used by household and institutional consumers; therefore, this rule does not
apply.
R307-361 Architectural Coatings NO This facility does not manufacture or sell architectural coatings; therefore this rule does not apply.
R307-401 Permit: New and Modified Sources YES This application proposes construction of a new installation which will or might reasonably be
expected to become a source of an indirect sour of air pollution; therefore this rule applies.
R307-403 Permits: New and Modified Sources in Nonattainment Areas and Maintenance Areas YES This facility will be located in Salt Lake county. Amazon will comply with the standards in this rule
as necessary.
R307-405 Permits: Major Sources in Attainment or Unclassified Areas (PSD)NO This facility will not be a major source; therefore this rule does not apply.
R307-406 Visibility NO This facility will not be located in a Class 1 area; therefore this rule does not apply.
R307-410 Permits: Emissions Impact Analysis NO
Air dispersion modeling for National Ambient Air Quality Standards (NAAQS) was not performed in
this permit application as the proposed emissions for criteria pollutants was below the ton per year
threshold listed it R307-410-4 Table 1.
Air dispersion modeling for Hazardous Air Pollutants (HAPs) was not performed in this permit
application as the proposed HAP emissions are below the calculated emissions threshold for each
pollutant. The emissions threshold was calculated using the methodology outlined in R307-410-5
(C).
R307-414 Permits: Fees for Approval Orders YES Amazon will remit permit fees as applicable.
R307-415 Permits: Operating Permit Requirements NO This facility is not a major source; therefore this rule does not apply.
R307-417 Permits: Acid Rain Sources NO
This facility will not be a major source of emissions for sulfur dioxide or nitrogen oxides and will not
operate named sources within the power sector (such as electric generating units); therefore this
rule does not apply.
R307-420 Permits: Ozone Offset Requirements in Davis and Salt Lake Counties NO This facility does not have the potential to emit to trigger offset requirements; therefore this rule
does not apply.
Amazon.com Services, LLC - Salt Lake City Facility
State and Federal Regulation Review
July 2024
Page 2 of 3
Amazon.com Services, LLC - Salt Lake City Facility
State and Federal Regulation Review
State Regulations - Utah Administrative Code Title 307. Environmental Quality, Air Quality
Rule Reference Rule Title Applicability Applicability Justification
R307-421 Permits: PM10 Offset Requirements in Salt Lake County and Utah County NO This facility does not have the potential to emit to trigger offset requirements; therefore this rule
does not apply.
R307-424 Permits: Mercury Requirements for Electric Generating Units NO This facility will not operate an electric generating unit; therefore this rule does not apply.
R307-501 Oil and Gas Industry: General Provisions NO This will not be an oil and gas facility; therefore this rule does not apply.
R307-502 Oil and Gas Industry: Pneumatic Controllers NO This will not be an oil and gas facility; therefore this rule does not apply.
R307-503 Oil and Gas Industry: Flares NO This will not be an oil and gas facility; therefore this rule does not apply.
R307-504 Oil and Gas Industry: Tank Truck Loading NO This will not be an oil and gas facility; therefore this rule does not apply.
R307-505 Oil and Gas Industry: Registration Requirements NO This will not be an oil and gas facility; therefore this rule does not apply.
R307-506 Oil and Gas Industry: Storage Vessel NO This will not be an oil and gas facility; therefore this rule does not apply.
R307-507 Oil and Gas Industry: Dehydrators NO This will not be an oil and gas facility; therefore this rule does not apply.
R307-508 Oil and Gas Industry: VOC Control Devices NO This will not be an oil and gas facility; therefore this rule does not apply.
R307-509 Oil and Gas Industry: Leak Detection and Repair Requirements NO This will not be an oil and gas facility; therefore this rule does not apply.
R307-510 Oil and Gas Industry: Natural Gas Engine Requirements NO This will not be an oil and gas facility; therefore this rule does not apply.
R307-801 Utah Asbestos Rule NO The facility will not operate sources regulated by this rule.
R307-840 Lead-Based Paint Program Purpose, Applicability, and Definitions NO The facility will not operate sources regulated by this rule.
R307-841 Residential Property and Child-Occupied Facility Renovation NO The facility will not operate sources regulated by this rule.
R307-842 Lead-Based Paint Activities NO The facility will not operate sources regulated by this rule.
Amazon.com Services, LLC - Salt Lake City Facility
State and Federal Regulation Review
July 2024
Page 3 of 3
Amazon.com Services, LLC - Salt Lake City Facility
Best Available Control Technology Review
Apparel Printing
Pollutant Control Analysis - Type Analysis - Determination
Carbon Adsorption System (CAS)Technical Feasibility
CAS has been included in this review because CASs are used
to control VOC emissions. However, a CAS is typically
employed to control vapors from single component VOCs or
simple mixtures. The inks employed for the proposed printing
operations have a VOC speciation that varies significantly from
one color to the next. Additionally, the fixation agent used for
apparel printing contains formic acid which will corrode the
carbon material in the CAS resulting in both ineffective VOC
capture as well as the generation of an additional solid waste
stream at the faciltiy due to the need to frequently replace the
carbon material.
Therefore, Amazon.com Services, LLC (Amazon) asserts that a
CAS is not a technically feasible control technology to be
employed in this situation and should not be considered BACT
for digital printing operations. Review of the various impacts of
employing this control is not warranted.
Flare Technical Feasibility
Flares have been included in this review because flares are
used to control VOC emissions. However, flares are not
typically employed for the purpose of controlling emissions from
printing operations specifically due to the lack of combustibility
of ink vapors. The nature of the flare design and the lack of
combustibility of the ink vapor stream means that unnecessarily
large amounts of natural gas would be required in order to
achieve acceptable ink vapor destruction.
Therefore, Amazon asserts that a flare is not a technically
feasible control technology to be employed in this situation and
should not be considered BACT for digital printing operations.
Review of the various impacts of employing this control is not
warranted.
Low-VOC Inks Technical Feasibility
Low-VOC inks have been included in this review because low-
VOC inks are used to reduce VOC emissions. Printing
operations will use low-VOC inks, however, apparel printing
operations proposed for this site will employ digital ink jet
printers that require proprietary inks from the manufacturer.
These inks may contain as much as 53.1% VOC, depending on
the ink color. A non-proprietary low-VOC ink option is not
available for the proposed apparel operations.
Therefore, Amazon asserts that low-VOC inks are not a
technically feasible control technology to be employed in this
situation and should not be considered BACT for digital printing
operations (apparel only). Review of the various impacts of
employing this control is not warranted.
Technical Feasibility
Water-based inks have been included in this review because
water-based inks are used to reduce VOC emissions. Printing
operations will use water-based inks and the proprietary inks for
apparel printing will contain a minimum of 31.5% water,
depending on the ink color.
Therefore, Amazon asserts that water-based inks are
technically feasible control technology and further impacts will
be evaluated for determining BACT applicability.Energy Impacts There are no energy impacts for this control.
Environmental Impacts
The proprietary, water-based inks require that a solvent be
used within the printers to keep the system unclogged. The use
of this solvent results in liquid waste that requires proper
disposal.
Economic Impacts
Economic impacts are not applicable as the inks to be used are
proprietary to the type of printer and must be sourced from the
manufacturer.
$0/tonOther Considerations N/A
Cost Calculation N/A
Control Feasibility Conclusion Water-Based Inks equate to BACT for this operation and will be
employed.VOC (Ink Vapors)
Water-Based Inks
Amazon.com Services, LLC - Salt Lake City Facility
Best Available Control Technology Review
July 2024
Page 1 of 4
Amazon.com Services, LLC - Salt Lake City Facility
Best Available Control Technology Review
Technical Feasibility
RTO/RCOs have been included in this review because
RTO/RCOs are used to reduce VOC emissions. Unlike flares,
RTO/RCOs are designed to effectively destroy VOC vapors
that are not inherently combustible.
Therefore, Amazon asserts that RTO/RCOs are technically
feasible control technology and further impacts will be
evaluated for determining BACT applicability.
Energy Impacts
An RTO/RCO would require natural gas as fuel and electricity
for any attached monitoring systems and electronics. Assuming
that an RTO with a 5 MMBtu/hr burner and 95% control
efficiency is installed, approximately 43 MMscf/yr of natural gas
would be required. This would equate to approximately 1.55
MMscf natural gas burned for each ton of VOC reduced.
Considering that the proposed apparel printing operations and
other activities at the site are classified as a minor source of
VOCs, Amazon asserts that the additional energy expenditures
to control the proposed amount of VOCs is excessive and
unnecessary.
Environmental Impacts
Natural gas combustion would result in additional NOx
emissions, which is an ozone precursor, as well as additional
emissions of particulate matter. Given the nonattainment status
of the area for PM2.5, avoiding unnecessarily adding to PM
emissions is appropriate.
Considering that the proposed apparel printing operations and
other activities at the site are classified as a minor source of
VOCs, Amazon asserts that the additional environmental
impacts to control the proposed amount of VOCs is excessive
and unnecessary.
Economic Impacts
$217,773.20 / ton
This is both the average cost-effectiveness and incremental
cost-effectiveness because there are no additional costs
associated with the next technically feasible control option
(water-based inks).
Other Considerations
Investment Feasibility Issue - The manufacturer of the inks is
actively working to reduce VOC and HAP content in the inks.
Each new series of inks has been effective in making this
reduction. The latest update was successful in completely
eliminating HAPs from both the yellow and red inks.
Considering that the proposed apparel printing operations and
other activities at the site are classified as a minor source of
VOCs and given that the manufacturer's successful efforts to
Cost Calculation
RTO Equipment Cost - $3,000,000
RTO Installation Cost - $1,200,000
Interest Rate - 8%
Depreciation Schedule - 5 years
Expected Annual Operating Cost - $500,000
Expected Emissions Reduction @ 95% Capture & 95% DRE -
27.79 tpy
Annualized Equipment Cost = (RTO Equipment Cost + RTO
Installation Cost) * [Interest Rate / (1 - (1 + Interest Rate) ^ -
(Depreciation Schedule))]
Annualized Equipment Cost = ($3,000,000 + $1,200,000) *
[0.08 / (1 - (1 + 0.08) ^ - (5))] = $1,051,917.11
Annualized Cost = (Annualized Equipment Cost + Expected
Annual Operating Cost) / Expected Emissions Reduction
Annualized Cost = ($1,051,917.11 + $500,000) / 27.79 tpy =
$217,773.20 / ton
Control Feasibility Conclusion
Given the annualized cost of $217,773.20/ton, the minor source
status of proposed operations, the energy impacts, the
additional environmental impacts, and the manufacturer's
continued efforts to deliver lower VOC and HAP containing inks,
Amazon asserts that installation of an RTO/RCO is not feasible
Water-based inks are BACT for the proposed apparel
printing operations.
VOC (Ink Vapors)
Regenerative Thermal Oxidizer (RTO) or Regenerative Catalytic Oxidizer (RCO)
BACT Conclusion
Amazon.com Services, LLC - Salt Lake City Facility
Best Available Control Technology Review
July 2024
Page 2 of 4
Amazon.com Services, LLC - Salt Lake City Facility
Best Available Control Technology Review
Apparel Dryers
Pollutant Control Analysis - Type Analysis - Determination
Low-NOx Burners Technical Feasibility
Low-NOx burners have been included in this review because
low-NOx burners are used to reduce NOx emissions from
natural gas combustion. However, the dryers proposed to be
used at the site have a burner rating of 0.4 MMBtu/hr and are
expected to emit a combined total of 1.37 tons of NOx per year.
The low burner rating and resulting insignificant emissions
makes retrofitting the dryers unnecessary.
Therefore, Amazon asserts that low-NO x burners are not a
technically feasible control technology to be employed in this
situation and should not be considered BACT for digital printing
operations. Review of the various impacts of employing this
control is not warranted.
Sweet Natural Gas Technical Feasibility
Sweet natural gas has been included in this review because
sweet natural gas is used to reduce emissions from combustion
sources. The apparel dryers are designed to burn natural gas.
Amazon asserts that sweet natural gas is technically feasible
control technology and, considering that the dryers are already
designed to accept that fuel, review of the various impacts of
using sweet natural gas is not warranted.
Sweet natural gas is BACT for the dryers proposed for
apparel printing operations.
Non-Apparel Printing
Pollutant Control Analysis - Type Analysis - Determination
Carbon Adsorption System Technical Feasibility
CAS has been included in this review because CASs are used
to control VOC emissions. However, a CAS is typically
employed to control vapors from single component VOCs or
simple mixtures. The inks employed for the proposed printing
operations have a VOC speciation that varies significantly from
one color to the next. Finally, emissions from non-apparel
printing are insignificant at no more than 0.2 tpy for a single
printer per year.
Therefore, Amazon asserts that a CAS is not a technically
Flare Technical Feasibility
Flares have been included in this review because flares are
used to control VOC emissions. However, flares are not
typically employed for the purpose of controlling emissions from
printing operations specifically due to the lack of combustibility
of ink vapors. The nature of the flare design and the lack of
combustibility of the ink vapor stream means that unnecessarily
large amounts of natural gas would be required in order to
achieve acceptable ink vapor destruction. Finally, emissions
from non-apparel printing are insignificant at no more than 0.2
tpy for a single printer per year.
Therefore, Amazon asserts that a flare is not a technically
Water-Based Inks Technical Feasibility
Water-based inks have been included in this review because
water-based inks are used to reduce VOC emissions. Printing
operations will use water-based inks, however, non-apparel
printing operations proposed for this site will employ digital ink
jet printers that require proprietary inks from the manufacturer.
These inks are not water-based.
Therefore, Amazon asserts that water-based inks are not a
technically feasible control technology to be employed in this
situation and should not be considered BACT for digital printing
operations (non-apparel only). Review of the various impacts
of employing this control is not warranted.
BACT Conclusion
VOC (Ink Vapors)
Products of Combustion
(NOx, SO2, PM, VOC, CO)
Amazon.com Services, LLC - Salt Lake City Facility
Best Available Control Technology Review
July 2024
Page 3 of 4
Amazon.com Services, LLC - Salt Lake City Facility
Best Available Control Technology Review
Technical Feasibility
Low-VOC inks have been included in this review because they
are used to reduce VOC emissions. Printing operations will use
low-VOC inks and the proprietary inks for non-apparel printing
will contain a maximum of 27.6% VOC.
Therefore, Amazon asserts that low-VOC inks are technically
feasible control technology and further impacts will be
evaluated for determining BACT applicability.
Energy Impacts There are no energy impacts for this control.
Environmental Impacts
The proprietary, low-VOC inks used in one of the two non-
apparel production lines require that a solvent be used within
the printers to keep the system unclogged. The use of this
solvent results in liquid waste that requires proper disposal.
Economic Impacts
Economic impacts are not applicable as the inks to be used are
proprietary to the type of printer and must be sourced from the
manufacturer.
$0/ton
Other Considerations N/A
Cost Calculation N/A
Control Feasibility Conclusion Low-VOC inks equate to BACT for this operation and will be
employed.
Regenerative Thermal Oxidizer (RTO) or Regenerative Catalytic Oxidizer (RCO)Technical Feasibility
RTO/RCOs have been included in this review because
RTO/RCOs are used to reduce VOC emissions. Unlike flares,
RTO/RCOs are designed to effectively destroy VOC vapors
that are not inherently combustible. However, emissions from
non-apparel printing are insignificant at no more than 0.2 tpy for
a single unit per year. Additionally, no dryers or stacks are
associated with non-apparel printing operations. Using an
RTO/RCO would require Amazon to install forced air ventilation
systems to capture insignificant amounts of VOCs.
Therefore, Amazon asserts that RTO/RCOs not a technically
feasible control technology to be employed in this situation and
should not be considered BACT for non-apparel digital printing
operations. Review of the various impacts of employing this
control is not warranted.
Low-VOC inks are BACT for the proposed non-apparel
printing operations.
Notes:
Cost calculation methodology was developed based on https://deq.utah.gov/legacy/destinations/u/uintah-basin/ozone/docs/2013/03Mar/Form01b.pdf
Definitions:
PM - Particulate Matter
VOC - Volatile Organic Compound
NOx - Nitrogen Oxides
CO - Carbon Monoxide
tpy - tons per year
MMBtu/hr - Million British thermal units per hour
MMscf/yr - Million standard cubic feet per year
BACT - Best Available Control Technology
VOC (Ink Vapors)
Low-VOC Inks
BACT Conclusion
Amazon.com Services, LLC - Salt Lake City Facility
Best Available Control Technology Review
July 2024
Page 4 of 4
Amazon.com Services, LLC - Salt Lake City Facility
Health Effects Emission Thresholds
Chemical Name CAS NO.TLV-TWA
(mg/m3)
TLV-C
(mg/m3)
Emission Threshold
Factor Table 2
(cubic meter pounds
per milligram hour)
Emissions
Threshold
(lb/hr)
Proposed
Emissions
(lb/hr)
Stack Emissions
Ethylene Glycol 107-21-1 63.47 --0.154 9.7744 0.1663
Fugitive Emissions
Ethylene Glycol 107-21-1 63.47 --0.038 2.4119 0.1026
Triethylene Glycol Monomethyl Ether 112-35-6 0.038 --0.1971
Calculation Methodology
Emissions Threshold = TLV-TWA * Emission Threshold Factor Table 2
Definitions
TLV - Threshold Limit Value
TWA - Time Weighted Average
C - Ceiling
Notes:
TLV-TWA values obtained from American Council of Government and Industrial Hygienists (ACGIH) 2018 Threshold Limit Values for Chemical Substances and Physical Agents Biological Exposure Indices
TLV-C Values obtained from American Council of Government and Industrial Hygienists (ACGIH) 2018 Threshold Limit Values for Chemical Substances and Physical Agents Biological Exposure Indices
Justification For Modeling Requirements
NAAQS
Health Effects Review
Air dispersion modeling for Hazardous Air Pollutants (HAP) was not performed in this permit application as the proposed HAP emissions are below the calculated emissions threshold for each pollutant. The
emissions threshold was calculated using the methodology outlined in R307-410-5 (C).
R307-410-5 Table 2 Emissions Threshold Factor for stack emissions was selected for Vertically-Unrestricted Emission Release Points for the acute category with a distance to property boundary of 50 meters
or less.
R307-410-5 Table 2 Emissions Threshold Factor for fugitive emissions was selected for Vertically-Resticted and Fugitive Emission Release Points for the acute category with a distance to property boundary
of 50 meters or less.
Air dispersion modeling for National Ambient Air Quality Standards was not performed in this permit application as the proposed emissions for criteria pollutants was below the ton per year threshold listed it
R307-410-4 Table 1
None Established
Amazon.com Services, LLC - Salt Lake City Facility
Health Effects Emission Thresholds
July 2024
Page 1 of 1
Amazon.com Services, LLC - Salt Lake City Facility
Emissions Summary
Hours of Operation (hr/day)24
Hours of Operation - Printers (hr/yr)8,760
Hours of Operation - Dryers (hr/yr)8,760
No. of Apparel Printers 24
Production per Apparel Printer (units/hr)60
Total Hourly Apparel Printer Production (units/hr)1,440
Total Apparel Printer Production (units/yr)12,614,400
No. of Dryers 8
Dryer Collection Efficiency (%) - Apparel Printing Operations 95%
Dryer Collection Efficiency (%) - Apparel Cleanup Operations 0%
Dryer Collection Efficiency (%) - Other Printing and Cleanup Operations 0%
Control Efficiency (%)0%
No. of UV Printers 12
Production per UV Printer (units/hr)135
Total Hourly UV Printer Production (units/hr)1,620
Total UV Printer Production (units/yr)14,191,200
No. of Sublimation Printers 20
Production per Sublimation Printer (units/hr)144
Total Hourly Sublimation Printer Production (units/hr)2,880
Total Sublimation Printer Production (units/yr)25,228,800
No. of DTF Apparel Printers 6
Production per DTF Apparel Printer (units/hr)60
Total Hourly DTF Apparel Printer Production (units/hr)360
Total DTF Apparel Printer Production (units/yr)3,153,600
lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy
Building Fugitive Emissions - Apparel Printing (95% Collection Efficiency)0.0706 0.3092 0.0088 0.0383 ------------------------------------
Building Fugitive Emissions - Cell Phone Ring Stand Printing 0.0062 0.0270 ----------------------------------------
Building Fugitive Emissions - Mug/Cell Phone Case Printing 1.0722 4.6962 0.1971 0.8633 ------------------------------------
Building Fugitive Emissions - DTF Apparel Printing 1.7419 5.0137 0.0939 0.2466 ------------------------------------
Building Fugitive Emissions - Apparel Printing Cleanup 0.6681 0.1219 ----------------------------------------
Building Fugitive Emissions - Cell Phone Ring Stand Printing Cleanup 8.4455 0.0507 ----------------------------------------
Building Fugitive Emissions - DTF Apparel Printing Cleanup 0.3155 0.0576 ----------------------------------------
Building Fugitives Sum 12.3200 10.2764 0.2997 1.1483 ------------------------------------
Dryer Stack Emissions - Dryer Combustion 0.0173 0.0756 ----0.3137 1.3741 0.2635 1.1543 0.0019 0.0082 0.0238 0.1044 0.0238 0.1044 0.0238 0.1044 0.0004 0.0016 0.0071 0.0309 0.0007 0.0031
Dryer Stack Emissions - Apparel Printing (95% Collection Efficiency)1.3414 5.8753 0.1663 0.7285 ------------------------------------
Dryer Stack Emissions Sum 1.3587 5.9509 0.1663 0.7285 0.3137 1.3741 0.2635 1.1543 0.0019 0.0082 0.0238 0.1044 0.0238 0.1044 0.0238 0.1044 0.0004 0.0016 0.0071 0.0309 0.0007 0.0031
13.68 16.23 0.47 1.88 0.31 1.37 0.26 1.15 0.002 0.01 0.02 0.10 0.02 0.10 0.02 0.10 0.0004 0.002 0.01 0.03 0.001 0.003
18.93 35.66 1.84 4.58 0.37 1.38 0.31 1.16 0.002 0.01 0.03 0.10 0.03 0.10 0.03 0.10 --0.003 --0.34 --0.05
-5.25 -19.43 -1.37 -2.70 -0.05 -3.18E-03 -0.04 -2.67E-03 -3.14E-04 -1.91E-05 -3.97E-03 -2.42E-04 -3.97E-03 -2.42E-04 -3.97E-03 -2.42E-04 ---1.36E-03 ---0.31 ---0.05
--100 --10/25 --100 --100 --100 --100 --100 --100 ------------
Notes:
Proposed Emissions (lb/hr) & (tpy) = Sum all Activity - Building Fugitives Sum - Dryer Stack Emissions Sum
Major Source/Title V Thresholds
Building
Fugitives
Dryer Stacks
Proposed Emissions
Currently Permitted Emissions
Change in Permitted Emissions
CO2 CH4 N2OPM2.5ActivityVOCHAPsNOXCOEmissions
Release Point
SO2 PM PM10
Amazon.com Services, LLC - Salt Lake City Facility
Emissions Summary
July 2024
Page 1 of 15
Amazon.com Services, LLC - Salt Lake City Facility
Consumption Estimates
Apparel Printing Emissions Data
Kornit Ink/Fixation VOC Emissions
(lb/hr)
HAP Emissions
(lb/hr)
Kornit EcoRapid Ink/Fixation 1.4120 0.1751
VOC Emissions are based on maximum stack test results from stack testing conducted at a similar facility (Amazon DFW5) on December 17, 2020.
HAP Emissions are based on VOC Emissions and the maximum weight percent of HAP in the inks.
PM emissions are not expected from these printing operations; therefore, the solids content of the inks is not evaluated.
A safety factor of 100% is applied to the hourly rates for conservatism.
UV Printer Application Data
Mimaki Ink Color Product Density
(g/ml) or (g/cm3)
Maximum
Production
(units/hr)
Print Volume
(cm3/unit)
Application
Rate*
(g/unit)
Emission
Rate**
(g/unit)
RTI Method
24 VOC
Content
HAP Content RTI Method
24 Sample ID
Cyan 1.09 22.50%0.00%S-32
Magenta 1.09 25.60%0.00%S-33
Yellow 1.09 27.60%0.00%S-35
Black 1.09 23.80%0.00%S-31
White 1.18 18.10%0.00%S-34
* A jig can hold up to 27 individual cell phone ring stand units. Each cell phone ring stand unit consumes 0.025 g of ink.
PM emissions are not expected from these printing operations; therefore, the solids content of the inks is not evaluated.
Max VOC and HAP content used for hourly and annual estimates.
Sublimation Printer Application Data
Epson Ink Color Product Density
(g/ml) or (g/cm3)
Print Volume*
(cm3/unit)
Application Rate
(g/unit)
RTI Method 24
VOC Content HAP Content RTI Method
24 Sample ID
Cyan (412)1.09 20.10%5%S-70
Magenta (413)1.10 13.40%5%S-71
Yellow (414)1.09 27.20%5%S-72
Black (411)1.09 20.30%5%S-69
* Based on assuming a worst case ink usage rate of four times the total average of all inks used on a single unit (0.141 mL per unit).
PM emissions are not expected from these printing operations; therefore, the solids content of the inks is not evaluated.
Max VOC and HAP content used for hourly and annual estimates.
DTF Apparel Printer Application Data
Consumable Product Density
(g/ml)
Application Rate*
(ml/unit)
Application Rate
(g/unit)
Max VOC
Content
Average VOC
Content
Max HAP
Content
Average HAP
Content
CMYK Ink 1.07 1.44 1.54 35.00%23.00%0.00%0.00%
White Ink 1.10 2.15 2.37 70.00%46.00%5.00%3.00%
Cleaning Solution 1.00 0.55 0.55 6.00%6.00%0.00%0.00%
* Based on R&D testing.
PM emissions are not expected from these printing operations; therefore, the solids content of the inks is not evaluated.
Except for the cleaning solution, max VOC/HAP content is used to estimate hourly emissions and average VOC/HAP content is used to estimate annual
emissions.
0.025
0.57 0.62
135.00 0.02 0.006
** Per U.S. EPA Technical Bulletin: Ultraviolet and Electron Beam Cured Coatings, Inks, and Adhesives , virtually all components of a UV formulation become a solid part of a
cured coating, ink, or adhesive. Generally, only small amounts of VOC may be emitted. Therefore, it is conservatively assumed that 25% of the ink application rate is emitted to
the environment.
Amazon.com Services, LLC - Salt Lake City Facility
Consumption Estimates
July 2024
Page 2 of 15
Amazon.com Services, LLC - Salt Lake City Facility
Apparel Printing Emissions Calculations - 95% Collection
Hourly Emissions Products
Parameter Units of measurement Ink/Fixation
Uncollected
Uncontrolled
Hourly Emissions
(lb/hr)
Collection
Efficiency %
Collected
Uncontrolled
Hourly Emissions
(lb/hr)
Control Efficiency
%
Building Fugitive
Emissions
(lb/hr)
Collected Stack
Hourly Emissions
(lb/hr)
Total Building
Fugitive and
Collected Stack
Hourly Emissions
(lb/hr)
VOC hourly emissions lb/hr 1.4120 1.4120 95.00%1.3414 0.00%0.0706 1.3414 1.4120
HAP hourly emissions lb/hr 0.1751 0.1751 95.00%0.1663 0.00%0.0088 0.1663 0.1751
Annual Emissions Products
Parameter Units of measurement Ink/Fixation
Uncollected
Uncontrolled
Annual Emissions
(tpy)
Collection
Efficiency %
Collected
Uncontrolled
Annual Emissions
(tpy)
Control Efficiency
%
Building Fugitive
Emissions
(tpy)
Collected Stack
Annual Emissions
(tpy)
Total Building
Fugitive and
Collected Stack
Annual Emissions
(tpy)
operating schedule hr/yr 8,760
VOC annual emissions tpy 6.1846 6.1846 95.00%5.8753 0.00%0.3092 5.8753 6.1846
HAP annual emissions tpy 0.7669 0.7669 95.00%0.7285 0.00%0.0383 0.7285 0.7669
Cleanup Solvent (assumes all building fugitives as cleanup is at the printer)
Parameter Units of measurement Wiping Fluid
Uncollected
Uncontrolled
Emissions
(lb/hr)
Uncollected
Uncontrolled
Emissions
(tpy)
Building Fugitives
Emissions
(lb/hr)
Building Fugitives
Emissions
(tpy)
Stack Emissions
(lb/hr)
Stack Emissions
(tpy)
consumption rate per hour* gal/hr 3.95
consumption rate per day gal/day 3.95
consumption rate per year gal/yr 1,440
product density g/ml 1.01
product density lb/gal 8.43
consumption rate per hour lb/hr 33.25
consumption rate per day lb/day 33.25
consumption rate per year lb/yr 12,137.55
Estimated Collection Efficiency % 0.00%
Control Efficiency % 0.00%
%VOC from formulation [VOC emissions] % 2.0%0.6681 0.1219 0.6681 0.1219 ----
%HAP from formulation [HAP emissions] % 0.00%------------
*consumption rate per hour assumes that all daily usage can be utilized in one hour (worst case)
Amazon.com Services, LLC - Salt Lake City Facility
Apparel Printing Emissions Calculations - 95% Collection
July 2024
Page 3 of 15
Amazon.com Services, LLC - Salt Lake City Facility
Apparel Printing Emissions Calculations - 95% Collection
Printing Notes:
Hourly Emissions
VOC hourly emissions (lb/hr) = maximum stack test results from stack testing conducted on December 17, 2020
VOC hourly emissions: Uncollected Uncontrolled Hourly Emissions (lb/hr) = VOC hourly emissions (lb/hr)
VOC hourly emissions: Collected Uncontrolled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency %
VOC hourly emissions: Building Fugitive Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * (1 – Collection Efficiency %)
VOC hourly emissions: Collected Stack Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency % * (1 - Control Efficiency %)
VOC hourly emissions: Total Building Fugitive and Collected Stack Hourly Emissions (lb/hr) = Building Fugitive Emissions (lb/hr) + Collected Stack Hourly Emissions (lb/hr)
HAP hourly emissions (lb/hr) = VOC hourly emissions (lb/hr) * Maximum HAP Weight Percent of All Inks (%)
HAP hourly emissions: Uncollected Uncontrolled Hourly Emissions (lb/hr) = HAP hourly emissions (lb/hr)
HAP hourly emissions: Collected Uncontrolled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency %
HAP hourly emissions: Building Fugitive Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * (1 – Collection Efficiency %)
HAP hourly emissions: Collected Stack Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency % * (1 - Control Efficiency %)
HAP hourly emissions: Total Building Fugitive and Collected Stack Hourly Emissions (lb/hr) = Building Fugitive Emissions (lb/hr) + Collected Stack Hourly Emissions (lb/hr)
Annual Emissions
VOC annual emissions (tpy) = VOC hourly emissions (lb/hr) * 8,760 (hr/yr) / 2,000 (lb/ton)
VOC annual emissions (tpy): Uncollected Uncontrolled Annual Emissions (tpy) = Sum of VOC annual emissions (tpy)
VOC annual emissions (tpy): Collected Uncontrolled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency %
VOC annual emissions (tpy): Building Fugitive Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * (1 – Collection Efficiency %)
VOC annual emissions (tpy): collected stack Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency % * (1 - Control Efficiency %)
VOC annual emissions (tpy): Total Building Fugitive and Collected Stack Annual Emissions (tpy) = Building Fugitive Emissions (tpy) + Collected Stack Annual Emissions (tpy)
HAP annual emissions (tpy) = HAP hourly emissions (lb/hr) * 8,760 (hr/yr) / 2,000 (lb/ton)
HAP annual emissions (tpy): Uncollected Uncontrolled Annual Emissions (tpy) = Sum of HAP annual emissions (tpy)
HAP annual emissions (tpy): Collected Uncontrolled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency %
HAP annual emissions (tpy): Building Fugitive/Roof Stack Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * (1 – Collection Efficiency %)
HAP annual emissions (tpy): Collected Stack Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency % * (1 - Control Efficiency %)
HAP annual emissions (tpy): Total Building Fugitive and Collected Stack Annual Emissions (tpy) = Building Fugitive Emissions (tpy) + Collected Stack Annual Emissions (tpy)
Cleanup Solvent Notes:
Hourly Emissions
consumption rate per hour (gal/hr) = consumption rate per day (gal/day) [assumes that all daily usage can be utilized in one hour (worst case)]
consumption rate per day (gal/day) = consumption rate per year (gal/yr) / 365 (day/yr)
consumption rate per year (gal/yr) = conservative estimate
product density (g/ml) = per product SDS
product density (lb/gal) = product density (g/ml) * 8.3454
consumption rate per hour (lb/hr) = consumption rate (gal/hr) * product density (lb/gal)
consumption rate per day (lb/day) = consumption rate (gal/day) * product density (lb/gal)
consumption rate per year (lb/yr) = consumption rate (gal/yr) * product density (lb/gal)
VOC hourly emissions: Uncollected Uncontrolled Emissions (lb/hr) = consumption rate per hour (lb/hr) * %VOC from formulation
VOC hourly emissions: Building Fugitives (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * (1 - Collection Efficiency %)
VOC hourly emissions: Stack Emissions (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * Collection Efficiency % * (1 - Control Efficiency %)
HAP hourly emissions: Uncollected Uncontrolled Emissions (lb/hr) = consumption rate per hour (lb/hr) * %HAP from formulation
HAP hourly emissions: Building Fugitives (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * (1 - Collection Efficiency %)
HAP hourly emissions: Stack Emissions (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * Collection Efficiency % * (1 - Control Efficiency %)
Annual Emissions
consumption rate per year (lb/yr) = consumption rate per year (gal/yr) * product density (lb/gal)
VOC annual emissions: Uncollected Uncontrolled Emissions (tpy) = consumption rate per year (lb/yr) * %VOC from formulation / 2000 (lb/ton)
VOC annual emissions: Building Fugitives (tpy) = Uncollected Uncontrolled Emissions (tpy) * (1 - Collection Efficiency %)
VOC annual emissions: Stack Emissions (tpy) = Uncollected Uncontrolled Emissions (tpy) * Collection Efficiency % * (1 - Control Efficiency %)
HAP annual emissions: Uncollected Uncontrolled Emissions (tpy) = consumption rate per hour (tpy) * %HAP from formulation
HAP annual emissions: Building Fugitives (tpy) = Uncollected Uncontrolled Emissions (tpy) * (1 - Collection Efficiency %)
HAP annual emissions: Stack Emissions (tpy) = Uncollected Uncontrolled Emissions (tpy) * Collection Efficiency % * (1 - Control Efficiency %)
Amazon.com Services, LLC - Salt Lake City Facility
Apparel Printing Emissions Calculations - 95% Collection
July 2024
Page 4 of 15
Amazon.com Services, LLC - Salt Lake City Facility
Cell Phone Ring Stand Emissions Calculations
Hourly Emissions Products
Parameter Units of measurement Ink
Uncollected
Uncontrolled
Hourly Emissions
(lb/hr)
Collection
Efficiency %
Collected
Uncontrolled
Hourly Emissions
(lb/hr)
Control Efficiency
%
Building Fugitive
Emissions
(lb/hr)
Collected
Controlled Hourly
Emissions
(lb/hr)
Total Building
Fugitive and
Collected
Controlled Hourly
Emissions
(lb/hr)
operating printers printer 12
single printer production rate unit/hr per printer 135
site hourly production rate unit/hr 1620
emission rate per unit g/unit 0.006
emission rate per hour g/hr 10.13
emission rate per hour lb/hr 0.0223
Max %VOC from formulation %27.60%
VOC hourly emissions lb/hr 0.0062 0.0062 0.00%--0.00%0.0062 --0.0062
%HAP from formulation %0.00%
HAP hourly emissions lb/hr 0.0000 --0.00%--0.00%------
Annual Emissions Products
Parameter Units of measurement Ink
Uncollected
Uncontrolled
Annual Emissions
(tpy)
Collection
Efficiency %
Collected
Uncontrolled
Annual Emissions
(tpy)
Control Efficiency
%
Building Fugitive
Emissions
(tpy)
Collected
Controlled Annual
Emissions
(tpy)
Total Building
Fugitive and
Collected
Controlled Annual
Emissions
(tpy)
operating schedule day/yr 365
operating schedule hr/day 24
operating schedule hr/yr 8,760
production rate unit/yr 14,191,200
annual emission rate g/yr 88,695.0000
annual emission rate lb/yr 195.5388
total consumption tpy 0.0978
Collection Efficiency % 0.00%
Control Efficiency % 0.00%
Max %VOC from formulation %27.60%
VOC annual emissions tpy 0.0270 0.0270 0.00%--0.00%0.0270 --0.0270
Max %HAP from formulation %0.00%
HAP annual emissions tpy 0.0000 --0.00%--0.00%------
Amazon.com Services, LLC - Salt Lake City Facility
Cell Phone Ring Stand Emissions Calculations
July 2024
Page 5 of 15
Amazon.com Services, LLC - Salt Lake City Facility
Cell Phone Ring Stand Emissions Calculations
Cleanup Solvent (assumes all building fugitives as cleanup is at the printer)
Parameter Units of measurement Washing Fluid
Uncollected
Uncontrolled
Emissions
(lb/hr)
Uncollected
Uncontrolled
Emissions
(tpy)
Building Fugitives
Emissions
(lb/hr)
Building Fugitives
Emissions
(tpy)
Stack Emissions
(lb/hr)
Stack Emissions
(tpy)
consumption rate per hour* gal/hr 1.00
consumption rate per day gal/day 1.00
average monthly consumption rate gal/month 1.00
consumption rate per year gal/yr 12.00
product density g/ml 1.01
product density lb/gal 8.45
consumption rate per hour lb/hr 8.45
consumption rate per day lb/day 8.45
average monthly consumption rate lb/month 8.45
consumption rate per year lb/yr 101.35
Collection Efficiency % 0.00%
Control Efficiency % 0.00%
%VOC from formulation [VOC emissions] % 100.00%8.4455 0.0507 8.4455 0.0507 ----
%HAP from formulation [HAP emissions] % 0.00%------------
*consumption rate per hour assumes that all daily usage can be utilized in one hour (worst case)
Amazon.com Services, LLC - Salt Lake City Facility
Cell Phone Ring Stand Emissions Calculations
July 2024
Page 6 of 15
Amazon.com Services, LLC - Salt Lake City Facility
Cell Phone Ring Stand Emissions Calculations
Printing Notes:
Hourly Emissions
operating printers (printer) = number of printers installed
single printer production rate (unit/hr per printer) = number of units that can be printed per hour per printer
site hourly production rate (unit/hr) = operating printers (# printers) * single printer production rate (unit/hr per printer)
emission rate per hour (g/hr) = production rate (unit/hr) * emission rate per unit (g/unit) [refer to Consumption Estimates]
emission rate per hour (lb/hr) = emission rate (g/hr) * 0.00220462 (lb/g)
VOC hourly emissions (lb/hr) = emission rate per hour (lb/hr) * Max %VOC from formulation
VOC hourly emissions: Uncollected Uncontrolled Hourly Emissions (lb/hr) = VOC hourly emissions (lb/hr)
VOC hourly emissions: Collected Uncontrolled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency %
VOC hourly emissions: Building Fugitive Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * (1 – Collection Efficiency %)
VOC hourly emissions: Collected Controlled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency % * (1 - Control Efficiency %)
VOC hourly emissions: Total Building Fugitive and Collected Controlled Hourly Emissions (lb/hr) = Building Fugitive Emissions (lb/hr) + Collected Controlled Hourly Emissions (lb/hr)
HAP hourly emissions (lb/hr) = emission rate per hour (lb/hr) * %HAP from formulation
HAP hourly emissions: Uncollected Uncontrolled Hourly Emissions (lb/hr) = HAP hourly emissions (lb/hr)
HAP hourly emissions: Collected Uncontrolled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency %
HAP hourly emissions: Building Fugitive Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * (1 – Collection Efficiency %)
HAP hourly emissions: Collected Controlled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency % * (1 - Control Efficiency %)
HAP hourly emissions: Total Building Fugitive and Collected Controlled Hourly Emissions (lb/hr) = Building Fugitive Emissions (lb/hr) + Collected Controlled Hourly Emissions (lb/hr)
Annual Emissions
operating schedule (hr/yr) = operating schedule (day/yr) * operating schedule (hr/day)
production rate (unit/yr) = production rate (unit/hr) * operating schedule (hr/yr)
annual emission rate (g/yr) = emission rate per hour (g/hr) * operating schedule (hr/yr)
annual emission rate (lb/yr) = annual emission rate (g/yr) * 0.00220462 (lb/g)
total emission (tpy) = annual emission rate (lb/yr) / 2,000 (lb/ton)
VOC annual emissions (tpy) = total emission (tpy) * Max %VOC from formulation
VOC annual emissions (tpy): Uncollected Uncontrolled Annual Emissions (tpy) = VOC annual emissions (tpy)
VOC annual emissions (tpy): Collected Uncontrolled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency %
VOC annual emissions (tpy): Building Fugitive Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * (1 – Collection Efficiency %)
VOC annual emissions (tpy): Collected Controlled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency % (1 - Control Efficiency %)
VOC annual emissions (tpy): Total Building Fugitive and Collected Controlled Annual Emissions (tpy) = Building Fugitive Emissions (tpy) + Collected Controlled Annual Emissions (tpy)
HAP annual emissions (tpy) = total consumption (tpy) * Max %HAP from formulation
HAP annual emissions (tpy): Uncollected Uncontrolled Annual Emissions (tpy) = HAP annual emissions (tpy)
HAP annual emissions (tpy): Collected Uncontrolled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency %
HAP annual emissions (tpy): Building Fugitive Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * (1 – Collection Efficiency %)
HAP annual emissions (tpy): Collected Controlled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency % * (1 - Control Efficiency %)
HAP annual emissions (tpy): Total Building Fugitive and Collected Controlled Annual Emissions (tpy) = Building Fugitive Emissions (tpy) + Collected Controlled Annual Emissions (tpy)
Cleanup Solvent Notes:
Hourly Emissions
consumption rate per hour (gal/hr) = consumption rate per day (gal/day) [assumes that all daily usage can be utilized in one hour (worst case)]
consumption rate per day (gal/day) = consumption rate per month (gal/month) [assumes that all monthly usage can be utilized in one day (worst case)]
average monthly consumption rate (gal/month) = consumption rate per year (gal/yr) / 12 (month/yr)
consumption rate per year (gal/yr) = conservative estimate
product density (g/ml) = per product SDS
product density (lb/gal) = product density (g/ml) * 8.3454
consumption rate per hour (lb/hr) = consumption rate (gal/hr) * product density (lb/gal)
consumption rate per day (lb/day) = consumption rate (gal/day) * product density (lb/gal)
average monthly consumption rate (lb/month) = average monthly consumption rate (gal/month) * product density (lb/gal)
VOC hourly emissions: Uncollected Uncontrolled Emissions (lb/hr) = consumption rate per hour (lb/hr) * %VOC from formulation
VOC hourly emissions: Building Fugitives (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * (1 - Collection Efficiency %)
VOC hourly emissions: Stack Emissions (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * Collection Efficiency * (1 - Control Efficiency %)
HAP hourly emissions: Uncollected Uncontrolled Emissions (lb/hr) = consumption rate per hour (lb/hr) * %HAP from formulation
HAP hourly emissions: Building Fugitives (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * (1 - Collection Efficiency %)
HAP hourly emissions: Stack Emissions (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * Collection Efficiency * (1 - Control Efficiency %)
Annual Emissions
consumption rate per year (lb/yr) = consumption rate per year (gal/yr) * product density (lb/gal)
VOC annual emissions: Uncollected Uncontrolled Emissions (tpy) = consumption rate per year (lb/yr) * %VOC from formulation / 2000 (lb/ton)
VOC annual emissions: Building Fugitives (tpy) = Uncollected Uncontrolled Emissions (tpy) * (1 - Collection Efficiency %)
VOC annual emissions: Stack Emissions (tpy) = Uncollected Uncontrolled Emissions (tpy) * Collection Efficiency * (1 - Control Efficiency %)
HAP annual emissions: Uncollected Uncontrolled Emissions (tpy) = consumption rate per hour (tpy) * %HAP from formulation
HAP annual emissions: Building Fugitives (tpy) = Uncollected Uncontrolled Emissions (tpy) * (1 - Collection Efficiency %)
HAP annual emissions: Stack Emissions (tpy) = Uncollected Uncontrolled Emissions (tpy) * Collection Efficiency * (1 - Control Efficiency %)
Amazon.com Services, LLC - Salt Lake City Facility
Cell Phone Ring Stand Emissions Calculations
July 2024
Page 7 of 15
Amazon.com Services, LLC - Salt Lake City Facility
Miscellaneous Products Printing Emissions Calculations
Hourly Emissions Products
Parameter Units of measurement Ink
Uncollected
Uncontrolled
Hourly Emissions
(lb/hr)
Collection
Efficiency %
Collected
Uncontrolled
Hourly Emissions
(lb/hr)
Control Efficiency
%
Building Fugitive
Emissions
(lb/hr)
Collected
Controlled Hourly
Emissions
(lb/hr)
Total Building
Fugitive and
Collected
Controlled Hourly
Emissions
(lb/hr)
operating printers printer 20
single printer production rate unit/hr per printer 144
site hourly production rate unit/hr 2880
consumption rate per unit* gr/unit 0.62
consumption rate per hour gr/hr 1,788.0221
consumption rate per hour lb/hr 3.9419
Max %VOC from formulation %27.20%
VOC hourly emissions lb/hr 1.0722 1.0722 0.00%--0.00%1.0722 --1.0722
Max %HAP from formulation %5.00%
HAP hourly emissions lb/hr 0.1971 0.1971 0.00%--0.00%0.1971 --0.1971
*Based on assuming a worst case ink usage rate of four times the total average of all inks used on a single unit (0.141 mL per unit).
Annual Emissions Products
Parameter Units of measurement Ink
Uncollected
Uncontrolled
Annual Emissions
(tpy)
Collection
Efficiency %
Collected
Uncontrolled
Annual Emissions
(tpy)
Control Efficiency
%
Building Fugitive
Emissions
(tpy)
Collected
Controlled Annual
Emissions
(tpy)
Total Building
Fugitive and
Collected
Controlled Annual
Emissions
(tpy)
operating schedule day/yr 365
operating schedule hr/day 24
operating schedule hr/yr 8,760
production rate unit/yr 25,228,800
annual consumption rate gr/yr 15,663,073.7404
annual consumption rate lb/yr 34,531.1256
average monthly consumption rate lb/month 2,877.5938
total consumption tpy 17.2656
Collection Efficiency % 0.00%
Control Efficiency % 0.00%
Max %VOC from formulation %27.20%
VOC annual emissions tpy 4.6962 4.6962 0.00%--0.00%4.6962 --4.6962
Max %HAP from formulation %5.00%
HAP annual emissions tpy 0.8633 0.8633 0.00%--0.00%0.8633 --0.8633
Amazon.com Services, LLC - Salt Lake City Facility
Miscellaneous Products Printing Emissions Calculations
July 2024
Page 8 of 15
Amazon.com Services, LLC - Salt Lake City Facility
Miscellaneous Products Printing Emissions Calculations
Printing Notes:
Hourly Emissions
operating printers (printer) = number of printers installed
single printer production rate (unit/hr per printer) = number of units that can be printed per hour per printer
site hourly production rate (unit/hr) = operating printers (# printers) * single printer production rate (unit/hr per printer)
consumption rate per hour (g/hr) = production rate (unit/hr) * consumption rate per unit (g/unit) [refer to Consumption Estimates]
consumption rate per hour (lb/hr) = consumption rate (g/hr) * 0.00220462 (lb/g)
VOC hourly emissions (lb/hr) = consumption rate per hour (lb/hr) * Max %VOC from formulation
VOC hourly emissions: Uncollected Uncontrolled Hourly Emissions (lb/hr) = VOC hourly emissions (lb/hr)
VOC hourly emissions: Collected Uncontrolled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency %
VOC hourly emissions: Building Fugitive Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * (1 – Collection Efficiency %)
VOC hourly emissions: Collected Controlled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency % * (1 - Control Efficiency %)
VOC hourly emissions: Total Building Fugitive and Collected Controlled Hourly Emissions (lb/hr) = Building Fugitive Emissions (lb/hr) + Collected Controlled Hourly Emissions (lb/hr)
HAP hourly emissions (lb/hr) = consumption rate per hour (lb/hr) * Max %HAP from formulation
HAP hourly emissions: Uncollected Uncontrolled Hourly Emissions (lb/hr) = HAP hourly emissions (lb/hr)
HAP hourly emissions: Collected Uncontrolled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency %
HAP hourly emissions: Building Fugitive Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * (1 – Collection Efficiency %)
HAP hourly emissions: Collected Controlled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Collection Efficiency % * (1 - Control Efficiency %)
HAP hourly emissions: Total Building Fugitive and Collected Controlled Hourly Emissions (lb/hr) = Building Fugitive Emissions (lb/hr) + Collected Controlled Hourly Emissions (lb/hr)
Annual Emissions
operating schedule (hr/yr) = operating schedule (day/yr) * operating schedule (hr/day)
production rate (unit/yr) = production rate (unit/hr) * operating schedule (hr/yr)
annual consumption rate (gr/yr) = consumption rate per hour (gr/hr) * operating schedule (hr/yr)
annual consumption rate (lb/yr) = annual consumption rate (gr/yr) * 0.00220462 (lb/gr)
average monthly consumption rate (lb/month) = annual consumption rate (lb/yr) / 12 (month/yr)
total consumption (tpy) = annual consumption rate (lb/yr) / 2,000 (lb/ton)
VOC annual emissions (tpy) = total consumption (tpy) * Max %VOC from formulation
VOC annual emissions (tpy): Uncollected Uncontrolled Annual Emissions (tpy) = VOC annual emissions (tpy)
VOC annual emissions (tpy): Collected Uncontrolled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency %
VOC annual emissions (tpy): Building Fugitive Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * (1 – Collection Efficiency %)
VOC annual emissions (tpy): Collected Controlled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency % (1 - Control Efficiency %)
VOC annual emissions (tpy): Total Building Fugitive and Collected Controlled Annual Emissions (tpy) = Building Fugitive Emissions (tpy) + Collected Controlled Annual Emissions (tpy)
HAP annual emissions (tpy) = total consumption (tpy) * Max %HAP from formulation
HAP annual emissions (tpy): Uncollected Uncontrolled Annual Emissions (tpy) = HAP annual emissions (tpy)
HAP annual emissions (tpy): Collected Uncontrolled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency %
HAP annual emissions (tpy): Building Fugitive Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * (1 – Collection Efficiency %)
HAP annual emissions (tpy): Collected Controlled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency % * (1 - Control Efficiency %)
HAP annual emissions (tpy): Total Building Fugitive and Collected Controlled Annual Emissions (tpy) = Building Fugitive Emissions (tpy) + Collected Controlled Annual Emissions (tpy)
Amazon.com Services, LLC - Salt Lake City Facility
Miscellaneous Products Printing Emissions Calculations
July 2024
Page 9 of 15
Amazon.com Services, LLC - Salt Lake City Facility
Dryer Combustion Emissions Calculations
Replacement Digital Printing Dryers (FINs MRDV1 - MRDV20)
Dryer Rating 0.4 MMBtu/hr
Maximum Operating Time 8,760 hr/yr
Maximum Number of Units 8
Fuel Natural Gas
Estimated Fuel Throughput 3,504.00 MMBtu/yr/dryer
35,048.41 Therms/yr/dryer
28,032.00 MMBtu/yr Total
280,387.28 Therms/yr Total
Individual Dryer
(lb/MMscf)(g/MMBtu)(lb/MMBtu)(lb/hr)(lb/hr)(tpy)
NOX 100.0 ----0.0392 0.3137 1.3741
VOC 5.5 ----0.0022 0.0173 0.0756
CO 84.0 ----0.0329 0.2635 1.1543
SO2 0.6 ----0.0002 0.0019 0.0082
PM/PM2.5/PM10 7.6 ----0.0030 0.0238 0.1044
CO2 --0.05 1.17E-04 4.68E-05 0.0004 0.0016
CH4 --1.00 2.20E-03 8.82E-04 0.0071 0.0309
N2O --0.10 2.20E-04 8.82E-05 0.0007 0.0031
Notes:
Criteria pollutant emission factors from U.S. Environmental Protection Agency AP-42 Section 1.4 Tables 1.4-1 and 1.4-2
GHG pollutant emission factors from U.S. Environmental Protection Agency 2024 GHG Emission Factors Hub.
Natural Gas Heat Value = 1,020 MMBtu/MMscf
Calculation Methodology:
Maximum Operating Time (hr/yr) = 8,760 (hr/yr)
Criteria Pollutant Individual Short-Term Emission Rate (lb/hr) = Dryer Rating (MMBtu/hr) * Emission Factor (lb/MMscf)) / 1,020 (MMBtu/MMscf)
Criteria Pollutant Combined Short-Term Emission Rate (lb/hr) = Dryer Rating (MMBtu/hr) * Emission Factor (lb/MMscf)) / 1,020 (MMBtu/MMscf) * Maximum Number of Units (#)
Criteria Pollutant Combined Annual Emission Rate (tpy) = Combined Short-Term Emission Rate (lb/hr) * Operating Time (hr/yr) / 2,000 (lb/ton)
GHG Individual Short-Term Emission Rate (lb/hr) = GHG Combined Short-Term Emission Rate (lb/hr) / Maximum Number of Units (#)
GHG Combined Short-Term Emission Rate (lb/hr) = GHG Combined Annual Emission Rate (tpy) * 2,000 (lb/ton) / Maximum Operating Time (hr/yr)
GHG Combined Annual Emission Rate (tpy) = Emission Factor (lb/MMBtu) * Total Estimated Fuel Throughput (MMBtu/yr) / 2,000 (lb/ton)
Digital Dryers Nos. 1 through 8
Combined Dryers
Annual
Emission Rate
Short-Term
Emission Rate Emission Source Contaminant Emission Factor Short-Term Emission
Rate Emission Factor Emission Factor
Amazon.com Services, LLC - Salt Lake City Facility
Dryer Combustion Emissions Calculations
July 2024
Page 10 of 15
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
Hourly Emissions
Parameter Units of measurement Ink (Cyan, Magenta,
Yellow, Black)White Ink
Uncollected
Uncontrolled
Hourly Emissions
(lb/hr)
Collection
Efficiency (%)
Collected
Uncontrolled
Hourly Emissions
(lb/hr)
Control Efficiency
(%)
Building Fugitive
Emissions
(lb/hr)
Collected
Controlled Hourly
Emissions
(lb/hr)
Total Building
Fugitive and
Collected
Controlled Hourly
Emissions
(lb/hr)
operating printers printer 6 6
printer production rate unit/hr*printer 60 60
production rate unit/hr 360 360
consumption rate per unit* gr/unit 1.54 2.37
consumption rate per hour gr/hr 554.69 851.40
consumption rate per hour lb/hr 1.2229 1.8770
Max %VOC from formulation %35.00%70.00%
VOC hourly emissions lb/hr 0.4280 1.3139 1.7419 ------1.7419 --1.7419
Max %HAP from formulation %--5.00%
HAP hourly emissions lb/hr --0.0939 0.0939 ------0.0939 --0.0939
*hightest %VOC or %HAP in any single product
Products
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
July 2024
Page 11 of 15
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
Annual Emissions
Parameter Units of measurement Ink (Cyan, Magenta,
Yellow, Black)White Ink
Uncollected
Uncontrolled
Annual Emissions
(tpy)
Collection
Efficiency (%)
Collected
Uncontrolled
Annual Emissions
(tpy)
Control Efficiency
(%)
Building Fugitive
Emissions
(tpy)
Collected
Controlled Annual
Emissions
(tpy)
Total Building
Fugitive and
Collected
Controlled Annual
Emissions
(tpy)
operating printers printer 6 6
printer production rate unit/hr*printer 60 60
consumption rate per unit gr/unit 1.54 2.37
production rate unit/yr 3,153,600 3,153,600
annual consumption rate gr/yr 4,859,067 7,458,264
annual consumption rate lb/yr 10712.40 16442.64
average monthly consumption rate lb/mo 892.70 1,370.22
total consumption ton/year 5.356 8.221
Collection Efficiency %%----
Control Efficiency %%----
Average %VOC from formulation %23.00%46.00%
VOC annual emissions ton/year 1.2319 3.7818 5.0137 ------5.0137 --5.0137
VOC annual emissions (building fugitives)ton/year 1.2319 3.7818
VOC annual emissions (collected controlled)ton/year ----
VOC annual emissions (fug + controlled)ton/year 1.2319 3.7818
Average %HAP from formulation %--3.00%
HAP annual emissions ton/year --0.2466 0.2466 ------0.2466 --0.2466
HAP annual emissions (building fugitives)ton/year --0.2466
HAP annual emissions (collected controlled)ton/year ----
HAP annual emissions (fug + controlled)ton/year --0.2466
Average %PM from formulation %----
Products
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
July 2024
Page 12 of 15
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
Cleanup Solvent (assumes all building fugitives as cleanup is at the printer)
Parameter Units of measurement Cleaning Solution
Uncollected
Uncontrolled
Emissions
(lb/hr)
Uncollected
Uncontrolled
Emissions
(ton/mo)
Uncollected
Uncontrolled
Emissions
(tpy)
Building Fugitives
Emissions
(lb/hr)
Building Fugitives
Emissions
(ton/mo)
Building Fugitives
Emissions
(tpy)
Stack Emissions
(lb/hr)
Stack Emissions
(ton/mo)
Stack Emissions
(tpy)
consumption rate per hour* gal/hr 0.63
consumption rate per day gal/day 0.63
average monthly consumption rate gal/mo 19.17
consumption rate per year gal/yr 230.00
product density g/ml 1.00
product density lb/gal 8.35
consumption rate per hour lb/hr 5.26
consumption rate per day lb/day 5.26
average monthly consumption rate lb/mo 159.95
consumption rate per year lb/yr 1,919.44
Estimated Collection Efficiency % 0.00%
Control Efficiency % 0.00%
%VOC from formulation [VOC emissions] % 6.00%0.3155 0.0048 0.0576 0.3155 0.0048 0.0576 0.0000 0.0000 0.0000
%HAP from formulation [HAP emissions] % 0.00%0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
*consumption rate per hour assumes that all daily usage can be utilized in one hour (worst case)
Printing Notes:
Hourly Emissions
operating printers (printer) = maximum number of printers to be installed
printer production rate (unit/hr*printer) = maximum number of units that can be printed per hour per printer
production rate (unit/hr) = operating printers (printer) * printer production rate (unit/hr*printer)
consumption rate per hour (gr/hr) = production rate (unit/hr) * consumption rate per unit (gr/unit) [refer to Consumption Estimates]
consumption rate per hour (lb/hr) = consumption rate (gr/hr) * 0.00220462 (lb/gr)
VOC hourly emissions (lb/hr) = consumption rate per hour (lb/hr) * Max %VOC from formulation
VOC hourly emissions: Uncollected Uncontrolled Hourly Emissions (lb/hr) = Sum of VOC hourly emissions (lb/hr) [total ink and concentrate fixation]
VOC hourly emissions: Collected Uncontrolled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Estimated Collection Efficiency %
VOC hourly emissions: Building Fugitive Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * (1 – Estimated Collection Efficiency %)
VOC hourly emissions: Collected Controlled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Estimated Collection Efficiency % * (1 - Control Efficiency %)
VOC hourly emissions: Total Building Fugitive and Collected Controlled Hourly Emissions (lb/hr) = Building Fugitive Emissions (lb/hr) + Collected Controlled Hourly Emissions (lb/hr)
HAP hourly emissions (lb/hr) [per product] = consumption rate per hour (lb/hr) * %HAP from formulation
HAP hourly emissions: Uncollected Uncontrolled Hourly Emissions (lb/hr) = Sum of HAP hourly emissions (lb/hr) [total ink, no HAP contained in the fixation material]
HAP hourly emissions: Collected Uncontrolled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Estimated Collection Efficiency %
HAP hourly emissions: Building Fugitive Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * (1 – Estimated Collection Efficiency %)
HAP hourly emissions: Collected Controlled Hourly Emissions (lb/hr) = Uncollected Uncontrolled Hourly Emissions (lb/hr) * Estimated Collection Efficiency % * (1 - Control Efficiency %)
HAP hourly emissions: Total Building Fugitive and Collected Controlled Hourly Emissions (lb/hr) = Building Fugitive Emissions (lb/hr) + Collected Controlled Hourly Emissions (lb/hr)
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
July 2024
Page 13 of 15
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
Annual Emissions
operating printers (printer) = maximum number of printers to be installed
printer production rate (unit/hr*printer) = maximum number of units that can be printed per hour per printer
production rate (unit/hr) = operating printers (printer) * printer production rate (unit/hr*printer)
consumption rate per hour (gr/hr) = production rate (unit/hr) * consumption rate per unit (gr/unit) [consumption rate per unit based on consumption rate process knowledge from a similar facility elsewhere in the United States or expected consumption rates for non-apparel products]
operating schedule (hr/yr) = operating schedule (day/yr) * operating schedule (hr/day)
production rate (unit/yr) = production rate (unit/hr) * operating schedule (hr/yr)
annual consumption rate (gr/yr) = consumption rate per hour (gr/hr) * operating schedule (hr/yr)
annual consumption rate (lb/yr) = annual consumption rate (gr/yr) * 0.00220462 (lb/gr)
average monthly consumption rate (lb/mo) = annual consumption rate (lb/yr) / 12 (mo/yr)
total consumption (ton/year) = annual consumption rate (lb/yr) / 2,000 (lb/ton)
VOC annual emissions (ton/year) [per product] = total consumption (ton/year) * Avg %VOC from formulation
VOC annual emissions (building fugitives) (ton/year) [per product] = VOC annual emissions (ton/year) [per product] * (1 – Estimated Collection Efficiency %)
VOC annual emissions (collected controlled) (ton/year) [per product] = VOC annual emissions (ton/year) [per product] * Estimated Collection Efficiency % * (1 - Control Efficiency %)
VOC annual emissions (fug + controlled) (ton/year) [per product] = VOC annual emissions (building fugitives) (ton/year) [per product] + VOC annual emissions (collected controlled) (ton/year) [per product]
VOC annual emissions (ton/year): Uncollected Uncontrolled Annual Emissions (tpy) = Sum of VOC annual emissions (ton/year) [per product]
VOC annual emissions (ton/year): Collected Uncontrolled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Collection Efficiency %
VOC annual emissions (ton/year): Building Fugitive Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * (1 – Estimated Collection Efficiency %)
VOC annual emissions (ton/year): Collected Controlled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Estimated Collection Efficiency % (1 - Control Efficiency %)
VOC annual emissions (ton/year): Total Building Fugitive and Collected Controlled Annual Emissions (tpy) = Building Fugitive Emissions (tpy) + Collected Controlled Annual Emissions (tpy)
HAP annual emissions (ton/year) [per product] = total consumption (ton/year) * %HAP from formulation
HAP annual emissions (building fugitives) (ton/year) [per product] = HAP annual emissions (ton/year) [per product] * (1 – Estimated Collection Efficiency %)
HAP annual emissions (collected controlled) (ton/year) [per product] = HAP annual emissions (ton/year) [per product] * Estimated Collection Efficiency % * (1 - Control Efficiency %)
HAP annual emissions (fug + controlled) (ton/year) [per product] = HAP annual emissions (building fugitives) (ton/year) [per product] + HAP annual emissions (collected controlled) (ton/year) [per product]
HAP annual emissions (ton/year): Uncollected Uncontrolled Annual Emissions (tpy) = Sum of HAP annual emissions (ton/year) [per product]
HAP annual emissions (ton/year): Collected Uncontrolled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Estimated Collection Efficiency %
HAP annual emissions (ton/year): Building Fugitive Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * (1 – Estimated Collection Efficiency %)
HAP annual emissions (ton/year): Collected Controlled Annual Emissions (tpy) = Uncollected Uncontrolled Annual Emissions (tpy) * Estimated Collection Efficiency % * (1 - Control Efficiency %)
HAP annual emissions (ton/year): Total Building Fugitive and Collected Controlled Annual Emissions (tpy) = Building Fugitive Emissions (tpy) + Collected Controlled Annual Emissions (tpy)
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
July 2024
Page 14 of 15
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
Cleanup Solvent Notes:
Hourly Emissions
consumption rate per hour (gal/hr) = consumption rate per day (gal/day) [assumes that all daily usage can be utilized in one hour (worst case)]
consumption rate per day (gal/day) = consumption rate per hour (gal/hr)
average monthly consumption rate (gal/mo) = consumption rate per day (gal/day) * 31 (day/mo)
consumption rate per year (gal/yr) = average monthly consumption rate (gal/mo) * 12 (mo/yr)
product density (g/ml) = per product SDS
product density (lb/gal) = product density (g/ml) * 8.3454
consumption rate per hour (lb/hr) = consumption rate (gal/hr) * product density (lb/gal)
consumption rate per day (lb/day) = consumption rate (gal/day) * product density (lb/gal)
average monthly consumption rate (lb/mo) = average monthly consumption rate (gal/mo) * product density (lb/gal)
VOC hourly emissions: Uncollected Uncontrolled Emissions (lb/hr) = consumption rate per hour (lb/hr) * %VOC from formulation
VOC hourly emissions: Building Fugitives (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * (1 - Estimated Collection Efficiency %)
VOC hourly emissions: Stack Emissions (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * Estimated Collection Efficiency * (1 - Control Efficiency %)
HAP hourly emissions: Uncollected Uncontrolled Emissions (lb/hr) = consumption rate per hour (lb/hr) * %HAP from formulation
HAP hourly emissions: Building Fugitives (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * (1 - Estimated Collection Efficiency %)
HAP hourly emissions: Stack Emissions (lb/hr) = Uncollected Uncontrolled Emissions (lb/hr) * Estimated Collection Efficiency * (1 - Control Efficiency %)
Annual Emissions
consumption rate per year (lb/yr) = consumption rate per year (gal/yr) * product density (lb/gal)
VOC monthly emissions: Uncollected Uncontrolled Emissions (ton/mo) = consumption rate per month (lb/mo) * %VOC from formulation / 2000 (lb/ton)
VOC monthly emissions: Building Fugitives (ton/mo) = Uncollected Uncontrolled Emissions (ton/mo) * (1 - Estimated Collection Efficiency %)
VOC monthly emissions: Stack Emissions (ton/mo) = Uncollected Uncontrolled Emissions (ton/mo) * Estimated Collection Efficiency * (1 - Control Efficiency %)
HAP monthly emissions: Uncollected Uncontrolled Emissions (ton/mo) = consumption rate per hour (ton/mo) * %HAP from formulation
HAP monthly emissions: Building Fugitives (ton/mo) = Uncollected Uncontrolled Emissions (ton/mo) * (1 - Estimated Collection Efficiency %)
HAP monthly emissions: Stack Emissions (ton/mo) = Uncollected Uncontrolled Emissions (ton/mo) * Estimated Collection Efficiency * (1 - Control Efficiency %)
VOC annual emissions: Uncollected Uncontrolled Emissions (tpy) = consumption rate per year (lb/yr) * %VOC from formulation / 2000 (lb/ton)
VOC annual emissions: Building Fugitives (tpy) = Uncollected Uncontrolled Emissions (tpy) * (1 - Estimated Collection Efficiency %)
VOC annual emissions: Stack Emissions (tpy) = Uncollected Uncontrolled Emissions (tpy) * Estimated Collection Efficiency * (1 - Control Efficiency %)
HAP annual emissions: Uncollected Uncontrolled Emissions (tpy) = consumption rate per hour (tpy) * %HAP from formulation
HAP annual emissions: Building Fugitives (tpy) = Uncollected Uncontrolled Emissions (tpy) * (1 - Estimated Collection Efficiency %)
HAP annual emissions: Stack Emissions (tpy) = Uncollected Uncontrolled Emissions (tpy) * Estimated Collection Efficiency * (1 - Control Efficiency %)
Amazon.com Services, LLC - Salt Lake City Facility
DTF Apparel Printing Emissions Calculations
July 2024
Page 15 of 15