DAQ-2024-008086

DAQE-IN104350031-24

March 21, 2024

Daniel May
Sterigenics US, LLC
2015 Spring Road, Suite 650
Oak Brook, IL 60523
[e-mail]

Dear Mr. May:

Re: Intent to Approve: Minor Modification to Approval Order DAQE-AN104350030-21 to Add
Research and Development Equipment and an Emergency Generator
Project Number: N104350031

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

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ: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

* ) ' & — - A @ v A ? A C @ B w @ C ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN104350031-24
Minor Modification to Approval Order DAQE-AN104350030-21 to
Add Research and Development Equipment and an Emergency
Generator

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Sterigenics US, LLC - Ethylene Oxide Commercial Sterilization Plant

Issued On
March 21, 2024

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}

* ) ' & — - A @ v A ? A C @ B w @ C ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 8
PERMIT HISTORY ................................................................................................................... 13
ACRONYMS ............................................................................................................................... 14

DAQE-IN104350031-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Sterigenics US, LLC Sterigenics US, LLC - Ethylene Oxide
Commercial Sterilization Plant

Mailing Address Physical Address
2015 Spring Road, Suite 650 5725 West Harold Gatty Drive
Oak Brook, IL 60523 Salt Lake City, UT 84116

Source Contact UTM Coordinates
Name: Daniel May 413,240 m Easting
Phone: [phone],514,932 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 7389 (Business Services, NEC)

SOURCE INFORMATION
General Description
Sterigenics US, LLC (Sterigenics) is a medical device sterilization facility located in Salt Lake City, UT.
The facility has sterilization chambers of various sizes used to sterilize medical devices and other
products using gaseous ethylene oxide. The process emissions are vented through packed bed scrubbers.
The facility also includes two (2) water tube boilers.
NSR Classification
Minor Modification at Minor Source

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

Applicable Federal Standards
NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), O: Ethylene Oxide Emissions Standards for Sterilization Facilities
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
DAQE-IN104350031-24
Page 4

Project Description
Sterigenics has requested a modification to the natural gas-fired emergency generator and additional
research and development (R&D) equipment. Additional R&D equipment includes the addition of a new
chamber (Chamber 18) and an EtO Abator for Chamber 18. This will result in an increase in site-wide
PTE of criteria pollutants but no increase in EtO emissions.

Additionally, Sterigenics requested to install new fugitive ethylene oxide (EtO) emissions controls and
associated supporting equipment. A new permanent enclosure will create a negative pressure
environment and send all EtO emissions through an additional Advanced Air Technologies (AAT) dry
bed scrubber before exiting through a new single stack. This change will convert existing fugitive
emissions to point-source emissions and direct them through a control system. Condition II.B.3.a
replaces the previous stack heights with the new singular stack requirement as requested by the source.

To comply with the requirements of R307-401-12(1)(b), the new equipment has been added to the
equipment list. The changes will be as follows:

One (1) new permanent enclosure. (All treated EtO exhaust from the facility will be routed through a
new single stack.)

One (1) Lunaire Model CEO-932W-4 0.33 m3 pre-conditioning chamber and one (1) Steris Model
M71GA2 0.42 m3 aeration chamber are provided for informational purposes only.

Additional administrative changes include:

Removal of Condition II.B.1.b. This condition requires personal EtO detection monitors, which ensure
employee exposure is below OSHA standards. However, indoor pollution is not regulated under the
Clean Air Act and therefore not relevant to this AO.

Removal of Item II.A.22, the Nitrogen Dioxide Sterilizer.

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 11 3938.00
Carbon Monoxide 0.04 1.24
Nitrogen Oxides 0.04 3.20
Particulate Matter - PM10 0 0.39
Particulate Matter - PM2.5 0 0.39
Sulfur Dioxide 0 0.02
Volatile Organic Compounds 0 2.16

DAQE-IN104350031-24
Page 5

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Ethylene Oxide (CAS #75218) 0 4200
Generic HAPs (CAS #GHAPS) 0 120
Change (TPY) Total (TPY)
Total HAPs 0 2.16

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the
requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be
constructed, installed, established, or modified prior to the issuance of an AO by the Director.

A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in the Salt Lake Tribune and Deseret News on March 24, 2024.
During the public comment period the proposal and the evaluation of its impact on air quality will be
available for the public to review and provide comment. If anyone so requests a public hearing within 15
days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as
close as practicable to the location of the source. Any comments received during the public comment
period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result
of the comments received.

SECTION I: GENERAL PROVISIONS

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

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

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

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

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

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

DAQE-IN104350031-24
Page 6

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

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

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

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

II.A THE APPROVED EQUIPMENT

II.A.1 Sterigenics US, LLC
Commercial medical equipment ethylene oxide sterilization facility.

II.A.2 One (1) Pre-conditioner (NEW)
Capacity: 0.33 m3
Included for informational purposes

II.A.3 Permanent Total Enclosure (NEW)
Control: AAT Dry Bed Scrubber
Encloses: II.A.2-II.A.22

II.A.4 EtO Sterilizer Chamber 1
Capacity: 1,087 cu. ft. (8-pallet)
Manufacture Date: 2004

II.A.5 EtO Sterilizer Chamber 2
Capacity: 1,087 cu. ft. (8-pallet)
Manufacture Date: 2000

II.A.6 EtO Sterilizer Chamber 3
Capacity: 1,087 cu. ft. (8-pallet)
Manufacture Date: 2004

II.A.7 EtO Sterilizer Chamber 4
Capacity: 1,087 cu. ft. (8-pallet)
Manufacture Date: 2003

II.A.8 EtO Sterilizer Chamber 5
Capacity: 35 cu. ft. (1-pallet)
Manufacture Date: 1990

DAQE-IN104350031-24
Page 7

II.A.9 EtO Sterilizer Chamber 6
Capacity: 1,080 cu. ft. (8-pallet)
Manufacture Date: 1999

II.A.10 EtO Sterilizer Chamber 7
Capacity: 1,087 cu. ft. (8-pallet)
Manufacture Date: 2002

II.A.11 EtO Sterilizer Chamber 8
Capacity: 1,133 cu. ft. (8-pallet)
Manufacture Date: 1990

II.A.12 EtO Sterilizer Chamber 9
Capacity: 283 cu. ft. (2-pallet)
Manufacture Date: 1992

II.A.13 EtO Sterilizer Chamber 10
Capacity: 3,600 cu. ft. (24-pallet)
Manufacture Date: 1997

II.A.14 EtO Sterilizer Chamber 11
Capacity: 198 cu. ft. (1-pallet)
Manufacture Date: 1999

II.A.15 EtO Sterilizer Chamber 12
Capacity: 20 cu. ft. (R&D)

II.A.16 EtO Sterilizer Chamber 13
Capacity: 20 Cu. Ft. (R&D)

II.A.17 EtO Sterilizer Chamber 14
Capacity: 6 cu ft. (R&D)

II.A.18 EtO Sterilizer Chamber 15
Capacity: 12 cu. ft. (R&D)

II.A.19 EtO Sterilizer Chamber 16
Capacity: 20 cu. ft. (R&D)

II.A.20 EtO Sterilizer Chamber 17
Capacity: 20 cu. ft. (R&D)

II.A.21 Chamber 18 (NEW)
Capacity: 20 cu. ft. (R&D)
Control: EtO Abator and vented to scrubber

II.A.22 One (1) Aeration Chamber (NEW)
Capacity: 0.42 m3
Included for informational purposes

II.A.23 Ceilcote Scrubber
One (1) scrubber equipped with a packed tower, reaction tanks, dual recycle piping, heat
exchanger and a control panel.

DAQE-IN104350031-24
Page 8

II.A.24 Advanced Air Technologies Scrubber
One (1) scrubber equipped with packed tower with a countercurrent flow running acid-water
Maximum air-flow rate: 13,000 cubic feet/minute

II.A.25 Advanced Air Technologies Adsorber
Seven (7) adsorbers consisting of dry beds

II.A.26 AAT Dry Bed Scrubber
Flow Rate: 44,000 cubic feet per minute

II.A.27 Various Water Tube Boilers
Maximum Rated Capacity: Less than 5.0 MMBtu/hr each
Fuel: Natural Gas

II.A.28 Natural Gas Emergency Engine (NEW)
Size: 240 hp
NSPS Applicability: Subpart JJJJ
MACT Applicability: Subpart ZZZZ

II.A.29 Comfort Heaters
Maximum Rated Capacity: Less than 5.0 MMBtu/hr each
Fuel: Natural Gas

II.A.30 Five (5) Non-Volatile Liquid Organic Storage Tanks
Two (2) 17,000 gallon and three (3) 18,500-gallon tanks, for information purposes.

II.A.31 Media Abrasive Blaster
*vents internally

SECTION II: SPECIAL PROVISIONS

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

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements and Limitations
II.B.1.a The owner/operator shall not use more than 210.2 tons of ethylene oxide gas per rolling
12-month period. [R307-401-8]

II.B.1.a.1 The owner/operator shall:

A. Determine and record usage on a daily basis.

B. Use the usage data to calculate a new rolling 12-month total by the 28th day of
each month using data from the previous 12 months.

[R307-401-8]

DAQE-IN104350031-24
Page 9

II.B.1.b Visible emissions from the following emission points shall not exceed the following values:

A. AAT scrubber and dry bed system - 0% opacity.

B. Storage Tanks - 0% opacity.

C. All other points - 20% opacity.

[R307-201-3]

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

II.B.2 Scrubber Requirements
II.B.2.a The Ceilcote scrubber shall be used to control all process streams from the sterilization chamber
vacuum pumps. The AAT scrubber and adsorber system shall control all process streams from
the aeration vents. [R307-401-8]

II.B.2.b Emissions from the Ceilcote scrubber shall be routed to the AAT scrubber and adsorber system.
[R307-401-8]

II.B.2.c The owner/operator shall route all ethylene oxide sterilizer back vent emissions through the AAT
scrubber and adsorber system. [R307-401-8]

II.B.2.d In case of an AAT adsorber system breakdown, the Ceilcote scrubber can be rerouted to the
Ceilcote stack to control sterilization chamber vacuum pump emissions. [R307-401-8]

II.B.2.e In case of Ceilcote breakdown, the AAT adsorber system shall be used to control the sterilization
chamber vacuum pumps, back vent and aeration emissions. [R307-401-8]

II.B.2.e.1 The owner/operator shall not allow the ethylene oxide concentration in the AAT adsorber
exhaust to exceed 5.415 ppmv (24-hour average) in the event of the Ceilcote scrubber breaking
down. This represents a 99% reduction as required by MACT Subpart O.
[40 CFR 63 Subpart O, R307-401-8]

II.B.2.f The owner/operator shall keep and maintain records of any scrubber breakdowns. [R307-401-8]

II.B.2.f.1 The scrubber breakdown records shall include the following items:

A. Date of breakdown.

B. Cause of breakdown.

C. Duration of breakdown.

D. Any corrective actions taken.

[R307-401-8]

DAQE-IN104350031-24
Page 10

II.B.2.g The following liquid flow rates in the scrubbers shall be maintained within the indicated ranges:

A. The Ceilcote scrubber average liquid flow rate shall be greater than 80 gallons
per minute.

B. The AAT scrubber average liquid flow rate shall be greater than 1,500 gallons
per minute.

[R307-401-8]

II.B.2.g.1 The owner/operator shall record daily the liquid flow rates. The records shall be kept as long as
the scrubbers are in operation and shall include the following items:

A. Date.

B. Scrubber Type.

C. Liquid flow rate.

[R307-401-8]

II.B.2.h The pH of the ethylene glycol solutions in the Ceilcote scrubber shall not exceed 2.0.
[R307-401-8]

II.B.2.h.1 The owner/operator shall record weekly the pH of the ethylene glycol solutions. The records
shall be maintained for all periods when the Ceilcote scrubber is in operation and shall include
the following items:

A. Date.

B. pH.

[R307-401-8]

II.B.2.i The AAT heat exchanger temperature difference between inlet and outlet (delta T) shall be
greater than 5 degrees Fahrenheit. The outlet temperature shall be greater than the inlet
temperature. [R307-401-8]

II.B.2.i.1 The owner/operator shall record daily the delta T and shall keep and maintain a logbook for all
periods when the AAT heat exchanger is in operation. The records shall include the following
items:

A. Date.

B. Delta T.

C. Any corrective actions taken.

[R307-401-8]

II.B.2.j The owner/operator shall sample the AAT scrubber liquor and analyze and record once per week
the ethylene glycol concentration of the scrubber using the test methods and procedures in 40
CFR 63, MACT Subpart O Section 63.365(e)(1). The source shall monitor and record once per
week the liquor level of the Ceilcote scrubber. Monitoring is not required during a week in
which the scrubber unit has not been operated. [40 CFR 63 Subpart O]

DAQE-IN104350031-24
Page 11

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

A. Ceilcote scrubber liquor level 181.5 inches in tank #2 when tank #1 is
completely full.

B. Ethylene glycol concentration in AAT scrubber 26.7%.

[40 CFR 63 Subpart O]

II.B.2.k The owner/operator shall monitor and record the ethylene oxide concentration according to
Subpart O Section 63.364(e). [40 CFR 63 Subpart O, R307-401-8]

II.B.2.k.1 In the event of a breakdown of the instrumentation for the hourly monitoring of ethylene oxide
concentrations at the AAT adsorber exhaust, the facility shall take a daily reading at the dry bed
sampling port using a portable Photo Ionization Detector (PID) analyzer, Draeger tube, or
equivalent technology. [R307-401-8]

II.B.3 Stack Requirements
II.B.3.a The height of the stack from the AAT Wet Acid Scrubber and Dry Bed System, Ceilcote
Scrubber, and AAT dry-bed scrubber, shall be a minimum of 60 feet above grade. [R307-401-8]

II.B.3.b The owner/operator shall monitor and record ethylene oxide concentration according to MACT
Subpart O, Section 63.362(c), Section 63.362(d), and 63.364(e). The AAT scrubber shall not
have less than a 99% reduction in ethylene oxide. The EtO from the vacuum pumps are reduced
by 99.5%. [40 CFR 63 Subpart O, R307-401-8]

II.B.3.b.1 Compliance Demonstration
To demonstrate compliance with the emissions limitations above, the owner/operator shall
perform stack testing on the AAT Scrubber according to the stack testing conditions contained in
this permit. [R307-165]

II.B.3.c Initial Test
The owner/operator shall conduct an initial stack test within 180 days after startup of the
combined scrubber system. [R307-165-2]

II.B.3.d Test Frequency
The owner/operator shall conduct subsequent emission tests within five (5) years after the date of
the most recent emission test. The Director may require the owner/operator to perform an
emission test at any time. [R307-165-2, R307-401-8]

DAQE-IN104350031-24
Page 12

II.B.3.e Notification
At least 60 days prior to conducting an emission test, the owner/operator shall submit a source
test protocol to the Director. The source test protocol shall include:

A. The date, time, and place of the proposed test.

B. The proposed test methodologies.

C. The stack to be tested.

D. The procedures to be used.

E. Any deviation from an EPA-approved test method.

F. Explanation of any deviation from an EPA-approved test method.

If so directed by the Director, the owner/operator shall attend a pretest conference.

[40 CFR 63, R307-165-3, R307-401-8]

II.B.3.f Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location.
[R307-401-8]

II.B.3.g Testing
The owner/operator shall conduct testing according to the approved source test protocol. The
Director may reject emission test data if the test did not follow the approved source test protocol
or if Director was not provided an opportunity to have an observer present at the test.
[R307-165-5, R307-401-8]

II.B.3.g.1 Reporting
Within 60 days after completing an emission test, the owner/operator shall submit a copy of the
test results to the Director. [40 CFR 63, R307-401-8]

II.B.3.g.2 Test Conditions
The owner/operator shall conduct all tests while the source is operating at the maximum
production at which the source will be operated unless otherwise specified in the approved
source test protocol. During the tests, the owner/operator shall burn fuels or combinations of
fuels, use raw materials, and maintain process conditions representative of normal operations. In
addition, the owner/operator shall operate under any other relevant conditions that the Director
specifies. [R307-165-4, R307-401-8]

II.B.3.g.3 Possible Rejection of Test Results
The Director may reject emissions test data if they are determined to be incomplete, inadequate,
not representative of operating conditions specified for the test, or if the Director was not
provided an opportunity to have an observer present at the test. [R307-165-5]

II.B.3.h Test Methods
When performing emission testing, the owner/operator shall use the appropriate EPA-approved
test methods as acceptable to the Director. Acceptable test methods for pollutants are listed
below. [R307-401-8]

II.B.3.h.1 Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other methods if approved by the Director. [R307-165]

DAQE-IN104350031-24
Page 13

II.B.3.h.2 Ethylene Oxide
40 CFR 63.7 of Subpart A according to applicability in Table 1 of Subpart O, the procedure
listed in Subpart O, 63.360 through 63.367, and the test methods listed in 63.365 of Subpart O.
Temperature, flow rate, and efficiency of control device shall be determined. [R307-401]

II.B.3.h.3 Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2 or other testing methods approved by the Director.
[R307-165]

II.B.3.h.4 Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation. [R307-165, R307-401]

II.B.3.h.5 Source Operation
The production rate during all compliance testing shall be no less than 90% of the maximum
production achieved in the previous three (3) years. Maximum production rate in this AO shall
mean the production rate in one (1) day (24 hours) at which amount of ethylene oxide is
consumed. [R307-165]

II.B.4 Emergency Engine Requirements
II.B.4.a The owner/operator shall not operate each emergency engine on site for more than 100 hours per
rolling 12-month period during non-emergency situations. There is no time limit on the use of
the engines during emergencies. [40 CFR 63 Subpart ZZZZ]

II.B.4.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of each emergency engine shall be kept in a log and shall include the
following:

1. The date the emergency engine was used.

2. The duration of operation in hours.

3. The reason for the emergency engine usage.

[40 CFR 63 Subpart ZZZZ]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN104350030-21 dated March 25, 2021
Is Derived From NOI dated September 23, 2023
Incorporates Additional Information dated December 7, 2023
Incorporates Additional Information dated January 19, 2024

DAQE-IN104350031-24
Page 14

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-NN104350031-24

March 21, 2024

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

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Salt Lake Tribune and
Deseret News on March 24, 2024.

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

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Wasatch Front Regional Council
cc: Salt Lake County

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

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN104350031-24
Page 2
NOTICE

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

Company Name: Sterigenics US, LLC
Location: Sterigenics US, LLC - Ethylene Oxide Commercial Sterilization Plant – 5725
West Harold Gatty Drive, Salt Lake City, UT
Project Description: Sterigenics US, LLC (Sterigenics) is a medical device sterilization facility
located in Salt Lake City, UT. The facility has sterilization chambers of various
sizes used to sterilize medical devices and other products using gaseous ethylene
oxide. Sterigenics has requested the addition of seven (7) new sterilizer
chambers at its facility. One (1) is 198 cubic feet and holds one pallet. The other
six (6) are research and development (R&D) sterilizer chambers of various sizes.
The source is also requesting to run the Ceilcote scrubber exhaust through the
AAT scrubber to further reduce emissions.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality and draft Approval Order are available for public inspection and comment at the
Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before April 23, 2024 will be considered in making
the final decision on the approval/disapproval of the proposed project. Email comments will also be
accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with
R307-401-7, UAC.

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

Date of Notice: March 24, 2024

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

The Salt Lake Tribune
Publication Name:
The Salt Lake Tribune
Publication URL:
Publication City and State:
Salt Lake City, UT
Publication County:
Salt Lake
Notice Popular Keyword Category:
Notice Keywords:
sterigenics
Notice Authentication Number:
202405221314361296847
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Notice Publish Date:
Sunday, March 24, 2024
Notice Content
NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been
received for consideration by the Director: Company Name: Sterigenics US, LLC Location: Sterigenics US, LLC - Ethylene Oxide Commercial
Sterilization Plant 5725 West Harold Gatty Drive, Salt Lake City, UT Project Description: Sterigenics US, LLC (Sterigenics) is a medical device
sterilization facility located in Salt Lake City, UT. The facility has sterilization chambers of various sizes used to sterilize medical devices and
other products using gaseous ethylene oxide. Sterigenics has requested the addition of seven (7) new sterilizer chambers at its facility. One
(1) is 198 cubic feet and holds one pallet. The other six (6) are research and development (R&D) sterilizer chambers of various sizes. The
source is also requesting to run the Ceilcote scrubber exhaust through the AAT scrubber to further reduce emissions. The completed
engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air quality regulations
and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period. The project
proposal, estimate of the effect on local air quality and draft Approval Order are available for public inspection and comment at the Utah
Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same address on or
before April 23, 2024 will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments
will also be accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of publication of this notice, a
hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may
only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and was supported with
sufficient information or documentation to enable the Director to fully consider the substance and significance of the issue. SLT0026692
Back

DAQE-MN104350031-24

M E M O R A N D U M

TO: Source File N10435-0031

FROM: John Jenks, Environmental Engineer IV

THROUGH: Jon L. Black, Environmental Program Manager I

DATE: April 25, 2024

SUBJECT: Comment Response

On March 24, 2024, the Utah Division of Air Quality (UDAQ) released for public comment DAQE-
IN104350031-24 for Sterigenics US, LLC (Sterigenics), a medical device sterilization facility located in
Salt Lake City, UT. The project for Sterigenics’ request to install seven new sterilizer chambers at its
facility.
During a public comment, a member of UDAQ commented that one line appeared in the project
description that made it appear that the Sterigenics project was being issued under an exemption,
specifically R307-401-12 Reduction in Air Pollution. This is not the case. The project is a minor
modification to an existing minor source, as new equipment is being installed.
UDAQ apologizes for any misunderstanding this may have caused. The errant line has been removed
from the final document.

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

0 0
JB
DAQE-

RN104350031
March 19, 2024

Daniel May
Sterigenics US, LLC
2015 Spring Road, Suite 650
Oak Brook, IL 60523
[e-mail]

Dear Daniel May,

Re: Engineer Review:
Minor Modification to Approval Order DAQE-AN104350030-21 to Add Research and
Development Equipment and an Emergency Generator
Project Number: N104350031

The DAQ requests a company representative review and sign the attached Engineer Review (ER). This
ER identifies all applicable elements of the New Source Review permitting program. Sterigenics US,
LLC should complete this review within 10 business days of receipt.

Sterigenics US, LLC should contact John Jenks at [phone] if there are questions or concerns with
the review of the draft permit conditions. Upon resolution of your concerns, please email John Jenks at
[e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare
an ITA for a 30-day public comment period. At the completion of the comment period, the DAQ will
address any comments and will prepare an Approval Order (AO) for signature by the DAQ Director.

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

Approval Signature _____________________________________________________________
(Signature & Date)

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

Kimberly D. Shelley Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird Director

State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Engineer Review N104350031: Sterigenics US, LLC- Ethylene Oxide Commercial Sterilization Plant
March 19, 2024
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N104350031
Owner Name Sterigenics US, LLC
Mailing Address 2015 Spring Road, Suite 650
Oak Brook, IL, 60523

Source Name Sterigenics US, LLC- Ethylene Oxide Commercial Sterilization
Plant
Source Location 5725 West Harold Gatty Drive
Salt Lake City, UT 84116

UTM Projection 413,240 m Easting, 4,514,932 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 7389 (Business Services, NEC)

Source Contact Daniel May
Phone Number [phone]
Email [e-mail]

Billing Contact Daniel May
Phone Number 262.930.5372
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted September 23, 2022
Date of Accepted Application November 17, 2022

Engineer Review N104350031: Sterigenics US, LLC- Ethylene Oxide Commercial Sterilization Plant
March 19, 2024
Page 2
SOURCE DESCRIPTION

General Description
Sterigenics US, LLC (Sterigenics) is a medical device sterilization facility located in Salt Lake
City, UT. The facility has sterilization chambers of various sizes used to sterilize medical devices
and other products using gaseous ethylene oxide. The process emissions are vented through
packed bed scrubbers. The facility also includes two water tube boilers.

NSR Classification:
Minor Modification at Minor Source

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

Applicable Federal Standards
NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), O: Ethylene Oxide Emissions Standards for Sterilization Facilities
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

Project Proposal
Minor Modification to Approval Order DAQE-AN104350030-21 to Add Research and
Development Equipment and an Emergency Generator

Project Description
Sterigenics has requested a modification to natural gas fired emergency generator and additional
research and development (R&D) equipment. Additional R&D equipment includes the addition
of a new chamber (Chamber 18) and an EtO Abator for Chamber 18. This will result in an
increase in site-wide PTE of criteria pollutants but no increases in EtO emissions.

Additionally, Sterigenics requested to install new fugitive ethylene oxide (EtO) emissions
controls and associated supporting equipment. A new permanent enclosure will create a negative
pressure environment and send all EtO emissions through an additional Advanced Air
Technologies (AAT) dry bed scrubber before exiting through a new single stack. This change will
convert existing fugitive emissions to point source emissions and direct them through a control
system. Condition II.B.3.a replaces the previous stack heights with the new singular stack
requirement as requested by the source.

To comply with the requirements of R307-401-12(1)(b) the new equipment has been added to the
equipment list. The changes will be as follows:

One new permanent enclosure. (All treated EtO exhaust from the facility will be routed through a
new single stack)

One Lunaire Model CEO-932W-4 0.33 m3 pre-conditioning chamber and one (1) Steris Model

Engineer Review N104350031: Sterigenics US, LLC- Ethylene Oxide Commercial Sterilization Plant
March 19, 2024
Page 3
M71GA2 0.42 m3 aeration chamber provided for informational purposes only.

Additional administrative changes include:

Removal of Condition II.B.1.b. This condition requires personal EtO detection monitors which
ensure employee exposure is below OSHA standards. However, indoor pollution is not regulated
under the Clean Air Act and therefore not relevant to this AO.

Removal of Item II.A.22, the Nitrogen Dioxide Sterilizer.

EMISSION IMPACT ANALYSIS
All criteria pollutants are below the modeling thresholds contained in R307-410-4. All HAP pollutant increases
are below their respective threshold values in R307-410-5. The source is subject to 40 CFR Part 63, Subpart O,
and R307-410-5(a)(i) exempts the source from modeling ethylene oxide. Therefore, no modeling is required
from this source. [Last updated January 31, 2024]

Engineer Review N104350031: Sterigenics US, LLC- Ethylene Oxide Commercial Sterilization Plant
March 19, 2024
Page 4
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 11 3938.00
Carbon Monoxide 0.04 1.24
Nitrogen Oxides 0.04 3.20
Particulate Matter - PM10 0 0.39
Particulate Matter - PM2.5 0 0.39
Sulfur Dioxide 0 0.02
Volatile Organic Compounds 0 2.16

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Ethylene Oxide (CAS #75218) 0 4200
Generic HAPs (CAS #GHAPS) 0 120
Change (TPY) Total (TPY)
Total HAPs 0 2.16

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

Engineer Review N104350031: Sterigenics US, LLC- Ethylene Oxide Commercial Sterilization Plant
March 19, 2024
Page 5
Review of BACT for New/Modified Emission Units

1. BACT review regarding New Emergency Engine
The 240 hp natural gas fired engine will increase CO, PM2.5, PM10, NOx, SO2 and VOC emissions.
Possible controls include a NSCR, use of low-sulfur fuels, and best operating practices.

The total increase in PTE is less than 0.05 tons/per year for each above-listed pollutants. As such it
is economically infeasible to install add-on control equipment. BACT for the engine is limited
hours of operation, good combustion practices, compliance with NSPS Subpart JJJJ and MACT
Subpart ZZZZ, and the use of pipeline quality natural gas. [Last updated February 14, 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]

Engineer Review N104350031: Sterigenics US, LLC- Ethylene Oxide Commercial Sterilization Plant
March 19, 2024
Page 6
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-
150]

I.8 The owner/operator shall submit documentation of the status of construction or modification
to the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director,
send the documentation to the Director, attn.: NSR Section. [R307-401-18]

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

II.A THE APPROVED EQUIPMENT

II.A.1 Sterigenics US, LLC
Commercial medical equipment ethylene oxide sterilization facility.

II.A.2
NEW
One Pre-conditioner (NEW)
Capacity: 0.33 m3
Included for informational purposes

II.A.3
NEW
Permanent Total Enclosure (NEW)
Control: AAT Dry Bed Scrubber
Encloses: II.A.2-II.A.22
II.A.4 EtO Sterilizer Chamber 1
Capacity: 1,087 cu. ft. (8-pallet)
Manufacture Date: 2004

II.A.5 EtO Sterilizer Chamber 2
Capacity: 1,087 cu. ft. (8-pallet)
Manufacture Date: 2000

II.A.6 EtO Sterilizer Chamber 3
Capacity: 1,087 cu. ft. (8-pallet)
Manufacture Date: 2004

II.A.7 EtO Sterilizer Chamber 4
Capacity: 1,087 cu. ft. (8-pallet)
Manufacture Date: 2003

II.A.8 EtO Sterilizer Chamber 5
Capacity: 35 cu. ft. (1-pallet)
Manufacture Date: 1990

Engineer Review N104350031: Sterigenics US, LLC- Ethylene Oxide Commercial Sterilization Plant
March 19, 2024
Page 7
II.A.9 EtO Sterilizer Chamber 6
Capacity: 1,080 cu. ft. (8-pallet)
Manufacture Date: 1999

II.A.10 EtO Sterilizer Chamber 7
Capacity: 1,087 cu. ft. (8-pallet)
Manufacture Date: 2002

II.A.11 EtO Sterilizer Chamber 8
Capacity: 1,133 cu. ft. (8-pallet)
Manufacture Date: 1990

II.A.12 EtO Sterilizer Chamber 9
Capacity: 283 cu. ft. (2-pallet)
Manufacture Date: 1992

II.A.13 EtO Sterilizer Chamber 10
Capacity: 3,600 cu. ft. (24-pallet)
Manufacture Date: 1997

II.A.14 EtO Sterilizer Chamber 11
Capacity: 198 cu. ft. (1-pallet)
Manufacture Date: 1999

II.A.15 EtO Sterilizer Chamber 12
Capacity: 20 cu. ft. (R&D)

II.A.16 EtO Sterilizer Chamber 13
Capacity: 20 Cu. Ft. (R&D)

II.A.17 EtO Sterilizer Chamber 14
Capacity: 6 cu ft. (R&D)

II.A.18 EtO Sterilizer Chamber 15
Capacity: 12 cu. ft. (R&D)

II.A.19 EtO Sterilizer Chamber 16
Capacity: 20 cu. ft. (R&D)

II.A.20 EtO Sterilizer Chamber 17
Capacity: 20 cu. ft. (R&D)

II.A.21
NEW
Chamber 18 (NEW)
Capacity: 20 cu. ft. (R&D)
Control: EtO Abator and vented to scrubber

II.A.22
NEW
One Aeration Chamber (NEW)
Capacity: 0.42 m3
Included for informational purposes

Engineer Review N104350031: Sterigenics US, LLC- Ethylene Oxide Commercial Sterilization Plant
March 19, 2024
Page 8
II.A.23 Ceilcote Scrubber
One scrubber equipped with a packed tower, reaction tanks, dual recycle piping, heat
exchanger and a control panel

II.A.24 Advanced Air Technologies Scrubber
One scrubber equipped with packed tower with a countercurrent flow running acid-water
Maximum air-flow rate: 13,000 cubic feet/minute

II.A.25 Advanced Air Technologies Adsorber
Seven adsorbers consisting of dry beds

II.A.26
NEW
AAT Dry Bed Scrubber
Flow Rate: 44,000 cubic feet per minute

II.A.27 Various Water Tube Boilers
Maximum Rated Capacity: Less than 5.0 MMBtu/hr each
Fuel: Natural Gas

II.A.28
NEW
Natural Gas Emergency Engine (NEW)
Size: 240 hp
NSPS Applicability: Subpart JJJJ
MACT Applicability: Subpart ZZZZ

II.A.29 Comfort Heaters
Maximum Rated Capacity: Less than 5.0 MMBtu/hr each
Fuel: Natural Gas

II.A.30 Five Non-Volatile Liquid Organic Storage Tanks
Two 17,000 gallon and three 18,500 gallon tanks, for information purposes.

II.A.31
NEW
Media Abrasive Blaster
*vents internally

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 not use more than 210.2 tons of ethylene oxide gas per rolling 12-
month period. [R307-401-8]

Engineer Review N104350031: Sterigenics US, LLC- Ethylene Oxide Commercial Sterilization Plant
March 19, 2024
Page 9
II.B.1.a.1
NEW
The owner/operator shall:

A. Determine and record usage on a daily basis

B. Use the usage data to calculate a new rolling 12-month total by the 28th day of each
month using data from the previous 12 months. [R307-401-8]

II.B.1.b Visible emissions from the following emission points shall not exceed the following values:

A. AAT scrubber and dry bed system - 0% opacity

B. Storage Tanks - 0% opacity

C. All other points - 20% opacity. [R307-201-3]

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

II.B.2 Scrubber Requirements

II.B.2.a The Ceilcote scrubber shall be used to control all process streams from the sterilization
chamber vacuum pumps. The Advanced Air Technologies (AAT) scrubber and adsorber
system shall control all process streams from the aeration vents. [R307-401-8]

II.B.2.b Emissions from the Ceilcote scrubber shall be routed to the AAT scrubber and adsorber
system. [R307-401-8]

II.B.2.c The owner/operator shall route all ethylene oxide sterilizer back vent emissions through the
AAT scrubber and adsorber system. [R307-401-8]

II.B.2.d In case of an AAT adsorber system breakdown, the Ceilcote scrubber can be rerouted to the
Ceilcote stack to control sterilization chamber vacuum pump emissions. [R307-401-8]

II.B.2.e In case of Ceilcote breakdown, the AAT adsorber system shall be used to control the
sterilization chamber vacuum pumps, back vent and aeration emissions. [R307-401-8]

II.B.2.e.1 The owner/operator shall not allow the ethylene oxide concentration in the AAT adsorber
exhaust to exceed 5.415 ppmv (24-hour average) in the event of the Ceilcote scrubber
breaking down. This represents a 99% reduction as required by MACT Subpart O. [40 CFR
63 Subpart O, R307-401-8]

II.B.2.f The owner/operator shall keep and maintain records of any scrubber breakdowns. [R307-401-
8]

Engineer Review N104350031: Sterigenics US, LLC- Ethylene Oxide Commercial Sterilization Plant
March 19, 2024
Page 10
II.B.2.f.1 The scrubber breakdown records shall include the following items:

A. Date of breakdown

B. Cause of breakdown

C. Duration of breakdown

D. Any corrective actions taken. [R307-401-8]

II.B.2.g The following liquid flow rates in the scrubbers shall be maintained within the indicated
ranges:

A. The Ceilcote scrubber average liquid flow rate shall be greater than 80 gallons per
minute

B. The AAT scrubber average liquid flow rate shall be greater than 1,500 gallons per
minute. [R307-401-8]

II.B.2.g.1 The owner/operator shall record daily the liquid flow rates. The records shall be kept as long
as the scrubbers are in operation and shall include the following items:

A. Date

B. Scrubber Type

C. Liquid flow rate. [R307-401-8]

II.B.2.h The pH of the ethylene glycol solutions in the Ceilcote scrubber shall not exceed 2.0. [R307-
401-8]

II.B.2.h.1 The owner/operator shall record weekly the pH of the ethylene glycol solutions. The records
shall be maintained for all periods when the Ceilcote scrubber is in operation and shall include
the following items:

A. Date

B. pH. [R307-401-8]

II.B.2.i The AAT heat exchanger temperature difference between inlet and outlet (delta T) shall be
greater than 5 degrees Fahrenheit. The outlet temperature shall be greater than the inlet
temperature. [R307-401-8]

Engineer Review N104350031: Sterigenics US, LLC- Ethylene Oxide Commercial Sterilization Plant
March 19, 2024
Page 11
II.B.2.i.1 The owner/operator shall record daily the delta T and shall keep and maintain a logbook for all
periods when the AAT heat exchanger is in operation. The records shall include the following
items:

A. Date

B. Delta T

C. Any corrective actions taken. [R307-401-8]

II.B.2.j The owner/operator shall sample the AAT scrubber liquor and analyze and record once per
week the ethylene glycol concentration of the scrubber using the test methods and procedures
in 40 CFR 63, MACT Subpart O Section 63.365(e)(1). The source shall monitor and record
once per week the liquor level of the Ceilcote scrubber. Monitoring is not required during a
week in which the scrubber unit has not been operated. [40 CFR 63 Subpart O]

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

A. Ceilcote scrubber liquor level 181.5 inches in tank #2 when tank #1 is completely full

B. Ethylene glycol concentration in AAT scrubber 26.7%. [40 CFR 63 Subpart O]

II.B.2.k The owner/operator shall monitor and record the ethylene oxide concentration according to
Subpart O Section 63.364(e). [40 CFR 63 Subpart O, R307-401-8]

II.B.2.k.1 In the event of a breakdown of the instrumentation for the hourly monitoring of ethylene oxide
concentrations at the AAT adsorber exhaust, the facility shall take a daily reading at the dry
bed sampling port using a portable Photo Ionization Detector (PID) analyzer, Draeger tube, or
equivalent technology. [R307-401-8]

II.B.3 Stack Requirements

II.B.3.a
NEW
The height of the stack from the AAT Wet Acid Scrubber and Dry Bed System, Ceilcote
Scrubber, and AAT dry-bed scrubber, shall be a minimum of 60 feet above grade. [R307-401-
8]

II.B.3.b
NEW
The owner/operator shall monitor and record ethylene oxide concentration according to
MACT Subpart O, Section 63.362(c), Section 63.362(d), and 63.364(e). The AAT scrubber
shall not have less than a 99% reduction in ethylene oxide. The EtO from the vacuum pumps
are reduced by 99.5%. [40 CFR 63 Subpart O, R307-401-8]

II.B.3.b.1 Compliance Demonstration
To demonstrate compliance with the emissions limitations above, the owner/operator shall
perform stack testing on the AAT Scrubber according to the stack testing conditions contained
in this permit. [R307-165]

II.B.3.c Initial Test
The owner/operator shall conduct an initial stack test within 180 days after start up of the
combined scrubber system. [R307-165-2]

Engineer Review N104350031: Sterigenics US, LLC- Ethylene Oxide Commercial Sterilization Plant
March 19, 2024
Page 12
II.B.3.d Test Frequency
The owner/operator shall conduct subsequent emission tests within five years after the date of
the most recent emission test. The Director may require the owner/operator to perform an
emission test at any time. [R307-165-2, R307-401-8]

II.B.3.e Notification
At least 60 days prior to conducting an emission test, the owner/operator shall submit a source
test protocol to the Director. The source test protocol shall include:

A. The date, time, and place of the proposed test

B. The proposed test methodologies

C. The stack to be tested

D. The procedures to be used

E. Any deviation from an EPA-approved test method

F. Explanation of any deviation from an EPA-approved test method

If so directed by the Director, the owner/operator shall attend a pretest conference. [40 CFR
63, R307-165-3, R307-401-8]

II.B.3.f Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-
401-8]

II.B.3.g Testing
The owner/operator shall conduct testing according to the approved source test protocol. The
Director may reject emission test data if the test did not follow the approved source test
protocol or if Director was not provided an opportunity to have an observer present at the test.
[R307-165-5, R307-401-8]

II.B.3.g.1 Reporting
Within 60 days after completing an emission test, the owner/operator shall submit a copy of
the test results to the Director. [40 CFR 63, R307-401-8]

II.B.3.g.2 Test Conditions
The owner/operator shall conduct all tests while the source is operating at the maximum
production at which the source will be operated unless otherwise specified in the approved
source test protocol. During the tests, the owner/operator shall burn fuels or combinations of
fuels, use raw materials, and maintain process conditions representative of normal operations.
In addition, the owner/operator shall operate under any other relevant conditions that the
Director specifies. [R307-165-4, R307-401-8]

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Page 13
II.B.3.g.3 Possible Rejection of Test Results
The Director may reject emissions test data if they are determined to be incomplete,
inadequate, not representative of operating conditions specified for the test, or if the Director
was not provided an opportunity to have an observer present at the test. [R307-165-5]

II.B.3.h Test Methods
When performing emission testing, the owner/operator shall use the appropriate EPA-
approved test methods as acceptable to the Director. Acceptable test methods for pollutants
are listed below. [R307-401-8]

II.B.3.h.1 Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other methods if approved by the Director. [R307-165]

II.B.3.h.2 Ethylene Oxide
40 CFR 63.7 of Subpart A according to applicability in Table 1 of Subpart O, the procedure
listed in Subpart O, 63.360 through 63.367, and the test methods listed in 63.365 of Subpart O.
Temperature, flow rate, and efficiency of control device shall be determined. [R307-401]

II.B.3.h.3 Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2 or other testing methods approved by the Director. [R307-
165]

II.B.3.h.4 Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation. [R307-165, R307-401]

II.B.3.h.5 Source Operation
The production rate during all compliance testing shall be no less than 90% of the maximum
production achieved in the previous three (3) years. Maximum production rate in this AO
shall mean the production rate in one day (24 hours) at which amount of ethylene oxide is
consumed. [R307-165]

II.B.4
NEW
Emergency Engine Requirements
II.B.4.a
NEW
The owner/operator shall not operate each emergency engine on site for more than 100 hours
per rolling 12-month period during non-emergency situations. There is no time limit on the
use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ]

II.B.4.a.1
NEW
To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 20th day of each month using data from the previous 12 months.
Records documenting the operation of each emergency engine shall be kept in a log and shall
include the following:

1. The date the emergency engine was used
2. The duration of operation in hours
3. The reason for the emergency engine usage. [40 CFR 63 Subpart ZZZZ]

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Page 14

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March 19, 2024
Page 15
PERMIT HISTORY

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

Supersedes DAQE-AN104350030-21 dated March 25, 2021
Is Derived From NOI dated September 23, 2023
Incorporates Additional Information dated December 7, 2023
Incorporates Additional Information dated January 19, 2024

REVIEWER COMMENTS

1. Comment regarding Emissions Estimates:
Emission Increases:
Emissions from the new emergency generator engine were calculated using emission factors from
the manufacturers spreadsheet (VOC: 0.96, NOx: 1.45, and CO: 1.36 g/hp-hr), AP-42 Section 3.4
Table 3.2-3 (SO2, PM10, and PM2.5 and HAPS) and from 40 CFR 98, Tables C-1 and C-2 for GHG
emissions.

Emission Reductions:
Ethylene oxide emissions were estimated using the following mass balance assumptions:

94.95% of the ethylene oxide used is emitted through the sterilization chamber vacuum pumps.

4% of ethylene oxide used is emitted through the aeration room exhaust.

1% of ethylene oxide used is emitted through the back vents.

0.05% ethylene oxide used is emitted through fugitive emissions. Fugitive emissions are considered
emissions that exhaust through the Chamber Room Ventilation Vents. The new system will capture
and control these emissions.

The new enclosure will operate under negative pressure and vent all EtO emissions through the new
AAT dry bed scrubber. The control efficiency was estimated using the minimum required reduction
in 40 CFR 63 Subpart O (99%) and an annual usage of 420,600 lbs of EtO. The new calculation
incorporates previously fugitive emissions. [Last updated February 14, 2024]

2. Comment regarding AAT Monitoring note:
There are no proposed changes to monitoring. The source uses gas chromatography to monitor the
AAT adsorber exhaust. This is not a continuous emissions monitoring (CEM) system. The system is
in place to ensure ongoing compliance with MACT Subpart O.
[Last updated February 14, 2024]

3. Comment regarding Stack Testing :
The AAT scrubber system will continue to be stack tested with the same constraints as previously
required. [Last updated October 26, 2023]

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Page 16
4. Comment regarding MACT Applicability:
40 CFR 63 MACT Subpart O: Ethylene Oxide Standards for Sterilization Facilities. Sterilization
sources that use more than one (1) ton of ethylene oxide in sterilization or fumigation operations are
subject to this subpart. Therefore, this facility is subject to MACT Subpart O. This subpart requires
the sterilization chamber vent and the aeration room vent reduce ethylene oxide emissions to the
atmosphere by 99%.

40 CFR 63 MACT Subpart FFFF: Miscellaneous Organic Chemical Manufacturing. The source does
not manufacture ethylene oxide; therefore, MACT Subpart FFFF does not apply to this facility.
[Last updated January 31, 2024]

5. 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. This facility is not subject to 40 CFR
60 (NSPS) or 40 CFR 61 (NESHAP). The source is subject to 40 CFR 63 (MACT) regulations.
MACT Subpart O exempts this facility from obtaining a 40 CFR part 70 permit due to the facility
being an area source. There are no other reasons why this source would be required to obtain a 40
CFR part 70 permit; therefore, Title V does not apply to this source. [Last updated January 31, 2024]

6. Comment regarding Change in conditions:
This project involves the following changes:

1. The existing individual stacks are being consolidated into a single combined stack. The new stack
has an increased stack height of 60 feet above grade.
2. New emergency equipment is added to the equipment list.
3. An existing nitrogen dioxide sterilizer unit which is no longer in use has been removed from the
equipment list. This unit is no longer located at the site.
4. Language regarding method 204 has been removed from the permit as this language is only
applicable to physical design of the capture system, and is not related to actual emissions of EtO -
these emissions are controlled under Subpart O which is still included in the permit.
[Last updated January 31, 2024]

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Page 17
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

UTAH DIVISION OF AIR QUALITY – NOTICE OF
INTENT
Sterigenics US, LLC- Salt Lake City, Utah
Modification of Approval Order – DAQE-AN113860033-21
Prepared By:
TRINITY CONSULTANTS
4525 Wasatch Boulevard
Suite 200
Salt Lake City, Utah 84104
[phone]
Submitted on Behalf of:
Sterigenics US, LLC
5725 Harold Gatty Dr.
Salt Lake City, Utah 84116
September 2022
Sterigenics US, LLC / NOI Air Permit Application
Trinity Consultants i
TABLE OF CONTENTS
TABLE OF CONTENTS I
EXECUTIVE SUMMARY III
SOURCE IDENTIFICATION INFORMATION 1
Source Identification Summary ............................................................................................ 1
Area Designation .................................................................................................................. 1
Source Size Determination ................................................................................................... 2
Notice of Intent Forms ......................................................................................................... 2
Notice of Intent Fees ............................................................................................................ 2
DESCRIPTION OF PROJECT AND PROCESS 3
Description of Project ........................................................................................................... 3
Fugitive Emission Control Equipment ...................................................................................... 3
Supporting Equipment ........................................................................................................... 3
AO Updates.......................................................................................................................... 3
Description of Process .......................................................................................................... 4
EMISSION RELATED INFORMATION 6
HAP and VOC Emissions – EtO Sterilization .......................................................................... 6
Natural Gas-Fired Emergency Generator .............................................................................. 6
GHG Emissions ...................................................................................................................... 6
Emissions Summary .............................................................................................................. 7
BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS 8
EtO Sterilization .................................................................................................................... 8
Natural Gas Emergency Generator – BACT Analysis .............................................................. 8
CO, PM2.5, PM10, NOx, SO2 and VOC Emissions Natural Gas Emergency Generator Step 1 - Identify
All Control Technologies ........................................................................................................ 8
CO, PM2.5, PM10, NOx, SO2 and VOC Emissions Natural Gas Emergency Generator
Step 2 – Eliminate Technically Infeasible Options ..................................................................... 9
CO, PM2.5, PM10, NOx, SO2 and VOC Emissions Natural Gas Emergency Generator Step 3 – Rank
Remaining Control Technologies by Control Effectiveness ......................................................... 9
CO, PM2.5, PM10, NOx, SO2 and VOC Emissions Natural Gas Emergency Generator Step 4 –
Evaluate Most Effective Controls and Document Results ........................................................... 9
CO, PM2.5, PM10, NOx, SO2 and VOC Emissions Natural Gas Emergency Generator Step 5 - Select
BACT 9
EMISSION IMPACT ANALYSIS 11
APPLICABLE REQUIREMENTS 13
Utah Regulations ................................................................................................................ 13
UAC R307-101 General Requirements ................................................................................... 16
UAC R307-107 General Requirements: Breakdowns ............................................................... 17
UAC R307-201-3(5): Emission Standards: General Emission Standards .................................... 17
UAC R307-203: Emission Standards: Sulfur Content of Fuels ................................................... 17
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UAC R307-401-4 General Requirements ................................................................................ 17
UAC R307-401-5 Notice of Intent ......................................................................................... 17
UAC R307-401-8 Approval Order .......................................................................................... 17
UAC R307-405 Permits: Major Sources in Attainment or Unclassified Areas ............................... 18
Federal Regulations ............................................................................................................ 18
New Source Performance Standards ..................................................................................... 18
National Emission Standards for Hazardous Air Pollutants ....................................................... 19
FORMS 21
EMISSION CALCULATIONS 29
DESIGN DRAWINGS AND SPECIFICATIONS 32
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EXECUTIVE SUMMARY
Sterigenics US, LLC (Sterigenics) owns and operates the ethylene oxide sterilization facility located at 5725
Harold Gatty Dr, Salt Lake City, Salt Lake County, Utah. The facility has sterilization chambers of various
sizes used to sterilize medical devices and other products using gaseous ethylene oxide. The process
emissions are vented through packed bed scrubbers. The facility also includes two (2) water tube boilers.
Sterigenics operates under Approval Order (AO) DAQE-AN104350030-21 issued by the Utah Division of Air
Quality (UDAQ). The plant is an existing minor source for all pollutants and subject to the Maximum
Achievable Control Technology (MACT) programs.

Sterigenics is submitting this Notice of Intent (NOI) air permit application to the UDAQ for the plant to
obtain an updated air quality AO. Sterigenics is proposing to upgrade their current facility to include state of
the art emission control for fugitive ethylene oxide (EtO) emissions and add miscellaneous supporting
equipment. The proposed fugitive EtO emission control will include adding a permanent total enclosure per
EPA Method 204 and routing all captured emissions to a new Advanced Air Technologies (AAT) dry bed
scrubber. The existing Ceilcote and AAT wet acid scrubbers exhaust streams will also be routed to the new
dry bed scrubber for polishing, creating a single stack for all controlled EtO emissions. The proposed
modification will result in a net decrease in EtO emissions.

The support equipment includes a natural gas fired emergency generator and additional research and
development (R&D) equipment. This addition to the facility will contribute to emissions of criteria pollutants,
namely particulate matter (PM) with an aerodynamic diameter of 10 microns or less (PM10), PM with an
aerodynamic diameter of 2.5 or less (PM2.5), oxides of nitrogen (NOX), sulfur dioxide (SO2), carbon
monoxide (CO), and volatile organic compounds (VOCs). Hazardous air pollutant (HAP) and greenhouse gas
(GHG) emissions will also be increased by the planned support equipment. The potential to emit (PTE)
increase in this NOI air permit application is: 1.9x10-3 tons per year (tpy) for PM10, 1.9x10-3 tpy for PM2.5,
0.04 tpy for NOX, 0.04 tpy for CO, 5.74x10-5 tpy for SO2, 0.05 tpy for VOCs, 0.02 tpy for HAPs, and 11.44
tpy for GHGs.

The proposed modification will include the following equipment and operations:

► One EPA Method 204 permanent total enclosure
► One (1) AAT dry bed scrubber
► One (1) natural gas-fired emergency generator engine
► Update R&D sterilization equipment
► Removal of the nitrogen dioxide sterilizer from the AO

The plant is located within an area of Salt Lake County that is classified as attainment for all pollutants with
exception to the following: (1) PM2.5, for which it is classified as a serious nonattainment area of the
National Ambient Air Quality Standards (NAAQS); (2) for the 2015 8-hour Ozone Standard, which is
designated as moderate nonattainment1; and (3) a marginal nonattainment area of SO2. The PM10
nonattainment area was redesignated as attainment by the Environment Protection Agency (EPA), effective
as of March 27, 2020.

1 Based on report from UDAQ on July 6, 2021: https://deq.utah.gov/air-quality/ozone-overview-and-standard-moderate-area-
ozone-sip
Sterigenics US, LLC / NOI Air Permit Application
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SOURCE IDENTIFICATION INFORMATION
The following section contains the information requested under the “Source Identification Information”
section of UDAQ Form 1 Notice of Intent (NOI) Application Checklist.
Source Identification Summary
► Company Name: Sterigenics US, LLC
► Address: 5725 Harold Gatty Dr., Salt Lake City, UT 84116
► County: Salt Lake
► UTM Coordinates: 413,240 m Easting, 4,514,932 m Northing, UTM Zone 12
► Primary SIC Code: 7389 (Business Services, Not Elsewhere Classified)
► Area Designation: Nonattainment area PM2.5, SO2, and ozone
► Source Size Determination: Minor Stationary Source
► Current AO: DAQE-AN104350030-21

All correspondence regarding this submission should be addressed to:
Mr. Kevin Wagner
VP, Environmental Health, and Safety
2015 Spring Road, Suite 650
Oak Brook, IL 60523
Phone: [phone]
Email: [e-mail]
Gwendolyn Jordan
Regional Manager, Environmental Health, and
Safety
2015 Spring Road, Suite 650
Oak Brook, IL 60523
Phone: [phone]
Email: [e-mail]
Area Designation
The plant is located within an area of Salt Lake County that is classified as attainment for all pollutants with
exception to the following: (1) PM2.5 for which it is classified as a serious nonattainment area of the NAAQS;
(2) for the 2015 Ozone Standard, which is designated as moderate nonattainment and 2; and (3) a marginal
nonattainment area of SO2. The PM10 nonattainment area was redesignated as in attainment by the EPA
effective as of March 27, 2020.

2 Based on report from UDAQ on July 6, 2021: https://deq.utah.gov/air-quality/ozone-overview-and-standard-moderate-area-
ozone-sip
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Source Size Determination
As presented in Section 3, site-wide emissions at the plant are below the major source threshold (MST) for
all criteria pollutants and therefore a minor source for New Source Review (NSR). This permitting action is a
minor modification to an existing minor source.
Notice of Intent Forms
The following UDAQ forms have been included with the NOI air permit application:
►Form 1 – Notice of Intent Application Checklist
►Form 2 – Source Identification Information
►Form 4 – Project Information
►Form 5 – Emissions Information Criteria/GHGs/ HAPs
►Form 9 - Scrubbers
►Form 17a – Natural Gas-Powered Generator
Notice of Intent Fees
Sterigenics will use the UDAQ’s Payment Portal to prepay the following UDAQ NOI air permit application fees
associated with this submittal:
“Application Filing Fee” for the “Major or Minor Modification (Including GAO)” category = $500
“Application Review Fee” for the “Existing Minor Source with a Minor Modification” category in maintenance
or non-attainment areas = $2,200
Total UDAQ fees = $2,700
Sterigenics understands that the total permit review fee is based on the total actual time spent by UDAQ
staff processing this NOI air permit application. Upon issuance of the AO, if the total review time is more
than 20 standard hours, UDAQ will invoice Sterigenics at $110 per hour for the additional time above 20
standard hours.
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DESCRIPTION OF PROJECT AND PROCESS
Description of Project
The facility has sterilization chambers of various sizes used to sterilize medical devices and other products
primarily using gaseous EtO. Process emissions are vented through packed bed scrubbers with a small
amount escaping as uncontrolled fugitive emissions. For this project, Sterigenics proposes to add capture
and collection technology for fugitive EtO emissions by implementing a permanent total enclosure around
the existing process and routing collected emissions to a new AAT dry bed scrubber. Exhaust from the two
existing scrubbers will also be routed to the AAT dry bed scrubber for redundancy. Controlling fugitive
emissions from EtO sterilization will reduce EtO exposure to employees and the public. The proposed project
represents the best available demonstrated control technology for controlling fugitive emissions from EtO
sterilization facilities. A list of proposed equipment is provided below.
Fugitive Emission Control Equipment
► One (1) Permanent total enclosure.
► One (1) AAT dry bed scrubber system rated at 44,000 cubic feet per minute (CFM) and 80%
minimum EtO destruction efficiency.
Supporting Equipment
► One (1) 240 horsepower (hp) natural gas fired emergency generator

As part of this permitting action, Sterigenics would like to update the list of permitted equipment in Section
II.A of the AO and applicable conditions in Section II.B. These updates have no impact on potential
emissions and are provided for informational purposes only. A list of AO updates is provided below.
AO Updates
► Remove Item II.A.22, the Nitrogen Dioxide Sterilizer. This equipment has been removed and can be
eliminated from the AO.
► Remove Condition II.B.1.b. This condition refers to the personal EtO detection monitors worn by
employees as a safety measure. These monitors ensure employee exposure is below standards for
occupational health and safety and are not regulated under the Clean Air Act.
► Add the proposed AAT dry bed scrubber to Section II.A. All treated EtO exhaust from the facility will
be routed through a new single stack. See the Design Documents and Specifications Appendix for
stack details.
► Add the natural gas-fired emergency generator to Section II.A.
► Update the R&D sterilizer chamber equipment list in Section II.A. to match the equipment listed in
Table 1. No increase in annual EtO throughput or emissions are proposed with this update.
► One (1) Lunaire Model CEO-932W-4 0.33 m3 pre-conditioning chamber and one (1) Steris Model
M71GA2 0.42 m3 aeration chamber provided for informational purposes only.

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Table 1 - Sterigenics R&D Sterilization Chambers
AO
Equipment
Item No.
AO Chamber
No.
Sterigenics
Assigned
No.
Manufacturer Serial N Model Chamber
Size
II.A.13 12 E-767 Joslyn 1193-2F 2038 0.23 m3
II.A.14 13 E-1202 Joslyn 121098-15 2038 0.23 m3
II.A.15 14 E-3391 Joslyn 2553-1 2038 0.23 m3
II.A.16 15 E-3392 Joslyn 1695-1 2038 0.23 m3
II.A.17 16 E-3255 Joslyn 2038-2000 2038 0.23 m3
II.A.18 17 E-TBD Steris 2022-0021 BIER 0.022 m3
New1 18 E-4112 3M HA000005 GS8X-
2D
0.22 m3
New EtO Abator for
Chamber 18.
E-4111 3M 300337 50AN N/A
1. This chamber includes the built in EtO control system 3M model 50AN. Exhaust from the system is
vented to the site wide EtO scrubbers for redundancy.
Description of Process
EtO sterilization efficiency is based on the four process parameters of EtO concentration, humidity,
temperature, and time. Temperature and humidity must be uniform throughout the product while exposed
to high concentration EtO for an extended time. This is a widely used process for sterilization of healthcare
products and single-use medical devices. The EtO sterilization process consists of three main process steps
of preconditioning, sterilization, and post sterilization aeration.

Product for sterilization is received at the facility on pallets and staged in the warehouse for preconditioning.
During preconditioning, the product is held at a set temperature and humidity for extended time to allow
the product to have uniform characteristics. This allows for better penetration of the EtO into the product
and improves process efficiency. Product is typically preconditioned for a minimum of six (6) hours prior to
entering a sterilization chamber.

The sterilization chamber is set to run on an automated cycle beginning with a leak test of the chamber and
EtO dispensing system to verify integrity of the system and ensure worker safety. Following the leak test,
the chamber is placed under a vacuum and filled with nitrogen creating an inert environment inhibiting EtO
oxidation. Reducing the chamber below atmospheric pressure improves EtO product penetration. EtO is
introduced to the chamber and allowed to penetrate the product for an extended time. Once the product is
sterilized, EtO is rapidly evacuated from the chamber vent via a vacuum pump and routed to the existing
Ceilcote scrubber. Following the vacuum pump evacuation, chamber “back vents” are opened, and chamber
air is pulled through the back vents with a fan to maintain a negative pressure while opening chamber
doors. Sterilization chamber back vents are routed to the existing AAT scrubber. Typical sterilization time is
8-10 hours.

Once sterilized, the product is moved to an aeration chamber to remove residual EtO within the product.
Aeration chambers are held at elevated temperature with rapid air circulation to promote degassing.
Exhaust from the aeration chamber is vented to the existing AAT scrubber. Sterilized product is then staged
for customer delivery. All process steps, including the EtO dispensing system, will be within a permanent
Sterigenics US, LLC / NOI Air Permit Application
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total enclosure vented to the proposed AAT dry bed scrubber. Exhaust from the existing scrubbers will be
routed through the AAT dry bed scrubber for polishing. A process diagram is provided below in Figure 1.

Figure 1 – EtO Sterilization Process Flow Diagram

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EMISSION RELATED INFORMATION
This section details the methodology used to calculate controlled and uncontrolled emissions for criteria
pollutants, greenhouse gases, and HAPs associated with each new unit and its associated fugitives as
regulated by R307-401-5(2)(b). Detailed emission calculation tables are included in Appendix B.
HAP and VOC Emissions – EtO Sterilization
Sterigenics provided detailed EtO emission estimates to UDAQ as part of the NOI application submitted on
September 24, 2020. A material balance approach was utilized to develop these estimates and no changes
to potential EtO usage is proposed for this modification. The annual potential fugitive emissions were
estimated assuming 0.05% of total EtO usage escapes the process as fugitives and is based on a study
conducted at a similar Sterigenics facility in Willowbrook, Illinois. What were uncontrolled EtO fugitive
emissions in the previous NOI, will now be controlled by the AAT dry bed scrubber, thus reducing overall
EtO emissions from the facility. Capture efficiency of the enclosure will be coupled with the scrubber
destruction efficiency to determine potential emissions for this modification. Per EPA guidance, capture
efficiency is assumed 100%3 and destruction efficiency of the scrubber is 80% as guaranteed by AAT.

𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 (𝑡𝑡𝑡𝑡𝑡𝑡)=𝑃𝑃𝑃𝑃𝐸𝐸𝑃𝑃𝑃𝑃𝐸𝐸𝐸𝐸 𝐹𝐹𝐹𝐹𝐹𝐹𝐸𝐸𝑡𝑡𝐸𝐸𝐹𝐹𝑃𝑃𝐸𝐸 �𝑙𝑙𝑙𝑙𝐸𝐸𝑡𝑡𝑃𝑃�× 100% 𝐶𝐶𝐶𝐶𝑡𝑡𝑡𝑡𝐹𝐹𝑃𝑃𝑃𝑃 𝐸𝐸𝐸𝐸𝐸𝐸. × (1 −80% 𝐷𝐷𝑃𝑃𝐸𝐸𝑡𝑡𝑃𝑃𝐹𝐹𝑃𝑃𝑡𝑡𝐸𝐸𝐸𝐸𝐸𝐸 𝐸𝐸𝐸𝐸𝐸𝐸.)÷ 2000 �𝑙𝑙𝑙𝑙𝐸𝐸𝑡𝑡𝐸𝐸𝐸𝐸�
Natural Gas-Fired Emergency Generator
Sterigenics is adding only one (1) natural gas fired emergency generator engine, rated at 240 hp. Emission
factors for NOx, VOC, and CO are provided by the manufacturer. Other criteria and hazardous air pollutants
(HAPs) emission factors are from EPAs AP-42 Section 3.2: Natural Gas Fired Reciprocating Engines. Annual
emissions estimates are calculated using the following equation:
Annual Emissions (tpy)=Heat Input �MMBtuhr�× EF �lbMMBtu�× 100 �hryr�× �ton2,000 lb�

The emission factors used, and the results of these calculations can be found in Appendix B.
GHG Emissions
GHG emissions are estimated from the combustion of natural gas in the proposed emergency generator. To
calculate total Carbon Dioxide Equivalent (CO2e, equivalent to GHG) emissions, total fuel usage was
multiplied by fuel-specific emission factors and global warming potentials (GWP) provided in 40 CFR 98
Tables A-1, C-1, and C-2.

3 EPA Air Pollution Control Technology Fact Sheet: Permanent Total Enclousres. EPA-452/F-03-033.
https://www.epa.gov/sites/default/files/2016-05/documents/fpte.pdf
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Natural Gas CO2 e Annual Emissions (tpy)=�Emission Factor CO2 �kgMMBtu�+Emission Factor CH4 �kgMMBtu� ∗GWP CH4+Emission Factor N2 O �kgMMBtu� ∗GWP N2O� ∗Heat Input �MMBtuhr� ∗Operating Hours �hryr�∗ �ton907.185 kg�
Emissions Summary
A summary of the potential emissions at the Salt Lake City facility resulting from this modification are
provided below in Table 1.
Table 2- Potential Emissions Summary (tpy)
Pollutant
EtO
Sterilization1
Natural Gas
Generator
Permitted
Potential
Emissions2
Proposed
Potential
Emissions
Proposed
Potential
Emissions Change
VOC 2.12 2.54E-02 2.16 2.21 0.05
NOx N/A 3.84E-02 3.16 3.20 0.04
CO N/A 3.60E-02 1.20 1.24 0.04
SO2 N/A 5.74E-05 0.02 0.02 5.74E-05
PM10 N/A 1.9E-03 0.39 0.39 1.90E-03
PM2.5 N/A 1.9E-03 0.39 0.39 1.90E-03
HAPs 2.12 3.17E-03 2.16 2.18 0.02
CO2e N/A 11.44 3,927 3,938 11.44
1.Fugitive emissions from EtO sterilization are reduced by this modification. Point source EtO
emissions nominally increase.
2.Permitted emissions are from AO DAQE-AN104350030-21 issued March 25, 2021.
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BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS
In the State of Utah, under R307-401-5(2)(d), Notice of Intent, every facility, operation, or process that
proposes any activity that would emit an air contaminant into the air, must consider Best Available Control
Technology (BACT) for a proposed new source or modification.4 The below BACT analysis only addresses
units which will be modified, installed, or otherwise addressed in this NOI air permit application.
EtO Sterilization
This permit modification constitutes a reduction in overall EtO emissions from existing levels and therefore a
detailed BACT analysis is not required or provided. It should be noted that the existing controls meet current
BACT and federal emissions standards. The proposed AAT dry bed scrubber is a newly available emission
control for fugitive emissions from EtO sterilization demonstrated as technically feasible.
Natural Gas Emergency Generator – BACT Analysis
Sterigenics is proposing to add one (1) natural gas-fired emergency generator engine, rated at 240 hp.
Natural gas-fired engines are classified as spark ignition (SI) internal combustion engines (ICE). The primary
pollutants in the exhaust gases include CO, NOX, VOC, SO2, PM10, and PM2.5. The natural gas-fired engine
proposed at Sterigenics is for emergency use only (except for readiness testing) and will use pipeline quality
natural gas.

EPA’s Reasonable Available Control Technology (RACT)/BACT/LAER (RBLC) Clearinghouse database was
queried to identify controls for other similar-sized emergency generator engines. The RBLC shows that
most natural gas-fired emergency generator engines have BACT emission limits or permitted emission limits
under other regulatory programs at or above the New Source Performance Standards (NSPS) Subpart JJJJ -
Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. Presented below are
the five steps of the top-down BACT analysis for the natural gas-fired emergency generator engine.
CO, PM2.5, PM10, NOx, SO2 and VOC Emissions Natural Gas Emergency
Generator Step 1 - Identify All Control Technologies

Available control technologies for natural gas-fired emergency generator engines include the following for
CO, VOCs, PM10, PM2.5, NOX, and SO2 5:

► Limited Hours of Operation;
► Good Combustion Practices;
► Use of an EPA Certified Engine;
► Using Pipeline Quality Natural Gas.
The following step evaluates the technical feasibility of each of these options.

4 UAC R307-401-4
5 Per RBLC database search conducted August 18, 2022.
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CO, PM2.5, PM10, NOx, SO2 and VOC Emissions Natural Gas Emergency Generator
Step 2 – Eliminate Technically Infeasible Options
Limited Hours of Operation
One of the apparent opportunities to control the emissions of all pollutants released from emergency
generator engines is to limit the hours of operation for the equipment. Due to the designation of the
proposed generator as emergency equipment, it is limited to 100 hours of operation for maintenance and
testing. Sterigenics minimizes planned operation time for the emergency generator engine to maintenance
and testing.
Good Combustion Practices
Good combustion practices refer to the operation of engines at high combustion efficiency, which reduces
the products of incomplete combustion. The emergency generator engine is designed to achieve maximum
combustion efficiency. The manufacturer has provided operation and maintenance manuals that detail the
required methods to achieve the highest levels of combustion efficiency. Sterigenics will operate and
maintain the emergency engine in accordance with the manufacture provided instructions and best industry
practices.
Use of an EPA Certified Engine
EPA noted that non-road engines were a significant source of emissions and began adopting emission
standards for these emission units in 1994. Today, engines are required to meet certain emission limits
based on the size and model year. The proposed engine used in this emergency generator set complies with
EPA emissions regulations under the provisions of 40 CFR Part 60, Subpart JJJJ.
Using Pipeline Quality Natural Gas
Limiting combustion to only pipeline quality natural ensures the fuel is free of impurities that can cause the
formation of excess air pollutants. Sterigenics proposes to use only pipeline quality natural gas in the
emergency generator.
CO, PM2.5, PM10, NOx, SO2 and VOC Emissions Natural Gas Emergency Generator
Step 3 – Rank Remaining Control Technologies by Control Effectiveness
Effective control technologies for natural gas engines include limited hours of operation, good combustion
practices, use of EPA certified engines, and the use of pipeline quality natural gas. All feasible control
technologies are proposed for implementation.
CO, PM2.5, PM10, NOx, SO2 and VOC Emissions Natural Gas Emergency
Generator Step 4 – Evaluate Most Effective Controls and Document Results
Because all feasible control technologies are proposed for implementation, no further consideration of
environmental or economic impacts are required.
CO, PM2.5, PM10, NOx, SO2 and VOC Emissions Natural Gas Emergency Generator
Step 5 - Select BACT
The proposed natural gas emergency generator engine is EPA certified compliant with 40 CFR 60 Subpart
JJJJ emission standards. Additionally, the emergency generator engine will be operated and maintained in
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accordance with good combustion practices and combust only pipeline quality natural gas. The hours of
operation are restricted to 100 hours for maintenance and testing per year. These controls and work
practices for the natural-fired emergency generator engines are selected as BACT.
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EMISSION IMPACT ANALYSIS
Tables 3 and 4 compares proposed emissions to applicable modeling thresholds contained in R307-403-4
through 7, R307-410-4, and R307-410-5. The proposed emissions from the project do not exceed any
modeling thresholds.
Table 3 - Facility-Wide Emissions and Comparison to Major Source and Modeling Thresholds.
Pollutant
(tons/yr)
Project
Totals
Permitted
Potential
Emissions1
Proposed
Potential
Emissions
Modeling
Limit2
Modeling
Required
(Y/N)5
Major
Source
Thresholds3,4
Major
Source
(Y/N)
VOC 0.05 2.16 2.21 - N 70 N
NOx 0.04 3.16 3.20 40 N 70 N
CO 0.04 1.20 1.24 100 N 250 N
SO2 5.74E-05 0.02 0.02 40 N 250 N
PM10 1.90E-03 0.39 0.39 15 N 70 N
PM2.5 1.90E-03 0.39 0.39 - N 70 N
HAPs 0.02 2.16 2.18 See HAP
Summary N 10/25 N
CO2e 11.44 3,927 3,938 - N 75,000 N
1.Permitted emissions from AO DAQE-AN104350030-21 issued March 25, 2021.
2.Modeling Limit is stated in UDAQ Emissions Impact Assessment Guidelines under Table 1: Total
Controlled Emission Rates for New Sources
3.Major source thresholds for PM2.5 and precursors are defined by 40 CFR section 51.165(a)(1)(iv)(A).
4.Total HAP Threshold is stated in 40 CFR Section 63.2 under definition of a Major Source.
Table 4 –HAP Modeling Screening
Pollutant Emissions (lb/hr) Emission Threshold
Value1
Modeling
Required (Y/N)
1,1,2,2-Tetrachloroethane 4.94E-05 1.359 N
1,1,2-Trichloroethane 2.99E-05 10.803 N
1,3-Butadiene 1.30E-03 0.292 N
1,3-Dichloropropene 2.48E-05 0.899 N
Acetaldehyde 5.45E-03 6.9363 N
Acrolein 5.14E-03 0.0353 N
Benzene 3.09E-03 0.3163 N
Carbon Tetrachloride 3.46E-05 2.0764 N
Chlorobenzene 2.52E-05 9.115 N
Chloroform 2.68E-05 9.668 N
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Pollutant Emissions (lb/hr) Emission Threshold
Value1
Modeling
Required (Y/N)
Ethylbenzene 4.84E-05 17.194 N
Ethylene Dibromide 4.16E-05 NA N
Formaldehyde 4.00E-02 0.0567 N
Methanol 5.98E-03 55.132 N
Methylene Chloride 8.05E-05 34.389 N
Naphthalene 1.90E-04 10.381 N
Polycyclic Aromatic
Hydrocarbons (PAH)
2.75E-04 NA N
Styrene 2.32E-05 16.87 N
Toluene 1.09E-03 14.922 N
Vinyl Chloride 1.40E-05 0.1687 N
Xylene 3.81E-04 85.97 N
Ethylene Oxide 4.80E-03 0.3567 N
1. Emission threshold value for point sources assumes vertically unrestricted release less than 50 meters
from property boundary.
2. Emission threshold values taken from: https://documents.deq.utah.gov/air-
quality/permitting/operating-permits/DAQ-2018-002269.pdf
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APPLICABLE REQUIREMENTS
Per UDAQ’s Form 1 NOI Checklist, the NOI air permit application must include a discussion of State and
Federal requirements and their applicability to the project. Regulations can include NAAQS, SIP, NSPS, and
MACT and Utah Air Quality Regulations.
Sterigenics has evaluated the applicability of the aforementioned regulatory measures associated with
projects described in this NOI application. Applicable regulatory measures associated with the projects
described in this NOI will be discussed in the subsequent sections. Regulatory measures not associated with
the projects described in this NOI application or previously permitted equipment will not be discussed, as
they have already been reviewed in a previous NOI application.
Utah Regulations
Sterigenics has determined that the following rules under the Utah Administrative Code (UAC) Title R307 will
apply to this project:
Table 5 - Evaluation of Utah Air Quality Rules
Reference Regulation Name Applicability
Yes No
R307-101 General Requirements X
R307-102 General Requirements: Broadly Applicable
Requirements X
R307-103 Administrative Procedures X
R307-104 Conflict of Interest X
R307-105 General Requirements: Emergency controls X
R307-107 General Requirements: Breakdowns X
R307-110 General Requirements: State Implementation
Plan X
R307-115 General Conformity X
R307-120 General Requirements: Tax Exemption for Air
Pollution Control Equipment X
R307-121 General Requirements: Clean Air and Efficient
Vehicle Tax Credit X
R307-122 General Requirements: Heavy Duty Vehicle Tax
Credit X
R307-123 General Requirements: Clean Fuels and Vehicle
Technology Grant and Loan Program X
R307-124 General Requirements: Conversion to Alternative
Fuel Grant Program X
R307-125 Clean Air Retrofit, Replacement, and Off-Road
Technology Program X
R307-130 General Penalty Policy X
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Reference Regulation Name Applicability
Yes No
R307-135 Enforcement Policy for Asbestos Hazard
Emergency Response Act X
R307-150 Emission Inventories X
R307-165 Emission Testing X
R307-170 Continuous Emission Monitoring Program X
R307-201 Emission Standards: General Emission Standards X
R307-202 Emission Standards: General Burning X
R307-203 Emission Standards: Sulfur Content of Fuels X
R307-204 Emission Standards: Smoke Management X
R307-205 Emission Standards: Fugitive Emissions and
Fugitive Dust X
R307-206 Emission Standards: Abrasive Blasting X
R307-207 Residential Fireplaces and Solid Fuel Burning
Devices X
R307-208 Outdoor Wood Boilers X
R307-210 Standards of Performance for New Stationary
Sources X
R307-214 National Emission Standards for Hazardous Air
Pollutants X
R307-220 Emission Standards: Plan for Designated Facilities X
R307-221 Emission Standards: Emission Controls for
Existing Municipal Solid Waste Landfills X
R307-222 Emission Standards: Existing incinerator for
Hospital, Medical, Infectious Waste X
R307-223 Emission Standards: Existing Small Municipal
Waste Combustion Units X
R307-224 Mercury Emission Standards: Coal Fired Electric
Generating Units X
R307-230 NOX Emission Limits for Natural Gas-Fired Water
Heaters X
R307-250 Western Backstop Sulfur Dioxide Trading Program X
R307-301 Utah and Weber Counties: Oxygenated Gasoline
Program as a Contingency Measure X
R307-302 Solid Fuel Burning Devices X
R307-303 Commercial Cooking X
R307-304 Solvent Cleaning X
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Reference Regulation Name Applicability
Yes No
R307-305
Nonattainment and Maintenance Areas for PM10:
Emission Standards X
R307-306
PM10 Nonattainment and Maintenance Areas:
Abrasive Blasting X
R307-307

Road Salting and Sanding X
R307-309
Nonattainment and Maintenance Areas for PM10
and PM2.5: Fugitive Emissions and Fugitive Dust X
R307-310 Salt Lake County: Trading of Emission Budgets
for Transportation Conformity X
R307-311 Utah County: Trading of Emission Budgets for
Transportation Conformity X
R307-312
Aggregate Processing Operations for PM2.5
Nonattainment Areas X
R307-320

Ozone Maintenance Areas and Ogden City:
Employer Based Trip Reduction X
R307-325

Ozone Nonattainment and Maintenance Areas:
General Requirements X
R307-326
Ozone Nonattainment and Maintenance Areas:
Control of Hydrocarbon Emissions in Petroleum
Refineries
X
R307-327 Ozone Nonattainment and Maintenance Areas:
Petroleum Liquid Storage X
R307-328

Gasoline Transfer and Storage X
R307-335

Degreasing X
R307-341

Ozone Nonattainment and Maintenance Areas:
Cutback Asphalt X
R307-342

Adhesives and Sealants X
R307-343 Wood Furniture Manufacturing Operations X
R307-344 Paper, Film, and Foil Coatings X
R307-345 Fabric and Vinyl Coatings X
R307-346 Metal Furniture Surface Coatings X
R307-347 Large Applicable Surface Coatings X
R307-348 Magnet Wire Coatings X
R307-349 Flat Wood Panel Coating X
R307-350 Misc. Metal Parts and Product Coating X
R307-351

Graphic Arts X
R307-352 Metal Container, Closure, and Coil Coatings X
R307-353 Plastic Parts Coatings X
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Reference Regulation Name Applicability
Yes No
R307-354 Automotive Refinishing Coatings X
R307-355 Aerospace Manufacture and Rework Facilities X
R307-356 Appliance Pilot Light X
R307-357 Consumer Products X
R307-361

Architectural Coatings X
R307-401 Permit: New and Modified Sources X
R307-403 Permits: New and Modified Sources in
Nonattainment and Maintenance Areas X
R307-405 Permits: Major Sources in Attainment or
Unclassified Areas (PSD) X
R307-406

Visibility X
R307-410

Permits: Emission Impact Analysis X
R307-414

Permits: Fees for Approval Orders X
R307-415

Permits: Operating Permit Requirements X
R307-417 Permits: Acid Rain Sources X
R307-420

Permits: Ozone Offset Requirements in Salt Lake
County and Utah County X
R307-421

Permits: PM10 Offset Requirements in Salt Lake
County and Utah County X
R307-424 Permits: Mercury Requirements for Electric
Generating Units X
R307-501 to 511 Oil and Gas Industry X
R307-801

Utah Asbestos Rule X
R307-840

Lead-Based Paint Program Purpose, Applicability,
and Definitions X
R307-841 Residential Property and Child-Occupied Facility
Renovation X
R307-842

Lead-Based Paint Activities X
Each of the regulations and how they apply to the facility as a result of the project are described below.
UAC R307-210 and R307-214 are incorporated into Utah regulations by referencing the federal statutes. As
such, applicability and requirements for these standards are discussed in the following Section.
UAC R307-101 General Requirements
With this project, Sterigenics will comply with those general requirements that are applicable to this project
as addressed in the definitions, terms, abbreviations, and references used in the UAC R307-101, and 40
CFR. As this requirement is already addressed in Sterigenics general requirements of its AO, no updates to
the current AO conditions are necessary for this requirement.
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UAC R307-107 General Requirements: Breakdowns
Sterigenics reports breakdowns, in accordance with Condition I.6 of the AO currently issued, within 24 hours
via telephone, electronic mail, fax, or other similar method and provides detailed written description within
14 days of the onset of the incident to UDAQ. As a result of the project, no updates to the current AO
conditions are necessary for this requirement.
UAC R307-201-3(5): Emission Standards: General Emission Standards
Sterigenics complies with visible emission standards from all point sources in accordance with Condition
II.B.1.c of the current AO. This condition has a 0% opacity limit for scrubbers and a 20% limit for all other
point sources. Additionally, opacity observations are required to be conducted in accordance with 40 CFR
60, Appendix A, Method 9, consistent with this rule. As a result of the project, no updates to the current AO
conditions are necessary for this requirement.
UAC R307-203: Emission Standards: Sulfur Content of Fuels
Sterigenics utilizes natural gas in the emergency generator engine. Recordkeeping and reporting regulations
in this rule will be met. Pipeline quality natural gas will be combusted in the emergency generator.
UAC R307-401-4 General Requirements
Sterigenics complies with the general requirements set forth for new and modified installations. All
equipment is adequately and properly maintained.
UAC R307-401-5 Notice of Intent
Sterigenics is satisfying the requirements by submitting this NOI application.
UAC R307-401-8 Approval Order
(1) The director will issue an AO if the conditions have been met.
(a) The degree of pollution control for emissions, to include fugitive emissions and fugitive dust,
is at least best available control technology. When determining best available control technology
for a new or modified source in an ozone nonattainment or maintenance area that will emit
volatile organic compounds or nitrogen oxides, best available control technology shall be at least
as stringent as any Control Technique Guidance document that has been published by EPA that
is applicable to the source.
(b) The proposed installation will meet the applicable requirements of:
(i) R307-403, Permits: New and Modified Sources in Nonattainment Areas and Maintenance
Areas;
(ii) R307-405, Permits: Major Sources in Attainment or Unclassified Areas (PSD);
(iii) R307-406, Visibility;
(iv) R307-410, Emissions Impact Analysis;
(v) R307-420, Permits: Ozone Offset Requirements in Davis and Salt Lake Counties;
(vi) R307-210, National Standards of Performance for New Stationary Sources;
(vii) National Primary and Secondary Ambient Air Quality Standards;
(viii) R307-214, National Emission Standards for Hazardous Air Pollutants;
(ix) R307-110, Utah State Implementation Plan; and
(x) All other provisions of R307.
(2) The approval order will require that all pollution control equipment be adequately and properly
maintained.
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(3) Receipt of an approval order does not relieve any owner or operator of the responsibility to
comply with the provisions of R307 or the State Implementation Plan.
As required by the Sterigenics AO, compliance is maintained by properly maintaining all pollution control
equipment. As documented in numerous conditions in Sterigenics’ AO, BACT provisions specified in UAC
R307-401 have been applied through installed control equipment and associated monitoring conditions.
UAC R307-405 Permits: Major Sources in Attainment or Unclassified Areas
This rule implements the federal PSD permitting program for major sources and major modifications in
attainment areas and maintenance areas as required by 40 CFR 51.166. The Sterigenics facility is in an
attainment area for PM10, nitrogen dioxide (NO2), CO, and Lead. Sterigenics emission impacts are below
major source thresholds of these pollutants. The Salt Lake City facility’s PTE does not exceed the major
source thresholds for these pollutants and is therefore not subject to PSD review for this modification.
Federal Regulations
New Source Performance Standards
NSPS require new, modified, or reconstructed sources to control emissions to the level achievable by the
best demonstrated technology as specified in the applicable provisions. Moreover, any source subject to an
NSPS is also subject to the general provisions of NSPS Subpart A, except as noted. The following section
details the applicability of NSPS regulations to the facility operations.
NSPS Subpart A – General Provisions
All affected sources subject to source specific NSPS are subject to the general provisions of NSPS Subpart A
unless specifically excluded by the source specific NSPS. Subpart A requires initial notification, performance
testing, recordkeeping, and monitoring, provides reference methods, and mandates general control device
requirements for all other subparts.
NSPS Subpart JJJJ - Stationary Spark Ignition Internal Combustion Engines
NSPS Subpart JJJJ, Standards of Performance for Stationary Spark Ignition Internal Combustion Engines,
establishes requirements for stationary SI internal combustion engines for which construction, modification,
or reconstruction commenced after June 12, 2006. The construction date is the date the engine was
ordered by the owner or operator. The emergency generator engine proposed to be added to Sterigenics’
AO was constructed after the specified construction dates. NSPS JJJJ is applicable to the proposed engine.
Emission Limitations
Emergency stationary SI ICE with a displacement of > 225 cubic centimeters and manufactured after
January 1, 2011, must comply with the Phase 3 emission standards for non-handheld engines identified in
40 CFR part 1054, for all listed pollutants and must be met for the life of the engine.6
Monitoring Requirements
Each SI internal combustion engine that does not meet the standards applicable to non-emergency engines,
must install a non-resettable hour meter prior to startup of the engine.7
6 40 CFR 60.4233.
7 40 CFR 60.4237(b).
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Compliance Requirements 8
► Purchase an engine certified according to procedures specified in NSPS JJJJ.
► Operate, maintain, install, and configure the stationary SI internal combustion engine and control
device according to the manufacturer's emission-related written instructions.
► Change only those emission-related settings that are permitted by the manufacturer.
► The engine may be operated for 100 hours per calendar year for maintenance checks, readiness
testing, periods where there is a deviation of voltage or frequency of 5 percent or greater below
standard voltage or frequency, and/or up to 50 hours per calendar year in non-emergency
situations.
► No limit for emergency usage of the engine in emergency situations.
► Propane may be used in emergency situations when natural gas is unavailable for up to 100 hours
per year. Exceeding 100 hours per year while using propane requires a performance test while
using propane.
Recordkeeping9
Records of all required notifications under NSPS JJJJ, all maintenance conducted on the engine, and
documentation from the manufacturer the engine is certified.
National Emission Standards for Hazardous Air Pollutants
NESHAP Subpart A – General Provisions
NESHAP Subpart A, General Provisions, contains national emissions standards for HAP defined in Section
112(b) of the Clean Air Act. All affected sources, which are subject to another NESHAP, are subject to the
general provisions of NESHAP Subpart A, unless specifically excluded by the source specific NEHSAP.
Subpart A requires initial notification, performance testing, recordkeeping, monitoring, provides
reference methods, and mandates general control device requirements for all other subparts. The following
sections detailing each subpart requirements also includes requirements that are referenced to Subpart A.
NESHAP Subpart O – Ethylene Oxide Emissions Standards for Sterilization Facilities
NESHAP Subpart O, National Emission Standards for Hazardous Air Pollutants: Ethylene Oxide Emissions
Standards for Sterilization Facilities, establishes requirements for EtO sterilization facilities using more than
one (1) ton of EtO annually. Subpart O contains emissions control standards, performance provisions,
monitoring, reporting, and recordkeeping requirements listed below.
Emission Control Standards 10
► Reduce emissions from the sterilization chamber vents by at least 99%.
► Reduce ethylene oxide emissions to the atmosphere from each aeration room vent to a maximum
concentration of 1 ppmv or by at least 99%, whichever is less stringent.

8 40 CFR 60.4243.
9 40 CFR 60.4245.
10 40 CFR 63.362
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Performance Provisions
Performance provisions found in 40 CFR 63.363 specify performance testing to verify compliance with
aeration and sterilization chamber vent emission controls. The proposed modification adds an emission
control for fugitive EtO emissions and no changes are proposed to the existing scrubbers controlling the
sterilization and aeration vents. Therefore, performance provisions of this subpart are not applicable.
Monitoring Requirements 11
The following monitoring requirements apply to EtO sterilization facilities using an acid water scrubber to
comply with emission control standards.
►Sample the scrubber liquor and analyze and record once per week the ethylene glycol concentration
of the scrubber liquor using the test methods and procedures in § 63.365(e)(1). Monitoring is
required during a week only if the scrubber unit has been operated; or
►Measure and record once per week the level of the scrubber liquor in the recirculation tank. The
owner or operator shall install, maintain, and use a liquid level indicator to measure the scrubber
liquor tank level (i.e., a marker on the tank wall, a dipstick, a magnetic indicator, etc.). Monitoring is
required during a week only if the scrubber unit has been operated.
►Measure and record once per hour the ethylene oxide concentration at the outlet to the atmosphere
after any control device according to the procedures specified in § 63.365(c)(1). Sterigenics must
compute and record a 24-hour average daily.
Reporting Requirements
Sterigenics must comply with the reporting requirements found in 40 CFR 63.10 according to the
applicability of found in Table 1 of 40 CFR 63.360. Specific notification requirements are summarized in 40
CFR 63.366.
Recordkeeping Requirements 12
All records shall be maintained such that they can be readily accessed and are suitable for inspection, in
hard copy or computer-readable form. Records must be maintained for at least five years. The most recent
2 years of records shall be maintained onsite or accessible for the inspector while onsite. Records for the
preceding 3 years may be kept offsite, if required.
NESHAP Subpart ZZZZ – Stationary Reciprocating Internal Combustion Engines (RICE)
Sterigenics is classified as a minor source of HAP and this project proposes one (1) Emergency SI RICE that
is requested to be added to Sterigenics’ AO. This RICE was constructed after June 12, 2006 and is
applicable to NSPS JJJJ Standards of Performance for Stationary Spark Ignition Internal Combustion
Engines. The applicable requirements for the proposed unit are satisfied by the NSPS JJJJ section above.
11 40 CFR 63.364
12 40 CFR 63.367
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FORMS
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 
1.Detailed description of the project and source process
2.Discussion of fuels, raw materials, and products consumed/produced
3.Description of equipment used in the process and operating schedule
4.Description of changes to the process, production rates, etc.
5.Site plan of source with building dimensions, stack parameters, etc.
6.Best Available Control Technology (BACT) Analysis [R307-401-8]
A.BACT analysis for all new and modified equipment
7.Emissions Related Information: [R307-401-2(b)]
A.Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs)
B.References/assumptions, SDS, for each calculation and pollutant
C.All speciated HAP emissions (list in lbs/hr)
8.Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
A.Composition and physical characteristics of effluent
(emission rates, temperature, volume, pollutant types and concentrations)
9.Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
A.NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
B.Alternative site analysis, Major source ownership compliance certification
10.Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
B.Visibility impact analysis, Class I area impact
11.Signature on Application
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.
1 of 1
Form 2 Date ____________
Company Information/Notice of Intent (NOI)
Utah Division of Air Quality
New Source Review Section
Application for: □ Initial Approval Order □Approval Order Modification
General Owner and Source Information
1.Company name and mailing address:
____________________________
____________________________
____________________________
Phone No.: ( )
Fax No.: ( )
2.Company** contact for environmental matters:
____________________________
Phone no.: ( )
Email: _______________________
** Company contact only; consultant or independent contractor contact
information can be provided in a cover letter
3.Source name and physical address (if different from
above):____________________________
____________________________
____________________________
Phone no.: ( )
Fax no.:( )
4.Source Property Universal Transverse Mercator
coordinates (UTM), including System and Datum:
UTM:_________________________
X:____________________________
Y:____________________________
5.The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC)
__ __ __ __
7.If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____
8.Brief (50 words or less) description of process.
Electronic NOI
9.A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black ([e-mail]) or Alan
Humpherys ([e-mail]) can expedite review process. Please mark application type.
Hard Copy Submittal Electronic Copy Submittal □ Both
Authorization/Signature
I hereby certify that the information and data submitted in and with this application is completely true, accurate and
complete, based on reasonable inquiry made by me and to the best of my knowledge and belief.
Signature:Title:
_______________________________________
Name (Type or print)
Telephone Number:
( )
Email:
Date:
Page 1 of 1
Form 4 Company____________________________
Project Information Site ______________________________
Utah Division of Air Quality
New Source Review Section
Process Data - For Modification/Amendment ONLY
1.Permit Number_______________________________
If submitting a new permit, then use Form 3
Requested Changes
2.Name of process to be modified/added:
_______________________________
End product of this process:
_______________________________
3.Permit Change Type: New Increase*
Equipment
Process
Condition Change ____________________
Other ______________________________
Other ______________________________
Other ______________________________
4.Does new emission unit affect existing
permitted process limits?
Yes No
5.Condition(s) Changing:
6.Description of Permit/Process Change**
7.New or modified materials and quantities used in process. **
Material Quantity Annually
8.New or modified process emitting units **
Emitting Unit(s) Capacity(s) Manufacture Date(s)
*If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an
emissions increase and a public comment period.
**If additional space is required, please generate a document to accommodate and attach to form.
Page 1 of 1
Company___________________________
Site _____________________________
Form 5
Emissions Information
Criteria/GHGs/ HAP’s
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
See Emission Calculations in
Appendix B
Utah Division of Air Quality
New Source Review Section Company ________________________
Site/Source
Form 9 Date _____________________________
Scrubbers & Wet Collectors
Equipment Information
1. Provide diagram of internal components (attachment)2. Manufacturer:__________________________
Model no._____________________________
3. Date installed:4. Emission Equipment served:
5. Type of pollutant(s) controlled:
Particulate (type)___________________________
SOx _____________________________________
Odor_____________________________________
Other ____________________________________
6. Type of Scrubber:
□Spray Chamber □ Venturi
□Cyclone □Packed Tower Type
□Orifice □Mechanical
7. Gas Stream Characteristics
Flow rate (acfm) Gas Stream
Temperature (oF)
Particulate Grain Loading
(grains/scf)
Design
Maximum
Average
Expected
Inlet Outlet Inlet Outlet
8. Particulate size: ____________________________ microns (mean geometric diameter)
Scrubbing Liquid Characteristics
10. Liquid Injection Rate (gpm)
Design Maximum Average Expected
9. Scrubbing Liquid
PH _________ Range ______ - _______
Composition Wt. %
1. ____________________ __________________
2. ____________________ __________________
3. ____________________ __________________
4. ____________________ __________________
5. ____________________ __________________
6. ____________________ __________________
11. Pressure at Spray
Nozzle: __________
(psia)
12. Pressure Drop thru
Scrubber
_____________
(inches of water)
Data for Venturi Scrubber Data for Packed Towers
13. Throat Dimensions
(Specify Units)
14. Throat Velocity
(ft/sec)
15. Type of Packing 16. Superficial Gas
Velocity through Bed
Page 1 of 3
Page 2 of 3
Form 9 Scrubbers & Wet Collectors - Continued
Data Stack/Exhaust Exit
17. Height: ______feet 18. Temperature of
exhaust stream:
_______ oF
19. Inside dimensions:
______feet diameter or
______feet x _______feet
20. Monitoring Equipment
Type Manufacturer Model Range Units
Gas Pressure ___________________ ________________ ______________ inches of water column
Water Flow ___________________ ________________ ______________ gallons per minute
Water Pressure ___________________ ________________ ______________ pounds per square inch
Settling Ponds
22. Flow rate through settling pond:21. Dimensions of settling pond:
Width:
Length:
Depth:23. Residence time of water in pond:
Emissions Calculations (PTE)
24. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Utah Division of Air Quality
New Source Review Section Company: ___________________
Site/Source: _________________
Form 17a Date: _______________________
Natural Gas Standby Generator
Company Information
1. Company Name and Address:
____________________________________________
____________________________________________
____________________________________________
____________________________________________
Phone Number: _______________________________
Fax Number: _______________________________
2.Company Contact:
____________________________________________
____________________________________________
____________________________________________
____________________________________________
Phone Number: _______________________________
Fax Number: _______________________________
3. Installation Address:
____________________________________________ County where facility is located: __________________
____________________________________________
____________________________________________ Latitude & Longitude or UTM Coordinates of Facility
____________________________________________ __________________________________________
Phone Number: _______________________________ __________________________________________
Fax Number: _______________________________
Standby Generator Information
4. Engines:
Maximum Maximum Emission Rate Date the Engine
Manufacturer Model Rated Hours of Rate of NOx Was Constructed
Horsepower or Kilowatts Operation grams/BHP-HR or Reconstructed
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
_______________________________________________________________________________________________
Attach Manufacturer supplied information
5. Calculated emissions for this equipment:
PM10____________ Lbs/hr _____________Tons/yr PM2.5____________ Lbs/hr _____________Tons/yr
NOx_____________Lbs/hr______________Tons/yr SOx ____________ Lbs/hr _____________Tons/yr
CO _____________Lbs/hr _____________Tons/yr VOC ____________ Lbs/hr _____________Tons/yr
CO2 ____________Tons/yr CH4 ____________ Tons/yr
N2O ____________Tons/yr
HAPs___________ Lbs/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.
Sterigenics Corporation / NOI Air Permit Application
Trinity Consultants 29
EMISSION CALCULATIONS
Table 6- Potential Emissions Summary (tpy)
Pollutant
EtO
Sterilization1
Natural Gas
Generator
Permitted Potential
Emissions2
Proposed Potential
Emissions
VOC 2.12 2.54E-02 2.16 2.21
NOx N/A 3.84E-02 3.16 3.20
CO N/A 3.60E-02 1.20 1.24
SO2 N/A 5.74E-05 0.02 0.02
PM10 N/A 1.9E-03 0.39 0.39
PM2.5 N/A 1.9E-03 0.39 0.39
HAPs 2.12 3.17E-03 2.16 2.18
CO2e N/A 11.44 3,927 3,938
1.Fugitive emissions from EtO sterilization each reduced by this modification. Point Source
emissions nominally increase.
2.Permitted emissions from AO DAQE-AN104350030-21 issued March 25, 2021.
Table 7 - Natural Gas Generator - Criteria Pollutant Potential Emissions
Pollutant
Emission
Factors1 (g/hp-
hr)
Emission
Factors2
(lb/MMBtu)
Potential to
Emit (lb/hr)
Potential to
Emit
(tpy)
VOC 0.96 NA 5.08E-01 2.54E-02
NOx 1.45 NA 7.67E-01 3.84E-02
CO 1.36 NA 7.20E-01 3.60E-02
SO2 NA 5.88E-04 1.15E-03 5.74E-05
PM10 NA 1.94E-02 3.79E-02 1.90E-03
PM2.5 NA 1.94E-02 3.79E-02 1.90E-03
PM2.5
Condensable NA 9.91E-03 1.94E-02 9.68E-04
1. Emission factors are taken from the manufacturers spec sheet.
2. Emission factors are taken conservatively from the AP-42 Section 3.2 (Natural Gas-fired
Reciprocating Engines) Table 3.2-3.
Sterigenics Corporation / NOI Air Permit Application
Trinity Consultants 30
Table 8 - Natural Gas Generator - HAP Potential Emissions
Pollutant Emission Factors 1 Potential to Emit
(lb/MMBtu) (lb/hr) (tpy)
1,1,2,2-Tetrachloroethane 2.53E-05 4.94E-05 2.47E-06
1,1,2-Trichloroethane 1.53E-05 2.99E-05 1.49E-06
1,3-Butadiene 6.63E-04 1.30E-03 6.48E-05
1,3-Dichloropropene 1.27E-05 2.48E-05 1.24E-06
Acetaldehyde 2.79E-03 5.45E-03 2.72E-04
Acrolein 2.63E-03 5.14E-03 2.57E-04
Benzene 1.58E-03 3.09E-03 1.54E-04
Carbon Tetrachloride 1.77E-05 3.46E-05 1.73E-06
Chlorobenzene 1.29E-05 2.52E-05 1.26E-06
Chloroform 1.37E-05 2.68E-05 1.34E-06
Ethylbenzene 2.48E-05 4.84E-05 2.42E-06
Ethylene Dibromide 2.13E-05 4.16E-05 2.08E-06
Formaldehyde 2.05E-02 4.00E-02 2.00E-03
Methanol 3.06E-03 5.98E-03 2.99E-04
Methylene Chloride 4.12E-05 8.05E-05 4.02E-06
Naphthalene 9.71E-05 1.90E-04 9.48E-06
Polycyclic Aromatic Hydrocarbons
(PAH) 1.41E-04 2.75E-04 1.38E-05
Styrene 1.19E-05 2.32E-05 1.16E-06
Toluene 5.58E-04 1.09E-03 5.45E-05
Vinyl Chloride 7.18E-06 1.40E-05 7.01E-07
Xylene 1.95E-04 3.81E-04 1.90E-05
Max 4.00E-02 2.00E-03
Total 6.33E-02 3.17E-03
1. HAP pollutant emission factors per AP-42, Section 3.2 (Natural Gas-fired Reciprocating
Engines), Table 3.2-3.
Table 9 - Natural Gas Generator - GHG Potential Emissions
Pollutant
Emission Factor
(kg/MMBtu)1
Potential to Emit
(lb/hr)
Potential to Emit
(tpy)
CO2 53.06 228.49 11.42
CH4 0.001 4.31E-03 2.15E-04
N2O 0.0001 4.31E-04 2.15E-05
CO2e 53.1148 228.73 11.44
1. GHG emission factors from 40 CFR 98, Tables C-1 and C-2.
2. CO2e is the sum of GHG constituents multiplied by their respective global warming potential
(i.e., 1 for CO2, 25 for CH4, and 298 for N2O), per Table A-1, 40 CFR 98, Subpart A.
Sterigenics Corporation / NOI Air Permit Application
Trinity Consultants 31
Table 10 - Potential EtO Emissions
Source
EtO Control
Device
Control
Efficiency
(%)1
Existing
EtO
Emissions
(lbs/yr)2
Δ Potential
EtO
Emissions
(lbs/yr)
Potential
EtO
Emissions
(lbs/yr)
Potential
EtO
Emissions
(tons/yr)
Sterilizer
Chamber(s)
Vacuum
Pumps
Ceilcote wet
acid scrubber,
AAT wet acid
scrubber, and
AAT dry bed
scrubber
99.0% 3,996 -2.10 3,994 2.00
Sterilizer
Chamber(s)
Back Vents
AAT wet acid
scrubber and
AAT dry bed
scrubber
99.0% 42.06 0 42.06 0.02
Aeration
Chamber(s)
AAT wet acid
scrubber and
AAT dry bed
scrubber
99.0% 168.24 0 168.24 0.08
Permanent Total
Enclosure
AAT dry bed
scrubber 80.0% 210.3 -168.24 42.06 0.021
Total 4,416 -170.34 4,246 2.12
1.Control efficiency based on the minimum requirements found in 40 CFR 63 Subpart OOO and
manufacturer guarantee for the new AAT dry bed scrubber.
2.Existing emissions based on emission estimates provided to UDAQ in the October 2020 NOI and related
supplemental information.
3.Captured fugitives from this modification increase stack emissions by 42.06 lbs/yr.
Annual EtO usage = 420,600 lbs
EtO Emission Factors
Emission Process Group % of EtO Usage Source
Chamber Vacuum Pump Evacuation 94.95% Mass Balance
Aeration Room Vent 4.00% EPA 2017 AirToxScreen Assessment
Chamber Exhaust Vent 1.00% EPA 2017 AirToxScreen Assessment
Total Fugitives 0.05% Sterigenics Section 114 Survey Response to
EPA
3
Sterigenics Corporation / NOI Air Permit Application
Trinity Consultants 32
DESIGN DRAWINGS AND SPECIFICATIONS
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AAT Dry Bed
Scrubber
Exhaust Emission Data Sheet
C150N6
60 Hz Spark Ignited Generator Set
EPA Emissions
Cummins Inc. Data and specification subject to change without notice EDS-3055b
(08/19)
Engine Information:
Model: Cummins QSJ8.9G-G2 Bore: 4.49 in. (114.1 mm)
Type: 4 cycle, in-line, 6 cylinder Stroke: 5.69 in. (144.5 mm)
Aspiration: Turbocharged and Aftercooled Displacement: 543 cu. in. (8.9 liters)
Compression Ratio: 8.5:1
Emission Control Device: Electronic Air/Fuel Ratio & Closed-
Loop Breather System
Natural Gas
1/4 1/2 3/4 Full
Performance Data Standby Standby Standby Standby
BHP @ 1800 RPM (60 Hz) 72.4 125.7 180.2 240.0
Fuel Consumption (SCFH) 718.7 1111.3 1487.2 1915.0
Exhaust Gas Flow (CFM) 535.0 894.0 1160.0 1431.0
Exhaust Gas Temperature (°F) 1191.0 1203.0 1196.0 1186.0
Air to Fuel Ratio 22.2 24.3 24.3 24.3
Exhaust Emission Data
HC (Total Unburned Hydrocarbons)* 0.99 1.31 1.01 0.96
NOx (Oxides of Nitrogen as NO2) 1.55 0.61 0.98 1.45
CO (Carbon Monoxide) 1.81 1.41 1.36 1.36
All values above are cited: g/BHP-hr
HC (Total Unburned Hydrocarbons)* 411 563 469 457
NOx (Oxides of Nitrogen as NO2) 222 90 155 236
CO (Carbon Monoxide) 425 340 352 363
All values above are cited: ppmv
*HC includes NMHC, VOC, POC, and ROC constituents (Non-Methane HC, Volatile Organic Compounds, Precursor Organic
Compounds and Reactive Organic Compounds.
Exhaust Emission Data Sheet
C150N6
60 Hz Spark Ignited Generator Set
EPA Emissions
Cummins Inc. Data and specification subject to change without notice EDS-3055b
(08/19)
Propane (LP)
1/4 1/2 3/4 Full
Performance Data Standby Standby Standby Standby
BHP @ 1800 RPM (60 Hz) 72.4 125.7 180.2 240.0
Fuel Consumption (SCFH) 288.4 438.5 596.3 783.0
Exhaust Gas Flow (CFM) 538.0 877.0 1176.0 1494.0
Exhaust Gas Temperature (°F) 1219.0 1298.0 1279.0 1236.0
Air to Fuel Ratio 21.1 22.1 22.7 23.3
Exhaust Emission Data
HC (Total Unburned Hydrocarbons)* 0.36 0.35 0.33 0.45
NOx (Oxides of Nitrogen as NO2) 1.49 1.28 1.38 1.23
CO (Carbon Monoxide) 3.21 2.46 2.10 2.14
All values above are cited: g/BHP-hr
HC (Total Unburned Hydrocarbons)* 153 163 159 215
NOx (Oxides of Nitrogen as NO2) 212 202 223 194
CO (Carbon Monoxide) 749 636 556 557
All values above are cited: ppmv
*HC includes NMHC, VOC, POC, and ROC constituents (Non-Methane HC, Volatile Organic Compounds, Precursor Organic
Compounds and Reactive Organic Compounds.
Test Conditions
Test Conditions apply to both Natural Gas and Propane
Data is representative of steady-state engine speed (± 25 RPM) with full load (±2%). Pressures, temperatures, and emission
rates were stabilized.
Fuel Specification: Natural Gas: Dry gas received from Supplier (1000 BTU/SCF)
Propane: Meets the requirements for Commercial Grade Propane under the
ASTM D1835 Standard Specification for Liquified Gases.
Fuel Inlet Temperature: 60 ± 9 °F at flow transmitter
Fuel Pressure: 14.73PSIA ± 0.5 PSIA at Flow Transmitter
Air Inlet Temperature: 77 ± 9 °F
Barometric Pressure: 22.92 ± 1 in. Hg
Humidity: NOx measurement corrected to 75 grains H2O/lb (10.7 g/kg) of dry air
The NOx, HC, CO and PM emission data tabulated here are representative of test data taken from a single engine under the test conditions
shown above. These data are subjected to instrumentation and engine-to-engine variability. Field emission test data are not guaranteed to
these levels. Actual field test results may vary due to test site conditions, installation, fuel specification, test procedures and instrumentation.
Engine operation with excessive air intake or exhaust restriction beyond published maximum limits, or with improper maintenance, may
results in elevated emission levels.
SOUTH VIEW LOOKING NORTH
SECTION A-A
SCALE 3/4" = 1'-0"
SECTION D-D
SCALE 3/4" = 1'-0"
VIEW H-H
INLET NO. 2
SCALE 1/2" = 1'-0"
SECTION B-B
SCALE 3/4" = 1'-0"
SECTION E-E
SCALE 3" = 1'-0"
SECTION F-F
SCALE 3" = 1'-0"
SECTION C-C
SCALE 3/4" = 1'-0"
VIEW G-G
INLET NO. 1
SCALE 1/2" = 1'-0"
AA
DD
HH
B B
E
E
F
F
CC
GG
11
22
33
44
55
66
77
88
A
A
B
B
C
C
D
D
SHEET 1 OF 5
DWG NO22KA19868-101
TITLE
CUSTOMER PO NO
REV
DATE
FILE NAME
19868-101-
PO00008691
SALT LAKE CITY, UT
STERIGENICS
INNOVATIVE SHEET METAL
FREE STANDING STACK
BASE REACTIONS & DETAILS
GENERAL ARRANGEMENT
AIR TECHNIQUES, INC.
2999 JOHNSON FERRY ROAD, MARIETTA, GA 30062
2999-B JOHNSON FERRY ROAD, MARIETTA, GA 30062
ASSOCIATED ENGINEERING RESOURCES, INC.
ENGINEERING AND DESIGN SERVICES BY
THIS DRAWING IS THE PROPERTY OF AIR TECHNIQUES, INC. AND SHALL NOT BE USED FOR
FABRICATION WIHOUT THE WRITTEN CONSENT AND FULL KNOWLEGE OF AIR TECHNIQUES, INC.
ENGINEERING SERVICES ARE PROVIDED BY ASSOCIATED ENGINEERING RESOURCES, INC.
Phone: [phone]
Fax: [phone]
WIND DESIGN DATA (ASCE 7-10 - CONVERTED)
A-36 CARBON STEEL
3/16"
1/16"
115 MPH (ASCE 7-10)
III
"C"
130ƒF
150ƒF
380 K-FT (ASCE 7-10)
12,500 LBS. (ASCE 7-10)
12,000 LBS. (MAX.)
10,000 LBS. (MIN. AFTER CORROSION)
12 KIPS (ASCE 7-10)
MATERIALS OF CONSTRUCTION:
MINIMUM SHELL PLATE THICKNESS:
CORROSION ALLOWANCE:
BASIC WIND SPEED:
RISK CATEGORY:
WIND EXPOSURE:
NORMAL OPERATING TEMPERATURE:
DESIGN TEMPERATURE:
WIND MOMENT AT STACK BASE:
WIND SHEAR AT STACK BASE:
TOTAL STACK WEIGHT:
MAX BOLT TENSION:
NOTES:
1.
SEISMIC LOADS DO NOT CONTROL DESIGN.
2.
FOUNDATION DESIGN ENGINEER SHALL USE THE APPLICABLE ASCE 7-10
REDUCTION FACTORS TO THE WIND LOADS IN THIS TABLE WHEN WIND
LOAD IS COMBINED WITH OTHER LOADS.
3.
WIND DESIGN DATA IS BASED ON CONVERTED ASCE 7-10 AS ADOPTED
BY THE ASME STS-1 2016 STEEL STACK STANDARD
APPROVED FOR FABRICATION
APPROVED AS NOTED
PROCEED WITH FABRICATION
NOT APPROVED REVISE
AND RE-SUBMIT
NOT APPROVED
SIGNATURE
T.O.G.
45'-0"
60'-0"
LOW POINT OF
FALSE BOTTOM
& 3"‘ DRAIN
29'-10 7/8"
LADDER WITH
FALL-ARREST
SYSTEM
GROUNDING
LUG
4'-9" O.D.
8'-8 3/4"
(INSIDE)
4
'-
9
"

O
.
D
.
4'-9" O.D.
TEST
PLATFORM
13'-0"
NOTES:
1.
FABRICATOR IS TO REPORT ANY DISCREPANCIES FOUND ON ANY
DRAWING AND REPORT TO ATI AS INSTRUCTED ON DRAWING -105
UNDER THE "CORRECTION TO WORK AND BACK CHARGE
AUTHORIZATION" NOTES SECTION.
2.
SECTION MARKS "I" AND "O" ARE OMITTED FROM THIS DRAWING SET.
3.
FOR GENERAL NOTES REFER TO DRAWING -105.
2"
3"
1"1'-0"1"
1 1/4"‘
HOLE
1 5/16"‘
HOLE
2"
3"
6 1/2"
1 1/2"
NON-SHRINK
GROUT
(BY OTHERS)
1'-2"
5"
1'-8 3/4"
ANCHOR BOLT PROJECTION
3/8"
CHAMFER
1 1/2"
1 1/2"
3/8"x3"x3"
PLATE W/
1"‘ HOLE
3/16
3/16
OUTSIDE OF
STACK SHELL
TOP
PLATE
OUTSIDE OF
STACK SHELL
3/16
3/161/4
1/4
3/16
3/16
3/16
3/16 1/4
1/4
1 1/2"
REVISION HISTORY
REV
DATE
DESCRIPTION
CAD
CHECKED BY
A
08/12/2022
ISSUED FOR APPROVAL
AAP
NZ
3"
FLG.
3"
FLG.
3'-2"
(INSIDE)
3"
FLG.
3"
FLG.
1 1/4"
TYP.
8'-6"
(17) SP @ 6"
1/4"
PLATE
08/12/22
U/S OF
BASE PLATE
U/S OF
BASE PLATE
SLOPE
ANCHOR BOLT TEMPLATE
SHALL BE IN ACCORDANCE
W/ DWG.: TEMPLATE-T101
S
ACCESS
DOOR
2'-10 1/2"
GROUNDING
LUG
2'-8 1/2"
3'-6"
N
CUSTOMER TO
VERIFY NORTH
DIRECTION
A
A
DOUBLE NUT
W/ WASHER
(BY OTHERS)
1"‘
F1554 GRADE 105
ANCHOR ROD
(24 @ 15ƒ)
(BY OTHERS)
S ACCESS
DOOR
5
'
-
1
"

B
.
C
.
3 1/8"3 1/8"
S
INLET
NO. 2
2'-10 1/2"
2'-8 1/2"
(DRAIN)
FALSE
BOTTOM
5 3/4"
2'-6"
(5) SP. @ 6"
5 3/4"
2'-2"
(INSIDE)
3"
FLG.
3"
FLG.
4'-5 3/4"
(INSIDE)
3"
FLG.
3"
FLG.
4 5/8"4'-0"
(8) SP. @ 6"
4 5/8"
1 1/4"
(TYP.)
5 3/4"
1'-6"
(3)
SP.
@ 6"
5 3/4"
1/4"
PLATE
5/8"
(30)
‘ HOLES
FOR 1/2"‘ BOLTS
4'-9"
O.D.
18'-3 3/8"
S
INLET
NO. 1
S INLET
NO. 1
S INLET
NO. 2
5/8"
(52)
‘ HOLES
FOR 1/2"‘ BOLTS
45ƒ
45ƒ
DAVIT
(250 LB.
CAPACITY)
(24) 3/8" STIFF. PLATES
EQ. SPACED BETWEEN
ANCHOR RODS
EXPANSION JOINTS AT
INLETS ARE BY OTHERS
7" THREAD
(24) 3/8" STIFFENER
PLATES EQ. SPACED
BETWEEN ANCHOR RODS
1
5
ƒ
SOUTH VIEW LOOKING NORTH SECTION B-B
SCALE 3/4" = 1'-0"
SECTION A-A
SCALE 3/4" = 1'-0"
VIEW D-D
SCALE 1" = 1'-0"
SECTION E-E
SCALE 3/4" = 1'-0"
SECTION F-F
SCALE 1" = 1'-0"
VIEW K-K
SCALE 1" = 1'-0"
SECTION G-G
SCALE 3" = 1'-0"
SECTION C-C
SCALE 3/4" = 1'-0"
SECTION H-H
SCALE 3" = 1'-0"
VIEW J-J
SCALE 3" = 1'-0"
B B
A A
D
D
E
E
F
F
K
K
G G
C C
H
H
J
J
1
1
2
2
3
3
4
4
5
5
6
6
7
7
8
8
A A
B B
C C
D D
SHEET 2 OF 5
DWG NO
22KA19868-102
TITLE
CUSTOMER PO NO REV
DATE FILE NAME
19868-102-
PO00008691
SALT LAKE CITY, UT
STERIGENICS
INNOVATIVE SHEET METAL FREE STANDING STACK
PLATFORM & TEST PORTS
GENERAL ARRANGEMENT
Phone: [phone]
Fax: [phone]
2999 JOHNSON FERRY ROAD, MARIETTA, GA 30062
2999-B JOHNSON FERRY ROAD, MARIETTA, GA 30062
ENGINEERING AND DESIGN SERVICES BY
THIS DRAWING IS THE PROPERTY OF AIR TECHNIQUES, INC. AND SHALL NOT BE USED FOR
FABRICATION WIHOUT THE WRITTEN CONSENT AND FULL KNOWLEGE OF AIR TECHNIQUES, INC.
ENGINEERING SERVICES ARE PROVIDED BY ASSOCIATED ENGINEERING RESOURCES, INC.
ASSOCIATED ENGINEERING RESOURCES, INC.
AIR TECHNIQUES, INC.
SIGNATURE
APPROVED FOR FABRICATION

APPROVED AS NOTED
PROCEED WITH FABRICATION

NOT APPROVED REVISE
AND RE-SUBMIT

NOT APPROVED
T.O.G.
FREQUENT INSPECTION OF THE
STACK INTERIOR, BELOW THE
FALSE BOTTOM, IS REQUIRED
35'-4 3/4"
14'-7 1/4"
(3.07 DIA. DOWNSTREAM)
10'-0"
(2.10 DIA. UPSTREAM)
45'-0"
5'-0"
60'-0"
CL OF P1 & P2
TEST PORTS
TOP OF
DISTURBANCE
U/S OF
BASE PLATE
TOP OF
STACK
NOTES:

1.FABRICATOR IS TO REPORT ANY DISCREPANCIES FOUND ON ANY
DRAWING AND REPORT TO ATI AS INSTRUCTED ON DRAWING -105
UNDER THE "CORRECTION TO WORK AND BACK CHARGE
AUTHORIZATION" NOTES SECTION.
2.SECTION MARKS "I" AND "O" ARE OMITTED FROM THIS DRAWING SET.
3.FOR GENERAL NOTES REFER TO DRAWING -105.
ITEM QTY.SIZE DESCRIPTION MATERIAL BOLT
PATTERN GASKET
P-1 2 2" SCH. 40 PIPE W/ PL FLANGE A-36 CS ANSI 150#GARLOCK
P-2 1 1 1/2" SCH. 40 PIPE W/ PL FLANGE A-36 CS ANSI 150#GARLOCK
1'-9 1/2"(4) SP =
(TYP.)
1 1/4"
(TYP.)
COVER
PLATE
9"
TYP.
9"
TYP.
1'-6"
(INSIDE)
(16) 5/8"‘ HOLES
FOR 1/2"‘ A-325
GALV. BOLTS
(2) HANDLES
FIBERGLASS
ROPE GASKET
3"
TYP.
REVISION HISTORY
REV DATE DESCRIPTION CAD CHECKED BY
A 08/12/2022 ISSUED FOR APPROVAL AAP
GRATING
HANDRAIL
POST
4'-9" O.D.
3'-0"
FABENCO G72-21
SELF-CLOSING
SAFETY GATE
(NOT SHOWN)
08/12/22
LADDER WITH TUF-TUG
FIXED LADDER SAFE CLIMB
FALL-ARREST CABLE
SYSTEM
3'-6"
S ACCESS
DOOR
3'-0"
4
'-
9
"
O
.
D
.
P-1
P-1
OUTSIDE OF
STACK SHELL
3/16
OUTSIDE OF
STACK SHELL
6"
50'-0"
1 1/2"‘ SCH. 40
HANDRAIL (TYP.)
2'-0"
1'-6"
3'-6"
6"
1'-2"
GRIND FLUSH
WITH INTERIOR
OF STACK
TEST PORT HOLES SHALL STRADDLE
NOZZLE CENTERLINE
1/4" PL
DOOR
COVER
1/4"x3"
PLATE
1/4"
PLATE
INSIDE OF
STACK SHELL
A
A
30ƒ
6
0
ƒ
1'-6"
1"
1"
P-2
KNEE BRACE
MONORAIL SUPPORT
POST 1 1/4"x6" SQ.
TUBE OR BAR
MONORAIL SUPPORT LUG
3/8"x2"x6" W/ 1"‘ HOLE
4'-9" O.D.
CONDUIT MOUNTING CLIPS
SPACED APPROX. 5'-0"
APART UP TO PLATFORM.
CLIPS START @ 5'-0"
ABOVE BASE PL.
CONDUIT CLIP
4'-9"
O
.
D
.
3/16
3/16 L4x3x1/4x6"
LONG
OUTSIDE OF
STACK SHELL
6"
1 1/2"
1/2"‘ HOLE
3/4"
1 1/2"
L5x3x1/4x6"
LONG
7/16"x5/8"
HORIZ. SLOTS
3/4"
1 1/2"2 0 ƒ
THERN FIRST MATE 250 LB. CAPACITY
DAVIT CRANE (5PF5G-P1) WITH HAND
WINCH (4WM2EGRA-K), PEDESTAL BASE (5B95G)
AND CABLE TO GRADE (WA25-60NS)
ISM IS TO REVIEW AND
VERIFY THAT 2"‘ PORTS
ARE NEEDED. 4"‘ OR 3"‘
ARE MORE COMMON FOR
EMISSIONS TESTING.
DAVIT
(250 LB. CAPACITY)
SERRATED GRATING
1 1/2"‘ SCH. 80
POSTS (TYP.)
1
1
2
2
3
3
4
4
5
5
6
6
7
7
8
8
A A
B B
C C
D D
SHEET 3 OF 5
DWG NO
22KA19868-103
TITLE
CUSTOMER PO NO REV
DATE FILE NAME
19868-103-
PO00008691
SALT LAKE CITY, UT
STERIGENICS
INNOVATIVE SHEET METAL FREE STANDING STACK
LIFT PLAN
ERECTION GUIDELINES
2999 JOHNSON FERRY ROAD, MARIETTA, GA 30062
2999-B JOHNSON FERRY ROAD, MARIETTA, GA 30062
Phone: [phone]
Fax: [phone]
ASSOCIATED ENGINEERING RESOURCES, INC.
THIS DRAWING IS THE PROPERTY OF AIR TECHNIQUES, INC. AND SHALL NOT BE USED FOR
FABRICATION WIHOUT THE WRITTEN CONSENT AND FULL KNOWLEGE OF AIR TECHNIQUES, INC.
ENGINEERING SERVICES ARE PROVIDED BY ASSOCIATED ENGINEERING RESOURCES, INC.
AIR TECHNIQUES, INC.
ENGINEERING AND DESIGN SERVICES BY
STEP 1
(SECTION NO. 1 = 10,200 LBS. W/O PLATFORM & LADDER)
(FOR OPTIONAL ADDITIONAL LIFT WEIGHT REFER TO STEP 6)
LIFT LIFT
LIFT
LIFT/GUIDE
LIFT/LOWER
GUIDE
STEP 2
STEP 3
FINAL ERECTED STACK
APPROVED FOR FABRICATION

APPROVED AS NOTED
PROCEED WITH FABRICATION

NOT APPROVED REVISE
AND RE-SUBMIT

NOT APPROVED
SIGNATURE
INSTALLATION NOTES

1.UNLESS NOTED OTHERWISE ON THE DETAIL DRAWINGS, THE
FOLLOWING PROCEDURES AND GUIDELINES SHALL BE IMPLEMENTED
FOR EACH TYPE OF BOLTED CONNECTION:

2.BOLT INSTALLATION INSPECTION - INSPECTION IS REQUIRED
DURING INSTALLATION OF BOLTS TO ENSURE IMPLEMENTATION OF
THE FOLLOWING TIGHTENING INSTRUCTIONS.

3.MATCH MARKING - MARKING OF THE NUT AND PROTRUDING END OF
THE BOLT AFTER SNUG-TIGHTENING CAN BE HELPFUL IN THE
SUBSEQUENT INSTALLATION PROCESS AND IS AN AID TO INSPECTION.

4.SNUG-TIGHT METHOD - THIS METHOD SHALL BE USED FOR MINOR
OR NON-STRUCTURAL JOINTS SUCH AS DRAIN CAPS, ACCESS DOORS,
TEST PORT CAPS, INLET FLANGES, AND TEMPORARY ALIGNMENT BOLTS
FOR WELDED FIELD SPLICES. THIS CONDITION IS ATTAINED WITH A
FEW IMPACTS OF AN IMPACT WRENCH, OR A FULL EFFORT BY A
PERSON USING AN ORDINARY SPUD WRENCH TO BRING THE
CONNECTED PLIES INTO FIRM CONTACT. THIS METHOD RESULTS IN A
SMALL PRETENSION LOAD IN THE BOLT.

5.TURN-OF-NUT METHOD - UNLESS NOTED OTHERWISE, THIS METHOD
OF BOLT TIGHTENING SHALL BE USED FOR STRUCTURAL JOINTS AND
CONNECTIONS SUCH AS PLATFORM CONNECTIONS AND BOLTED STACK
SPLICES. WITH TURN-OF-NUT METHOD, GENERALLY, A PRETENSION
LOAD OF CLOSE TO 70% OF THE BOLT ALLOWABLE TENSILE STRESS IS
RESULTED. IN THIS METHOD THE BOLT IS FIRST SNUG-TIGHT. THEN
THE NUT SHALL BE ROTATED 1/2 TURN. THE PART NOT TURNED BY
THE WRENCH SHALL BE PREVENTED FROM ROTATING DURING THIS
OPERATION.

6.LADDER STAND-OFF BOLT TIGHTENING - FOR (FIXED) LADDER
CONNECTIONS THE BOLTS SHALL BE THE TURN-OF-NUT METHOD. FOR
TYPE (SLOTTED) LADDER CONNECTIONS THE BOLTS SHALL BE
FINGER-TIGHT. A WRENCH WITH MINIMAL TORQUE CAN BE USED.
THE BOLT SHALL BE ABLE TO MOVE VERTICALLY IN THE SLOT DUE TO
DIFFERENTIAL THERMAL EXPANSION AND SHRINKAGE BETWEEN THE
STACK AND LADDER. THE NUT SHALL BE WELDED TO THE BOLT.

7.ANCHOR BOLT TIGHTENING - FIRST SNUG-TIGHT ALL ANCHOR
BOLTS. THEN TURN NUT 1/3 ROTATION. THE ANCHOR BOLTS SHALL
NOT BE TIGHTENED EARLIER THAN (7) DAYS AFTER CONCRETE IS
POURED. ANCHOR BOLTS SHOULD BE RETIGHTENED (30) DAYS AFTER
STACK ERECTION. PERIODIC RETIGHTENING OF THE ANCHOR BOLTS
IS RECOMMENDED.

8.BREECHING FLANGE BOLT TIGHTENING - AS A MINIMUM THE
BOLTS SHALL BE SNUG TIGHT. DISCLAIMER

THIS DRAWING IS PRESENTED TO INFORM THE INSTALLING CONTRACTOR
OF THE RECOMMENDED INSTALLATION STEPS AND METHODS FOR
INSTALLING THE STACK. THESE STEPS AND METHODS ARE NOT INTENDED
TO NEGATE THE REQUIREMENT FOR PRACTICE OF GOOD JUDGEMENT AND
THE NEED FOR FIELD ERECTION EXPERIENCE ON THE PART OF THE
INSTALLING CONTRACTOR. DEVIATION FROM THESE INSTRUCTIONS MAY BE
NECESSARY IN ORDER TO SUIT UNFORESEEN SITE CONDITIONS AND TO
ENSURE THE SAFETY OF MEN AND EQUIPMENT.

THE RESPONSIBILITY FOR THE SELECTION OF ERECTION METHODS,
EQUIPMENT AND MATERIALS LIES SOLELY WITH THE SITE INSTALLING
SUPERINTENDENT. THIS DRAWING ALONG WITH TAGGING, MARKING AND
SUPPORTING DOCUMENTS ARE OFFERED TO AID AND ASSIST AND ARE NOT
MEANT TO BE EXACT INSTRUCTIONS TO FOLLOW FOR ASSEMBLY.
INSTALLING CONTRACTOR SHALL ADHERE TO THE SAFETY POLICIES AND
PRACTICES OF THE PLANT. THIS PROCEDURE DOES NOT SUPERSEDE LOCAL
AND PLANT SAFETY POLICIES AND PRACTICES.

ERECTED STACK SECTIONS SHALL BE PLUMB WITHIN 1" IN 100'-0".

WEIGHTS NOTED ON THIS DRAWING DO NOT INCLUDE REQUIRED
SAFETY FACTORS FOR LIFTING.

WEIGHTS ON THIS DRAWING MAY NOT MATCH THOSE LISTED IN THE WIND
DESIGN DATA BOX SHOWN ON DRAWING -101.
SHIPPING SPIDER
SHALL BE REMOVED PRIOR
TO LIFTING STACK
STEP 4
REFER TO NOTE NO. 7
"ANCHOR BOLT
TIGHTENING"

DO NOT RELEASE THE
CRANE LOAD LINE UNTIL
THE STACK IS COMPLETELY
SECURED TO THE
FOUNDATION
STEP 6
INSTALL PLATFORM AND LADDER

IF DESIRED, PLATFORM AND LADDER
INSTALLATION CAN BE PERFORMED
PRIOR TO STEP 1. ADD 1,800 LBS.
TO THE WEIGHT OF THE STACK
IF THE PLATFORM AND LADDER
ARE INSTALLED PRIOR TO STEP 1.

FOR PLATFORM INSTALLATION
REFER TO NOTE NO. 5
"TURN-OF-NUT METHOD"

FOR LADDER INSTALLATION
REFER TO NOTE NO. 6
"LADDER STAND-OFF
BOLT TIGHTENING"
REVISION HISTORY
REV DATE DESCRIPTION CAD CHECKED BY
A 08/12/2022 ISSUED FOR APPROVAL AAP
08/12/22
60'-0"
STEP 5
VERIFY THAT THE
STACK IS PLUMB
WITHIN 1" OVER
100'-0"
USE TDC HOLE IN TOP PLATE
FOR RIGGING/TAILING POINT
A
A
4'-9" O.D.
1
1
2
2
3
3
4
4
5
5
6
6
7
7
8
8
A A
B B
C C
D D
SHEET 4 OF 5
DWG NO
22KA19868-104
TITLE
CUSTOMER PO NO REV
DATE FILE NAME
19868-104-
PO00008691
SALT LAKE CITY, UT
STERIGENICS
INNOVATIVE SHEET METAL FREE STANDING STACK
VIEWS
GENERAL ARRANGEMENT
ASSOCIATED ENGINEERING RESOURCES, INC.
AIR TECHNIQUES, INC.
THIS DRAWING IS THE PROPERTY OF AIR TECHNIQUES, INC. AND SHALL NOT BE USED FOR
FABRICATION WIHOUT THE WRITTEN CONSENT AND FULL KNOWLEGE OF AIR TECHNIQUES, INC.
ENGINEERING SERVICES ARE PROVIDED BY ASSOCIATED ENGINEERING RESOURCES, INC.
ENGINEERING AND DESIGN SERVICES BY
2999-B JOHNSON FERRY ROAD, MARIETTA, GA 30062
2999 JOHNSON FERRY ROAD, MARIETTA, GA 30062
Phone: [phone]
Fax: [phone]
APPROVED FOR FABRICATION

APPROVED AS NOTED
PROCEED WITH FABRICATION

NOT APPROVED REVISE
AND RE-SUBMIT

NOT APPROVED
SIGNATURE
NOTES:

1.FABRICATOR IS TO REPORT ANY DISCREPANCIES FOUND ON ANY
DRAWING AND REPORT TO ATI AS INSTRUCTED ON DRAWING -105
UNDER THE "CORRECTION TO WORK AND BACK CHARGE
AUTHORIZATION" NOTES SECTION.
2.SECTION MARKS "I" AND "O" ARE OMITTED FROM THIS DRAWING SET.
3.FOR GENERAL NOTES REFER TO DRAWING -105.
SOUTH ELEVATION LOOKING NORTH EAST ELEVATION LOOKING WEST NORTH ELEVATION LOOKING SOUTH WEST ELEVATION LOOKING EAST
REVISION HISTORY
REV DATE DESCRIPTION CAD CHECKED BY
A 08/12/2022 ISSUED FOR APPROVAL AAP
08/12/22 A
A
CUSTOMER TO
CONFIRM
1
1
2
2
3
3
4
4
5
5
6
6
7
7
8
8
A A
B B
C C
D D
SHEET 5 OF 5
DWG NO
22KA19868-105
TITLE
CUSTOMER PO NO REV
DATE FILE NAME
19868-105-
PO00008691
SALT LAKE CITY, UT
STERIGENICS
INNOVATIVE SHEET METAL FREE STANDING STACK
FABRICATION
GENERAL NOTES
Phone: [phone]
Fax: [phone]
2999 JOHNSON FERRY ROAD, MARIETTA, GA 30062
2999-B JOHNSON FERRY ROAD, MARIETTA, GA 30062
ENGINEERING AND DESIGN SERVICES BY
THIS DRAWING IS THE PROPERTY OF AIR TECHNIQUES, INC. AND SHALL NOT BE USED FOR
FABRICATION WIHOUT THE WRITTEN CONSENT AND FULL KNOWLEGE OF AIR TECHNIQUES, INC.
ENGINEERING SERVICES ARE PROVIDED BY ASSOCIATED ENGINEERING RESOURCES, INC.
AIR TECHNIQUES, INC.
ASSOCIATED ENGINEERING RESOURCES, INC.
GENERAL

1.THE FOLLOWING SHALL ESTABLISH THE MINIMUM ACCEPTABLE REQUIREMENTS FOR
FINISHING, INSPECTION/TESTING, IDENTIFICATION & TAGGING, AND DELIVERY TO THE
JOBSITE OF THE SUBJECT FABRICATED STEEL PLATEWORK.

2.THE FABRICATOR SHALL SUPPLY ALL MATERIALS AND FABRICATION WORK AS
REQUIRED BY THE REFERENCED DESIGN DRAWINGS AND THE REQUIREMENTS
CONTAINED ON THIS SHEET.

3.ALL WORK SHALL BE PERFORMED IN STRICT ACCORDANCE WITH THE REFERENCED
DESIGN DRAWINGS AND THESE REQUIREMENTS.

4.APPLICABLE PUBLICATIONS: THE PRACTICES AND STANDARDS DESCRIBED IN THE
CURRENT ISSUES OF THE FOLLOWING PUBLICATIONS ARE TO BE STRICTLY ADHERED
TO. IN THE EVENT OF DISCREPANCIES BETWEEN THE LISTED STANDARDS AND THE
LISTED REQUIREMENTS ON THIS SHEET, THE ATTACHED LISTED REQUIREMENTS ON
THIS SHEET SHALL GOVERN.

A.AISC "SPECIFICATION FOR THE DESIGN, FABRICATION, AND ERECTION OF STRUCTURAL
STEEL FOR BUILDINGS 15TH EDITION", INCLUDING ALL SUPPLEMENTS.

B.AMERICAN SOCIETY FOR TESTING AND MATERIALS (ASTM).
A36 SPECIFICATION FOR STRUCTURAL STEEL
A53 SPECIFICATION FOR WELDED AND SEAMLESS STEEL PIPE
A240 HEAT RESISTING CHROMIUM AND CHROMIUM-NICKEL STAINLESS PLATE
A325 STANDARD SPECIFICATION FOR HIGH STRENGTH BOLTS FOR STRUCTURAL
STEEL JOINTS, INCLUDING SUITABLE NUTS AND PLAIN HARDENED WASHERS
A193 SPECIFICATION FOR ALLOY STEEL BOLTING MATERIALS FOR HIGH-TEMP SERVICE
A992 SPECIFICATION FOR STANDARD STEEL SHAPES

C.AMERICAN WELDING SOCIETY (AWS)
D1.1 STRUCTURAL WELDING CODE - STEEL
D1.6 STRUCTURAL WELDING CODE - STAINLESS STEEL
A5.1 SPECIFICATION FOR COVERED CARBON STEEL ARC-WELD ELECTRODES

D.STEEL STRUCTURES PAINTING COUNCIL (SSPC)

E.AMERICAN NATIONAL STANDARDS INSTITUTE (ANSI)
B1.1 UNIFIED SCREW THREADS SOCIETY OF AUTOMOTIVE ENGINEERS (SAE)
J429 SPECIFICATION FOR MECHANICAL AND QUALITY FOR EXTERNALLY
THREADED FASTENERS

F.ASME STS-1-2016 STEEL STACKS

G.ASCE 7-10 (LATEST ADOPTED BY STS-1 2016 STEEL STACKS STANDARD)

MATERIALS

1.STEEL PLATE, BARS, AND SHAPES:

ALL STACK SHELL PLATES SHALL CONFORM TO ASTM A-36 CARBON STEEL AND SHALL BE
FROM UNUSED MILL PRODUCTS, FREE FROM DEFECTS IMPAIRING STRENGTH, DURABILITY,
AND/OR APPEARANCE.

ALL EXTERNAL STEEL BARS, SHAPES AND ANGLES USED FOR REINFORCING, STIFFENING AND
ANCHOR BOLT CHAIRS SHALL CONFORM TO ASTM A-36 CARBON STEEL, UNLESS NOTED
OTHERWISE ON THE DRAWINGS AND SHALL BE FROM UNUSED MILL PRODUCTS, FREE FROM
DEFECTS IMPAIRING STRENGTH, DURABILITY, AND/OR APPEARANCE.

MILL CERTIFICATION ON ALL STEEL SHALL BE SUPPLIED TO AIR TECHNIQUES FOR REVIEW,
UPON REQUEST, BEFORE START OF FABRICATION. CERTIFIED MILL TEST REPORTS SHALL
INCLUDE HEAT NUMBER AND CHEMICAL/PHYSICAL PROPERTIES OF THE MATERIALS
FURNISHED.

2.WELDING MATERIALS:

ALL WELDING ELECTRODES, WIRE, AND FLUXES SHALL BE CAPABLE OF PRODUCING
SATISFACTORY WELDS WHEN USED BY A QUALIFIED WELDER OR WELDING OPERATOR,
WHEN USING QUALIFIED WELDING PROCEDURES. ALL WELDING MATERIALS SHALL COMPLY
WITH THE APPLICABLE REQUIREMENTS OF AWS D1.1. STICK WELD ELECTRODES SHALL
CONFORM TO AWS A5.1 OR A5.5, E70XX. SUBMERGED ARC ELECTRODES AND GRANULAR
FLUX SHALL CONFORM TO AWS A5.17, F7X-EXXX.

FABRICATOR SHALL SUBMIT WELDING PROCEDURES AND QUALIFICATIONS (UPON REQUEST)
FOR APPROVAL WITHIN ONE (1) WEEK OF ORDER PLACEMENT.

3.BOLTING:

ALL FLANGES, CONNECTIONS AND BOLTED ASSEMBLIES SHALL BE FURNISHED WITH THE
REQUIRED NUMBER OF BOLTS TO COMPLETE THE JOINTS INVOLVED. BOLTS, UNLESS
OTHERWISE NOTED ON DRAWINGS, SHALL CONFORM TO ASTM A325 FOR DIAMETERS EQUAL
TO OR GREATER THAN 1/2". FABRICATOR SHALL FURNISH HARD CIRCULAR WASHERS AND
HEAVY HEX NUTS WITH ALL SUPPLIED BOLTS. ALL FASTENERS TO BE HOT DIPPED
GALVANIZED UNLESS OTHERWISE NOTED.

4.SUBSTITUTIONS:

SUBSTITUTIONS OF SECTIONS MAY BE MADE TO SUIT AVAILABILITY OF MATERIAL.
REQUEST FOR SUBSTITUTIONS SHALL BE MADE IN WRITING TO ATI AND SHALL BE
APPROVED BY ATI PRIOR TO MATERIAL PROCUREMENT OR FABRICATION.

5.MATERIALS IDENTIFICATION

AS A MINIMUM ALL MATERIALS USED SHALL HAVE WAREHOUSE CERTIFICATION OF THE
GRADE SPECIFIED. UNIDENTIFIED MATERIAL SHALL NOT BE USED.

FABRICATION

1.FABRICATION SHALL BE IN STRICT ACCORDANCE WITH THE REQUIREMENTS ON THIS SHEET, THE
REFERENCED DESIGN DRAWINGS, AND ATI APPROVED SHOP DRAWINGS (IF APPLICABLE).
2.THE FABRICATOR SHALL BE RESPONSIBLE FOR ALL ERRORS OR DETAILING, FABRICATION, AND
FOR THE CORRECT FITTING OF ALL FABRICATED PARTS. FABRICATION ERRORS DISCOVERED IN
THE FIELD AFTER DELIVERY MAY BE CORRECTED IN THE FIELD BY THE ERECTOR WITH ANY SUCH
EXTRA COSTS TO BE FOR THE FABRICATORS ACCOUNT.

3.WELDS SHALL BE MADE ONLY BY WELDERS WHO HAVE PREVIOUSLY QUALIFIED BY TESTS, AS
PRESCRIBED IN AWS D1.1 TO PERFORM THE TYPE OF WORK REQUIRED AND PROOF OF SUCH
QUALIFICATION SHALL BE SUBMITTED IN DUPLICATE UPON REQUEST OF ATI.

4.UNLESS OTHERWISE SPECIFIED ON THE DRAWINGS, ASSEMBLIES SHALL BE FABRICATED TO THE
FOLLOWING NON-ACCUMULATIVE TOLERANCES:

DIMENSION TOLERANCE
0-3 FT. +0"/-1/32"
3-10 FT. +0"/-1/16"
GREATER THAN 10 FT. +0"/-1/8"

STACK SHELL PLATES SHALL BE FABRICATED IN ACCORDANCE WITH THE FOLLOWING
TOLERANCES:

A. MAXIMUM DEVIATION OF BASE RING FROM CENTERLINE OF STACK SUCH THAT ERECTION OF
THE STACK CAN BE PLUMBED TO WITHIN A MAXIMUM DEVIATION OF 1" PER 100' OF HEIGHT.
B. MAXIMUM OUT-OF-ROUNDNESS OF ANY SECTION - DIFFERENCE BETWEEN MINIMUM AND
MAXIMUM DIAMETER - LESS THAN 1% OF NORMAL DIAMETER.
C. MAXIMUM MISALIGNMENT OF PLATES AT ANY JOINT SHALL NOT EXCEED 25% OF NORMAL
THICKNESS OR 1/8", WHICHEVER IS LESS.
D. ADJOINING PLATE SECTIONS SHALL BE PAIRED FOR FULL 100% DEVELOPMENT.
E. PEAKING OF VERTICAL JOINTS SHALL NOT EXCEED 1/4" AS MEASURED FROM THE TRUE
RADIUS OF THE STACK.

OTHERWISE, FABRICATION SHALL BE IN ACCORDANCE WITH THE AISC "SPECIFICATION FOR THE
DESIGN, FABRICATION AND ERECTION OF STRUCTURAL STEEL FOR BUILDINGS", AND ACCEPTED GOOD
SHOP PRACTICE.

5.WELDING, PREHEATING OF BASE METAL, JOINTS PREPARATION AND WELDING PROCEDURES AND
WELDER QUALIFICATIONS SHALL CONFORM TO AWS D1.1. ALL SHOP WELDS SHALL BE SUITABLE
FOR THE POSITIONS AND CONDITIONS OF INTENDED USE AND IN ACCORDANCE WITH THE AWS
D1.1 CODE.

6.ALL BUTT WELDED LONGITUDINAL AND CIRCUMFERENTIAL JOINTS ON PLATEWORK SHALL BE
CONTINUOUS, GASTIGHT, AND OF THE FULL PENETRATION TYPE, AND SHALL DEVELOP THE FULL
STRENGTH OF THE SECTION BEING FORMED.

7.LONGITUDINAL JOINTS SHALL BE STAGGERED 90ƒ.

8.ALL STACK SHELL CIRCUMFERENTIAL AND VERTICAL WELDS SHALL BE DONE BY THE AUTOMATIC
OR SEMI-AUTOMATIC SUBMERGED ARC PROCESS. AS AN OPTION, THE FLUX CORE PROCESS
UTILIZING AN INERT SHIELDING GAS MAY BE UTILIZED. ALL OTHER WELDS SHALL BE COMPLETED
USING ONLY ATI APPROVED, PRE-QUALIFIED WELDING PROCEDURES AND PROCESSES.

9.WELDING STARTS AND STOPS SHALL BE MAINTAINED AT A MINIMUM AND EACH POSITION
CONDITIONED BEFORE PROCEEDING WITH ADJACENT WELDING.

10.LONG CONTINUOUS WELDS SHALL BE PERFORMED ON A SUITABLE "STAGGER SYSTEM", TO
PREVENT WARPAGE OF FABRICATED ITEM.

11.EXPOSED WELDS, WHICH WOULD BE A SAFETY HAZARD, SHALL BE GROUND SMOOTH.

12.STRUCTURAL SECTIONS SHALL BE CONTINUOUS IN LENGTH UNLESS SPLICING IS APPROVED BY
ATI. PLATE AND SHAPE SPLICES GENERALLY SHALL BE FULL PENETRATION GAS-TIGHT BUTT
WELDS AND THE FINAL SECTION SHALL MEET SPECIFIED TOLERANCE REQUIREMENTS FOR
STRAIGHTNESS, CAMBER, AND SWEEP. REQUEST FOR SPLICING SHALL BE MADE ON A PIECE BY
PIECE BASIS AND APPROVAL WILL BE MADE ON THE SAME BASIS.

13.ANY TEMPORARY LIFTING LUGS, CLIPS, BRACES, OR OTHER TEMPORARY FIXTURES REQUIRED FOR
MOVING, SHIFTING, ROTATING, AND/OR POSITIONING THE FABRICATED ITEM IN THE SHOP SHALL
BE DESIGNED, PROVIDED AND INSTALLED BY THE FABRICATOR. ANY SUCH ITEMS SHALL BE
REMOVED BY THE FABRICATOR IMMEDIATELY PRIOR TO SHIPMENT WITH ALL WELDS, GOUGES,
SCARS, SPLATTERS OR ANY OTHER DISFIGUREMENT OF THE ITEMS TO BE GROUND SMOOTH,
RESURFACES AND REPAINTED PER THE SHOP PAINTING SPECIFICATION.

14.PERMANENT LIFTING AND TAILING LUGS WILL BE INSTALLED BY THE FABRICATOR PRIOR TO
SHIPMENT. LIFTING AND TAILING LUG DESIGN AND LOCATION ARE INCLUDED IN THIS DRAWING
PACKAGE AND SHALL BE USED TO LOAD AND UNLOAD THE STACK SECTIONS FROM THE TRAILERS
AND FOR FIELD ERECTION.

15.WELDED SHELL JOINTS SHALL BE FULL PENETRATION BUTT TYPE, AWS D1.1 JOINT DESIGNATION
B-U2-GF. FILLED WELDS ARE AS SHOWN ON DRAWINGS.

16.WELD SIZE SHALL NOT EXCEED THE THICKNESS OF THE THINNEST PLATE BEING WELDED.

17.UNLESS NOTED OTHERWISE ON THIS DRAWING SET, OR WITH APPROVAL FROM THE ENGINEER,
WHEN CONTINUOUSLY WELDING BOTH SIDES OF A STEEL MEMBER, THE DISTANCE BETWEEN THE
TWO PARALLEL WELDS (THICKNESS OF THE MEMBER) SHALL BE GREATER THAN TWICE THE SIZE
OF THE TOTAL WELD. EXAMPLE: THE MINIMUM THICKNESS OF A PLATE HAVING A CONTINUOUS
3/16" FILLET WELD ON BOTH SIDES IS 3/8" (2x3/16" = 3/8").

18.ANY WELD TO THE STACK SHELL PLATE LARGER THAN THAT SHOWN ON THE DRAWINGS IS NOT
ALLOWED WITHOUT WRITTEN APPROVAL FROM AN ATI ENGINEER.

19.WELD REINFORCEMENT SHALL BLEND SMOOTHLY WITH THE SURFACE AND SHOULD NOT EXCEED
PARAMETERS AS STATED FOR AWS D1.1.

20.SEGREGATION OF FERROUS AND NON-FERROUS TOOLS, MATERIALS AND EQUIPMENT
SHALL BE STRICTLY ADHERED TO.
SURFACE PREPARATION AND PAINTING

EXTERIOR & INTERIOR SURFACES:

1.ALL ROUGH WELDS SHALL BE GROUND SMOOTH. ALL WELD FLUX AND SPATTER SHALL BE
REMOVED BY POWER TOOL CLEANING.

EXTERIOR SURFACES

1.ALL CARBON STEEL COMPONENTS INCLUDING THE SHELL AND ALL EXTERNAL COMPONENTS
WELDED TO THE STACK SHELL SHALL RECEIVE A SANDBLAST TO SSPC-SP6.

2.ALL CARBON STEEL COMPONENTS INCLUDING THE SHELL AND ALL EXTERNAL COMPONENTS
WELDED TO THE STACK SHELL SHALL RECEIVE THE FOLLOWING PAINT SYSTEM:

A.PRIMER TO BE SHERWIN WILLIAMS KEM KROMIK UNIVERSAL METAL PRIMER APPLIED PER
THE GUIDELINES LISTED ON THE MANUFACTURERS PRODUCT DATA SHEET.

B.TOP COAT TO BE SHERWIN WILLIAMS INDUSTRIAL ENAMEL APPLIED PER THE
GUIDELINES LISTED ON THE MANUFACTURERS PRODUCT DATA SHEET.

C.FINISH COLOR TO BE GRAY.

3.PROVIDE A SUFFICIENT AMOUNT OF TOUCH-UP PAINT FOR EACH COATING SYSTEM AND SHIP
TO THE FIELD WITH THE STACK.

GALVANIZING

1.TEST PLATFORM STRUCTURE, GRATING, HANDRAILS, LADDER, AND GATE SHALL BE HOT
DIPPED GALVANIZED IN ACCORDANCE WITH ASTM A-123.

2.ALL BURS TO BE REMOVED OR GROUND SMOOTH.

3.REPAIRS TO GALVANIZED STEEL SHALL BE MADE IN ACCORDANCE WITH ASTM A780.

INSPECTION AND TESTS

1.THE FABRICATOR SHALL INSTITUTE A QUALITY CONTROL AND INSPECTION PROGRAM WHICH
SHALL INSURE ALL FABRICATION WORK AND MATERIALS SUPPLIED MEET THE REQUIREMENTS
OF THE CONTRACT DOCUMENTS AND TEST REQUIREMENTS, PRIOR TO BEING SHIPPED TO THE
JOB SITE. A COPY OF THE WRITTEN QUALITY CONTROL / QUALITY ASSURANCE MANUAL
SHALL BE SUBMITTED TO ATI PRIOR TO THE COMMENCEMENT OF FABRICATION.

2.FABRICATOR TO SHOP FIT-UP ALL STACK FIELD SPLICES. FIELD SPLICE JOINTS MAY BE FIT-UP
IN LESS THAN FULL SHIPPING SECTIONS IF IT IS NOT POSSIBLE TO HANDLE FULL STACK
SECTIONS IN THE SHOP. FABRICATOR IS TO NOTIFY ATI TWO (2) WORKING DAYS PRIOR TO
EACH SPLICE FIT-UP BY DOCUMENTED MEANS. SHOULD ATI OR ATI'S CUSTOMER BE UNABLE
TO WITNESS SHOP FIT-UP'S, FABRICATOR IS TO PROVIDE ATI WITH DIGITAL PHOTOS OF THE
TRIAL FIT-UP. FABRICATOR WILL NOT BE DELAYED FROM FURTHER MANUFACTURING DUE TO
"WITNESS HOLDS" BEYOND THE 48 HOUR NOTICE PERIOD. SEE MATCH MARKINGS ON THIS
DRAWING.

3.THE PLATFORM, GRATING, HANDRAILS, LADDER AND GATE SHALL BE TRIAL FIT-UP TO THE
STACK AND REMOVED TO INSURE PROPER PROPER ATTACHMENT. DIGITAL PHOTOS OF THE
FIT-UP MUST BE TAKEN AND SUBMITTED TO ATI FOR REVIEW.

4.THE MATERIALS AND WORKMANSHIP TO BE FURNISHED SHALL BE SUBJECT TO INSPECTION IN
THE MILL, SHOP, AND FIELD BY ATI AND/OR ATI'S CLIENT.

5.THE FABRICATOR SHALL GUARANTEE FREE ACCESS TO THE SHOP FOR INSPECTION OF
FABRICATION WORK. ATI AND/OR ATI'S CUSTOMER SHALL BE ALLOWED TO OBSERVE
FABRICATION CREWS WHILE WORK IS IN PROGRESS AND LADDERS OR TEMPORARY
SCAFFOLDING SHALL BE MADE AVAILABLE UPON REQUEST FOR THE PURPOSE OF INSPECTING
ANY AREAS WHICH ARE DIFFICULT TO REACH.

6.INSPECTION AND ACCEPTANCE, OR FAILURE TO INSPECT, SHALL IN NO WAY RELIEVE THE
FABRICATOR FROM THE RESPONSIBILITY TO FURNISH MATERIALS AND WORKMANSHIP IN
ACCORDANCE WITH HE CONTRACT REQUIREMENTS. ATI RESERVES THE RIGHT TO REQUIRE
THE REPAIR OR REPLACEMENT OF ANY MATERIAL OR WORKMANSHIP THAT DOES NOT MEET
THE REQUIREMENT OF THE DRAWINGS OR OF THE REQUIREMENTS ON THIS SHEET.

7.RADIOGRAPHIC TESTING: A MINIMUM OF ONE RADIOGRAPH PER EACH (3) SHOP
CIRCUMFERENTIAL SEAMS ON THE STACK STRUCTURAL SHELL SHALL BE MADE,
PREFERABLY AT THE VERTICAL WELD INTERSECTION ("T" JOINT).

IDENTIFICATION AND TAGGING

1.ALL ASSEMBLIES, SUB-ASSEMBLIES, AND LOOSE ITEMS SHALL BE CLEARLY MARKED
(STENCILED, INSIDE AND OUTSIDE WITH PIECE MARKS AS SHOWN ON THE DRAWINGS FOR
EASY IDENTIFICATION, BY THE ON-SITE ERECTORS OR ON-SITE CONTROLLERS.

2.PRIOR TO SHIPPING, THE FABRICATOR SHALL SUBMIT A LIST OF ALL ASSEMBLIES,
SUBASSEMBLIES, AND LOOSE ITEMS BY MARK NUMBERS WITH THE APPROPRIATE ACTUAL
WEIGHTS OF EACH SO ERECTION CONTRACTOR CAN REFERENCE FOR CRANE RIGGING.

3.TAGGING OF ALL INSTRUMENTS SHALL BE PER THE REQUIREMENTS OF THE PROJECT
SPECIFICATIONS IF REQUIRED.

SHIPPING INSTRUCTIONS

1.ALL COMPONENTS SHALL BE SECURED AND OF SUFFICIENT RIGIDITY AND STRENGTH FOR THE NORMAL
HANDLING DURING SHIPPING AND FIELD ERECTION. SHOP WORK SHALL INCLUDE SUFFICIENT
PERMANENTLY AND/OR TEMPORARILY ATTACHED BRACES, STRUTS, AND LIFTING LUGS TO PERMIT
HANDLING WITHOUT DAMAGE.

2.ALL FLANGES SHALL BE PROTECTED AGAINST DAMAGE IN SHIPMENT OR HANDLING BY THE USE OF WOOD
OR OTHER SUITABLE COVERS. THREADED COUPLINGS, OR PIPE NIPPLES SHALL BE PROTECTED WITH
PLUGS OR THREADED PROTECTORS.

3.EQUIPMENT SHALL BE PROPERLY PROTECTED AND SO LOADED AS TO PREVENT DAMAGE IN TRANSIT. USE
OF CHAINS OR METAL CABLES IS PROHIBITED. CLOTH HOLD DOWN STRAPS ARE ALLOWED. LAYOUT PAPER
OR SIMILAR MATERIAL SHALL BE USED UNDER ALL HOLD DOWNS TO PREVENT PAINT DAMAGE BY STRAPS.
BOLTS, NUTS, WASHERS, CLIPS, ETC. SHALL BE PACKED IN WEATHER RESISTANT BOXES OR KEGS AND
SHALL BE PROPERLY LABELED FOR SHIPMENT AND SHIPPED WITH THE FIRST SHIPMENT TO THE JOBSITE.

4.HARDWARE FOR BOLTED FIELD SPLICES SHALL BE SEPARATELY PACKAGED AND CLEARLY
IDENTIFIED.

5.WHEN SHIPPING BOLTS, CARE SHALL BE TAKEN THAT ALL THE DIFFERENT KINDS, TYPES, AND SIZES ARE
KEPT SEPARATE, EITHER BY SEPARATE CONTAINERS OR PARTITIONS IN THE SAME CONTAINERS (ALL
CONTAINERS TO BE WEATHER RESISTANT).

6.WHERE SEPARATE PARTS ARE TOO SMALL TO MARK, THEY SHALL BE TAGGED AND PLACED IN CONTAINERS
PLAINLY MARKED ON THE OUTSIDE AS TO THEIR CONTENTS. (ALL CONTAINERS TO BE WEATHER
RESISTANT.

7.BLIND FLANGES, PLUGS, AND COVERS TO BE BOLTED TO THE STACK AND SHIPPED IN FINAL
CONFIGURATION. DOOR COVERS BELOW THE FALSE BOTTOM ARE TO BE SHIPPED IN PLACE WITH MINIMAL
HARDWARE IN PLACE FOR QUICK REMOVAL AT THE SITE.

8.EQUIPMENT SHALL BE DISASSEMBLED ONLY TO THE EXTENT NECESSARY TO PERMIT SHIPPING.

9.PACKING SLIPS AND BILLS OF LADING SHALL ACCOMPANY EACH CASE OR PARCEL SHOWING
IDENTIFICATION, INCLUDING A DESCRIPTION OF CONTENTS. PACKING SLIPS AND BOL'S TO BE SUBMITTED
TO ATI BEFORE SHIPMENT.

10.IF SHIPMENTS ARE MADE WITHOUT THE PROPER IDENTIFICATION AND CANNOT BE RECEIVED OR
UNLOADED AT THE JOBSITE, SHIPMENTS WILL BE RETURNED AND ALL FREIGHT CHARGES, ETC. WILL BE
FOR THE FABRICATORS ACCOUNT.

11.STACK SECTIONS SHALL BE LOADED TO MINIMIZE NUMBER OF SHIPPING LOADS AND WITH CONVENIENCE
OF UNLOADING IN MIND. PIECES MUST BE POSITIONED SO LIFTING LUGS AND TAILING LUGS MAY BE
USED FOR UNLOADING WITHOUT ROTATING THE PIECE.

CORRECTION TO WORK/BACK CHARGE AUTHORIZATION

1.PLEASE READ CAREFULLY AS ABSOLUTELY NO BACKCHARGES FOR CORRECTIVE WORK ON ANY EQUIPMENT
SUPPLIED BY AIR TECHNIQUES WILL BE HONORED UNLESS THE FOLLOWING PROCEDURES ARE FOLLOWED.

2.AIR TECHNIQUES RESERVES THE RIGHT TO CORRECT, REPLACE OR REPAIR ANY INCORRECTLY FABRICATED
OR DEFECTIVE WORK, MATERIAL, OR SUPPLIES. FAILURE TO FOLLOW THESE CORRECTIVE WORK
PROCEDURES MAY VOID OUR WARRANTY ON THE PRODUCT.

3.AT THE FIRST TIME OF DISCOVERY OF ANY POTENTIAL PROBLEM WITH THE WORK THAT COULD REQUIRE
REPLACEMENT OR CORRECTIVE ACTION, FIRST NOTIFY A REPRESENTATIVE OF AIR TECHNIQUES
FOLLOWING THE CALL PROCEDURE BELOW:

CONTACT OUR MAIN OFFICE M-F 8:15 AM TO 5:30 PM EST BY CALLING 770-518-7200. DO NOT LEAVE A
MESSAGE IF AFTER HOURS AND PROCEED WITH ACTION, RATHER CALL ONE OF THE FOLLOWING CELL PHONE
NUMBERS:

CELL PHONES - THESE NUMBERS OPERATE 24 HOURS PER DAY 7 DAYS PER WEEK AND ARE ASSIGNED TO AIR
TECHNIQUES MANAGERS AND ENGINEERS. (404-580-0619) & (404-245-5023). LEAVE A MESSAGE AND RETURN
PHONE NUMBER IF NO ONE ANSWERS, AS THESE NUMBERS ARE MONITORED HOURLY.

DESCRIBE THE PROBLEM TO THE REPRESENTATIVE REFERRING TO DRAWING NUMBERS AND DETAIL WHERE
POSSIBLE.

USE DIGITAL CAMERAS, CELL PHONES, EMAIL, FAX AND OTHER COMMUNICATION TECHNOLOGY AVAILABLE
TODAY. AIR TECHNIQUES WILL NOT ACCEPT AN "AFTER THE FACT" DESCRIPTION THAT THE WORK HAD TO
PROCEED. IF THIS OCCURS, IT IS DONE SO AT FULL RISK OF NO REWARD BY AIR TECHNIQUES AND WARRANTY
INVALIDATION.

ONCE A CORRECTIVE REPAIR OR REPLACEMENT PROCEDURE IS APPROVED, AN ESTIMATE OF LABOR, MATERIAL
& EQUIPMENT, WILL BE REQUIRED BEFORE THE PROCEDURE WILL BE APPROVED.

APPROVED FOR FABRICATION

APPROVED AS NOTED
PROCEED WITH FABRICATION

NOT APPROVED REVISE
AND RE-SUBMIT

NOT APPROVED
SIGNATURE
REVISION HISTORY
REV DATE DESCRIPTION CAD CHECKED BY
A 08/12/2022 ISSUED FOR APPROVAL AAP
FOR BOLT AND INSTALLATION
NOTES REFER TO DRAWING -103.
08/12/22 A
A