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HomeMy WebLinkAboutDAQ-2024-0073531 DAQC-CI116440001-24 Site ID 11644 (B1) MEMORANDUM TO: FILE – ICU MEDICAL, INC. – Salt Lake Medical Products Manufacturing THROUGH: Chad Gilgen, Minor Source Compliance Section Manager FROM: Susan Weisenberg, Environmental Scientist DATE: March 19, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Salt Lake County INSPECTION DATE: March 8, 2024 SOURCE LOCATION: 4455 South Atherton Drive Taylorsville, UT 84123 DIRECTIONS: From I-15 south bound, take 4500 S Exit 301. Take the west bound exit direction to Taylorsville (west bound Taylorsville express) to Atherton Drive.. SOURCE CONTACTS: Pedro Villarreal, Facility Manager 801-284-1206 Pedro.Villarreal@icumed.com OPERATING STATUS: Operating normally, residual removal furnace not operating. PROCESS DESCRIPTION: ICU Medical, Incorporated (ICU) manufactures critical care medical products. Solvent bonding, cleaning, injection molding, and final assembly are used in the manufacturing processes. As parts are assembled, small amounts of solvent are used to bond pieces together. The solvent is stored and dispensed in small vapor tight containers that dispense small droplets of solvent onto the items to be bonded. Small amounts of VOC-containing solvent are used to clean various manufactured plastic products and equipment. Generally, solvents are applied to rags and wiped on the products or equipment. Raw plastic products are formed by injection molding. Plastic granules are stored in bins (gaylords) until they are pneumatically piped to an injection mold machine storage device. The raw products include polyvinyl chloride, polycarbonate, polypropylene, and other plastics. The VOC content of the plastic pellets is very small. The plastic pellets are heated in the injection-molding machine and extruded into molds. Once the parts are set and stable, they are pulled from the machine and allowed to cool before being transferred to another part of the facility or packaged. Many of the parts are assembled into ready to-use systems and shipped to medical supply vendors for sale and further dispensing to hospitals. 2 APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN116440009-23, dated November 2, 2023 NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines, MACT (Part 63) ZZZZ: National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. SOURCE EVALUATION: Name of Permittee: Permitted Location: ICU Medical, Inc. - Salt Lake Medical Products Manufacturing 4455 Atherton Drive 4455 South Atherton Drive Taylorsville, UT 84123 Taylorsville, UT 84123 SIC Code: 3841: (Surgical & Medical Instruments & Apparatus) Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] 3 I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] Status: In Compliance. No limits established by the AO were exceeded based on the submitted documents and the observations made during this inspection. Maintenance is performed as per the manufacturer's specifications and records are kept as required. No R307-107 applicable breakdowns have occurred. Emissions Inventories are submitted as required. The 2023 inventory year will be submitted by April 15, 2024. The 2020 inventory has been attached to this inspection memo. The emergency generator referenced as new by II.A.3 is a Replacement-In-Kind and the installation notification can be viewed on GN116440008-21 dated November 2, 2021. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 ICU Medical, Inc. Salt Lake Medical Products Manufacturing II.A.2 Various Boilers Capacity: <5MMBtu/hr each Fuel: natural gas For informational purposes only II.A.3 Emergency Generator (new) One (1) Emergency generator Capacity: 200 kW (264 hp) Fuel: diesel Manufactured: 2023 II.A.4 Various Comfort Heaters Comfort heaters, gas packs, sun units, or humidifiers Capacity; <5MMBtu/hr each Fuel: natural gas For information purposes only II.A.5 Mold Cleaning Equipment Resin Residual Removal Furnace Various solvent bonding, solvent cleaning, injection molding, and residual plastic resins removal chemicals used in the medical device manufacturing process. Status: In Compliance. The equipment listed within II.A.1 through II.A.5 has been installed and is operating as described, with the exception of II.A.3, the 200 kW (264 hp) generator, which is identified as new equipment and having a manufacture date of 2023. This generator was manufactured in 2020 and is rated as a Tier III, 200 kW (268 hp). ICU Medical Inc., attempted to correct the engine's permitted specifications prior to the issuance of this AO on August 16, 2023. See the attached email correspondence to the DAQ engineer. This engine was also permitted as an equivalent, Replacement-In-Kind engine on GN116440008-21. See the attached equipment replacement document for all specifications for this engine. 4 II.B Requirements and Limitations II.B.1 Limitations and Requirements II.B.1.a Visible emissions from the following emission points shall not exceed the following values: A. Electric resin residual removal furnace - 10% opacity B. All natural gas-fired heater/boiler exhausts - 10% opacity C. Diesel engine exhaust - 20% opacity. [R307-401-8] Status: In Compliance. No emissions could be viewed from the natural gas-fired boiler exhausts. Neither the electric resin residual furnace, nor the emergency generator were operating at the time of the observations. II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. Observations were made in a manner consistent with Method 9. No emissions were detected from any vent or point. See the attached VEO. II.B.1.b The owner/operator shall not burn more than five (5) pounds of resin per day in the resin residual removal furnace. [R307-401-8] Status: In Compliance. The electric resin residual removal furnace is used to sporadically clean a thin layer of residual plastic film from the molds. The facility manager, Pedro Villarreal, stated that typically less than 2.5 pounds of resin will be burned off during any month. The facility switched from an hourly resin burn limit to a limit based on weight when the November 2, 2023, AO was issued. Since that time, the heaviest resin weights were reported as 2.3 pounds a month for November 2023, and December 2023. See the attached "Screw Burner Oven" table. II.B.1.b.1 To determine compliance, the owner/operator shall keep a record of the weight of resin remaining in each residual mold per day put into the resin residual removal furnace, for all periods when the plant is in operation. Weight of the resin combusted in each mold shall be the total weight of the resin plus the mold minus the weight of each mold, measured with a mass balance. [R307-401-8] Status: In Compliance. Resin weights are calculated as required using a mass balance method. II.B.2 Fuel Requirements II.B.2.a The owner/operator shall use only natural gas as fuel in all the boilers and heaters. [R307-401-8] Status: In Compliance. Only natural gas is used in the boilers and heaters. II.B.2.b The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the emergency generator engine. All diesel burned shall meet the definition of ultra-low sulfur diesel (ULSD), and contain no more than 15 ppm sulfur. [R307-401-8] Status: In Compliance. Only certified ultra-low sulfur diesel fuel is used for the emergency generator. See the attached invoice. II.B.2.b.1 To demonstrate compliance with the diesel fuel requirements for any diesel fuel purchased, the owner/operator shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements, or the owner/operator shall obtain certification of sulfur content from the fuel supplier. [R307-401-8] Status: In Compliance. See the attached ULSD invoice from Reladyne West LLC. 5 II.B.3 Engine Requirements II.B.3.a The owner/operator shall not operate the emergency generator engine on site for more than 100 hours per rolling 12-month period during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ] Status: In Compliance. The emergency generator is operated for one hour each month for testing and maintenance. A total of 11 hours was reported for the 12-month rolling period of March 2023 through February 2024. A facility shutdown occurred during the month of July 2023, causing the generator to be run as backup power for 10 hours during that month. See the attached Diesel Generator spreadsheet. II.B.3.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. Records documenting the operation of each emergency engine shall be kept in a log and shall include the following: A. The date the emergency engine was used B. The duration of operation in hours C. The reason for the emergency engine usage. [R307-401-8] Status: In Compliance. A generator operation log is kept and then transferred to an electronic log. The generator is tested for maintenance for one hour each month and this duration of time used is recorded. A comment field stating the reason for the generator use is recorded. II.B.4 Volatile Organic Compound (VOC) Limitations II.B.4.a The VOC content of the solvent bonding, solvent cleaning, injection molding, and residual plastic resins removal chemicals as used shall not exceed the density limits established by R307- 304 and R307-353. High solids (low VOC content) chemicals shall not be thinned or otherwise reduced beyond manufacturers recommendations. These parameters shall be tested by using the appropriate ASTM method or another method approved by the Director. [R307-304, R307-353] Status: In Compliance. This facility is exempt from R307-304 Solvent Cleaning requirements as per R307-304-3(1) as the source is subject to R307-353. ICU Medical, Inc., is exempt from R307-353 Plastic Parts Coatings provisions as per R307-353-3(5) which states: " The provisions of this rule do not apply to coating products on medical devices up to 800 pounds of VOC per year". This provision was discussed with the facility manager who stated that they are still exempt given that they use approximately the same 250 pounds of coating products. The plastic coating process consists of wiping the catheter lines with a solution of Heparin and IPA solution. See DAQC-CI116440001-23 for more information. A copy of R307-353 was provided to the facility manager to inform the contact of the restrictions that will apply should their process exceed the applicable 800 pounds of VOC per year. II.B.4.b The owner/operator shall not emit more than the following from evaporative sources (solvent bonding, solvent cleaning, injection molding, residual plastic resins removal, etc.) on site: 17.13 tons of VOC per rolling 12-month period 0.88 tons of formaldehyde, hexane, nickel compounds, toluene, xylene, cyanide compounds, ethyl benzene, ethylene dichloride, ethylene glycol, glycol ethers, isophorone, methanol, methylene chloride, propylene oxide, and methyl methacrylate combined This does not include the emissions from the natural gas and diesel combustion sources. [R307-401-8] 6 II.B.4.b.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed]. [R307-401-8] II.B.4.b.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307- 401-8] II.B.4.b.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material B. The maximum percent by weight of VOCs and each HAP in each material used C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8] Status: In Compliance. For the rolling 12-month period of March 2023 through the end of February 2024, VOC was reported as 5.7 tons. For the listed chemical compounds only formaldehyde, cyanide compounds, glycol ethers, and methylene chloride were reported as used. The total amount used for this 12-month period was recorded as 0.0679 tons. Emission totals are based on the required calculations. See the attached summary table for reported emissions. Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. NSPS (Part 60) Dc: Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units. Status: Not Applicable. The permitted boilers have a design capacity that is under 5 MMBtu/hr and are listed as "informational purposes only" on this AO. 7 NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. Status: In Compliance. Compliance with this subpart is satisfied by installing a certified engine, maintaining and operating the engines in accordance with the manufacturer's instructions, installation of a non-resettable hour meter, and maintaining records of use. See Conditions II.B.3.a and II.B.3.a.1 for more information. MACT (Part 63) ZZZZ: National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. Status: In Compliance. This engine is a Tier III and was installed in 2020 as is documented on GN116440008-21. Only ULSD is used. The engine is operated for maintenance and testing purposes for under 100 hours each rolling 12-month period. A non-resettable meter has been installed and operating records are kept as required. See Conditions II.B.3.a and II.B.3.a.1 for more information. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Stationary Sources [R307-210] Status: In Compliance. R307-210 for Stationary Sources incorporates NSPS IIII for Stationary Compression Ignition Internal Combustion Engines. NSPS IIII is satisfied by compliance with Conditions II.B.3.a and II.B.3.a.1 on this AO. National Emission Standards for Hazardous Air Pollutants [R307-214] Status: In Compliance. R307-214 for National Emission Standards for Hazardous Air Pollutants incorporates MACT ZZZZ for Stationary Reciprocating Internal Combustion Engines. This subpart is satisfied by Conditions II.B.3.a and II.B.3.a.1 of this AO. Solvent Cleaning [R307-304] Status: Not Applicable. This rule applies to Solvent Cleaning. As per R307-304-3(1) the requirements of R307-304 do not apply to the operations that are subject to R307-349 through R307-355. Graphic Arts [R307-351] Status: In Compliance. The requirements for R307-351 for Graphic Arts were reviewed with the ICU Medical contact. Mr. Villarreal stated that their current product use list and amounts have not changed since the previous January 2023 inspection. See DAQC-CI116440001-23 for additional information. The following products are used for cleaning in the print shop: 4 gaVyr of IPA 70 o, 15 gaUyr of Gans Low Odor Wash, and 2.5 gtUyr of Glaze Remover 113, for a total of 22 gallons per year. R307-351-3(2) states "A graphic arts printing operation may use up to 55 gallons of cleaning materials per year that do not comply with the VOC composite vapor pressure requirement of the VOC content requirement of R307-351-5(4). A printed copy of this rule was provided to Mr. Villarreal to let the source know what requirements will become applicable in the event that the cleaning material product use should ever exceed 55 gallons. 8 Plastic Parts Coatings [R307-353] Status: In Compliance. R307-353 applies to Plastic Parts Coatings. R307-353-3(5) states "The provisions of this rule do not apply to coating products on medical devices up to 800 pounds of VOC per year". The plastic coating process wipes catheter lines with a solution of Heparin and IPA solution with a resulting VOC that the ICU Medical Facility Manager, Mr. Villarreal states is essentially the same as what was reported during the previous January 2023 inspection. He also stated that the historical use of the applicable products has been consistently under this limit. A printed copy of R307-353 was provided to inform the source of what restrictions will become applicable should the 800-pound limit be exceeded in the future. EMISSION INVENTORY: An Emissions Inventory was submitted for the 2020 activity year and has been attached as a document to this inspection memo. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN116440009-23, dated November 2, 2023, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr Ammonia 0.19 CO2 Equivalent 7041.00 Carbon Monoxide 4.98 Nitrogen Oxides 5.99 Particulate Matter - PM10 0.80 Particulate Matter - PM2.5 0.80 Sulfur Dioxide 0.06 Volatile Organic Compounds 17.99 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Cyanide Compounds (CAS #143339) 6 Ethyl Benzene (CAS #100414) 4 Ethylene Dichloride (1,2-Dichloroethane) (CAS #107062) 376 Ethylene Glycol (CAS #107211) 9 Formaldehyde (CAS #50000) 9 Glycol Ethers (CAS #EDF109) 47 Hexane (CAS #110543) 501 Isophorone (CAS #78591) 25 Methanol (CAS #67561) 52 Methyl Methacrylate (CAS #80626) 12 Methylene Chloride (Dichloromethane) (CAS #75092) 660 Nickel Compounds (CAS #NDB000) 4 Propylene Oxide (CAS #75569) 4 Toluene (CAS #108883) 134 Xylenes (Isomers And Mixture) (CAS #1330207) 154 9 PREVIOUS ENFORCEMENT ACTIONS: A Compliance Advisory was issued on March 22, 2022 (DAQC-496-22), for exceeding the hourly limits for residual resin burn rates. A Signed Early Settlement Agreement was issued on May 13, 2022 (DAQC-604-22), for $807.00. The unit of measurement for limiting residual resin burning was changed from an hourly to a weight measurement on the AO AN116440009-23. COMPLIANCE STATUS & RECOMMENDATIONS: ICU Medical Inc. should be considered to be in compliance with the AO AN116440009-23, dated November 2, 2023, at the time of this inspection. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect as usual maintaining the same targeting frequency. NSR RECOMMENDATIONS: ATTACHMENTS: VEO, DAQ issued emergency generator Replacement-In-Kind notification, email correspondence requesting generator specification corrections, residual resin burning records, VOC and chemical emissions 12-month rolling totals, generator operation hours, ULSD fuel invoice, and 2020 Emissions Inventory Summary. AUTOMATIC TRANSFER SWITCH Test Documents As fault currents can occur at any level, a transfer switch must be capable of withstanding any fault current up to its maximum rating. This rating is based on the rating of the protective device in front of the unit and must be considered on that basis. Cat tests show results based on various current values and time durations, and include additional high current tests with fuses. By considering this range of values, it is possible to predict performance with different fuse characteristics or specific circuit breaker current-time curves with a given available short circuit current. Interrupting Ratings Some manufacturers of circuit breaker type automatic transfer switches list interrupting current (IC) ratings in lieu of WCR. These switches will then open on faults instead of withstanding the fault until the external protective device clears. As the transfer switch is then used to open the fault current in place of a protective device-this may leave the transfer switch with both normal and emergency open which then requires manual resetting of the breakers within the transfer switch enclosure. The circuit breakers may require factory inspection after high current interruption in accordance with common circuit breaker procedures. WCR ratings, as opposed to IC ratings appear to offer a better choice to the system designer as he attempts to coordinate the protection of the entire system. Knowing the maximum amount and duration of fault current a switch will withstand gives the designer the information necessary for complete coordinated system design. Advantage of RMS Symmetrical Ratings •Data is consistently reported based on UL test procedures. 115 •Where time beyond the first ½ cycle is given suitable decisions can be made to use circuit breakers orfuses. •Misleading reporting is eliminated. Blow-On Effects on Short Circuit Current in Contacts Some switch designers analyze "blow­ on" and "blow-off' effects and force vectors (due to electromagnetic repulsion) to claim increased WCR capability of their product. Such calculations are very rough approximations because of inherent errors in estimating "domain" size and number, current "pinch" effect and the problem of complex geometry of actual contact structures when compared to idealized models. The only proof of a successful design are tests, uniformly performed and consistently reported al to the same criterion such as UL 1008. AUTOMATIC TRANSFER SWITCH Coordinated Breaker Model Types (cont.) 35,000 480V 50,000 Eaton 250A HJD, JDC, JGC, JGH, 200,000 600A (300-400A) 80 JGU,JGX (Class J) 100 .,..CrG 150 400A CHLD4, CLO, HLD4, 100,000 (OT) (400A) 200 CLDC, LDC, KOC, HKD, (dass RKS, CHMDL4, CMDL4 225 RKl) 260 600A CHLD6, HDL6, (DTJ (40-400AJ 300 CHMDL6, CMDL6, CLDC, CLD6, LDC6, CLDC6 (OT)(225-800A CHMDL8, HMDL8, 400A) MDL8,CMDL8 ITE/ 250A CFD6, HFD6, HFXD6, (DT,CT) (40-400A) Siemens HHFD6, HHFXD6 CBTS 400A CJD6 (OT.on 600A CLD6, HHLD6, (100-400A) HHLXD6, HLD6, HLXD6 Cl'E (OT) 800A CMD6, MD6, HMD6, (225-400A) HMXD6,MXD6 Cl'E General 250A SFL,SFP Electric (DT,CTI 400A SGL,SGP (40-400A) 600A SGL, SGP, FGL, FGP CBTE Schneider !OT.on 150A HJ,HL,HR (100-400AJ 250A JJ, JL, JR 600A LJ, LL, LR 800A MJ 600V 42000 Eaton 250A JGU,JGX 200,000'"""' 400A CLDC4, KOC, LDC4 (Class J) 600A CLDC6, LDC6, NB Tri-Pac 800A NB Tri-Pac ITE/ 250A CFD6 Siemens 400A CJD6,SCLD6 600A CLD6, HHLD6, HHLXD6, SCLD6 800A CMD6, HMD6, HMXD6, SCMD6, SHMD6 General 150A THLCl Electric 400A FGL4, FGP4, THLC 4, TLB4 600A SGL, SGP, FGL6, FGP6 800A SKL8,SKP8 Schneider 150A HJ,HL,HR 250A JJ, JL, JR 600A LJ, LL, LR 800A MJ 116 3/15/24, 10:38 AM State of Utah Mail - RE: 3/8/24 Visit Follow-up https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1793358148055682519%7Cmsg-f:1793434051263593629&simpl=msg-f:1793434051263593629&mb=1 1/4 Susan Weisenberg <sweisenberg@utah.gov> RE: 3/8/24 Visit Follow-up 1 message Pedro Villarreal <Pedro.Villarreal@icumed.com> To: Susan Weisenberg <sweisenberg@utah.gov> Of course, see below, Generator hours: 3/15/24, 10:38 AM State of Utah Mail - RE: 3/8/24 Visit Follow-up https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1793358148055682519%7Cmsg-f:1793434051263593629&simpl=msg-f:1793434051263593629&mb=1 2/4 Mold Cleaning Process (screw burner) Best Regards, Pedro Villarreal EHS Manager 4455 Atherton Drive Salt Lake City, UT 84123 Phone: 801-284-1206 www.icumed.com From: Susan Weisenberg <sweisenberg@utah.gov> Sent: Tuesday, March 12, 2024 5:48 PM To: Pedro Villarreal <Pedro.Villarreal@icumed.com> Subject: Re: 3/8/24 Visit Follow-up CAUTION: This message has originated from an EXTERNAL SOURCE. Please use proper judgment and cauon when opening aachments, clicking links, or responding to this email. Hello, thank you for your prompt response for the burn and VOC/chemical compound records. Would it be possible to get the rolling 12-month period to be for the time frame of March 2023 through February 2024, rather than the 2023 calendar year? Also, As per Conditions II.B.3.a and II.B.3.a.1 - I need documentation that the emergency generator was not operated for testing/maintenance purposes for over 100 hours during the same rolling 12-month time period. Thanks, let me know if you have any questions. 3/15/24, 10:38 AM State of Utah Mail - RE: 3/8/24 Visit Follow-up https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1793358148055682519%7Cmsg-f:1793434051263593629&simpl=msg-f:1793434051263593629&mb=1 3/4 Susan Weisenberg, Environmental Scientist Office: 385-306-6512 On Tue, Mar 12, 2024 at 3:40 PM Pedro Villarreal <Pedro.Villarreal@icumed.com> wrote: Hi Susan- Attached is the invoice for the fuel purchased for our backup generator. Also below is a screenshot of our VOC inventory for 2023. Here is the rolling 12 of our permitted resin removal process (equipment). You will see the transition from burn hours to weight. 3/15/24, 10:38 AM State of Utah Mail - RE: 3/8/24 Visit Follow-up https://mail.google.com/mail/u/0/?ik=bffac613d3&view=pt&search=all&permthid=thread-f:1793358148055682519%7Cmsg-f:1793434051263593629&simpl=msg-f:1793434051263593629&mb=1 4/4 Please let me know if you have any questions or need anything else. Best Regards, Pedro Villarreal EHS Manager 4455 Atherton Drive Salt Lake City, UT 84123 Phone: 801-284-1206 www.icumed.com INVOICE Bill To:Ship To: TW ICU MEDICAL, INC - FUEL 4455 ATHERTON DR SALT LAKE CITY, UT 84123 Invoice Number: Invoice Date: Salesperson: 31-0010006 0855143-IN Order Number: Order Date: 0855143 TJ MERANDA 0001 ICU MEDICAL INC 951 CALLE AMANECER San Clemente, CA 92673 Page 1 of 1 Invoice Due Date: 07/05/2022 07/15/2022 07/05/2022 Remit Payment to: RelaDyne West LLC PO Box 954039 St Louis, MO 63195-4039 Payments not received by the due date will be assessed interest at a rate of 1.50% per month. There will be a 3% processing fee added to the total invoice balance at the time of processing for all Credit Card Payments. Customer P.O.Truck 134910A Driver Terms NET 10 DAYS Item Number UOM Unit Price AmountOrderedShippedBackOrder Comment C10 Warehouse Supplier#: Item Description 51 0.00 0.00 0.00 0.00 0.0000 5.070300228GAL 1,095.18 216.00DYED #2 ULTRA LOW SULFUR DSL 228 216.00 0.00 0.00 0.00 0.00 0.0000 FEDERAL LUST FEE - DSL 0.22 0.00100 0.00 0.00 0.00 0.00 0.0000 FEDERAL ENV FEE - DSL 0.46 0.00214 0.00 0.00 0.00 0.00 0.0000 UT STATE ENV SURCHARGE - DSL 1.40 0.00650 0.00 0.00 6.48 6.48 0.0300 0.00 0.00 6.48 6.48 0.0300 Item Total: 1,097.26 5.07994 0.00 0.00 6.48 6.48 0.0300 0.00 0.00 6.48 6.48 0.0300 0.00 0.00 0.00 6.48 0.0000 0.000000/FLSFMT 75.00FUEL SERVICE FEE MID TKWGN 0.00 0.00 0.00 6.48 0.0000 0.00 0.00 0.00 6.48 0.0000 14.95 0.00 0.00 6.48 0.0000 14.95 0.00 0.00 6.48 0.0000 14.95 0.00 0.00 6.48 0.0000 14.95 0.00 0.00 6.48 0.0000 BRAD ROBERTS 801-264-1328, COREY 385-441-1050 Save Time! Go online to manage your account, place orders, access signed delivery tickets, and more! Sign up today at my.RelaDyne.com Net Invoice: 1,172.26 Handling Fee: 1,279.61Invoice Total: 85.92Sales Tax: Fuel Surcharge: 14.95 6.48 2020 Emissions Inventory Report ICU Medical, Inc.- Salt Lake Medical Products Manufacturing (11644) Emissions Summary CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS Pollutant Code/CAS #Pollutant Name Emissions (tons, excluding tailpipe) Tailpipe Emissions (tons) Total Emissions (tons)* PM10-PRI PM10 Primary (Filt + Cond)0.33803 <.00001 0.33803 PM10-FIL PM10 Filterable 0.02487 <.00001 0.02487 PM25-PRI PM2.5 Primary (Filt + Cond)0.33803 <.00001 0.33803 PM25-FIL PM2.5 Filterable 0.02487 <.00001 0.02487 PM-CON PM Condensible 0.07461 <.00001 0.07461 SO2 Sulfur Dioxide 0.01582 <.00001 0.01582 NOX Nitrogen Oxides 1.42947 <.00001 1.42947 VOC Volatile Organic Compounds 2.78176 <.00001 2.78176 CO Carbon Monoxide 1.12552 <.00001 1.12552 7439921 Lead 0.00001 <.00001 0.00001 NH3 Ammonia 0.04189 <.00001 0.04189 HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions (tons)* 7440439 Cadmium (HAP)PM 0.00001 57125 Cyanide (HAP)PM 0.001 171 Glycol Ethers (HAP)VOC 0.01 246 Polycyclic Organic Matter (HAP)VOC 0.00001 *Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated. 1/2