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     Office of Air Quality, Permitting & Enforcement Division

               Mechanical Section Policy Memorandum


Date:  February 14, 1994                            No.: 9

From:  Skip Clark, P.E. 

Approved by:  Gary Wallin, P.E. 

Subject:  Standard Exemption No. 89



Under part (c)(2) of Standard Exemption No. 89, it requires
within 60 days of start-up, the control device performance
must be verified through stack testing or other TNRCC approved
test methods or procedures.  If the control device
manufacturing company can provide emission data which shows
that the same model as being installed was tested somewhere
else and the testing procedure can be quality assured by our
Mobile Source and Monitoring Section, we will accept the
results of that testing toward satisfying the conditions of
verifying the removal efficiency of the control device.  


In the development of this exemption, it was felt that the
control device efficiency needed to be verified, but it was
also noted that this might put an economical burden on some
small hospitals.  Since most ethylene oxide (ETO) sterilizer
control devices have shown high removal efficiencies and since
there are not much variation within each model, the sampling
of a particular model would be the same no matter where the
unit was tested.  Also as a point of clarification, only those
sterilizers that use between 100 and 1000 pounds of ETO per
year need to be registered with a PI-7. 

Necessary Action:  None  

cc:  All Mechanical Section