AQ_F_0100010_20190409_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF AIR QUALITY Winston-Salem Regional Office
Stericycle,Inc.
Inspection Report NC Facility ID: 0100010
Date: 04/12/2019 Count /FIPS: Alamance/001
Facility Data Permit Data
Permit: 05896/T25
Facility Name: Stericycle, Inc. Issued: 12/19/2016
Facility Address: 1168 Porter Avenue Expires: 11/30/2021
Haw River,NC 27258 Classification: Title V
Lat: 36d 3.9660m Long: 79d 20.9230m Permit Status: Active
SIC: 4953/Refuse Systems Current Permit Application(s): None
NAICS: 562213 /Solid Waste Combustors and Incinerators
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact
SIP/Title V
Alan Skrzypczak Alan Skrzypczak Alan Skrzypczak MACT Part63: Subpart ZZZZ
Facility Manager Facility Manager Facility Manager NSPS Part 60: Subpart fill
336 578-8901 336 578-8901 336 578-8901 40 CFR Part 62: Subpart HHH
Compliance Data
Comments:
Inspection Date: 04/09/2019
Inspector's Name: Taylor Hartsfield
Inspector's Signature: _.,- y Operating Status: Operating
Compliance Code: Compliance - inspection
Date of Signature: LAI � I lr� DMM Action Code: FCE
1 On-Site Inspection Result: Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2017 1.0000 0.2300 21.35 0.8500 0.5000 0.8000 55.93
2016 1.04 0.2300 21.67 0.8700 0.5000 0.8200 57.04
2015 0.9500 0.2400 18.01 0.8500 0.5300 0.7500 137.97
* Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Tvae Rule Violated Violation Resolution
Date
05/18/2018 NOV/NRE 2D .1206 Hospital, Medical,and Infectious Waste Incinerators 06/04/2018
11/08/2017 NOV/NRE Part 60 -NSPS Subpart Ec Hospital/Medical/Infectious Waste 11/17/2017
Incinerators for Which Construction is Commenced>June 20, 1996
11/08/2017 NOV/NRE 2D .1206 Hospital, Medical,and Infectious Waste Incinerators 11/17/2017
04/21/2017 NOV/NRE 21) .1206 Hospital, Medical,and Infectious Waste Incinerators 05/19/2017
04/21/2017 NOV/NRE Part 60-NSPS Subpart Ec Hospital/Medical/Infectious Waste 05/19/2017
Incinerators for Which Construction is Commenced>June 20, 1996
10/24/2016 NOV/NRE Part 60-NSPS Subpart Ec Hospital/Medical/Infectious Waste 11/18/2016
Incinerators for Which Construction is Commenced>June 20, 1996
1 1/02/2015 NOV 21) .1206 Hospital, Medical,and Infectious Waste Incinerators 11/16/2015
02/18/2015 NOV Permit Condition 03/13/2015
Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
04/11/2018 Compliance Method 26A, Method 29, Method 5, Method 9 ES01, ES02
Page 1 of 14

INTRODUCTION
On April 9,2019,Taylor Hartsfield,DAQ-WSRO Compliance Supervisor, visited Stericycle,Inc. in Alamance County in order to
conduct a compliance inspection and stack test observation.The facility was targeted this year and has a facility classification of Title
V.The facility contact and Facility Manager,Alan Skrzypczak,was requested to help facilitate the inspection.Other representatives of
the facility that were present during the inspection and stack test were Kirk Yarbrough, Incinerator Operations Supervisor,and Don
Nuss,Atlantic Region Environmental Manager. Mr. Skrzypczak verified that all the contact information in the IBEAM database was
correct and up to date.
Stericycle, Inc. is a hospital,medical,and infectious waste incineration facility consisting of two identical units. According to Mr.
Skrzypczak,the facility operates 24 hours per day, 7 days a week for 52 weeks per year. The facility received its last compliance
inspection on April 10-11,2018, by this inspector.At that time,the facility appeared to be in compliance with its Air Quality Permit
(05896/T25).
PERMITTED SOURCES
1�kloga . F tlrC5ttlSdti - �BSCI I3#1r1Ilq e I i p 't i s t a �Y �i � 8f BCiiYr� �a i
?: `�„ E ,�'s' t.,.:.�° ��IE * +. _...mi �fl°.1..�t�.'" . _. .� .`,. �r
dual chamber hospital,medical CD07 one selective non-catalytic reduction(SNCR)system with ammonia
a td infectious waste incinerator
or urea injection(19,700 ACFM,outlet airflow rate),
(HMI WI)firing natural gas(4.6
ES01 CDO1 one packed bed scrubber and associated quench column in series with
million Btu hr primary chamber CD03 one venturi scrubber equipped with a mist eliminator,and
burner and 6.0 million Btu/hr
CD05 one sulfur impregnated carbon bed(6,000 ACFM, inlet airflow rate) !
;secondary chamber burner)
dual chamber hospital, medical 1 CD08 !one selective non-catalytic reduction (SNCR)system with ammonia
:and infectious waste incinerator
(HMIWI)firing natural gas(46 I for urea injection(19,700 ACFM, outlet airflow rate),
.
ES02 1 CD02 one packed bed scrubber and associated quench column in series with
million Btu/hr primary chamber i
burner and 6.0 million Btu/hr 1 CD04 one venturi scrubber equipped with a mist eliminator,and
secondary chamber burner) CD06 one sulfur impregnated carbon bed(6,000 ACFM, inlet airflow rate)
I
EGl diesel-fired emergency generator N/A N/A
�(500 kW maximum capacity)
INSIGNIFICANT/EXEMPT SOURCES
L
��.'tn19 i 0S.- bits :ID :?! .. 1'Fnn
.I rta fott Snnt�C .87eSCrl tAe ( .(
s, . o , _ ..,, A:.
j 1-CT-1 and 1-CT-2- Two cooling towers(55,200 gallons per hour water recirculation rate each)
I-AMM Facility-wide storage of 19%aqueous ammonia
SAFETY
When inspecting this facility, DAQ personnel are required to wear reflective vests, safety shoes,safety glasses, and hearing protection.
General safety practices froth the required HAZWOPER training should always be followed.
LATITUDE/LONGITUDE VERIFICATION
The latitude and longitude coordinates of the facility were verified and did not need to be updated by this inspector.
APPLICABLE REGULATIONS
The following Title 15A North Carolina Administrative Code(NCAC)air quality regulations apply to Stericycle,Inc.: Subchapter 2D
.0516,2D .0521,2D .0524,2D.0535,2D .0540,2D.0611,2D.1100,2D.1 111,2D .1206,21) .1806,2Q.0508,40 CFR Part 60,
Subpart 11I1,40 CFR Part 62,Subpart HHH,and 40 CFR Part 63, Subpart ZZZZ.
Page 2 of 14

PERMIT APPLICATIONS
There are not any permit applications in process by DAQ-RCO for this facility at the time of this inspection.
SOURCE TEST
At the time of the inspection, the facility was testing both hospital, medical and infectious waste incinerators(HMIWI)(ES01 and
ES02). Both incinerators were being tested for visible emissions(VE)using EPA Method 9. Both incinerators are subject to 15A
NCAC 2D .1206"Hospital, Medical and Infectious Waste Incinerators,"which incorporates parts of 40 CFR Part 60, Subparts Cc and
Ec by reference. Both units are also subject to 15A NCAC 2D .1100"Control of Toxic Air Pollutants"and 40 CFR Part 62 Subpart
HHH "Federal Plan Requirements for Hospital/Medical/lnfectious Incinerators Constructed on or Before June 20, 1996."The limit
for VE is 6%opacity on a 6-minute block average.
The test was performed by Pat Daley of TRC Environmental Corporation based out of Raleigh,NC.The Protocol Submittal Form was
received by this office on February 11,2019.The protocol was approved by the DAQ-WSRO on February 13,2019. The test
consisted of three 1-hour runs on each incinerator unit.Run#1 was from 9:30-10:30,Run#2 was from 10:31-11:31,and Run#3 was
from 11:32-12:32. ESO1 and ES02 were operating with charge rates of 1,707.7 and 1,703.8 Ibs/hr,respectively. The other operating
parameters at the time of source test are summarized below under Condition 2.1.A.2.n. There were not any detectable visible
emissions throughout the testing period other than an attached steam plume on both incinerator stacks. The weather was cloudy,and
the temperature ranged from 60-70°F with a 7-mph wind from the West. According to TRC's on-site results of the Method 9 tests
performed on both units,all readings were 0%. Preliminary results indicate compliance with the opacity limits. The results will be due
by May 9, 2019.
The facility previously conducted testing on both units on April 10-1 I,2018, Both incinerators were tested for particulate matter
(PM), visible emissions(VE), hydrogen chloride(HCI), and metals using EPA Methods 5,9,26A,and 29,respectively. The metals
testing included lead(Pb), cadmium(Cd), and mercury(Hg). The results were received on time and indicated compliance with the
applicable limits,as indicated in the DAQ-SSCB memo on June 4,2018.The following tables summarize the results:
ESOI 4/10/2018 Emissions Test Results
Pollutant Emissions Emission Limit Regulation Compliance
0.0168 m dscm 7%Oz 0.036 m dscm 7%02 2D .1206 Yes
Lead(Pb) 0.000117 lb/hr ---
1.025lb/ r' --- --- ---
0.00227 m dscm 7%02 0.0092 m dscm 7%02 2D.1206 Yes
Cadmium(Cd) 0,0000266lb/hr --- --- ---
0.233 Ib/ r' 63.91 Ib/ r2 2D .1100 Yes
<0.000994 m dscm 7%02 0.018 m dscm 7%02 2D .1206 Yes
Mercury (Hg) <0.0000I I I lb/hr --- ---
<0.000266 lb/day' 3,82 lb/day' 2D .1100 Yes
Filterable PM 8.78 m dscm 7%02 25 m dscm 7%02 2D .1206 Yes
0.098 lb/hr
HCI 0,0354 mvd 7%02 6.6 mvd 7%02 2D .1206 Yes
0.000630lb/hr 2.2lb/hr2
Visible Emissions 0% 56% 2D .1206 Yes
ES02 4/11/2018 Emissions Test Results
Pollutant Emissions Emission Limit Regulation Compliance
0.0275 m dscm 7%02 0.036 m dscm 7%02 2D .1206 Yes
Lead(Ph) 0.000371lb/hr
3.25 Ib/ r' ---
0.000482 m dscm 7%02 0.0092 m dscm 7%02 2D.1206 Yes
Cadmium(Cd) 0,00000648lb/hr ---
0.0568 lb/ r' 63.91 Ib/ r2 2D 1100 Yes
<0.000973 m /dscm 7%02 0.018 m dscm 7%O2 2D .1206 Yes
Mercury(Hg) <0.0000131 lb/hr
Page 3 of 14

Pollutant Emissions Emission Limit Re ulation Compliance
<0.000315 lb/day' 3.82 lb/da 2 2D .1100 Yes
Filterable PM 9.21 m dscm 7%02 25 m dscm 7%02 2D .1206 Yes
0.124lb/hr --- --- ---
HCI 0.0976 mvd 7%02 6.6 mvd 7%02 2D .1206 Yes
0.00197lb/hr 2.2lb/hr2 --- ---
Visible Emissions 0% <6% 2D .1206 Yes
' Assuming 24-fir operation.2 Emission limit is for ESOI and ES02 combined.
DISCUSSION
The facility has two dual chamber hospital,medical and infectious waste incinerators(HMIWI)(ESO1 and ES02)firing natural gas,
each with a 4.6 million Btu/hr primary chamber burner and a 6.0 million Btu/hr secondary chamber burner.Each incinerator is
controlled by a selective non-catalytic reduction(SNCR)system, a packed bed scrubber,a venturi scrubber equipped with mist
eliminator,and a sulfur impregnated carbon bed,all installed in series.These control devices are installed to control emissions of PM,
CO,NOx,dioxins/furans,and other HAP/TAPS.During the inspection,both incinerators and their respective control devices were
operating.There were no visible emissions observed other than steam plumes from the incinerator stacks. These stacks were observed
from ground level.The operating parameters at the time of inspection are summarized below under Condition 2.I.A.2.n.
A basic description of the operation of a HMIWI at this facility is as follows: A hopper is loaded with boxes of HMI W, which
represents a charge. The hopper is tipped into an open pre-incineration chamber,and, after closing, a hydraulic ram pushes the charge
into the primary combustion chamber. From there,the charge is combusted as it moves down the primary chamber, aided by other
rams and underfire air. At the end of the primary chamber, the ash and non-combusted material is quenched with water and an auger
transfers the ash to a waste bin. This bin then goes to a landfill as the waste no longer has its original hazardous properties.
Back in the incinerator,the combustion gases from the primary chamber travel up to a secondary chamber. A secondary burner
destroys any combustible content of the primary combustion gases and reduces CO emissions.The exhaust then enters the SNCR
system where ammonia or urea is injected in order to reduce NOx formation. Afterwards,the gases enter a packed bed scrubber and
associated quench column. The packed bed scrubber has a caustic solution to reduce acid gas emissions.The quencher reduces
temperature which reduces dioxin/f iran emissions.After quenching,the gases pass into the venturi scrubber to reduce PM emissions.
Following the venturi scrubber,the gases go through a mist eliminator to remove some of the steam plume. The last step is for the
exhaust to pass through the sulfur impregnated carbon bed to reduce mercury emissions.
Associated with the two HMIWIs are two exempt cooling towers(I-CT-I and 1-CT-2)each with a 55,200 gallons per hour water
recirculation rate. The cooling towers assist the quencher in reducing the temperature of the exhaust.These cooling towers were in
operation during the inspection with small amounts of steam emissions visible from the roof of the facility.
The facility also has a diesel-fired emergency generator(EG 1). It was not in operation during the inspection. The generator is a 500
kW Caterpillar model DCPXL that was installed in July 2013.The non-resettable hours meter was replaced on September 23, 2016,
and it read 109.1 hours during the inspection. Before being replaced,the old hour meter read 164.2 hours. A certification sticker for
NSPS purposes is located on the engine,and it was observed by this inspector.The generator uses ultra-low sulfur diesel (ULSD)fuel
from Alamance Oil. Carolina CAT services the engine quarterly. The engine is tested twice per week for about 20 minutes. During an
emergency loss of power,the engine is equipped to start automatically to provide power to the incinerators and prevent opening of the
bypass stacks, which would occur seven seconds after the incinerators lose power.
PERMIT CONDITIONS
Section 2—Specific Limitations and Conditions
1.1 —Emission Source(s)and Control Device(s)Specific Limitations and Conditions
A. Two natural gas-fired dual-chamber hospital, medical,and infectious waste incinerators IHMIWII (ID Nos. ESOI and
ES02),each controlled with one selective non-catalytic reduction (SNCR)system (ID Nos. CD07 and CD08), in series with
one packed bed scrubber(ID Nos. CDOI and CD02), in series with one venturi scrubber(ID Nos. CD03 and CD04), in
series with one sulfur impregnated carbon bed(ID Nos. CD05 and CD06)
Page 4 of 14

Condition 2.1.A.La contains the requirements for 2D.1100 which requires the facility to limit the release toxic air pollutant(TAP)
emissions.The limits for each TAP emitted by the affected emissions sources are established in the table below.The facility
conducted source testing on the units from April 28-May 1,2015.The results of that test were approved by the DAQ-SSCB per the
memo issued on June 22,2016, The facility now only tests for hydrogen chloride,cadmium,and mercury on a three-year cycle. The
last three-year test was on April 10-1 I,2018,and the results of that test were approved by the DAQ-SSCB per the memo issued on
June 4,2018. The following table summarizes the testing results.
Affected Emission EmtsstomLimit S 4/28-5/1/Z015 i 44011/2048
Sourcd(s) Toile Air Potlutant (tUt )f4rppth) � ' Test Res Its(taia)' Test;)i�sults.(.04D
.............. _. _. ______ _,_,___m ___ ._..____ ___.____ _
t
Arsenic 2.673 Ibs/yr 0.1654 Ibs/yr Not tested
Beryllium 4764Ibs/yr <0.0330Ibs/yr �Nottested� V l
_ _e _.._
Cadmium 63.91 Ibs/yr ( 0 0954 lbs/yr 0.2898 lbs/yr
24.00lbs/day; <0.02111bs/day;
Chlorine Not tested
1.00lbs/hr <O.00108lbs/hr
Chromium VI 0.964lbs/yr F 0.0670 Ibs/yr _ I Not tested
jIncinerators Hexachlorodibenzo-P-dioxin ', 0.8831 Ibs/yr 5.62E58 lbs/yr Not tested
(ID Nos. ES01 --- - - _....._r.
and ES02) Tetrachlorodibenzo-P-dioxin 0 0349 Ibs/yr 4.10E-07 Ibs/yr Not tested
....... _,_.._-.__ ____.._ --------
Hydrogen Chloride 2.2 Ibs/hr 0.00911 Ibs/hr 0,0026 Ibs/hr
Hydrogen Fluoride 24.00 Ibs/day; <0.0280 Ibs/day; Not tested
1.00lbs/hr <0.001 17 lbs/hr
Manganese 8.22 Ibs/hr <0.00131 Ibs/hr Not tested
Mercury 3.82 Ibs/day j <5.54E-04lbs/day j <5.81E 04 Ibs/day
Nickel i 12.00lbs/day 0.00300lbs/day I Not tested
Condition 2.1.A.l.b states that to comply with the above limits,the charge rates into the incinerators shall not exceed 1,870.0 pounds
per hour for ESOI and 1,870.0 pounds per hour for ES02. In addition,each incinerator's stack height shall be a minimum of 82A feet
above ground level. Also,the maximum carbon bed inlet temperatures shall not exceed 168.1°F for CD05(for ESOI)and 164.1OF for
CD06(for ES02). During the inspection,the 3-hour average charge rates of ESOI and ES02 read 1,707.7 and 1,703.8 pounds per hour,
respectively,on the data acquisition system(DAS)utilized by the facility.The stacks appeared to remain at the appropriate height, and
there was no evidence that they had been adjusted.The 3-hour average maximum carbon bed inlet temperatures for CD05 and CD06
were 146.1 OF and 161.4°F,respectively. The facility appears to be in compliance.
Condition 2.1.A.l.c states that in order to minimize bypass event duration and emissions,the facility shall do the following:
A. Install an uninterruptible power supply (UPS) for the control system to eliminate any "reboot" time associated with the
programmable logic controllers(PLCs). The UPS shall be equipped with a readiness indicator;
B. Install a power outage indicator as an input to the PLCs;
C. Revise the PLC logic to require automatic re-closure of the bypass stack within 5 minutes after a power failure;
D. Install a low-level switch on the emergency generator diesel tank;
E. Install a pressure switch to the water supply to alert operators to a loss of water supply;
F. Operate devices to assure continuous removal of the ash from the primary chamber; and
G. Reduce combustion air to the primary chamber by alternately shutting the fan off and on in 1-minute cycles to achieve a net
reduction in airflow of 50%during the bypass event.
According to Mr. Skrzypczak,the applicable devices(A-E)have been installed/revised, and the operational changes(F-G)have been
implemented. Therefore,the facility appears to be in compliance.
Condition 2.1.A.l.d states that the facility shall not incinerate dental waste, as defined in the waste management plan required by
Section 2.1.A.2.bb. During the inspection, it was verified that the facility is not incinerating any dental waste. Any dental waste
(indicated with grey labels)received is set aside and trucked out for incineration elsewhere. If any dental waste containers are
accidentally placed on the conveyors to the incinerators,the scanners before the loading mechanism would alert the facility of the
problem and stop the process. The facility appears to be in compliance.
Page 5 of 14

Conditions 2A.A.Le and if state that the facility shall comply with the testing requirements in Section 2.1.A.2.j.for cadmium and
mercury. The testing shall also be performed in accordance with General Condition JJ.As previously mentioned,the facility tested
both units for cadmium and mercury on April 10-11,2018, and the results of that test were approved by the DAQ-SSCB per the memo
issued on June 4,2018.The facility appears to be in compliance.
Condition 2.1.A.I.s states that the facility shall conduct the monitoring, maintenance,and inspections for each incinerator and each
control device,as required by Sections 2.1.A.2.u. through an. See this section below for a detailed discussion. The facility appears to
be in compliance.
Conditions 2.1.A.l.h and i states that the facility shall maintain records or any other process operational information as is necessary
to determine compliance with 15A NCAC 2D.1100.In addition,the facility shall keep records of inspections and maintenance on the
control devices as required by Section 2.1.A.2.117. See this section below for a detailed discussion. The facility appears to be in
compliance.
Condition 2.1.A.l.i states that for each stack test,the facility shall track and record details for the waste being burned and the material
that may be carried over into the stack test period. Tracking shall include,at a minimum,a cross-reference of the identity of the waste
generator with the company's customer list(the identity information shall include the nature of the business activity),the type of
business waste,the total weight of each container,and the time the material entered the incinerator.This information shall be
summarized and submitted as part of the stack test report. Mr. Skrzypczak assured that this information would be provided with each
stack test report. The facility appears to be in compliance.
Condition 2.1.A.Lk states that the reporting requirements of 15A NCAC 2D.1206(see Sections 2.I.A.2.hh. and ii.)shall be
considered sufficient for reporting compliance with 15A NCAC 2D .1100. See this section below for a detailed discussion. The
facility appears to be in compliance.
Conditions 2.1.A.2.a and b states the emissions limitations for both HMIWI units(ESOI and ES02)as stipulated by Table I B of 40
CFR Part 60, Subpart Cc. The facility conducted source testing on the units from April 10-11,2018,and the results of that test were
approved by the DAQ-SSCB per the memo issued on June 4,2018. The facility will complete repeat(every 3 years)testing on both
units in CY2021. The facility appears to be in compliance. ■) Q D 1 i tt y 'i``l�Ik i!y" tS t�£2�3 {' .E h�i+_:!i iiiyt�!I,I', , j-1Y0-�IN 'Y+1 1•iALe�tlt,�`(L��e�a $)L
} �! i �,iFi, .. l�Sbvdt �tifrP{i lvitrf '-`S"" i € ' P r"^^^.
,� S. �!` , �,y ,
!{,v.vrili E�Ln a.i 163L'Lnin 3�v. M.
! g ! dF tails:t 'E:T94.y�.�v j' 4y i l.A I��3*ki rY i
.. aY bd
Particulate matter 25 milligrams per dry standard cubic meter(mg/dscm)OR 8,78 mg dscm 9.21 mg/dscm
0.011 grains per dry standard cubic foot(gr/dscf)
Carbon monoxide 11 parts per million by volume(ppmv) Not tested(CEMS) I--Not tested(CEMS)
i
9.3 nanograms per dry standard cubic meter total dioxins/furans !
(ng/dscm)OR
i
4.1 grains per billion dry standard cubic feet(gr/l0'dscf)
Dioxins/furans OR Not tested Not tested
0.054 ng/dscm TEQ OR
0.024 gr/10'dscf TEQ
Hydrogen chloride 6.6 parts per million by volume(ppmv) 0.0354 ppmvd 0.0976 ppmvd
Sulfur dioxide 4.6 parts per million by volume(ppmv) Not tested Not tested
Nitrogen dioxide F140 parts per million by volume(ppmv) F Not tested F Not tested
Lead 0.0�36 milligrams per dry standard cubic meter(mgddscm)OR 0.0108 mg/dscm 0.0275 mg/dscm
0.016 grains per thousand dry standard cubic feet(gr/10 dscf)
Cadmium 0.0092 milligrams per dry standard cubic meter(mg/dscm)OR 0.00227 mg/dscm 0.000482 mg/dscm
0.0040 grains per thousand dry standard cubic feet(gr/10'dscf)
Mercury 0.018 milligrams per dry standard cubic meter(mg/dscm)OR <0.000994 <0.000973 j
0.0079 grains per thousand dry standard cubic feet(gr/10 dscf) mg/dscm mg/dscm
Opacity 6%opacity(6-minute block average) 0% 0%
-_.-...._. ... .. ........ .. . ___.__._,.,.
'Limits based on 7%oxygen(dry basis) '.
Page 6 of 14

Pollatarit On _U
77
Limits based on a three-run average with a minimum sample time of one hour per ran,except for dioxins/furans which is based on a three-run average with a
minimum sample time of four hours per run
The facility shall also comply with the calculated emission limits listed in Section 2.I.A.La. of this permit for the following
pollutants: arsenic and its compounds,beryllium and its compounds,cadmium and its compounds, and chromium(VI)and its
compounds. The emission limits apply at all times.The facility appears to be in compliance.
Condition 2.1.A.2.c states that the test methods and procedures described in 15A NCAC 02D .2600,40 CFR Part 60 Appendix A,and
40 CFR Part 61 Appendix B shall be used to determine compliance with emission limits.All testing shall be conducted according to
the provisions of General Condition JJ. When determining compliance with emission limits for metals,Method 29 of 40 CFR Part 60
shall be used,except that SW 846 Method 0061 shall be used for chromium(VI). [Note: Currently,this condition wrongly states that
Method 29 shall be used for sampling chromium(VI).]As mentioned,the facility conducted source testing on the units from April 10-
11,2018,and the results of that test were approved by the DAQ-SSCB per the memo issued on June 4,2018.The facility will
complete repeat(every 3 years)testing on both units in CY202 1.The facility appears to be in compliance.
Conditions 2.1.A.2.d through 2 state that the facility shall conduct an initial performance test in order to determine compliance with
the emission limits in Section 2.1 A.2.a, and to establish maximum and minimum values for the following operating parameters for
each control device, as applicable: maximum charge rate; maximum flue gas/carbon bed inlet temperature; minimum secondary
chamber temperature; minimum pressure drop across the venturi scrubbers,or minimum amperage to wet scrubber; minimum venturi
scrubber liquor flow rate; minimum packed bed scrubber liquor pH;and minimum SNCR reagent flowrate.The facility may conduct
repeat performance tests at any time in order to establish new operating parameters. Upon receipt of an approved test that
demonstrates different operating parameters,the facility shall attach the approval memo containing the revised operating parameters to
this permit and maintain the parameters in the associated ranges contained therein. The facility may conduct a repeat performance test
within 30 days of violation of applicable operating parameter(s)to demonstrate that the affected facility is not in violation of the
applicable emissions limit(s). Repeat performance tests conducted pursuant to this paragraph shall be conducted using the identical
operating parameters that indicated a violation. The facility has not established any new operating parameters since the issuance of this
permit.Therefore,the operating parameters summarized under Section 2.I.A.2.n still apply.The facility appears to be in compliance.
Conditions 2.1.A.2.h through k state the requirements and frequency for emissions testing. The facility shall conduct annual
performance tests for the opacity limit and meet the requirements of 40 CFR 60.56c(b).For compliance with the PM and HCI
emissions limits,the facility shall start by testing annually. If three tests over a three-year period indicate compliance,then the facility
may test for PM and HC1 once every three years(no more than 36 months from previous test). Annual tests shall be resumed if a test
results in non-compliance. For compliance with the mercury,cadmium, and lead emission limits,the facility shall test once every
three years(no more than 36 months from previous test). For each metals test,the facility shall track and record details for the waste
being burned and the material that may be carried over into the stack test period.Tracking shall include, at a minimum: a cross-
reference of the identity of the waste generator with the company's customer list(the identity information shall include the nature of
the business activity);the type of business waste;the total weight of each container;and the time the material entered the incinerator.
This information shall be summarized and submitted as part of the stack test report. The use of the bypass stack during a performance
test shall invalidate the performance test. During the inspection,the facility was testing both units for opacity. The facility is currently
on a 3-year cycle for testing both units,except that opacity testing is annual. The facility will complete repeat 3-year testing on both
units in CY2021.The waste tracking records from the test performed during this inspection will be submitted with the results of the
test due by May 9,2019.There was no use of the bypass stack during this performance test.The facility appears to be in compliance.
Conditions 2.1.A.2.1 and in state the types of materials allowed to be incinerated.The facility shall only incinerate waste that meets
one of the following requirements: hospital waste or medical/infectious waste,as defined by 40 CFR Part 60, Subpart Ec and 15A
NCAC 02D .1202; international garbage(USDA/APHIS);confidential documents generated in the health care industry; controlled
substances captured by law enforcement agencies; non-hazardous trace chemotherapeutic waste materials; or non-hazardous
pharmaceuticals. Dental waste, as defined in the DAQ approved waste management plan(See 2.I.A.2.bb), is not to be incinerated.
During the inspection, most of the labels on the waste boxes indicated that they were received from hospitals,health clinics, and
medical labs. None of the boxes were opened for verification, but it's presumed that the labeling is accurate. As mentioned under
section 2.I.A.Ld,the facility does not incinerate any dental waste. The facility appears to be in compliance.
Page 7 of 14

Condition 2.I.A.2.n states that the facility shall ensure that all operating parameters remain within the acceptable range as measured
on a 3-hour rolling average,following the date on which the maximum and minimum operating parameters are established. Operation
outside of acceptable ranges shall constitute a violation of established operating parameter(s),except that operating parameter limits
do not apply during performance tests or during periods of startup and shutdown when no waste is being charged. The following table
summarizes the most current operating parameters and those observed during the inspection. During the inspection, Mr. Skrzypczak
stated that the facility has an electronic control system with interlocks that prevents charging of the units if the operating parameters
are not met.The facility appears to be in compliance.
ES01 ES02
iJper tmg)�afameter _ T2$ 4/10 11/18 4/4/14 T25 4/10 11118 4/9/]9.{; (iSsod on 3 hr rollirragry
_ .
.,.. ., I ,�) )# . curet hest, 1u p€ctron [ .. tmit Snureelest Inspcetion ,
�— Max.charge rate(lbs hr) i 1,87o.0 1,704.3 1,707.7 1,870.0 1,704.7 — 1,703.8
Min.pressure drop across venturi scrubber 39.0� r 44.2 44.7 f 38.9 42.4 41.6
(in. W.C•) .. ___�_
_
Min. secondary chamber temperature(°F) 1762.8 C 1 951.2 ( 1 959.5 � 1,759.5 ( 2,008.10 � 2 051.8
.. . .uri -.-. ... . _--- ---- . ._ __ - _.__: _..... ........
Mm, venturi scrubber liquor flow rate(gpm) 'r 65.2 '[ 73.9 r__ �74 0 �� fi5.7.__...`_. 72 6 I 71.0
— km packed bed scrubber liquor pH F-4.10 4.6 F 5.51 4.10 4.5 _ 5.88
_....___...___--____-_..m_____- __ .__ _ ._ —_---- -----._--,..—....._.
I Max. flue gas/carbon bed inlet temp. ff) i 168.1 —�153.5 146.1 164.1 153.1 161.4
Min. SNCR flow rate for urea(gph) I.] 1.2
Min. SNCR flow rate for ammonia(gph) 1.0 - r 1.2 l 2 1.0 1.2 1.2
Condition 2.1.A.2.o states that the scenarios summarized in the following table shall constitute a violation of an emission limit(each
parameter is measured on a 3-hour rolling average). During the inspection,there were no such incidents, and therefore no emissions
limit violations.The facility appears to be in compliance.
-------- _ ...... _ _ _ ..... _. -------
_
Operating Scenario Emissions Limit Violation
Above maximum charge rate AND below minimum pressure drop across venturi scrubber PM
.........
Above maximum charge rate AND below minimum secondary chamber temperature CO
j Above maximum charge rate AND below minimum secondary chamber temperature
below minimum venturi scrubber liquor flow rate Dwxin furans
Above maximum charge rate AND below minimum packed bed scrubber liquor pH _ —r HCl — —
Above the maximum carbon bed inlet temperature AND above maximum charge rate 1 Hg
Uses bypass stack PM, dioxin/furan, HCI, Pb, Cd and Hg
. Above maximum charge rate AND below minimum secondary temperature AND below NOx
minimum reagent flow rate
Conditions 2.I.A.2.1)through r state the requirements and frequency for parameter monitoring. The facility shall install, calibrate(to
the manufacturer's specifications), maintain,and operate the following monitoring devices:
• Devices for monitoring the maximum and minimum parameters, listed in Section 2.1.A.2.n. such that these devices measure
and record values for those parameters at the frequencies listed in Table 3 to 40 CFR Part 60 Subpart Ec.
• A device or method for measuring the use of the bypass stacks,including date,time,and duration.
• A continuous temperature monitoring and recording system for temperature in the primary chamber of each affected HMIWI.
• A device to continuously measure the reagent flowrate to the SNCR and record the data at least once per minute.
• A continuous monitor for both oxygen and CO in order to determine proper operation of each HMI WL
The facility shall obtain monitoring data at all times during HMIWI operation except during periods of monitoring equipment
malfunction, calibration,or repair. At a minimum, valid monitoring data shall be obtained for 75%of the operating hours per day for
90%of the operating days per calendar quarter that the affected facility is combusting HMI W. All monitoring devices and associated
equipment used to show compliance with emission limits shall be subject to a Quality Assurance (QA)program which must include
Page 8 of 14

procedures and frequency of the following: calibrations; standards traceability;operational checks; maintenance; auditing;data
validation;and a schedule for implementing the QA program.The QA program must be submitted to and approved by the DAQ-
WSRO Regional Supervisor. As previously mentioned,the facility has a DAS for monitoring all required operating parameters and
use of the bypass stack. According to the semi-annual report received January 30,2019, for ESOI and ES02,the facility had 13.98 and
1.0 hours of inoperative monitor data, which represents 0.38 and 0.05%of the total operating time in CY2018,respectively. As this is
less than what is allowed,the facility appears to be in compliance.
Condition 2.1.A.2.s states that to assure compliance with the visible emissions limit,the facility shall observe the emission points of
each HMIWI for any visible emissions above normal once a day.The daily observation must be made for each day of the calendar
year period to ensure compliance with this requirement. The facility shall be allowed three days of absent observations per semi-
annual period.The observations must be maintained in a log on-site and include the dates,times,results,and any corrective actions.
During the inspection,the daily visible emissions observations log sheets for CY2018 and CY2019 were spot checked.The facility
keeps an annual calendar sheet and crosses off each day after the VE observation has been filed.All the days for CY2018,except
September 14-15,2018(closed/shutdown for Hurricane Florence)and December 25,2018(closed/shutdown for Christmas),were
crossed off on the calendar. There were no visible emissions observed during the inspection other than steam plumes.The facility
appears to be in compliance.
Condition 2.1.A.2.t states that the facility shall install a carbon monoxide continuous emissions monitoring system(CO CEMS)on
the exhaust stack of each incinerator. The CO CEMS shall be used to determine compliance with the CO emission limit using a 12-
hour block average. The CO CEMS shall be operated in accordance with the applicable procedures under appendices B and F of 40
CFR Part 60. When demonstrating compliance with the CO emission limit, the Permittee may substitute a CO CEMS for the annual
CO performance test and minimum secondary chamber temperature. Excess CO emission reports as measured by the CEM systems
must be submitted semi-annually. During the inspection,the CO CEMS were operating and the 3-hour averages for ESOI and ES02
were 1.84 and 0.41 ppmv,respectively,which is less than the 11 ppmv limit. According to the semi-annual CEM report received
January 30,2019, ESOI and ES02 had no instances of excess CO emissions. The CEM report was accepted by the DAQ-SSCB on
February 25,2019.The facility appears to be in compliance.
Conditions 2.1.A.2.0 through w state that the facility shall perform an annual inspection of each HMIWI. The inspection shall,at a
minimum,meet the requirements of 40 CFR 60.36e(a)(1)(i)through(xvii).Also,the facility shall perform an annual inspection of
each control device associated with each HMIWI.At a minimum,each control device must meet the following criteria(if applicable):
ensure proper calibration of thermocouples,sorbent feed systems,and any other monitoring equipment;and generally observe that the
equipment is maintained in good operating condition.Any necessary repairs found during an inspection of a HMIWI or control device
shall be completed within 10 operating days of the inspection unless the owner or operator submits a written request to the Director for
an extension of the 10 operating day period. According to the facility's records,ESOI and all associated controls were annually
inspected on May 18,2018, and ES02 and all associated controls were annually inspected on June 8,2018. During these shut downs,
the facility thoroughly inspects the incinerators and performs any required annual maintenance on the packed bed scrubbers(CDOI
and CD02), venturi scrubbers (CD03 and CD04),and the selective non-catalytic reduction (SNCR)systems(CD07 and CD08). All
maintenance was performed in a timely manner. Further discussion about the carbon beds(CD05 and CD06) is in the following
section. The facility appears to be in compliance.
Conditions 2.1.A.2.x through as state the carbon bed requirements. The carbon beds(CD05 and CD06), used for the control of
mercury(Hg)emissions, shall be designed and operated with two beds in series,with the second bed serving as a guard bed. While
operating the carbon beds,the facility shall replace the carbon in each bed before it has reached the end of its useful life.For the
replacement of carbon in the primary bed,the secondary bed will be rotated into the primary bed position and the new carbon will be
used in the secondary bed position. In addition,the facility shall use the type of activated carbon used during the most recent
performance test demonstrating compliance with the Hg emission limit until a subsequent performance test is conducted.The facility
may substitute at any time a different brand of activated carbon,if the replacement has equivalent or improved properties compared to
the carbon used in the most recent performance test. The facility shall monitor the performance of the carbon beds in each system to
ensure that the carbon in each bed has not reached the end of its useful life.The monitoring shall be conducted consistent with the
manufacturer's specifications and recommendations. The facility shall document the monitoring procedures used and keep records of
any performance monitoring. According to the records,the carbon in CD05 and CD06 was charged on January 8, 2018 and February
8,2018,respectively.The facility plans to recharge the carbon in January-February 2020 for both units. Both contain Calgon carbon,
which was considered an equivalent replacement for Jacobi carbon. When the carbon is first charged, it is washed every 3-4 weeks to
increase its useful life. When the carbon is close to the end of its useful life,washing may occur as frequently as every 3-4 days.
Currently,the facility is washing the carbon about every 10 days. The facility performs quarterly checks of the carbon beds to ensure
Page 9 of 14

breakthrough has not occurred.This was last done on January 15,2019 and March 11,2019 for CD05 and CD06,respectively. The
facility appears to be in compliance.
Condition 2.1.A.2.bb states that the facility shall,by January 30th of each calendar year,develop and submit to DAQ a waste
management plan that meets and follows the guidelines listed in 40 CFR 60.55c. The facility shall implement the approved waste
management plan in its entirety. In addition,the waste management plan shall address the management of dental waste.The last
annual report received on January 30,2019 contained the facility's waste management plan which was most recently revised on
November 11,2005. Pages 3-5 of the plan specifically address the management of dental waste. The facility appears to be in
compliance.
Condition 2.1.A.2.cc states that the facility shall comply with 15A NCAC 02D .0535 "Excess Emissions Reporting and
Malfunctions". Emissions from bypass conditions shall not be exempted by 15A NCAC 02D.0535(c)or(g). Rule 2D .0535 requires
the facility to notify the DAQ of any source causing an excess of emissions lasting more than four hours and that results from a
malfunction,a breakdown of process or control equipment,or any other abnormal conditions.According to the semi-annual report
received January 30,2019,ES01 and ES02 had 8.0 and 0.0 hours of excess emissions,respectively,in CY2018.The excess emissions
from ESO1 occurred during a bypass stack opening,and therefore not exempt as previously mentioned. The facility was issued a
NOV/NRE on May 18,2018.Further details are contained in the Compliance History section of this report.
Condition 2.I.A.2.dd states that the facility may operate a HMIWI using only combustion controls during periods of startup and
shutdown when no waste is being combusted.During such periods,the Permittee shall monitor and record the following: verify that
no waste is being combusted;the secondary chamber temperature;and the amount and type of fuel being combusted. The facility's
DAS monitors and records these parameters any time the HMIWI are in operation. Therefore, verifying compliance with this alternate
operating scenario is ensured. Based on the facility's operation records,the facility appears to be in compliance.
Condition 2.1.A.2.ee states that the facility shall not allow a HMIWI to operate at any time unless a fully trained and qualified
HMIWI operator is accessible,either at the facility or available within one hour. The trained and qualified HMIWI operator may
operate the HMIWI directly or be the direct supervisor of one or more HMIWI operators. Operator training and qualification shall be
obtained by completing the requirements of 40 CFR 60.53c(c)through(g).The facility shall maintain, all items required by 40 CFR
60.53c(h)(1)through(h)(l0).The facility shall establish a program for reviewing this information annually with each HMIWI
operator.This information shall be kept in location readily accessible for all HMIWI operators. During the inspection,training
materials,required documents,and names of the operators were reviewed and found to be complete. Refresher training was last
conducted at the facility on January 28-30,2019.The prior refresher training was conducted on November 1-3,2017.As no refresher
training took place in CY2018,the facility was issued a NOD on February 19,2019.Further details are contained in the Compliance
History section of this report.
Conditions 2.1.A.2.ff and Qe state the recordkeeping requirements for the facility. The records shall be kept for a period of at least
five years and maintained on-site to be made available to an authorized representative upon request. All required records were
reviewed and found to be complete. All records have been discussed in previous sections of this report. The facility appears to be in
compliance.
Conditions 2.1.A.2.hh and ii state the reporting requirements for the facility. The facility shall submit a semi-annual summary report
of monitoring and recordkeeping activities postmarked on or before January 30 and July 30 of each calendar year for the preceding
24-month period. All instances of deviations from the requirements of this permit must be clearly identified. The report shall include:
• The values for the site-specific operating parameters;
• The highest maximum operating parameter and the lowest minimum operating parameter,as applicable, for each operating
parameter recorded for the calendar year being reported and for the previous calendar year;
• If a performance test was conducted during the reporting period,the results of the test shall be included;
• Dates where monitoring data was not collected, indicated exceedances,or indicated a malfunction;and
• If no exceedances or malfunctions occurred during the calendar year being reported,a statement to that effect shall be
included in the report.
As previously mentioned,the last semi-annual report was received on January 30,2019 and contained all the necessary elements. The
facility appears to be in compliance.
Condition 2.1.A.3 states that the HMIWI units(ES01 and ES02)are subject to 40 CFR Part 62, Subpart HHH"Federal Plan
Requirements for Hospital/Medical/Infectious Waste Incinerators Constructed On/Or Before December 1,2008."The facility shall
Page 10 of 14

comply with all applicable requirements of this subpart, and is currently doing so by complying with Conditions 2.1.A.1 and 2.I.A.2.
The facility appears to be in compliance.
B. One diesel fuel-fired emergency generator(ID No. EGI)
Condition 2.1.B.1 contains the requirements for 2D .0516 which requires the facility to limit sulfur dioxide emissions from
combustion sources, such as the emergency generator(EGI). The sulfur dioxide emissions should not exceed 2.3 pounds per million
Btu input. Diesel fuel will produce 0.29 pounds of SO2 per million Btu based upon an emission factor found in AP-42 (Table 3.3-1).
The facility appears to be in compliance.
Condition 2.1.B.2. contains the requirements for 2D .0521 which requires the facility to control the visible emissions from any
emission source that may be discharged from vents or stacks. The emergency generator (EGI) was manufactured after July 1, 1971.
Therefore, the visible emissions from the generator are not to exceed 20 percent opacity when averaged over a six-minute period. The
generator was not operating during the inspection, so no visible emissions could be detected. If the generator operates according to
manufacturer specifications, it will likely be in compliance.
Condition 2.1.13.3 contains the requirements for 2D .0524 which involves the New Source Performance Standards (NSPS) federal
regulations promulgated by the EPA. The facility's diesel fuel-Fred emergency generator(EGI) is subject to 40 CFR Part 60, Subpart
1111 for"Stationary Compression Ignition Internal Combustion Engines" as it was constructed after July 11, 2005, and manufactured
after April 1, 2006. The generator is a certified engine according to the procedures of this subpart as verified during the inspection via
a sticker on the engine. The emission limits for the generator are 6.4 g/kW-hr of NOx+NMHC, 3.5 g/kW-hr of CO, and 0.20 g/kW-hr
of PM emissions. The exhaust opacity is limited to 20%during the acceleration mode, 15%during the lugging mode,and 50% during
the peaks in either the acceleration or lugging modes. The diesel fuel is limited to a maximum sulfur content of 15 ppm (0.0015%)and
a minimum cetane index of 40 or a maximum aromatic content of 35% volume. To comply, the facility must purchase a certified
engine and operate and maintain it according to manufacturer specifications. The engine must be fitted with a non-resettable hour
meter. Operation for maintenance checks and readiness testing is limited to 100 hours per year. Operation in non-emergency situations
is allowed up to 50 hours per year, but those 50 hours are counted towards the 100 hours per year provided for maintenance and
testing. There is no time limit on the use of emergency stationary ICE in emergency situations.
The facility is required to keep records of all maintenance conducted on the engine and documentation that the engine is certified. The
facility must also keep records of the hours of operation of the engine that is recorded through the non-resettable hour meter. The
owner or operator must document how many hours are spent for emergency operation including what classified the operation as
emergency and how many hours are spent for non-emergency operation. The facility is also required to submit semi-annual summary
reports of the monitoring and recordkeeping activities.
During the inspection, the diesel fuel-fired emergency generator (EGI) was not operating. It is a 500 kW Caterpillar model DCPXL
engine. The non-resettable hours meter was replaced on September 23,2016,and read 109.1 hours during the inspection. Before being
replaced, the old hour meter read 164.2 hours. Mr. Skrzypczak stated that the engine is tested twice per week for about 20 minutes.
The facility is using ultra low sulfur diesel fuel (ULSD) from Alamance Oil. The facility hires Carolina CAT to service the engine
quarterly. The engine was last fully serviced on March 28, 2019. The last semi-annual report was received on January 30, 2019.
According to that report, the engine ran a total of 51.5 hours in CY2018, with 23.1 hours attributed to maintenance and 28.4 hours
attributed to emergency use. The facility appears to be in compliance.
Condition 2.1.11.4 contains the requirements for 2D .I I II which involves the National Emissions Standards for Hazardous Air
Pollutants (NESHAP) federal regulations promulgated by the EPA. The facility is subject to 40 CFR Part 63, Subpart ZZZZ for
"Stationary Reciprocating Internal Combustion Engines"due to the diesel fuel-fired emergency generator(EGI). Per this rule,engines
are considered "existing" if construction commenced before June 12, 2006, and are considered "new" if construction commenced on
or after this date. EG I is considered a new source as it was constructed in July 2013 and is for emergency use only. The new engine
has no other requirements under Subpart ZZZZ, except to comply with the requirements of NSPS 40 CFR Part 60, Subpart 1111 (see
Condition 2.1.B.4 below).
2.2 —Multiple Emission Source(s)Specific Limitations and Conditions
A. Facility-wide emission sources
Page 11 of 14

Condition.2.2.A.1 contains the requirements for 2D.1806 which requires the facility to control and prevent odorous emissions from
causing or contributing to objectionable odors beyond the facility's boundary. If the DAQ Director determines that a source or facility
is emitting an objectionable odor,then the facility will have to implement maximum feasible controls.During the inspection,there
were not any objectionable odors encountered outdoors near the property boundaries.A review of the facility file showed that no
recent odor complaints have been received by this office.The facility appears to be in compliance.
2.3 —Permit Shield for Non-Applicable Requirements
Conditions 2.3.A and B state that the facility is shielded from the following nonapplicable requirements as of the date of issuance of
this permit based on information furnished with all previous applications. This shield does not apply to future modifications or
changes in the method of operation:
• 40 CFR Part 60,Subpart Cc does not apply to this facility because this rule is specifically excluded from applicability in 15A
NCAC 02D .0524.
• 40 CFR Part 60, Subpart Ec does not apply to this facility because the HMIWIs were constructed and/or modified before the
applicability date in 40 CFR 60.56c(a).
It should be noted that sections of 40 CFR Part 60, Subparts Cc and Ec are incorporated by reference under I5A NCAC 02D .1206
"Hospital,Medical, and Infectious Waste Incinerators."This permit shield does not exempt the Permittee from complying with all
aspects of 15A NCAC 02D.1206.The facility appears to be in compliance.
Section 3—General Conditions
Condition 3.P—This contains the requirements of 2Q.0508(n)which requires the facility to submit an Annual Compliance
Certification(ACC)to the DAQ and EPA postmarked on or before March I s'.The ACC should be certified by the responsible official
and address all federally-enforceable terms and conditions in the permit, including emissions limitations, standards,or work practices.
The DAQ-WSRO received the facility's CY2018 ACC report on January 30,2019. It was reviewed and accepted on February 7, 20I9,
by this inspector. The facility did experience deviations in CY20I8 that were summarized adequately. They are further summarized in
the"Compliance History"section of this report, below. The facility appears to be in compliance.
Condition 3.X—This contains the requirements of 2Q .0207 which requires the facility to submit an Emissions Inventory (EI)to the
DAQ by June 3011 each year. The EI must include each air pollutant listed in 2Q .0207(a)from each emission source within the facility
during the previous calendar year and be certified by the responsible official.The DAQ-WSRO received the facility's CY2017 EI on
April 30,2018. The EI was reviewed and accepted on September 14,2018,by this inspector.The facility appears to be in compliance.
Condition 3.MM—This contains the requirements for 2D .0540 which requires the facility to control any fugitive dust emissions that
may travel beyond the property boundary and cause a complaint.Upon review of the facility file,no recent fugitive dust complaints
have been received by this office.There was not any fugitive dust encountered during the inspection.The facility's entrance and
parking lot is unpaved,but covered with large gravel that minimizes fugitive dust. Trucks entering and exiting the property did not
cause any dust to go beyond the property boundary during this inspection. The facility appears to be in compliance.
NSPS/NESHAP/112(r)APPLICABILITY
The facility is subject to a New Source Performance Standard(NSPS)regulation. The facility is subject to 40 CFR Part 60, Subpart
1111"Stationary Spark Ignition Internal Combustion Engines"due to the diesel fuel-fired emergency generator(EG I)as discussed
under Condition 2.1.B.3 above.
The facility is not subject to 40 CFR Part 60, Subpart Cc"Emission Guidelines and Compliance Times for Hospital/Medical/
Infectious Waste Incinerators"nor Subpart Ec"Standards of Performance for New Stationary Sources: Hospital/Medical/Infectious
Waste Incinerators,"but only those parts incorporated by reference in 2D.1206 as discussed under Conditions 2.3.A and B above.
The facility is not subject to 40 CFR Part 61, Subpart FF as it is not a chemical manufacturing plant,coke by-product recovery plant,
or petroleum refinery.
The facility is subject to 40 CFR Part 62, Subpart HHH"Federal Plan Requirements for Hospital/Medical/Infectious Waste
Incinerators Constructed on or Before December I,2008"as discussed under Condition 2.I.A.3 above.
Page 12 of 14

The facility is subject to a National Emissions Standards for Hazardous Air Pollutants(NESHAP)regulation.The facility is subject to
40 CFR Part 63, Subpart ZZZZ"Stationary Reciprocating Internal Combustion Engines" due to the diesel fuel-fired emergency
generator(EG 1)as discussed under Condition 2.LBA above.
The facility is not subject to 40 CFR Part 63, Subpart Q as the cooling towers are not operated with chromium-based water treatment
chemicals.The facility is not subject to 40 CFR Part 63, Subpart DD as the facility is not a major source of hazardous air pollutant
(HAP)emissions. The facility is not subject to 40 CFR Part 63, Subpart EEE as ESOI and ES02 are not hazardous waste incinerators.
The facility does not use, store,or manufacture any of the regulated substances in quantities above the thresholds for the Section
112(r)program involving Risk Management Practice(RMP)requirements. They are only subject to the General Duty requirements
contained in the General Condition.
FACILITY EMISSIONS
The following table summarizes the facility wide actual emissions. The actual emissions are from the CY2016 and CY2017 emissions
inventories that were submitted by the facility.
CY2016 ActgafEmissions, CY1017 ,ptua)Emissidn$,
Pollutant (
tonsly an Cpri"ear
PM 1.04 1.00 -3 8
-----------
_----.. - -- -- —� 0.82 F 0.80 I -2.4
�_PMzs 7I 0.56 0.54
SOz 0.23 -_...-.- . 0.23 ( .. . O0
----._,.._ _. ... -- - - -----. _ _ - --- .. . ....-
NOx 21,67 w 21.35 — r_____ -1.5
- CO 0.50 - 0.50 0.0
VOC 0.87 0.85 -2.3
HAPrm„i 0.049 0.047 -4.1
HAPH,Fhnt(HCI) 0.029 0.028 -3.4
PERMIT CONSIDERATIONS
Condition 2.1.A.2.c incorrectly states that Method 29 shall be used for sampling chromium(VI). Instead, SW 846 Method 0061 shall
be used for chromium(VI).
COMPLIANCE HISTORY (LAST 5 YEARS)
February 19,2019-The facility received a Notice of Deficiency(NOD)due to the facility failing to perform HMIWI operator
training in CY2018. This was a deficiency of 2D .1206 as referenced in Condition 2.1.A.2.ee of Air Quality Permit 05896/T25. A
response was received on May 6,2019,and indicated that the training was done on January 28-30,2019.The training will be
performed in the first quarter,rather than the fourth quarter,of each year going forward.
May 18,2018-The facility received a Notice of Violation and Notice of Recommendation for Enforcement(NOV/NRE)due to the
facility experiencing an event on April 15, 2018, with a duration of eight hours during which the control system ESOI was bypassed.
The event was the result of a programable logic controller(PLC) fault indicating an invalid rack configuration error code failure,thus
removing control power to the HMI W I.The bypass stack events were violations of 2D .1206 as referenced by Condition 2.LA.2.o of
Air Quality Permit 05896T25. A written response letter was received by the WSRO on June 4, 2018. Per enforcement case No. 2018-
025,the facility was assessed a civil penalty of$5,256,which was paid in full on September 6,2018.
November 8,2017-The facility received a NOV/NRE due to the facility experiencing four discrete events on September 10,22,26,
and October 7,2017,with durations of 14, 10,2, and 3 minutes,respectively,during which the control system for one of the HMIWls
was bypassed. The first and fourth event involved ES02,and the second and third events involved ESO1. The first three events were
the result of failures of the uninterruptible power supply(UPS)unit,thus removing control power to the HMI WI.The last event was
Page 13 of 14

the result of frayed wires causing a short,thus removing control power to the HMIWI.The bypass stack events were violations of 2D
.1206 as referenced by Condition 2.1.A.2.o of Air Quality Permit 05896T25.A written response letter was received by the WSRO on
November 21,2017.Per enforcement case No.2017-066,the facility was assessed a civil penalty of$20,249,which was paid in full
on May 2,2018.
April 21,2017-The facility received a NOVNRE due to the facility experiencing two events(one on February 21,2017 with a 5-
minute duration involving ES02 and one on February 26,2017 with an 8-hour duration involving ESO1)in which the HMIWI control
systems were bypassed. The two bypass stack events were violations of 2D.1206 as referenced by Condition 2.1.A.2.o of Air Quality
Permit 05896T25.The facility preemptively responded to this NOVNRE with a letter received on March 31,2017. Per enforcement
case No. 2017-025,the facility was assessed a civil penalty of$2,747, which was paid in full on August 15, 2017.
October 24,2016-The facility received a NOWNRE after the facility experienced an event on September 26,2016 with a duration of
thirteen minutes during which the control system for ES02 was bypassed due to operator error of the incinerator control panel. This
was a violation of NSPS 40 CFR Part 60, Subpart Ec and 2D.1206 as referenced by Condition 2.I.A.1.bA of Air Quality Permit
05896/T24.A response was received on November 17,2016,detailing that the facility has retrained their operators on the use of the
bypass stack and has installed a plastic cover to the bypass stack control button.Per enforcement case No.2017-001,the facility was
assessed a civil penalty of$5,208,which was paid in full on April 11,2017.
November 2,2015-The facility received a Notice of Violation(NOV)after the facility experienced five events comprising a total
duration of fourteen minutes during which the HMIWI control system on ES01 was bypassed due to a discontented employee
tampering with the control panel on September 16-17,2015.This was a violation of Air Quality Permit 05896/T23, Condition
2.I.A.l.bA for 2D .1206 and NSPS Subpart Ec. The facility responded on November 16,2015,with a plan regarding training of
employees to ensure this type of violation does not reoccur.
July 10,2015-The facility received a Notice of Deficiency(NOD)for a late submittal of the CY2014 Emissions Inventory, including
certification page and supporting calculations, as required by Air Quality Permit 05869/T22,Condition 3.X. This documentation was
due on June 30, 2015,and was ultimately received on July 7, 2015.
February 18,2015-The facility received a NOV due to the discovery(by Hilary King, former DAQ-WSRO Environmental Engineer,
during his compliance inspection on February 3,2015)that the ammonia tank that supplies the SNCR units(CD07 and CD08)with
reagent ran dry during incinerator operation for approximately one hour on December 12,2014. This is a violation of Air Quality
Permit 05896/T22,Condition 2.I.A.1.The facility responded on March 13,2015,with a plan of procedural changes to ensure this type
of violation does not reoccur.
CONCLUSION
Stericycle, Inc.appears to be operating in compliance with all appropriate regulations based upon the visual observations and the
DAQ records at the time of this inspection.
Page 14 of 14