AQ_F_0100010_20180316_ST_ProtRvw (4)

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
Air Quality MICHAEL A. ABRACZINSKAS
ENVIRONMENTAL QUALITY Director
March 16,2018
Mr.Alan Skrzypczak,Plant Manager
Stericycle,Inc.
P.O.Box 310
Haw River,NC 27258-0310
Subject: Stericycle,Inc.,Facility ID 0100010,Tracking No. 2018-044ST
Haw River,Alamance County,North Carolina,Air Permit No. 05896T25
Emissions Compliance Testing of Two Dual Chamber Hospital,Medical,and Infectious
Waste Incinerator Emission Sources ID No.ESO1 and ES02
Proposed Test Dates: Week of April 9,2018
To be performed by TRC Environmental Corporation
Dear Mr. Skrzypczak:
The emissions test protocol for the two subject sources has been reviewed. Incinerators ES01 and ES02
each controlled respectively in series by: selective non-catalytic reduction(SNCR) system with ammonia
or urea injection ID No. CD07 and CDO8,packed bed scrubber and associated quench column ID No.
CDO1 and CD02,with Venturi scrubber ID No. CD03 and CD04,and sulfur impregnated carbon bed ID
No. CD05 and CD06. Incinerators ESO1 and ES02 are subject to 15A NCAC 2D.1206 Hospital,Medical
and Infectious Waste Incinerators; 15A NCAC 2D .1100 Control of Toxic Air Pollutants;40 CFR 60
Subpart Ce Emission Guidelines and Compliance Times for Hospital/Medical/Infectious Incinerators;
40 CFR 60 Subpart Ec Standards of Performancefor Hospital/Medical/Infectious Incinerators for Which
Construction is Commenced After June 20, 1996; and 40 CFR 62 Subpart HHH Federal Plan
Requirements for Hospital/Medical/Infectious Incinerators Constructed on or Before June 20, 1996. The
following table lists the pollutants and acceptable test methods for each incinerator to be tested.
Incinerator ES01 and ES02-Pollutants and Test Methods
Source To Be Tested Pollutant EPA Method Rum Time Notes
Oxygen and Carbon Dioxide 3A 3 runs,60-120 minutes Concurrent with 5/29,
each 26A
ES01 Filterable Particulate,
and Cadmium(Cd),Lead(Pb), 5/29 3 runs, 120 minutes each
ES02 Mercury(Hg)
Visible Emissions 9 3 runs,60 minutes each
Hydrogen Chloride(HCl) 26A 3 runs,60 minutes each
The tester must verify the absence of cyclonic flow as described in Section 11.4 of EPA Method 1.
TRC shall perform a pre-test analysis of the filter blank, following the procedure in EPA Method 29
section 7.2.1. Stericycle must submit to the Division of Air Quality(DAQ)the pretest filter blank
analysis values for each target metal prior to testing. DAQ will not allow any correction to the test results
above the maximum blank correction as specified in EPA Method 29. TRC will also prepare duplicate
Method 29 field blanks for potential analyses by DAQ.
State of North Carolina I Environmental Quality I Air Quality
217 W.Jones Street 11641 Mail Service Center I Raleigh.North Carolina 27699 1641
919 707 8400

Mr. Alan Skrzypczak-Plant Manager
March 16,2018
Page 2(Stericycle,Inc.—Incinerator ESO1 and ES02—April 2018 Emissions Compliance Testing)
Note that audits sample analyses are required for Methods 26A and 29. TRC has submitted an audit
sample order request. The sample must be present for inspection on request during the test period. For
additional information please see this EPA web page htip://www.epa.gov/emc/emc-technical-support.
Please note that the detection limits for some of the proposed methods are based on actual source
parameters. No estimated detection limits are listed in the protocol. Therefore,the responsibility will
remain with Stericycle and the tester to ensure that the minimum method detection limits will be low
enough to demonstrate compliance with the applicable emissions limits. The result cannot be reported as
zero. The result must be reported as less than the method detection limit determined from the test.
Permit condition 2.1.A.La,limits the total combined emissions from both incinerators. Thus, Stericycle
has proposed to test both units for comparison with the condition 2.1.A.La toxic emission limits.
The test protocol is approved as represented in the table. Stericycle shall be responsible for ensuring,
within the limits of practicality,that each subject incinerator being tested is operated at or near the
maximum normal waste charge rate(i.e., at or above approximately 90%of the maximum). The
maximum normal waste charge rate for each incinerator is 1,870 pounds per hour. Thus,the proposed
test period waste charge rate of 1,710 pounds per hour is acceptable. The final report must include the
applicable test period monitored parameters data(i.e.,incinerator hourly waste charge rate and secondary
chamber temperature)and the control system parameters data(i.e., flue gas temperature, secondary
chamber temperature,NO.reagent injection rate,pressure drop across scrubbers, scrubber liquor flow
rates, scrubber pH and the bypass stack position). The parametric data shall be based on a 3-hour rolling
average calculated each hour as the average of the previous 3 operating hours.
Approval of the proposed methods does not exempt the tester,in any way, from the minimum
requirements of the applicable test methods. Any deviations from the applicable methodologies not
specifically addressed in this letter remains subject to the approval of the Division of Air Quality. If there
are questions concerning this matter,please contact me at(919)707-8415 or greg .o, nealAncdenr.gov.
Sincerely,
l
Thomas G. O`Neal,III,P.E.,Environmental Engineer
Division of Air Quality,NCDEQ
cc: Derek Brewster,TRC Environmental Corporation,-Raleigh,NC
Lisa Edwards,P.E.,Winston-Salem Regional Office
Central Files,Alamance County
IBEAM Documents-0100010