AQ_F_0100010_20180518_CMPL_NOV-NRE (4)

ROY COOPER
In
`�' GouernoY
MIC.HAE:L S-REGAN
Secretary
Air Quality MI'CHAEL.:A. AB:RACZINSKAS:
'ENVIRONMENTAL QUALITY VirecCOr
May 18,2018
CERTIFIED MAIL NUMBER 7010 0780 0002 0107 0265
RETURN RECEIPT REQUESTED
Alan Skrzypczak
'Stericycle,Inc.
Post Office Box 310
Haw River,NC 27258
SUBJECT: Notice of Violation and Notice of Recommendation for Enforcement
Stericycle,Inc.
Haw River,North Carolina
Alamance County
04-0100010-Title V Air Permit No.05896T25
Dear Mr. Skrzypczak:
On April30,2018,this office received a letter from Don Nuss detailing an incident that occurred
at the above referenced facility.Per the correspondence,the facility experienced an event on April 15,
2018,with a duration of eight hours during which the control system for one of the hospital,medical,and
infectious waste incinerators(BA4M)(Emission Source ID No.ES01)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 BA4M.This bypass stack event is a violation of 15A NCAC
2D .1206"Hospital,Medical,and Infectious Waste Incinerators"as referenced by Condition 2.l.A.2.o of
Air Quality Permit 05896T25.Per 2D.1206(d)(4),the rule incorporates by reference 40 CFR 60.56c,part
of 40 CFR 60 Subpart Ec"Standards of Performance for New Stationary Sources:
Hospital/Medical/Infectious Waste Incinerators."Per 40 CFR 60.56c(f)(6),"Use of the bypass stack shall
constitute a violation of the PM, dioxin/furan, HCI, Pb, Cd and Hg emission limits."
This facility previously received a Notice of Violation and Notice of Recommendation for
Enforcement(NOV/NRE),dated November 8,2017,for use of the bypass stack detailed in letters
received by this office on October 3 and November 1,2017.According to that correspondence,the
facility experienced 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'HMIWI control system was bypassed.The first
and fourth event involved ES02,and the second and third events involved ESOL The first three events
were the result of failures of the uninterruptible power'supply(UPS)unit,thus removing control power to
the HMIWI. The last event was the result of frayed wires causing a short,thus removing control power to
the HMIWI.
This facility also previously received a NOV/NRE,dated April 21,2017,for use of the bypass
stack detailed in a letter received by this office on March 31,2017.According to that correspondence,on
February 21,2017,the facility experienced an event with a duration of five minutes during which the
HMIWI control system for ES02 was bypassed due to an upset in the chamber,which caused positive
pressure.Then,the facility experienced another event on February 26,2017 with a duration of
approximately eight hours during which the HMIWI control system for ESO1 was bypassed due to power
State oF,North Car611na{:Environmental.Quality.I Air Quality
Winsf6n=SaletnRegionalOffice 1 450'WdstElaiies Mill Road;Suite300 J'Winston-Salem}NorthCaebiina27105
336 776 980 0 T f 336 776 9797 F

Mr.Alan Skrzypczak
May 18,2018
Page 2
_ failure caused by melted wires in a power panel that led to the ash hoe motor. In the March 31,2017
correspondance, it was detailed that use of the bypass stack during a malfunction is critical to protecting
the safety of the employees and integrity of the equipment.
This facility also previously received a NOWNRE,dated October 24,2016.for use of the bypass
stack detailed in a letter received by this office on October 18,2016.According to that correspondence,
on September 26,2016,the facility experienced an event with a duration of thirteen minutes during which
the IIMIWI control system for ES02 was bypassed due to operator error of the incinerator control panel.
In the response received by this office on November 17,2016,it was detailed 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.
This facility also previously received a NOV,dated November 2,2015,for use of the bypass
stack detailed in a letter received by this office on September 30,2015.According to that correspondence,
on September 16 and 17,2015,the facility experienced five events comprising a total duration of fourteen
minutes during which the HMIWI control system for ESO 1 was bypassed due to.a discontented employee
tampering with the control panel. In the response received by this office on November 25,2015,it was
detailed that this employee was terminated and other employees would be trained on the incinerator
control panel.
Each day that you continue to operate in violation of.15A NCAC 2D .,1206 may constitute an
additional violation. Each violation is subject to enforcement action,including a civil penalty of up to
$25,000 and/or injunctive relief,pursuant to North Carolina General Statute(NCGS) 143-21.5.114A or
permit revocation as authorized by NCGS 143-215.108(b)(3).L You may wish to contact the Division of
Environmental Assistance and Outreach at 1-877-623-6748 if you need assistance.
We have prepared a report detailing this violation and intend to forward it to the Division of Air
Quality staff in Raleigh. The report concludes with a recommendation by this office for enforcement
action for the violation of 15A NCAC 2D .1206. If you wish to present an explanation for the cited
violation or if you believe there are other factors which should be considered,please send the information
to me in writing within 10 days following receipt of this letter. The information will be reviewed and,if
an enforcement action is still deemed appropriate,your explanation will be forwarded to the Director with
the enforcement package for his consideration.
Please contact Taylor Hartsfield or me if you have any questions.
Sincerely,
vwv �
Lisa Edwards,P.E.,Regional Supervisor
Division of Air Quality,NCDEQ
c: WSRO county file
WSRO enforcement file