AQ_F_0100010_20171108_CMPL_NOV-NRE (4)

ROY COOPER
i Governor
MICHAEL S. REGAN
_. secretary
Air Quality MICHAEL A. A.BRACZINSKAS
ENVIRONMENTAL QUALITY Director
November 8,2017
CERTIFIED MAIL NUMBER 7010 0780 0002 0109 7125
RETURN RECEIPT REQUESTED
Alan Skrzypezak
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 October 3 and November 1,2017,this office received letters from Don Nuss detailing several
incidents that occurred at the above referenced facility.Per the 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 control system for one of the hospital,medical,and infectious
waste incinerators(HMIWI)was bypassed. The first and fourth event involved Emission Source ID No.
ES02, and the second and third events involved Emission Source ID No. ES01. 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. All four bypass stack events are violations of 15A NCAC 2D.1206"Hospital,Medical,and
Infectious Waste Incinerators"as referenced by Condition 2.1.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 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 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.
State of North Carolina I Environmental Quality I Air Quality
Winston-Salem Regional Office 1 450 West Hanes Mill Road,Suite 300 1 Winston-Salem,North Carolina 27105
336 776 9800 T 1 336 776 9797 F

Mr.Alan Skrzypczak
November 8,2017
Page 2
This facility also previously received a NOV/NRE, 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 HMIWI 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 ESO1 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) 143-215.114A or
permit revocation as authorized by NCGS 143-215.108(b)(3). 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,
Lisa Edwards,P.E.,Regional Supervisor
Division of Air Quality,NCDEQ
c: WSRO county file
WSRO enforcement filer