AQ_F_0100010_20170628_ST_RvwMemo (4)

DIVISION OF AIR QUALITY
June 28,2017
MEMORANDUM
To: Lisa Edwards,P.E.,Winston Salem Regional Office
From: Brent W.Hall, Stationary Source Compliance Branch(SSCB)
'At-
Subj ect: Stericycle, Inc.
Haw River,Alamance County,North Carolina
Air Permit No.05896T25,Facility ID 0100010
Visible Emissions Testing of ESO1 and ES02
Lead(Pb) and Cadmium(Cd)Testing of ES01
Performed April 18,2017 by TRC Environmental Corporation(TRC)
DAQ Tracking No. 2017-106ST
TRC performed EPA Method 29 for Pb and Cd emissions from ESO1 and EPA Method 9 visible
emissions testing for ES01 and ES02. The test results indicate compliance with the applicable limits.
ES01 and ES02 are two dual chamber,natural gas-fired hospital,medical,and infectious waste
incinerators. Each incinerator is controlled respectively in series by: selective non-catalytic reduction
(SNCR)system with ammonia or urea injection(ID No. CD07 and CD08),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).
15A NCAC 2D .1100 Control of Toxic Air Pollutants, 15A NCAC 2D .1206 Hospital,Medical and
Infectious Waste Incinerators, and 40 CFR 62 Subpart HHH Federal Plan Requirements for
Hospital/Medical/Infectious Incinerators Constructed on or Before June 20, 1996 apply. 2D .1100 limits
cadmium to 63.91 pounds per year(lb/yr)for both incinerators combined. 2D .1206 limits the lead to
0.036 milligrams per dry standard cubic meter corrected to 7%02(mg/dscm@7%02)and the
concentration of cadmium to 0.0092 mg/dscm@7%02. The table below presents ES01 lead and
cadmium test results.
ESO1 —EPA Method 29 Emissions Test Results
Pollutant Emissions Emission Limit Regulation Compliance
0.0179 mg/dscm @ 7%02 0.036 mg/dscm @ 7%02 2D .1206 Yes
Lead(Pb) 0.000215 lb/hr --- --- ---
1.881b/)72
0.00313 mg/dscm @ 7%02 0.0092 mg/dscm @ 7%02 2D .1206 Yes
Cadmium'(Cd) 0.0000381b/hr --- --- ---
0.33 lb/yr2 63.91 1b/yr3 2D .1100 Yes
' Results presented in this memorandum differ from the reported test results which included the"back half'
minimum detection limit(MDL)value to calculate the cadmium results. The value presented above is calculated
based on the detected front half catch weight in the lab report.
2 Mass emission rate for ES01 only;assuming 24-hr operation
s Emission limit is for ESO1 and ES02 combined

Section 2.1.A.2.a. of the permit states that the incinerators"shall not allow ...gases that exhibit greater
than 6% opacity." Visible emissions results for both incinerators are shown in the following table. The
results shown are the maximum six-minute block averages.
EPA Method 9 Visible Emissions Test Results
Source Test 1 Test 2 Test 3 Limit Compliance
ES01 1.5% 0.8% 0.6% 6.0% Yes
ES02 0.4% 0.4% 0.6% 6.0% Yes
The permit states the maximum charge rate for both incinerators is 1870.0 lb/hr. The maximum charge
rate during testing was 1705.0 lb/hr for ES01 and 1704.4 lb/hr for ES02. These charge rates are
acceptable. The lead and cadmium emission results are acceptable for ES01 and the visible emissions
results for ESO1 and ES02 are acceptable. If there are any questions regarding this review,please contact
me for further clarification at(919)707-8427 or Brent.Haligncdenngov.
Sincerely,
Brent W.Hall
Environmental Engineer
Division of Air Quality,NCDEQ
cc: Central Files,Alamance County
IBEAM Documents 01-00010