AQ_F_0100010_20150618_CEM_GenCorr

Alamance County
Division of Air Quality
June 18, 2015
MEMORANDUM
To: William D. Willets, P.E., Chief, Permitting Section
From: Alan Drake, Stationary Source Compliance Branch (SSC
Through: Michael Pjetraj, Supervisor, SSCB
Subject: Suggested Administrative Corrections to Air Pen-nit No. 05896T22
Stericycle, Inc. —Haw River Facility
Haw River, Alamance County, North Carolina
Facility ID#0100010
Due to a recent enforcement-related matter involving the facility, SSCB believes that several
conditions in the permit should be updated administratively for accuracy:
1. Specific Condition 2.1.A.Lc of the permit currently exempts the facility from meeting the
emission limits during periods of startup,shutdown or malfunction(SSM). The condition
probably refers to a pre-2009 version of 40 CFR 60.56c, which provides an SSM
exemption. The current version of 60.56c states that"operating parameters" not
"emission limits" are applicable at all times except during SSM. Emission limits apply at
all times and should not be exempted by SSM.
2. Specific Condition 2.1.A.Le of the pen-nit implies that the source is subject to new source
perfonnance standard (NSPS) Ec. In fact, paragraph (4) of this condition states that"the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524." This is not an
Ec source; therefore, the 2D .0524 noncompliance references should be removed.
3. Specific Condition 2.1.A.1.e.5 of the permit requires monitoring per 60.57c(a) and then
provides an exception during periods of startup and shutdown. This exception is no
longer found in 60.57c(a).
4. Specific Condition 2.1.A.Lh of the permit implies the source is subject to NSPS Ec and
twice indicates "noncompliance with 15A NCAC 2D .0524." This is not an Ec source;
therefore, the 2D .0524 noncompliance references should be removed.
5. Specific Condition 2.1.A.Li of the pen-nit implies the existing source is subject to the
emission guidelines (EG) of 40 CFR Part 60 Subpart Ce and indicates"noncompliance
with NSPS Ce." DAQ does not have an EPA-approved EG Ce program; therefore, the
noncompliance reference should be removed.
6. Specific Condition 2.1.A.2 of the permit refers to Subpart HHH as an NSPS. The section
should be labeled "FEDERAL-ENFORCEABLE ONLY" and replace "NSPS"with "40
CFR Part 62."
If you should have any questions,please contact me at [phone] or alan.drake*ncdenr.gov.