AQ_F_0100010_20121212_CEM_RptRvwLtr

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RCDENR
North Carolina Department of Environment and Natural Resources
Division of Air Quality
Beverly Eaves Perdue Sheila C. Holman Dee Freeman
Governor Director Secretary
December 12, 2012
Mr. Alan Skrzypczak
Facility Manager
Stericycle,Inc.
Post Office Box 310
Haw River,North Carolina 27258
SUBJECT: Review of 2012 CO/02 CEMS RATA
Stericycle, Inc.
Haw River, Alamance County,North Carolina
Facility ID# 0100010
Air Permit No. 05896T20
Dear Mr. Skrzypczak:
Thank you for the timely submittal of the subject report received,December 6, 2012, from
Stericycle, Inc. - Haw River. The Division of Air Quality(DAQ) has completed its review of the
relative accuracy test audit(RATA) conducted by Custom Stack Analysis, LLC. Testing was
conducted on both of Stericycle's hospital,medical and infectious waste incinerators (HMIWI
ESO 1 and ES02) on October 23-24, 2012. The results reported for the carbon monoxide (CO)
continuous emission monitoring systems(CEMS) and oxygen(02)diluent monitors are
summarized below.
Emission Source Analyzer Relative Accuracy
ESO1 CO 1.24 ppmv*
02 14.79%
ES02 CO 1.43 ppmv*
02 18.92% -
*Alternative demonstration: RA<5 ppmv when the RA is calculated as absolute average difference
between reference method and source's CEMS plus 2.5 percent confidence coefficient.
Based on our review, we offer the following comments:
1. Test results from the RATA indicate all CO and 02 analyzers appear to have met the relative
accuracy requirements set forth in Performance Specifications(PS) 4A & 3, which are found
in 40 CFR Part 60, Appendix B.
Technical Services Section
1641 Mail Service Center,Raleigh,North Carolina 27699-1641 One
217 West Jones Street,Raleigh,NC 27603 NorthCarohna
Phone: [phone]/FAX [phone]/Internet: www.ncair.org )Vatmally
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Mr. Alan Skrzypczak
December 12, 2012
Page 2
2. 40 CFR Part 60, Appendix F (permit specific condition 2.1.A.l.h.) requires that quarterly
audits must be conducted, with a RATA being conducted at least once every four calendar
quarters. The next RATA for ESO 1 and ES02 should be completed by December 31,"2013.
Please ensure that the QA/QC requirements are met and complied with at all times. In
addition, please notify this office at least 45 days prior to performing the annual RATA so
that arrangements can be made to observe the test.
3. During our October 24, 2012, facility visit, you indicated that Stericycle was testing a like-
kind (i.e., same manufacturer and model number as primary monitor) backup CO CEMS for
possible use on ESO1 and ES02. You requested DAQ approval to use the backup analyzer as
a replacement monitor in the event one of the primary monitors failed. DAQ has considered
your request and will consider data obtained from backup CO CEMS (Mfg/model: Thermo
Scientific/48i; Serial#: CM 09080034) to be valid provided the following conditions are met:
a. Daily calibration drift test. Consistent with PS-4A, the CEMS calibration must not drift or
deviate from the reference value of the calibration gas by more than 5 percent of the
established span value. This test should be conducted immediately after installing the
backup CO CEMS.
b. Linearity error test. This is a three-point gas audit using calibration gases in the following
ranges (as percent of analyzer span): low (20-30%), mid (50-60%) and high (80-100%).
The error in linearity for each calibration gas concentration (low-, mid-, and high levels)
shall not exceed or deviate from the reference value by more than 5.0 percent as calculated
by the equation: LE_ (JR-Al/R)*100% where LE = Percent Linearity Error; R= Reference
value of calibration gas; A = Average of monitoring system response. This test should be
conducted as soon as practicable after installing the backup CO CEMS.
c. RATA. If the backup analyzer is used for more than 720 cumulative hours during any
calendar year, a RATA must be conducted.
If you should have any questions, please contact me at [phone] or [e-mail].
Sincerely,
Alan Drake
Environmental Engineer
cc: Michael Pjetraj, RCO Central Files, Alamance County
Margaret Love, WSRO IBEAM (0 1000 10)