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HomeMy WebLinkAboutAQ_F_0100010_20150430_CEM_RptRvwLtr (8) PWA NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory Donald R. van der Vaart Governor Secretary April 30, 2015 CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. Alan Skrzypczak Facility Manager Stericycle, Inc. Post Office Box 310 Haw River, North Carolina 27258 SUBJECT: Review of 2014 Second Semester CO CEMS Report Stericycle, Inc. —Haw River Facility Haw River, Alamance County,North Carolina Air Permit No. 05896T22 Facility ID# 0 1000 10 Dear Mr. Skrzypczak: Thank you for your timely submittal of the subject report, dated January 23, 2015. The excess emissions report assessed the carbon monoxide (CO) /oxygen(02) continuous emissions monitoring systems (CEMS) operating at the Haw River Facility during the second half of 2014. We requested and received additional clarification from you via email concerning excess emissions of CO during startup. The Division of Air Quality(DAQ) has completed its review and offers the following comments: 1. Hospital, medical, and infectious waste incinerators (HMIWI) ESO1 & ES02 were reviewed for compliance with the state-only CO emissions limit of 11 parts per million by volume (ppmv, 7% 02, 12-hour rolling average) as stated in Air Permit No. 05896T22, Specific Condition 2.1.A.La. Although there were no excess emissions exceedances reported for ESO1 during this time period, there were twelve(12) excess emissions exceedances reported for ES02. All CO exceedances occurred during incinerator startup on October 10, 2014, with a maximum 12-hour average of 12.44 ppmv. The report indicated the startup for ES02 was extended [no waste incinerated] until the 12-hour CO average was cleared. After reviewing the incident, our office has determined that Stericycle must further address the CO exceedances. It is requested that a written response to this letter be submitted to the Division Director as soon as possible, but no later than fifteen (15) days following receipt of this letter. The response should outline the steps that you plan to take or have taken to assure compliance with the aforementioned requirement at all times. 1641 Mail Service Center,Raleigh,North Carolina 27699-1641 Phone:919-707-84001 Internet:www.ncdenr.gov An Equal Opportunity 1 Affirmative Aclion Employer—Made in part by recycled paper Mr. Alan Skrzypczak April 30, 2015 Page 2 2. The report also contained a similar incident which occurred during the first quarter of 2015. On January 11, 2015, there were nine (9) excess emissions exceedances reported for ES02. These exceedances also occurred during startup with a maximum 12-hour CO average of 14.41 ppmv. Please address this incident as well in your correspondence to the Director. 3. Quarterly summary reports were reviewed for compliance with good operation and maintenance (O&M)practices pursuant to 15A NCAC 02D .0611(d), General Condition 3.F and summarized as follows: Unit Quarter %EE %MD HMIWI ESO1 3rd 0.0 0.1 4th 0.0 0.0 HMIWI ES02 3rd 0.0 0.1 4th 0.6 0.2 The incinerators, along with associated CEMS units, appear to have operated using good O&M practices since quarterly percent excess emissions (%EE) and percent monitor downtime(%MD) were less than 6% for any single calendar quarter and less than 3% for two consecutive quarters. If you should have any questions,please call me at(919) 707-8497 or Alan Drake of my staff at (919) 707-8493. Sincerely, 0/11 Michael Pje aj, P.E., Supervisor Stationary Source Compliance Branch Division of Air Quality, NCDENR cc: Lisa Edwards, WSRO Michael Pjetraj, RCO Central Files, Alamance County IBEAM (0100010)