AQ_F_0100010_20131121_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY Stericycle,Inc.
NC Facility ID 0100010
Inspection Report County/FIPS:Alamance/001
Date: 11/21/2013
Facility Data Compliance Data
Stericycle, Inc. Inspection Date 11/21/2013
1168 Porter Avenue Inspector's Name Alan Drake, Samir Parekh
Haw River,NC 27258 Operating Status Operating
Lat: 36d 3.9660m Long: 79d 20.9230m Compliance Code Compliance-inspection
SIC: 4953/Refuse Systems Action Code FCE
NAICS: 562213/Solid Waste Combustors and Incinerators On-Site Inspection Result Compliance
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 05896/T21
Alan Skrzypczak Alan Skrzypczak Alan Skrzypczak Issued 5/17/2013
Facility Manager Facility Manager Facility Manager Expires 1/31/2016
[phone] [phone] [phone] Classification Title V
Permit Status Active
Inspector's Signature: Comments:
CO CEMS certification RATA on Unit 2
Date of Signature: �I Z I
DISCUSSION:
On November 21, 2013,about 9:00 a.m., Samir Parekh and I(Alan Drake)met with Alan Skrzypczak, Plant
Manager,and Don Nuss,Regional Environmental Manager.After signing in at the front office,we went to the testing
trailer. There we met Derek Brewster, Project Manager with TRC Solutions. Mr. Brewster indicated they had just finished
Run#1 on ES02. I initialed his printouts and copied some of the run and calibration information(see attachment). I also
recorded TRC's CO and 02 analyzer information as well as their results from the response time test. I asked about the CO
emission limit for ES02 and was informed that it was 11 ppmv in accordance with the new limits (40 CFR Part 60,
Subpart Ce,Table 1B). During the course of our discussion,we learned that Stericycle had moved their sampling
locations in March 2013,to accommodate the installation of a new sulfur impregnated carbon bed unit(for Hg control) on
each stack.
We then went inside the facility and were shown the new sample location. We informed Stericycle that moving
the sampling location constituted a major modification to their sampling system and that both CEMS would need to be
certified again.I asked about the current process rate and was told it was about 1,800 pounds per hour(the max normal
process rate is about 1,900 pounds per hour. We went to the facility's CEMS station where I recorded the following
analyzer information:
Source Manufacturer/Model Previous Correct
Serial No. Serial No.
ES02 Thermo Scientific 48i CM 090800035 CM 09080035

Stericycle Inspection Report- 11/21/2013
Page 2
Stericycle was also conducting a RATA on a backup CO CEMS (same make and model) in the event a primary
CO CEMS went down. We then proceeded to a conference room where we discussed the need to certify the CEMS again.
We discussed what constituted a major modification to a sampling system;I indicated that I would send them further
information.After looking at PS 4,PS 4A, and PS 4B,we concluded that PS 4A would be the most appropriate
specification since it was intended for sources with CO limits less than 200 ppmv. We suggested that Stericycle conduct a
7-day drift test and a response time test in addition to the RATA. These tests would have to be conducted on both CO
CEMS since both sampling probes were relocated. I asked if the CEMS was reconfigured to handle the new 11 ppmv
limit. Stericycle indicated the alarms and calibration settings were adjusted. We asked about the averaging time and told it
was a 12-hour rolling average.We mentioned that we interpreted the rule to be a 24-hour block average but asked them to
reconfirm it with the permitting section.Before we left,we returned to the test trailer to inform TRC the CEMS needed to
be certified according to PS 4A.I asked about the current estimated relative accuracy and was told it was about 2.5%for
CO through Run#5 and that 02 was essentially identical.
PERMITTED EMISSION SOURCES:
Emission Emission Source Description Control Control Device Description
Source Device
ID No. ID No.
ESO 1 dual chamber hospital,medical and * CD07 one selective non-catalytic reduction
infectious waste incinerator(HMIWI) (SNCR)system with ammonia
firing natural gas(4.6 million Btu/hr injection(19700 ACFM,outlet
primary chamber burner and 6.0 airflow rate)
million Btu/hr secondary chamber CDO 1 one packed bed scrubber and
burner) associated quench column in series
CD03 with venturi scrubber equipped with a
mist eliminator
*CD05 one sulfur impregnated carbon bed
1 (6,000 ACFM,inlet airflow rate)
ES02 dual chamber hospital,medical and *CD08 one selective non-catalytic reduction
infectious waste incinerator(HMIWI) (SNCR)system with ammonia
firing natural gas(4.6 million Btu/hr injection(19700 ACFM,outlet
primary chamber burner and 6.0 airflow rate)
million Btu/hr secondary chamber CD02 one packed bed scrubber and
burner) associated quench column in series
CD04 with venturi scrubber equipped with a
mist eliminator
* CD06 one sulfur impregnated carbon bed
(6,000 ACFM,inlet airflow rate)
rEGI diesel-fired emergency generator(500 N/A N/A
MACT ekW)
ZZZZ
2

NC DAQ Source Test Observers Checklist - Reference Method CEM Testing
Facility Name/Location : S +er \, L" C ( � r�,,W (Zi
Facility Contact/ Phone#: A lao 1 lD I
Testing Firm/ Contact: �(�r`, �,e ftk e(' % 9 -
Permit#/Source Tested: C) rj 1(oTZ1 .Cs O
IIApplicable Regulation/Pollutant: ��j r 2 J7 (7-)(0
Process Data/Production Rate(see reverse side):
Sample Date/Time:Run 1 , / ��- _� Run 2 / - Run 3 / -
Ask for an explanation to any question answered"No"and attach comments to this form.
Method 1 -Sample and Velocity Traverses for Stationary Sources YES NO
1.1)Method 1 calculated correctly(see reverse side)? V7
1.2)Cyclonic flow check completed? (Average of absolute value of all angles<20 degrees?)
Method 2-Determination of Stack Gas Velocity and Volumetric Flow Rate YES NO
2.1)Pitot tube leak check completed after each run?
2.2)Visual check of pitot tube heads-good condition?
2.3)Manometer level and zeroed correctly?
2.4)Static pressure measured during the test day?
2.5)Barometric pressure recorded and adjusted for elevation?(see reverse side)
II2.6)Pitot tube heads oriented to axis of flue?/Pitot tube perpendicular to axis of stack? I I I
2.7)Temperature recorded at each sampling point?
Method 3 -Gas Analysis for 021 COD and Dry Molecular Weight YES NO II
IISkip this section if Oi&CO,concentrations are determined via analyzers. I II
3.1)Orsat or Fyrites used?(circle)
3.2)Orsat perfonned in triplicate?Analysis consistent? I I II
II Method 4- Determination of Moisture Content in Stack Gases YES NO II
II 4.1)Impingers used or some other type of condenser? Multi point sample?
II 4.2)H2O in first 2 impingers,3rd impinger empty,silica gel in 4th impinger? I I II
II4.3)Temperature at the exit of impingers/condenser<68F?(see reverse side) I I II
IL4.4) Silica gel in good condition��t -new,Pink-spent(unable to absorb more H2Oj I I II
11 CEM Methods: Meth 3A-Q-2XO2, M6C-SO21 WE-NOX, to-CO) YES NO II
II 5.1)System leak check performed during test day?(not required per method but od Q-A.)"
II5.2)Sample point w/in centroid of stack(compliance test)?
5.3)Sample conditioner/dryer used?
5.4)Heated sample line used prior to sample Condit ner?
5.5)Moisture visible in the sample line? (Do not explain a"No")
5.6)Filter used: "In stack"Cr gated out of stackO,'
5.7)Sample system flow rates within 10%of calibration flowrates?
5.8)All concentration m urements below the span value for that pollutant? V
5.9) Data Recorder igital- Strip chart/Manual/other (circle one)
5.10)NO,monitoring:NO,to NO convertor operating?Total NO,being analyzed?
5.11)Calibration Error Check performed for all analyzers and within specifications(2%of span)? ,j
5.12)System Bias Check performed for each analyzer before the first run,between each run,and after the last run? y
5.13 Test team monitoring analyzer zero drift and calibration drift between each run? J
The following page(front/back)should be completed to the extent possible. The data may be transferred from print outs provided by
the tester. Preferably,the calibrations should be viewed at the time they are performed to assure monitor stability and correct
flowrates for each calibration gas.

Process Data: It is absolutely imperative for the facility to record the pertinent data during the test so that the measured emissions can be
correlated to a production rate and compared to the permit limit. The test will be unacceptable without production data.
Method 1:If stack is between 4"- 12"then Method I a must be employed. If duct is<4"then alternative methods must be used. (Contact
SSCB with any test questions)
Stack Diameter? Measured on site?
Port distance from upstream disturbance(A) Upstream Diameters(A)
Port distance from downstream disturbance(B) Downstream Diameters(B)
#of Sampling Points? (Draw a line vertically from the"Distance A"axis down to the step chart,and from the"Distance B"axis up
to the step chart. The maximum#of points marked on the chart yields the minimum#of points to be sampled.)
Did D anot ers llbst r eamf r om A ow D st ur bane* (D st ane A)
.5 1.0 1.5 2.0 2.5
Uft-Ohla acks or ads LFO=
St r
Aeen�rl
16 aack0 ant a >061 (24io)
�r �Tyke 12
1 os[ouNekU(94"E �., tzrtradim, etc. 9
sack0aver =0.30 o0.61m(12-24in.)
Did D armt er s DNnst r eam f r om A ow D st to bane* (D st ane B)
Figure 1-2.Minimum number of traverse points for velocity(nonparticulate)traverses.
Points correctly marked on the pitot tube? Port length accounted for in calculations?
Remarks:
Barometric Pressure:Barometric pressure must be adjusted minus 0.1"per I00ft elevation increase or vice versa for elevation decrease.
(Elevation at which barometric pressure is measured compared to the elevation at the test platform.)
Exit Temperature: The temperature of the dry gas leaving the impingers/condenser must be below 68F. When the ambient temperature is
above 68F it may take approximately 5 minutes for the thermal effects of the ice bath to cool the exit thermometer below 68F.
CEM Methods:
There shall be no adjustments made to the analyzers after the start of the Calibration Error test. If an adjustment is made,reject all data since
the last completed system calibration. The Calibration Error test shall be re-performed and any subsequent system calibrations that are
necessary. The calibration and sample gas flow rates can and should be adjusted to within 10%of the flowrate during the calibration error test.
The mid range or high range gas can be used for the system bias test;however,it is preferred to use the upscale calibration gas closest to the
effluent concentration. It is also possible to use more than the required number of gases as long as the minimum gases were used. Single point
gas sampling is acceptable for compliance testing. The gas sample should be extracted from the center of the stack. The span of the analyzers
shall be selected such that the gas concentration equivalent to the emission standard is not less than 30%of the span. If at any time during a run
the measured gas concentration exceeds the span,the run shall be considered invalid.
Remarks:

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1

CEM Cal.Gas Direct Cal. Cal.Error % System Cal. System Bias % System Cal. System Bias % System Cal. System Bias % System Cal. System Bias %
Page Values Response [(A-B)/C]*100 Response Pre-Run 1 Response Pre-Run 2 Response Pre-Run 3 Response Post-Run 3
2/2 (A) (B) Pre-Run 1 (R1) [(R1-B)/C]*100 Pre-Run 2(R2) [(R2-B)/C]*100 Pre-Run 3 [(R3-B)/C]*10o Post-Run 3 [(R4-B)/C]*100
(<2%) (<5%) (<5%) (R3) (<5%) (R4) (<5%)
oZ o (1 v,z II I
Span:(c) I� z_ to, !; z 0,7 10.
Fco_ZTo
Span:(c)
ILI
SOZ 0
Spare(c)
NOz 0
Span:(c)
CO 0
Span:(c)
�OD L1, )o L13 I 5
jL)0.j c; 1, 12— 0, IF I
Calibration Error value shall be equal to or less than 2%. System Calibration Bias shall be equal to or less than 5%. The sampling team shall calculate and report the calibration drift for
each analyzer between each calibration. The zero drift and calibration drift are limited to 3%of the span over the period of each run. The calculation for drift is:
(Final system cal.-Initial system cal)/span *100. All calibration gases shall be used for the calibration error test. Only the zero and one span gas are required for the system calibrations.
CEM San Run 1 Maximum Conc. Run 1 Average Conc. Run 2 Maximum Conc. Run 2 Average Conc. Run 3 Maximum Conc. Run 3 Avera a Conc.
OZ
CO,
SOZ
NO,
CO

CEM % Calibration Gas Ranges Calibration Gas Values Gas Manufacturer&Cylinder# Protocol 1 Expiration
Page 1/2 gas? Date OK?
OZ 0-10% 0-10% NZ or other non-OZ gas C_ 21 � ` —Z
Span: 40-60% (,: l - C �� 17_�
co, 0 0 Nz or other non-CO, gas
Span: 40-60%
80-100%
so, 0 0 Nz or other non-SOZ gas
Span: 40-60%
80-100%
NO. 0 0 NZ or other non-NO,gas
Span: 40-60%
80-100%
CO 0 0 NZ or other non-CO gas
Span: —30% L
-60%
Span ,Q ��, D CC_, 2-1 0 r
To calculate cylinder gas range,multiply span by corresponding percentage(0.4* span,0.6* span). The calibration gas to be used shall fall within these values. CO gases do not need
to be exactly 30%,60%,and span,but should approximate the percentages. For CO testing,the"Span"gas value can be considered 80-100%of the calibrated span. Method 10 for
carbon monoxide has slight variations from method 6c,but most test companies perform CO testing to method 6c requirements.