AQ_F_0100010_20170505_CMPL_InspRpt

NORTH CAROLINA DIVISION OF AIR QUALITY Winston-Salem Regional Office
' Stericycle,Inc.
Inspection Report NC Facility.ID: 0100010
Date: 05/05/2017 Count /FIPS: Alamance/001
Facility Data Permit Data
Permit: 05896/T25
Facility Name: Stericycle,Ina Issued: 12/19/2016
Facility Address: 1168 Porter Avenue Expires: 11/30/2021
Haw River,NC 27258 Classification: Title V
Lat: 36d 3.9660m Long: 79d 20.9230m Permit Status: Active
SIC: 4953/Refuse Systems Current Permit Application(s): None
NAILS: 562213/Solid Waste Combustors and Incinerators
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact
SIP/Title V
Alan Skrzypczak Alan Skrzypczak Alan Skrzypczak MACT Part 63: Subpart ZZZZ
Facility Manager Facility Manager Facility Manager NSPS Part 60: Subpart IIII
[phone] [phone] [phone] 40 CFR Part 62: Subpart HHH
Compliance Data
Comments:
Inspection Date: 64/18/2017
Inspector's Name: Taylor Hartsfield
Inspector's Signature: Operating Status: Operating
^ Compliance Code: Compliance-inspection
Date of Si nature: "wA,
RS Action Code: FCE
g 5/5tl ` On-Site Inspection Result: Com liance
Total Actual emissions in TONS/YEAR:
TSP S02' NOx VOC CO PM10 *HAP
2015 0.95 0.24 18.01 0.85 0.53 0.75 137.97
2014 0.79 0.23 13.57 0.80 0.54 0.59 1037.72
2013 0.99 0.27 14.26 0.76 0.47 0.81 234.29
*Highest HAP Emitted(in pounds)
Five Year Violation History
Date Letter Type Rule Violated Violation Resolution Date
10/24/2016 NOV/NRE Part 60-NSPS Subpart Ec Hospital/Medical/Infectious Waste 11/18/2016
Incinerators
11/02/2015 NOV 2D.1206 Hospital,Medical,and Infectious Waste Incinerators 11/16/2015
02/18/2015 NOV Permit Condition 03/13/2015
01/15/2014 NOV/NRE 2D.1206 Hospital,Medical,and Infectious Waste Incinerators 11/20/2013
10/08/2013 NOV 2D.1206 Hospital,Medical,and Infectious Waste Incinerators 11/20/2013
10/08/2013 NOV Permit Condition 11/20/2013
12/17/2012 NOV/NRE Permit Condition 12/10/2012
Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
04/18/2017 Pending Method 29,Method 9 ES01,ES02
04/19/2016 Compliance Method 29,Method 9 ES0l,ES02
Page 1 of 14

INTRODUCTION
On April 18,2017,Taylor Hartsfield,DAQ-WSRO Environmental Engineer,and TJ Gray,DAQ-WSRO Environmental Specialist,
visited Stericycle,Inc.in Alamance County in order to conduct a compliance inspection and stack test observation.The facility was
targeted this year and has a facility classification of Title V.The facility contact and Facility Manager,Alan Skrzypczak,was
requested to help facilitate the inspection.Mr. Skrzypczak verified that all the contact information in the IBEAM database was correct
and up to date.
Stericycle,Inc. is a hospital,medical,and infectious waste incineration facility consisting of two identical units.According to Mr.
Skrzypczak,the facility operates 24 hours per day,7 days a week for 52 weeks per year.The facility received its last compliance
inspection on February 17,2016,by this inspector.At that time,the facility appeared to be in compliance with its Air Quality Permit
(05896/T24).
PERMITTED SOURCES
dual chamber hospital,medical CD07 one selective non-catalytic reduction(SNCR)system with ammonia
and infectious waste incinerator or urea injection(19,700 ACFM,outlet airflow rate),
(HMIWI)firing natural gas{4.6 ES01 CDO1 one packed bed scrubber and associated quench column in series with
million Btu/hr primary chamber CD03 one venturi scrubber equipped with a mist eliminator,and
burner and 6.0 million Btu/hr CD05 ilone sulfur impregnated carbon bed(6,000 ACFM,inlet airflow rate)
secondary chamber burner)
dual chamber hospital,medical CD08 one selective non-catalytic reduction(SNCR)system with ammonia
and infectious waste incinerator or urea injection(19,700 ACFM,outlet airflow rate),
(HMIWI)firing natural gas(4.6
ES02 CD02 1 one packed bed scrubber and associated quench column in series with
million Btu/hr primary chamber
CD04 ?one venturi scrubber equipped with a mist eliminator,and
burner and 6.0 million Btu/hr CD06 one sulfur impregnated carbon bed(6,000 ACFM,inlet airflow rate)
secondary chamber burner)
diesel fired emergency generator
EG1 N/A N/A
(500 kW maximum capacity)...
INSIGNIFICANT/EXEMPT SOURCES
I CT-1 and I-CT-2 Two cooling towers(55,200 gallons per hour water recirculation rate each)
I-AMM Facility-wide storage of 19%aqueous ammonia
SAFETY
When inspecting this facility,DAQ personnel are required to wear safety shoes,safety glasses,and hearing protection. General safety
practices from the required HAZWOPER training should always be followed.
LATITUDE/LONGITUDE VERIFICATION
The latitude and longitude coordinates of the facility were verified and did not need to be updated by this inspector.
APPLICABLE REGULATIONS
The following Title 15A North Carolina Administrative Code(NCAC)air quality regulations apply to Stericycle,Inc.: Subchapter 2D
.0516,2D.0521,2D.0524,2D.0535,2D.0540,2D .0611,2D.1100,2D.1111,2D.1206,2D.1806,2Q.0508,40 CFR Part 60,
Subpart IIII,40 CFR Part 62,Subpart HHH,and 40 CFR Part 63,Subpart ZZZZ.
Page 2 of 14

PERMIT APPLICATIONS
There are not any permit applications in process by DAQ-RCO for this facility at the time of this inspection.
SOURCE TEST
At the time of the inspection,the facility was testing both hospital,medical and infectious waste incinerators(HMIWI)(ESO1 and
ES02).Both incinerators were being tested for visible emissions using EPA Method 9.Only ESO1 was being tested for cadmium(Cd)
and lead(Pb)using EPA Method 29.EPA Method 3A was performed concurrently for oxygen and carbon monoxide.This was due to
it being three years since this unit was last tested for these pollutants.Both incinerators are subject to 15A NCAC 2D .1206"Hospital,
Medical and Infectious Waste Incinerators,"which incorporates parts of 40 CFR Part 60,Subparts Ce and Ec by reference.Both units
are also subject to 15A NCAC 21).1100"Control of Toxic Air Pollutants"and 40 CFR Part 62 Subpart HHH"Federal Plan
Requirements for Hospital/Medical/Infectious Incinerators Constructed on or Before June 20, 1996."The limit for visible emissions is
6%opacity on a 6-minute block average.The limits for Cd and Pb are 63.91 lbs/yr and 0.036 mg/dscm,respectively.
The test was performed by Derek Brewster and Joe Thompson,of TRC Environmental Corporation based out of Raleigh,NC.The
Protocol Submittal Form was received by this office on March 6,2017.The protocol was approved by the DAQ-SSCB on April 10,
2017.The test consisted of at least three 2-hour runs with all EPA Methods performed concurrently.One meter box was used.Meter
box E49 was calibrated on December 20,2016,by T.Mills and had AH= 1.747 and y= 1.0108.
ES01 and ES02 were operating with charge rates of,1,135 and 1,579 lbs/hr,respectively.The other operating parameters at the time of
source test are summarized below under Condition 2.1.A.2.n.Run#1 was from 8:30 to 10:34 AM(124 mins).Run#2 was from 11:00
AM to 1:04 PM(124 mins).Run#3 was from 1:20 to 3:25 PM(125 mins).There were not any detectable visible emissions
throughout the testing period other than an attached steam plume on both incinerator stacks.The weather was cloudy,—65°F with an
8-mph wind from ENE.According to TRC's on-site results of the Method 9 tests performed on both units,most readings were 0%
with a couple 5%readings.Preliminary results indicate compliance with the opacity limits.
DISCUSSION
The facility has two dual chamber hospital,medical and infectious waste incinerators(HMIWI)(ESO1 and ES02)firing natural gas,
each with a 4.6 million Btu/hrprimary chamber burner and a 6.0 million Btu/hr secondary chamber burner.Each incinerator is
controlled by a selective non-catalytic reduction(SNCR)system,a packed bed scrubber,a venturi scrubber equipped with mist
eliminator,and a sulfur impregnated carbon bed,all installed in series.These control devices are installed to control emissions of PM,
CO,NOx,dioxins/furans,and other HAP/TAPs.During the inspection,both incinerators and their respective control devices were
operating.There were no visible emissions observed other than steam plumes from the incinerator stacks.These stacks were observed
from the roof.The operating parameters at the time of inspection are summarized below under Condition 2.1.A,2.n.
A basic description of the operation of a HMIWI at this facility is as follows:A hopper is loaded with boxes of HMIW,which
represents a charge. The hopper is tipped into an open pre-incineration chamber,and,after closing,a hydraulic ram pushes the charge
into the primary combustion chamber.From there,the charge is combusted as it moves down the primary chamber,aided by other
rams and underfire air.At the end of the primary chamber,the ash and non-combusted material is quenched with water and an auger
transfers the ash to a waste bin.This bin then goes to a landfill as the waste no longer has its original hazardous properties.
Back in the incinerator,the combustion gases from the primary chamber travel up to a secondary chamber.A secondary burner
destroys any combustible content of the primary combustion gases and reduces CO emissions.The exhaust then enters the SNCR
system where ammonia or urea is injected in order to reduce NOx formation.Afterwards,the gases enter a packed bed scrubber and
associated quench column.The packed bed scrubber has a caustic solution to reduce acid gas emissions.The quencher reduces
temperature which reduces dioxin/f Iran emissions.After quenching,the gases pass into the venturi scrubber to reduce PM emissions.
Following the venturi scrubber,the gases go through a mist eliminator to remove some of the steam plume.The last step is for the
exhaust to pass through the sulfur impregnated carbon bed to reduce mercury emissions.
Associated with the two HMIWIs are two exempt cooling towers(1-CT-1 and 1-CT-2)each with a 55,200 gallons per hour water
recirculation rate.The cooling towers assist the quencher in reducing the temperature of the exhaust.These cooling towers were in
operation during the inspection with small amounts of steam emissions visible from the roof of the facility.
Page 3 of 14

The facility also has a diesel-fired emergency generator(EG1).It was not in operation during the inspection.The generator is a 500
kW Caterpillar model DCPXL that was installed in July 2013.The non-resettable hours meter was recently replaced on September 23,
2016,and read 22.9 hours during the inspection.Before being replaced,the old hour meter read 164.2 hours.A certification sticker for
NSPS purposes is located on the engine,and was observed by this inspector.The generator uses ultra-low sulfur diesel(ULSD)fuel
from Alamance Oil. Carolina CAT services the engine semi-annually.The engine is tested twice per week for about 20 minutes.
During an emergency loss of power,the engine is equipped to start automatically to provide power to the incinerators and prevent
opening of the bypass stacks,which would occur seven seconds after the incinerators lose power.
PERMIT CONDITIONS
Section 2-Specific Limitations and Conditions
2.1 -Emission Source(s)and Control Device(s)Specific Limitations and Conditions
A. Two natural gas-fired dual-chamber hospital,medical,and infectious waste incinerators [HMIWI] (ID Nos.ES01 and
ES02),each controlled with one selective non-catalytic reduction(SNCR)system(ID Nos.CD07 and CD08),in series with
one packed bed scrubber(ID Nos.CDO1 and CD02),in series with one venturi scrubber(ID Nos.CD03 and CD04),in
series with one sulfur impregnated carbon bed(ID Nos.CD05 and CD06)
Condition 2.1.A.La contains the requirements for 2D.1100 which requires the facility to limit the release toxic air pollutant(TAP)
emissions.The limits for each TAP emitted by the affected emissions sources are established in the table below.The facility
conducted source testing on the units from April 28 May 1,2015.The results of that test were approved by the DAQ-SSC13 per the
memo issued on June 22,2016.
__.
to`. NO. 1t W W l )',
_[ Arsenic € 2.673^lbs/yr - 6.0827 lbs/yr 0.1654 lbs/yr
Beryllium „ 47 641bs/yr <0 01651bs/yr <0 0330 lbs/yr
m 63 91 lbs/yr 0.04771bs/yr 0.0954 lbs/yr
Cadmium -.....
Chlorine j 24.00lbs/day; <0.008631bs/day, 01741bs/day, <0.0261 lbs/day,
.:......
1.00 lbs/hr <3.60E 041bs/hr 7 27E 04 lbs/hr <0 00108 lbs/hr
Chromium VI 0.964 Ibs/yr F6 0335 lbs/yr 0.0670 lbs/yr,
Incinerators Hexachlorodibenzo-P-di xo m 0.8831 lbs/yr - 2.81E-081bs/yr F.
5.62E-081bs/yr
(ID Nos.ESO1 -- mm--
and ES02) Tetrachlorodibenzo P-dioxm 0 03491bs/ 2 OSE 071bs/ 4 10E-071bs/yr
yr .................. yl .:
�.mm .. ....... _ ...
Hydrogen Chloride 2.2 lbs/hr 0.00231 lbs/hr 0.006801bs/hr 0 00911 Ibs/hr
.. ..__._ . m.__... ., ...,,,,. ._.
Hydrogen Fluoride 24.00 lbs/day; <0 0131 lbs/day, <0 0149 lbs/day, <0 0280 lbs/day,
1.00 lbs/hr <5 Ibs/hr F.47E-046 21E 041bs/hr <0 001171bs/hr
} Man anese 8 22 lbs/hr <6 35E 041bs/hr <0 00131 lbs/hr
g �
Mercury ' 3 82 lbs/da <2 77E 041bs/day <5 54E 04 lbs/day
Nickel [ 12.00 lbs/day �0 001501bs/day 0.00300 1bs/day
Condition 2.1.A.l.b states that to comply with the above limits,the charge rates into the incinerators shall not exceed 1,870.0 pounds
per hour for ESO1 and 1,870.0 pounds per hour for ES02.In addition,each incinerator's stack height shall be a minimum of 82.4 feet
above ground level.Also,the maximum carbon bed inlet temperatures shall not exceed 168.1°F for CD05(for ESO1)and 164.1°F for
CD06(for ES02).During the inspection,the 3-hour average charge rates of ESOI and ES02 read 1,135.1 and 1,579.3 pounds per hour,
respectively,on the data acquisition system(DAS)utilized by the facility.The stacks appeared to remain at the appropriate height, and
there was no evidence that they had been adjusted.The 3-hour average maximum carbon bed inlet temperatures for CD05 and CD06
were 159.1°F and 149.7 17,respectively.The facility appears to be in compliance.
Page 4 of 14

Condition 2.1.A.l.c states that in order to minimize bypass event duration and emissions,the facility shall do the following:
A. Install an uninterruptible power supply (UPS) for the control system to eliminate any "reboot" time associated with the
programmable logic controllers(PLCs).The UPS shall be equipped with a readiness indicator;
B. Install a power outage indicator as an input to the PLCs;
C. Revise the PLC logic to require automatic re-closure of the bypass stack within 5 minutes after a power failure;
D. Install a low level switch on the emergency generator diesel tank;
E. ' Install apressure switch to the water supply to alert operators to a loss of water supply;
F. Operate devices to assure continuous removal of the ash from the primary chamber;and
G. Reduce combustion air to the primary chamber by alternately shutting the fan off and on in 1 minute cycles to achieve a net
reduction in airflow of 50%during the bypass event.
According to Mr. Skrzypczak,the applicable devices(A-E)have been installed/revised,and the operational changes(F-G)have been
implemented.Therefore,the facility appears to be in compliance.
Condition 2.1.A.1.d states that the facility shall not incinerate dental waste,as defined in the waste management plan required by
Section 21.A.2.bb.During the inspection,it was verified that the facility is not incinerating any dental waste.Any dental waste
received is set aside and trucked out for incineration elsewhere.If any dental waste containers are accidentally placed on the
conveyors to the incinerators,the scanners before the loading mechanism would alert the facility of the problem and stop the process.
The facility appears to be in compliance:
Conditions 2.1.A.Le and f state that the facility shall comply with the testing requirements in Section 2.LA.2 j.for cadmium and
mercury.The testing shall also be performed in accordance with General Condition JJ.As previously mentioned,the facility was
testing ESOI for cadmium during the inspection.Both units are planned to be tested for cadmium and mercury next year,so that they
will be on a consistent testing schedule.The facility appears to be in compliance.
Condition 2.1.A.l.n states that the facility shall conduct the monitoring,maintenance,and inspections for each incinerator and each
control device;as required by Sections 2.1.A.2.u.through aa. See this section below for a detailed discussion.The facility appears to
be incompliance.
Conditions 2.1.A.l.h and i states that the facility shall maintain records or any other process operational information as is necessary
to determine compliance with 15A NCAC 2D.1100.In addition,the facility shall keep records of inspections and maintenance on the
control devices as required by Section 2.LA.2.ff, See this section below for a detailed discussion.The facility appears to be in
compliance.
Condition 2.1.A.1.8 states that for each stack test,the facility shall track and record details for the waste being burned and the material
that may be carried over into the stack test period.Tracking shall include,at a minimum,a cross-reference of the identity of the waste
generator with the company's customer list(the identity information shall include the nature of the business activity),the type of
business waste,the total weight of each container,and the time the material entered the incinerator.This information will be
summarized and submitted as part of the stack test report.Mr. Skrzypczak assured that this information would be provided with the
stack test report for the test being conducted at the time of the inspection.The facility appears to be in compliance.
Condition 2.1.A.Lk states that the reporting requirements of 15A NCAC 2D.1206(see Sections 2,I.A.21h.and ii.)shall be
considered sufficient for reporting compliance with 15A NCAC 2D.1100.See this section below for a detailed discussion.The
facility appears to be in compliance.
Conditions 2.1.A.2.a and b states the emissions limitations for both HMIWI units(ES01 and ES02)as stipulated by Table 113 of 40
CFR Part 60,Subpart Ce.The facility conducted source testing on the units from April 28-May 1,2015.The results of that test were
approved by the DAQ-SSCB per the memo issued on June 22 2016.
., .,
law
' Particulate matter ` 25 milligrams per dry standard cubic meter(mg/dscm)OR 9.48 mg/dscm 8.94 mg/dscm
0.011 grains per dry standard cubic foot(gr/dscf) 0.00414 gr/dscf 0.00391 gr/dscf
'Carbon monoxide i 11 parts per million by volume(ppmv) <0.170 ppmv <0 158 ppmv
Page 5 of 14

F
_. W :
N I
9.3 nanograms per dry standard cubic meter total dioxins/furans
(ng/dscm)OR
4.1 grains per billion dry standard cubic feet(gr/109 dscf) 0.0614 total ng/dsm
Dioxins/furans Not tested
OR 0.00103 ng/dscm TEQ
0.054 ng/dscm TEQ OR
0.024 gr/109 dscf TEQ...... .....
......
......
Hydrogen chloride 6 6 arts per b volume my 0 107 ppmv 0 332 ppmv
. _._.. p... P y �P,.. )
Sulfur dioxide 9 0 arts er million b volume my Not tested Not tested
., P p _......._y . Epp... ) _ ....._=C� � .��. ..
Nitrogen dioxide ; 140 parts per million by volume(p�mv)„ v 132 3�pmv 122 4pmv
0.036 milligrams per dry standard cubic meter(mg/dscm)OR
Lead 0.016 ams er thousand standard cubic feet /103 dsc Not tested0197 mg/dscm
....., p. _ _.,� ? fl ._.... .. _._..
0.0092 milligrams per dry standard cubic meter(mg/dscm)OR
Cadmium 3 Not tested <0.000410 mg/dscm
.....
0 0040 grams per thousand dry standard cubic feet(g/10 dsc fl
0.018 milligrams per dry standard cubic meter(mg/dscm)OR
Mercury s Not tested <0.000863 mg/dscm
0.0079 grams per thousand standard cubic feet /10 dsc
P. ....... ........ fl,
�"', Opacity 6%opacity(6 minute block average) _.,...,,... . . 0%
[_*Limits based on 7% . **Limits based on a three run average with a minimum sample time of one hour per run,except for
oxygen(dry basis) dioxins/furans which is based on a three run average with a minimum sample time of four hours per run
The facility shall also comply with the calculated emission limits listed in Section 2.I.A.1.a.of this permit for the following
pollutants: arsenic and its compounds,beryllium and its compounds,cadmium and its compounds,and chromium(VI)and its
compounds.The emission limits apply at all times.The facility appears to be in compliance.
Condition 2.1.A.2.c states that the test methods and procedures described in 15A NCAC 02D .2600,40 CFR Part 60 Appendix A,and
40 CFR Part 61 Appendix B shall be used to determine compliance with emission limits.All testing shall be conducted according to
the provisions of General Condition JJ. When determining compliance with emission limits for metals,Method 29 of 40 CFR Part 60
shall be.used,except that SW 846 Method 0061 shall be used for chromium(VI). [Note:Currently,this condition wrongly states that
Method 29 shall be used for sampling chromium(VI).]As mentioned,the facility was performing testing on ESO1 for cadmium and
lead during this inspection.The facility was using Method 29,and'therefore,appears to be incompliance.
Conditions 2.1.A.2.d throuuh estate that the facility shall conduct an initial performance test in order to determine compliance with
the emission limits in Section 2.1 A.2.a,and to establish maximum and minimum values for the following operating parameters for
each control device,as applicable:maximum charge rate;maximum flue gas/carbon bed inlet temperature;minimum secondary
chamber temperature;minimum pressure drop across the venturi scrubbers,or minimum amperage to wet scrubber;minimum venturi
scrubber liquor flow rate;minimum packed bed scrubber liquor pH;and minimum SNCR reagent flowrate.The facility may conduct
repeat performance tests at any time in order to establish new operating parameters.Upon receipt of an approved test that
demonstrates different operating parameters,the facility shall attach the approval memo containing the revised operating parameters to
this permit and maintain the parameters in the associated ranges contained therein.The facility may conduct a repeat performance test
within 30 days of violation of applicable operating parameter(s)to demonstrate that the affected facility is not in violation of the
applicable emissionslimit(s).Repeat performance tests conducted pursuant to this paragraph shall be conducted using the identical
operating parameters that indicated a violation.The facility has not established any new operating parameters since the issuance of this
permit.Therefore,the operating parameters summarized under Section 2.1.A.2.n still apply.The facility appears to be in compliance.
Conditions 2.1.A.2.h throueh k state the requirements and frequency for emissions testing.The facility shall conduct annual
performance tests for the opacity limit,and meet the requirements of 40 CFR 60.56c(b).For compliance with the PM and HCl
emissions limits,the facility shall start by testing annually.If three tests over a three-year period indicate compliance,then the facility
may test for PM and HCl once every three years(no more than 36 months from previous test).Annual tests shall be resumed if a test
results in non-compliance.For compliance with the mercury,cadmium,and lead emission limits,the facility shall test once every
three years(no more than 36 months from previous test).For each metals test,the facility shall track and record details for the waste
being burned and the material that may be carried over into the stack test period.Tracking shall include,at a minimum: a cross-
Page 6 of 14

reference of the identity of the waste generator with the company's customer list(the identity information shall include the nature of
the business activity);the type of business waste;the total weight of each container;and the time the material entered the incinerator.
This information will be summarized and submitted as part of the stack test report.The use of the bypass stack during a performance
test shall invalidate the performance test.During the inspection,the facility was testing both units for opacity and only ESO 1 for
cadmium and lead.Next year(2018),both incinerator units will be due for testing for all pollutants.The facility intends to retest ESO1
next year for cadmium and lead to get it on the same schedule as ES02.The waste tracking records from the test performed during this
inspection will be submitted with the results of the test.There was no use of the bypass stack during this performance test.The facility
appears to be in compliance:
Conditions 2.1.A.2.1 and m state the types of materials allowed to be incinerated;The facility shall only incinerate waste that meets
one of the following requirements:hospital waste or medical/infectious waste,as defined by 40 CFR Part 60,Subpart Ec and 15A
NCAC 02D.1202;international garbage(USDA/APHIS);confidential documents generated in the health care industry;controlled
substances captured by law enforcement agencies;non-hazardous trace chemotherapeutic waste materials;or non-hazardous
pharmaceuticals.Dental waste,as defined in the DAQ approved waste management plan(See 2.1.A.2.bb),is not to be incinerated.
During the inspection,most of the labels on the waste boxes indicated that they were received from hospitals,health clinics,and
medical labs.None of the boxes were opened for verification,but it's presumed that the labeling is accurate.As mentioned under
section2.LA,Lid,the facility does not incinerate any dental waste.The facility appears to be in compliance.
Condition 2.1.A.2.n states that the facility shall ensure that all operating parameters remain within the acceptable range as measured
on a 3-hour rolling average,following the.date on which the maximum and minimum operating parameters are established.Operation
outside of acceptable ranges shall constitute a violation of established operating parameter(s),except that operating parameter limits
do not apply during performance tests or during periods of startup and shutdown when no waste is being charged.The following table
summarizes the most current operating parameters and those observed during the inspection.During the inspection,Mr. Skrzypczak
stated that the facility has an electronic control system with interlocks that prevents charging of the units if the operating parameters
are not met.The facility appears to be in compliance.
4
Max charge rate(lbs/hr) ,870.0 2,096.6. 1,135.1 1,870 0 2,094.0 1,579.3
Min.pressure drop across venturi scru............-bber ,
(in.W.C.)
.. F0I...................38.7 44.8 �38.9. 37.9 43.0
secondary chamber temperature(°F) 1,762 1,803 2 1,960 4 1,759 5 1,782.7 1,983 2
Min venture scrubber liquor flow rate 5 264 4 71 7 66 7 64 µ9 F 70.8
Min packed bed scrubber liquor pH 10 4 , ...4. 11 5 52 �4.104 065 50
Max'flue gas/carbon bed,inlet temp (°F) 168 1 �168.1 T ; 159 1 m4 1 167.0 149.7
Min SNCR flow rate for urea h 14 1 2
Min. SNCR flow rate for ammonia(gph) 1.0 1.1 � 12 �l.0 1 1 1 2
Condition 2.1.A.2.o states that the scenarios summarized in'the following table shall constitute a violation of an emission limit(each
parameter is measured on a 3-hour rolling average).During the inspection,there were no such incidents,' and therefore no emissions
limit violations.The facility appears to be in compliance.
,.... zr;'r;#,. 1 4 Q
Above maximum charge rate AND below,mmimum pressure drop across venturi scrubber PM
Above maximum charge rate AND below minimum secondary chamber temperature CO
Above maximum charge rate AND below minimum secondary chamber temperature AND Dioxin/furans
below minimum venture scrubber liquor flow rate ,
Above maximum charge rate AND below minimum packed bed scrubber liquor pH HCl
Above the maximum carbon bed inlet temperature AND above maximum charge rate Hg
Page 7 of 14

Uses bypass stack I I PM,dioxin/furanr HCI>Pb, Cd and Hg
....
Above maximum charge rate AND below minimum secondary temperature AND below
minimum reagent flow rate
. ....... ..... ....... NOx . ........ ....... . .. ...
Conditions 2.1.A.2.n through r state the requirements and frequency for parameter monitoring.The facility shall install,calibrate(to
the manufacturer's specifications),maintain,and operate the following monitoring devices:
• Devices for monitoring the maximum and minimum parameters,listed in Section 2.1.A.2.n.such that these devices measure
and record values for those parameters at the frequencies listed in Table 3 to 40 CFR Part 60 Subpart Ec._
• A device or,method for measuring the use of the bypass stacks,including date,time,and duration.
• A continuous temperature monitoring and recording system for temperature in the primary chamber of each affected HMIWI.
•' A device to continuously measure the reagent flowrate to the SNCR and record the data at least once per minute.
• A continuous monitor for both oxygen and CO in order to determine proper operation of each HMIWI.
The facility shall obtain monitoring data at all times during HMIWI operation except during periods of monitoring equipment
malfunction,calibration,or repair.At a minimum,valid monitoring data shall be obtained for 75%of the operating hours per day for
90%of the operating days per calendar quarter that the affected facility is combusting HMIW.All monitoring devices and associated
equipment used to show compliance withr emission limits shall be subject to a Quality Assurance(QA)program which must include
procedures and frequency of the following: calibrations;standards traceability;operational checks;maintenance;auditing;data
validation;and a schedule for implementing.the QA program;The QA program must be submitted to and approved by the DAQ-
WSRO Regional Supervisor.As previouslymentioned,the facility has a DAS for monitoring allrequired operating parameters and
use of the bypass stack.According to the semi-annual report received January 31,2017(PM: O 1/30/17),for ES01 and ES02,the
facility had 0.20 and 4.13 hours of inoperative monitor data,which represents 0.002 and 0.05%of the total operating time in CY2016,
respectively.As this is less than what is allowed,the facility appears to be incompliance.
Condition 2.1.A.2.s states that to assure compliance with the visible emissions limit,the facility shall observe the emission points of
each HMIWI for any visible emissions above normal once a day.r The daily observation must be made for each day of the calendar
year period to ensure compliance with this requirement.The facility shall be allowed three days of absent observations per'semi-
annual'period.The observations must be maintained in a log on-site and include the dates;times,results,,and any corrective actions.
During the inspection,the daily visible emissions observations log'sheets for CY2016 were spot checked.The facility keeps an annual
calendar sheet and crosses off each day after the VE observation has been filed.All the days for CY2016 were crossed off on the
calendar,so it seems that no daily observations were missed.There were no visible emissions observed during the inspection other
than steam plumes.The facility appears to be in compliance.
Condition 2.1.A.2.t states that the facility shall install a carbon monoxide continuous emissions monitoring system(CO GEMS)on
the exhaust stack of each incinerator.The CO CEMS shall be used to determine compliance with the CO emission limit using,a 12-
hour block average.The CO CEMS shall be operated in accordance with the applicable procedures under appendices B and F of 40
CFR Part 60.When demonstrating compliance with the CO emission limit,the Permittee may substitute a CO CEMS for the annual
CO performance test and minimum secondary chamber temperature.Excess CO emission reports as measured by the CEM systems
must be submitted semi-annually.During the inspection,'the CO OEMs were operating and the 3-hour averages for ESOI and ES02
were 4.1058 and 0.9762 ppmv,respectively,which is less than the 11 ppmv limit.According to the semi-annual CEM report received
January 30,2017,E9SO1 and ES02 had no instances of excess CO emissions.The CEM report was accepted by the DAQ-SSCB on
March 9,2017.The facility appears to be incompliance.
Conditions 2.1.A.2.0 through w state that the facility shall perform an annual inspection of each HMIWI.The inspection shall, at a
minimum,meet the requirements of 40 CFR 60.36e(a)(1)(i)through(xvii).Also,the facility shall perform an annual inspection of
each control device associated with each HMIWL At a minimum,each control device must meet the following criteria(if applicable):
ensure proper calibration of thermocouples,sorbent feed systems,and any other monitoring equipment;and generally observe that the
equipment is maintained in good operating condition.Any.necessary repairs found during an inspection of a HMIWI or control device
shall be completed within 10 operating days of the inspection unless the owner or operator submits a written request to the Director for
an extension of the 10 operating day period.According to the facility's records,ESO f and all associated controls were inspected on
June 30,2016,and ES02 and all associated controls were inspected on July 29,2016.During these shut downs,the facility thoroughly
inspects the incinerators and performs any required annual maintenance on the packed bed,(CDOI and CD02)and venturi'(CD03 and
CD04)scrubbers.All maintenance was performed in a timely manner.Further discussion about the carbon beds(CD05 and CD06)is
in the following section.The facility appears to be incompliance.
Page 8 of 14

Conditions 2.1.A.2.x through as state the carbon bed requirements.The carbon beds(CD05 and CD06),used for the control of
mercury(Hg)emissions,shall be designed and operated with two beds in series,with the second bed serving as a guard bed.While
operating the carbon beds;the facility shall replace the carbon in each bed before it has reached the end of its useful life.For the
replacement of carbon in the primary bed,the secondary bed will be rotated into the primary bed position and the new carbon will be
used in the secondary bed position.In addition,the facility shall use the type of activated carbon used during the most recent
performance test demonstrating compliance with the Hg emission limit until a subsequent performance test is conducted.The facility
may substitute at any time a different brand of activated carbon,if the replacement has equivalent or improved properties compared to
the carbon used in the most recent performance test.The facility shall monitor the performance of the carbon beds in each system to
ensure that the carbon in each bed has not reached the end of its useful life.The monitoring shall be conducted consistent with the
manufacturer's specifications and recommendations.The facility shall document the monitoring procedures used and keep records of
any performance monitoring.According to the records,the carbon in CD05 and CD06 was charged on March 2016 and December
2015,respectively.CDO5 contains Calgon carbon and CD06 contains Jacobi carbon.The Calgon carbon was considered an equivalent
replacement for the Jacobi carbon.The beds are inspected and tested about every two months to ensure that the carbon has not reached
the end of its useful life.This was last done for CD05 and CD06 on January 13 2017,and February 6,2017,respectively.Both tests
indicated that the carbon was still useful.The facility appears to be in compliance.
Condition 2.1.A.2.bb states that the facility shall,by January 30th of each calendar year,develop and submit to DAQ a waste
management plan that meets and follows the guidelines listed in 40 CFR 60.55c.The facility shall implement the approved waste
management plan in its entirety.In addition,the waste management plan shall address the management of dental waste.The last
annual report received on January 31,2017(PM:01/30/17)contained the facility's waste management plan which was most recently
revised on November 11,2005.Pages 3-5 of the plan specifically address the management of dental waste.The facility appears to be
in compliance.
Condition 2.1.A.2.cc states that the facility shall comply with 15A NCAC 02D .0535"Excess Emissions Reporting and
Malfunctions".Emissions from bypass conditions shall not be exempted by 15A NCAC 02D.0535(c)or(g).Rule 2D.0535 requires
the facility to notify the DAQ of any source causing an excess of emissions lasting more than four hours and that results from a
malfunction,a breakdown of process or control equipment,or any other abnormal conditions.According to the semi-annual report
received January 31,2013(PM:01/30/17),ES01 and ES02 had 0 and 0.22 hours of excess emissions,respectively,in CY2016.The
excess emissions from ES02 occurred during a bypass stack opening,and therefore not exempt as previously mentioned.The facility
was subsequently issued.a Notice of Violation and Notice of Recommendation for Enforcement(NOV/NRE)on October 24,2016.As
for the 2017 records,the�facility experienced excess emissions also resulting in bypass events on February 21 (ES02;5 minutes)and
February 27(ESO1; 8 hours).The NOV/NRE for both of these events was issued on April 21,2017,following the date of this
inspection.Further details are contained in the Compliance History section of this report.
Condition 2.1.A.2.dd'states that the facility may operate a HMIWI using only combustion controls during periods of startup and
shutdown when no waste is being combusted.During such periods,the Permittee shall monitor and record the following:verify that
no waste is being combusted;the secondary chamber temperature;and the amount and type of fuel being combusted.The facility's
DAS monitor's and records these parameters any time the HMIWI are in operation.Therefore,verifying compliance with this
alternate operating scenario is ensured.Based on the facility's operation records,the facility appears to be in compliance.
Condition 2.1.A.2.ee states that the facility shall not allow a HMIWI to operate at any time unless a fully trained and qualified
HMIWI operator is accessible,either at the facility or available within one hour.The trained and qualified HMIWI operator may
operate the HMIWI directly or be the direct supervisor of one or more HMIWI operators.Operator training and qualification shall be
obtained by completing the requirements of 40 CFR 60.53c(c)through(g).The facility shall maintain,all items required by 40 CFR
60.53c(h)(1)through(h)(10).The facility shall establish a program for reviewing this information annually.with each HMIWI
operator.This information shall be kept in location readily accessible for all HMIWI operators.During the inspection,training
materials,required documents,and names of the operators were reviewed and found to be complete.Refresher training was last
conducted at the facility on November 7 and 11,2016.
Conditions 2.1.A.2.ff and HE state the recordkeeping requirements for the facility.The records shall be kept for a period of at least
five years and maintained on-site to be made available to an authorized representative upon request.All required records were
reviewed and found to be complete.All records have been discussed in previous sections of this report.The facility appears to be in
compliance.
Page 9 of 14

Conditions 2.1.A.2.hh and ii state the reporting requirements for the facility.The facility shall submit a semi-annual summary report
of monitoring and recordkeeping activities postmarked on or before January 30 and July 30 of each calendar year for the preceding
24-month period. All instances of deviations from the requirements of this permit must be clearly identified.The report shall include:
• The values for the site-specific operating parameters;
• The highest maximum operating parameter and the lowest minimum operating parameter,as applicable,for each operating
parameter recorded for the calendar year being reported and for the previous calendar year;
• If a performance test was conducted during the reporting period,the results of the test shall be included;
• Dates where monitoring data was not collected,indicated exceedences,or indicated a malfunction;and
• If no exceedances or malfunctions occurred during the calendar year being reported,a statement to that effect shall be
included in the report.
As previously mentioned,the last semi-annual report was received on January 31,2017(PM:01/30/17)and contained all the
necessary elements.The facility appears to be in compliance.
Condition 2.1.A.3 states that the HMIWI units(ESO1 and ES02)are subject to 40 CFR Part 62,Subpart HHH"Federal Plan
Requirements for Hospital/Medical/Infectious Waste Incinerators Constructed On/Or Before December 1,2008."The facility shall
comply with all applicable requirements of this subpart,and is currently doing so by complying with Conditions 2.LA.1 and 2.LA.2.
The facility appears to be in compliance.
B. One diesel fuel-fired emergency generator(ID No.EGI)
Condition 2.1.B.1 contains the requirements for 2D .0516 which requires the facility to limit sulfur dioxide emissions from
combustion sources, such as the emergency generator(EG1). The sulfur dioxide emissions should not exceed 2.3 pounds per million
Btu input. Diesel fuel will produce 0.29 pounds of S02 per million Btu based upon an emission factor found in AP-42 (Table 3.3-1).
The facility appears to be incompliance.
Condition 2.1.B.2._contains the requirements for 2D .0521 which requires the facility to control the visible emissions from any
emission source that may be discharged from vents.or stacks. The emergency generator(EG1)was manufactured after July 1,,1971,
Therefore,the visible emissions from the generator are not to exceed 20 percent opacity when averaged over a six minute period. The
generator was not operating during the inspection, so no visible emissions could be detected. If the generator operates according to
manufacturer specifications,it will likely be in compliance:
Condition 2.1.B.3 contains the requirements.for 2D .0524 which involves the New Source Performance Standards (NSPS) federal
regulations promulgated by the EPA. The facility's diesel fuel-fired emergency generator(EG1)is subject to 40 CFR Part 60, Subpart
IIII for"Stationary Compression Ignition Internal Combustion Engines" as it was constructed after July 11, 2005, and manufactured
after April 1,2006.The generator is a certified engine according to the procedures of this subpart as verified during the inspection via
a sticker on the engine. The emission limits for the generator are 6.4 g/kW-hr of NOx+NMHC,3.5 g/kW-hr of CO, and 0.20 g/kW-hr
of PM emissions. The exhaust opacity is limited to 20%during the acceleration mode, 15%o during the lugging mode,and 50% during
the peaks in either the acceleration or lugging modes.The diesel fuel is limited to a maximum sulfur content of 15 ppm(0.0015%)and
a minimum cetane index of 40 or a maximum aromatic content of 35% volume.:To comply, the facility must purchase a certified
engine and operate and maintain it according to manufacturer specifications. The engine must be fitted with a non-resettable hour
meter. Operation for maintenance checks and readiness testing is limited to 100 hours per year.Operation in non-emergency situations
is allowed up to,50 hours per year,but those 50 hours are counted towards the 100 hours per year provided for maintenance and
testing.There is no time limit on the use of emergency stationary ICE in emergency situations.
The facility is required to keep records of all maintenance conducted on the engine and documentation that the engine is certified.The
facility must also keep records of the hours of operation of the engine that is recorded through the non-resettable hour meter. The
owner or operator must document how many hours are spent for emergency operation including what classified the operation as
emergency and how many hours are spent for non-emergency operation. The facility is also required to submit semi-annual summary
reports of the monitoring and recordkeeping activities.
During the inspection, the diesel fuel-fired emergency generator(EG1)was not operating. It is a 500 kW Caterpillar model DCPXL
engine. The non-resettable hours meter was recently replaced on September 23, 2016, and read 22.9 hours during the inspection.
Before being replaced,the old hour meter read 164.2 hours. Mr. Skrzypczak stated-that the engine is tested twice per week for about
20 minutes. The facility is using ultra low sulfur diesel fuel (ULSD)from Alamance Oil The facility hires Carolina CAT to service
the engine semi-annually. The engine was last fully serviced on July 28, 2016, and partially serviced on January 10, 2017. The last
Page 10 of 14

4
d
semi-annual report was received on January 31,2017(PM: 01/30/17).According to that report,the engine ran a total of 34.2 hours in
CY2016,with most of that operation being due to readiness testing. The facility appears to be in compliance.
Condition 2.LBA contains the requirements for 2D .I I I I which involves the. National Emissions Standards for Hazardous Air
Pollutants (NESHAP) federal regulations promulgated by the EPA. The facility is subject to 40 CFR Part 63, Subpart ZZZZ for
"Stationary Reciprocating Internal Combustion Engines"due to the diesel fuel-fired emergency generator(EG1).Per this rule,engines
are considered"existing" if construction commenced before June 12, 2006, and are considered"new" if construction commenced on
or after this date.EG1 is considered a new source as it was constructed in July 2013 and is for emergency use only. The new engine
has no other requirements under Subpart ZZZZ, except to comply with the requirements of NSPS 40 CFR Part 60, Subpart IIII (see
Condition 2.1.B.4 below).
2.2 —Multiple Emission Source(s)Specific Limitations and Conditions
A. Facility-wide emission sources
Condition 2.2.A.1 contains the requirements for 2D.1806 which requires the facility to control and prevent odorous emissions from
causing or contributing to objectionable odors beyond the facility's boundary.If the DAQ Director determines that a source or facility
is emitting an objectionable odor,then the facility will have to implement maximum feasible controls.During the inspection,there
were not any objectionable odors encountered outdoors near the property boundaries.A review of the facility file showed that no
recent odor complaints have been received by this office.The facility appears to be in compliance.
2.3 Permit Shield for Non Applicable Requirements
Conditions 2.3.A and B state that the facility is shielded from the following nonapplicable requirements as of the date of issuance of
this permit based on information furnished with all previous applications. This shield does not apply to future modifications or
changes in the method of operation:
• 40 CFR Part 60 Subpart Ce does not apply to this facility because this rule is specifically excluded from applicability in 15A
NCAC 02D.0524.
• 40 CFR Part 60,Subpart Ec does not apply to this facility because the HMIWIs were constructed and/or modified before the
applicability date in 40 CFR 60.56c(a).
It should be noted that sections of 40 CFR Part 60,Subparts Ce and Ec are incorporated by reference under 15A NCAC 02D.1206
"Hospital,Medical, and Infectious Waste Incinerators."This permit shield does not exempt the Permittee from complying with all
aspects of 15A NCAC 02D.1206.The facility appears to be in compliance.
Section 3-General Conditions
Condition 3.P-This contains the requirements of 2Q.0508(n)which requires the facility to submit an Annual Compliance
Certification(ACC)to the DAQ and EPA postmarked on or before March I".The ACC should be certified by the responsible official
and address all federally-enforceable terms and conditions in the permit,including emissions limitations,standards,or work practices.
The DAQ-WSRO received the facility's CY2016 ACC report on January 31,2017(PM:01/30/17).It was reviewed and accepted on
February 8,2017,by this inspector.The facility did experience deviations in CY2016 that were summarized adequately. Some of
these deviations resulted in NOVs that are summarized in the"Compliance History"section of this report,below.The facility appears
to be in compliance.
Condition 3.X—This contains the requirements of 2Q.0207 which requires the facility to submit an Emissions Inventory(EI)to the
DAQ by June 30a'each year.The El must include each air pollutant listed in 2Q.0207(a)from each emission source within the facility
during the previous calendar year and be certified by the responsible official.The DAQ-WSRO received the facility's CY2015 EI on
June 2,2016.The EI was reviewed and accepted on June 17,2016,by this inspector.The facility appears to be in compliance.
Condition 3.MM—This contains the requirements for 21).0540 which requires the facility to control any fugitive dust emissions that
may travel beyond the property boundary and cause a complaint.Upon review of the facility file,no recent fugitive dust complaints
have been received by this office.There was not any fugitive dust encountered during the inspection.The facility's entrance and
parking lot is unpaved,but covered with large gravel that minimizes fugitive dust.Trucks entering and exiting the property did not
cause any dust to go beyond the property boundary during this inspection.The facility appears to be in compliance.
Page 11 of 14

NSPS/NESHAP/112(r)APPLICABILITY
The facility is subject to a New Source Performance Standard(NSPS)regulation.The facility is subject to 40 CFR Part 60, Subpart
IIII"Stationary Spark Ignition Internal Combustion Engines"due to the diesel fuel-fired emergency generator(EG1)as discussed
under Condition 2.1.B.3 above.
The facility is not subject to 40 CFR Part 60,Subpart Ce"Emission Guidelines and Compliance Times for Hospital/Medical/
Infectious Waste.Incinerators"nor Subpart Ec"Standards of Performance for New Stationary Sources:Hospital/Medical/Infectious
Waste Incinerators,"but only those parts incorporated by reference in 2D.1206 as discussed under Conditions 2.3.A and B above.
The facility is not subject to 40 CFR Part 61,Subpart FF as it is not a chemical manufacturing plant,coke by-product recovery plant,
or petroleum refinery.
The facility is subject to 40 CFR Part 62, Subpart HHH"Federal Plan Requirements for Hospital/Medical/Infectious Waste
Incinerators Constructed on or Before December 1,2008"as discussed under Condition 2.LA.3 above.,
The facility is subject to a National Emissions Standards for Hazardous Air Pollutants(NESHAP)regulation.The facility is subject to
40 CFR Part 63,Subpart ZZZZ"Stationary Reciprocating Internal Combustion Engines"due to the diesel fuel-fired emergency
generator(EG1)as discussed under Condition 2.LBA above.
The facility is not subject to 40 CFR Part 63,Subpart Q as the cooling towers are not operated with chromium-based water treatment
chemicals.The facility is not subject to 40 CFR Part 63,Subpart DD as the facility is not a major source of hazardous air pollutant
(HAP)emissions.The facility is not subject to 40 CFR Part 63, Subpart EEE as ESO1 and ES02 are not hazardous waste incinerators.
The facility does not use,store,or manufacture any of the regulated substances in quantities above the thresholds for the Section
112(r)program involving Risk Management Practice(RMP)requirements.They are only subject to the General Duty requirements
contained in the General Condition.
FACILITY EMISSIONS
The following table summarizes the facility wide actual emissions.The actual emissions are from the CY2014 and CY2015 emissions
inventories that were submitted by the facility.
� i
..r, . ......PM_,. _...._.'..,,...` . 0..79 ........... .. .0.95....,.:.: +20.3..._.....
PMIo 0..59 0.75 +271
{— +160.0
[ PMzs...... :. 0.20 0.52
SOz ...... ... ,0.23 0..24„,. +4 3
NOx........ 13.57 18.01 +32.7
._.
......
CO 0.54 0.53 19
VOC ' 0.80 0.85 +6 3
.Y.W HAPTocd . _............. 0,58. � ......,.,.,.., .,, 0.079 _, 86.4.
! HAPx,ghest 0.52(Chlorine) 0 069(HCl) N/A
PERMIT CONSIDERATIONS
There are not any permit considerations to be made at this time.
Page 12 of 14

a
COMPLIANCE HISTORY(LAST 5 YEARS)
April 21,2017(shortly after the date of this inspection)-The facility received a Notice of Violation and Notice of Recommendation
for Enforcement(NOWNRE)due to the facility experiencing two events(one on February 21,2017 with a 5-minute duration
involving ES02 and one on February 26,2017 with an 8-hour duration involving ES01)in which the HMIWI control systems were
bypassed.The two bypass stack events were violations of 2D .1206 as referenced by Condition 2.1.A.2.o of Air Quality Permit
05896T25.The facility preemptively responded to this NOVNRE with a letter received on March 31,2017.The DAQ-WSRO is still
waiting on any further response.
October 24,2016-The facility received a NOWNRE after the facility experienced an event on September 26,2016 with a duration of
thirteen minutes during which the control system for ES02 was bypassed due to operator error of the incinerator control panel.This
was a violation of NSPS 40 CFR Part 60,Subpart Ec and 2D.1206 as referenced by Condition 2.LA.LbA of Air Quality Permit
05896/T24.A response was received on November 17,2016,detailing that the facility has retrained their operators on the use of the
bypass stack and has installed a plastic cover to the bypass stack control button.The facility was assessed a civil penalty of$5,208 on
March 16,2017.
November 2,2015-The facility received a Notice of Violation(NOV)after the facility experienced five events comprising a total
duration of fourteen minutes during which the HMIWI control system on ES01 was bypassed due to a discontented employee
tampering with the control panel on September 16-17,2015.This was a violation of Air Quality Permit 05896/T23,Condition
2.1.A.1.b.4 for 2D.1206 and NSPS Subpart Ec.The facility responded on November 16,2015,with a plan regarding training of
employees to ensure this type of violation does not reoccur.
July 10,2015-The facility received a Notice of Deficiency(NOD)for a late submittal of the CY2014 Emissions Inventory,including
certification page and supporting calculations,as required by Air Quality Permit 05869/T22,Condition 3.X.This documentation was
due on June 30,2015,and was ultimately received on July 7,2015.
February 18,2015-The facility received a NOV due to the discovery(by Hilary King, former DAQ-WSRO Environmental Engineer,
during his compliance inspection on February 3,2015)that the ammonia tank that supplies the SNCR units(CD07 and CD08)with
reagent ran dry during incinerator operation for approximately one hour on December 12,2014. This is a violation of Air Quality
Permit 05896/T22,Condition 2.1.A.1.The facility responded on March 13,2015,with a plan of procedural changes to ensure this type
of violation does not reoccur.
January 15,2014-The facility received a NOWNRE due to ES02's exceedance of the 3-hour average lead emissions limit during the
source testing performed on November 19-20,2013.This was a violation of Air Quality Permit 05896/T21,Condition 2.1.A.1 for 2D
.1206 and NSPS Subpart Ce.A civil penalty of$4,208 was paid by the facility on June 11,2014 to settle case#2014-03.ES02 was
ultimately tested again on February 25,2014,and found to be in compliance with the lead emissions limit on March 25,2015,by the
DAQ-SSCB.
October 8,2013-The facility received a NOV due to the facility failing to comply with the emission guidelines to control emissions
from the existing HMIWI(ES01 and ES02)by no later than July 1,2013.This was a violation of Air Quality Permit 05896/T21,
Condition 2.LA.l d for 2D .1206 and NSPS Subpart Ce.The facility performed source testing on November 19-20,2013,to try to
comply with the emission guidelines,but those results lead to the January 15,2014,NOWNRE above.
December 17,2012-The facility received a NOWNRE due to an incident that occurred on October 8,2012,that was reported in a
letter to the DAQ-WSRO received on December 10,2012.The bypass stack cap for ESO1 was inadvertently opened due to human
error for a period of approximately 5 minutes while the incinerator was shutting down for routine maintenance.This was a violation of
Air Quality Permit 05896/T20,Condition 2.LA.1.b.4 for 2D.1206 and NSPS Subpart Ec,On January 4,2013,the DAQ-WSRO
decided not to recommend enforcement because of the following:the bypass stack was open for a relatively short time period;the
incident was not a result of poor maintenance or operator error on the part of the facility,but because of poor communication of
between the equipment vendor and facility management;and the facility implemented a new Standard Operating Procedure requiring
all outside vendors to meet with the Facility Manager and Maintenance Supervisor prior to beginning work to ensure the incinerator is
completely shut down.
CONCLUSION
Page 13 of 14

Stericycle,Inc.appears to be operating in compliance with all appropriate regulations based upon the visual observations and the
DAQ records at the time of this inspection.
Page 14 of 14

NC DAQ Source Test Observers Checklist - Reference Method CEM Testing
" Facility Name/Location : �� LrG ,�tt -"I�n�
Facility Contact/Phone#: tcw1 SiC7 1 X a
Testing Firm/Contact:
Permit#/Source Tested:
Applicable Regulation/Pollutant: d�
i eac\ , ccy-6vv,;
Process Data/Production Rate(see reverse side):
Sample Date/Time:Runj-44' / ` '-3G- . ` Run 2 Run 3-44i@t/
Ask tor an explanatio7to any question answered"No'and attach comments to tins torm.
Method 1 - Sample and Velocity Traverses for Stationa Sources CYW NO
1.1)Method 1 calculated correctly(see reverse side)? tom/
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 CYES 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)
2.6)Pitot tube heads oriented to axis of flue?/Pitot tube perpendicular to axis of stack?
2.7)Temperature recorded at each sampling point?
Method 3 -Gas Analysis for 02,CO, and Dry Molecular Weight YES
Skip this section if O,&CO,concentrations are determined via analyzers.
3.1)Or at or Fyrites used?(circle)
3.2)Or at performed in triplicate?Analysis consistent?
r
Method 4 -Determination of Moisture Content in Stack Gases YEJ& NO
V5.2)
pingers used or some other type of condenser? Multi point sample?
O in first 2 impingers,3rd impinger empty,silica gel in 4 impinger?
mperature at the exit of impingers 7 condenser<68F?(see reverse side)
ica gel in.good condition?-Blue-new,Pink-spent(unable to absorb more H2O)
Methods: ethod 3A-O /CO M6C-SO , M7E-NO , M10-CO YE NO
stem leak check performed during test day?(not required per method but good Q.A.)
mple point Win centroid of stack(compliance test)?
5.3)Sample conditioner/dryer used?
5.4)Heated sample line used prior to sample conditioner?
5.5)Moisture visible in the sample line? (Do not explain a"No")
5.6)Filter used:"In stack"or"heated out of stack" I
5.7) Sample system flow rates within 10%of calibration flowrates?
5.8)All concentration measurements below the span value for that pollutant?
5.9)Data Recorder:Digital/Strip chart/Manual/other (circle one)
5.10)NO,monitoring:NO2 to NO convertor operating?Total NO,,being analyzed?
5.11)Calibration Error Check performed for all analyzers and within specifications(2%of span)?
5.12)System Bias Check performed for each analyzer before the first run,between each run,and after the last run?
5.13 Test team monitoring analyzer zero drift and calibration drift between each run?
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.
r
°t09

Process Data:It is absolutely imperative for the facility to record the pertinent data Iging 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 la 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.)
RKt ❑arreters LWreemfronHwDsturtanoe* (ostarmA)
5 1.0 1.5 2.0 2.5
ell
!412� %r Gael s � ❑st rr
- "4e 1
o st Lrbb
16 Sack OcyMer>a61 (24 irt)
TTi�ee�c�F 12
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Figure 1-2,Minimum number of traverse points for velocity(nonparticulate)traverses. k
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 100ft 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. f
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.
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