HomeMy WebLinkAboutAQ_F_0100010_20220913_CEM_RptRvwLtr (4) Etc STATE
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ROY COOPER
Governor
ELIZABETH S.BISERf,z�M
Secretary
MICHAEL ABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
September 13, 2022
Mr. Kirk Yarbrough
Facility Manager
Stericycle, Inc.
1168 Porter Avenue
Haw River,North Carolina 27258-9547
SUBJECT: Review of 2022 Semiannual CO/02 CEMS Report, First Half
Stericycle, Inc. —Haw River Facility
Haw River, Alamance County,North Carolina
Air Permit No. 05896T25
Facility ID No. 0100010
Dear Mr. Yarbrough:
Thank you for your timely submittal of the subject report, dated July 27, 2022. The
excess emissions report assessed the carbon monoxide (CO)/oxygen(02) continuous emissions
monitoring systems (CEMS) operating at the Haw River Facility during the first half of 2022.
Additional clarification regarding CO emissions was provided via conference call on September
12, 2022. The Division of Air Quality (DAQ)has completed its review of the CEMS-related
information in the report and has the following comments:
1. The CO/02 CEMS were installed on Stericycle's hospital, medical, and infectious waste
incinerators (HMIWI) ESO1 & ES02 pursuant to 15A NCAC 02D .1206—Hospital, Medical,
and Infectious Waste Incinerators and Air Permit No. 05896, Specific Condition 2.1.A.2.t.
2. The report was reviewed for compliance with the CO emissions limit of 11 parts per million
by volume (ppmv, 7% 02, 12-hour block average) as listed in Table I to 40 CFR Part 60,
Subpart Ce—Emission Guidelines and Compliance Times for Hospital/Medical/Infectious
Waste Incinerators [15A NCAC 02D .1206(c)(3)] and Specific Condition 2.1.A.2.a. The
report indicated that a bypass event occurred on April 28, 2022, which resulted in a Notice of
Violation/Notice of Recommendation for Enforcement being issued on May 18, 2022,by the
DAQ Winston-Salem Regional Office.
3. A review was also conducted for compliance with good operation and maintenance (O&M)
practices pursuant to 15A NCAC 02D .0611(d) and General Condition 3.17. When compared
to the total quarterly operating time of the incinerators, percent excess emissions (%EE) and
percent monitor downtime (%MD)were reported as follows:
D Q2177 North Carolina Department of Environmental Quality I Division of Air QualityE West Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699-1641
NORTH CAROLINA
oePanment of Environmental Uwi\ /� 919.707.8400
Mr. Kirk Yarbrough
September 13, 2022
Page 2
Unit Quarter %EE %MD
HMIWI ES01 1st 0.0 0.0
2nd 0.0 0.0
HMIWI ES02 1st 0.0 0.1
2nd 0.1 0.0
DAQ considers source to have operated using good O&M practices for minimizing emissions
if quarterly%EE and%MD are less than 6% for any single calendar quarter and less than 3%
for two consecutive quarters.
4. Finally, a review was conducted on periodic quality assurance (QA) tests pursuant to
Section 5 of 40 CFR Part 60 Appendix F, Procedure 1 - Quality Assurance Requirements for
Gas Continuous Emission Monitoring Systems Used for Compliance Determination and
Specific Condition 2.1.A.2.t. Quarterly audits must be conducted—either a cylinder gas
audit(CGA) or a relative accuracy audit(RAA)—with a relative accuracy test audit (RATA)
being conducted at least once every four calendar quarters. During the first half of 2022, a
CGA on the CO/02 CEMS was conducted on March 4, 2022, March 23, 2022, and June 23,
2022, with reported results appearing to have met the 15% accuracy requirement of
Procedure 1.
In addition to the mailing of this letter, an electronic copy(e-copy) is being provided for
your records. If you should have any questions,please contact me at(919) 707-8493 or
alan.drake@ncdenr.gov.
Sincerely,
a rake, Environmental Engineer
Division of Air Quality,NCDEQ
c: Kirk Yarbrough, Stericycle (e-copy)
Don Nuss, Stericycle (e-copy)
Ray Stewart, DAQ WSRO (e-copy)
Gary Saunders, DAQ SSCB (e-copy)
IBEAM Documents, 0100010 (e-copy)
Central File, Alamance County