AQ_F_0100010_20210518_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY Stericycle,Inc.
NC Facility ID 0100010
Inspection Report County/FIPS:Alamance/001
Date: 05/18/2021
Facility Data Permit Data
Stericycle,Inc. Permit 05896/T25
1168 Porter Avenue Issued 12/19/2016
Haw River,NC 27258 Expires 11/30/2021 ,
Lat: 36d 3.9660m Long: 79d 20.9230m Class/Status Title V
SIC: 4953/Refuse Systems Permit Status Active
NAICS: 562213/Solid Waste Combustors and Incinerators Current Permit Application(s)TV-Renewal
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Don Nuss Kirk Yarbrough Don Nuss MACT Part 63: Subpart ZZZZNSPS: Subpart Ce, Subpart Ec,Subpart IIII
Regional Compliance Facility Manager Regional Compliance
Manager [phone] Manager
[phone] [phone]
Compliance Data
Comments:
Inspection Date 05/18/2021
Inspector's Name Davis Murphy
Inspector's Signature: 922v ` '� Operating Status Operating
Compliance Status Violation-emissions
Action Code FCE
Date of Signature: TRS Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2019 0.9800 0.2200 20.72 0.8200 0.8900 0.7800 37.27
2018 0.9400 0.2300 19.91 0.8000 0.6900 0.7500 26.58
2017 1.0000 0.2300 21.35 0.8500 0.5000 0.8000 55.93
Hi hest HAP Emitted in ounds
1

Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
04/15/2021 NOV/NRE 2D.1206 Hospital,Medical,and Infectious Waste Pending
Incinerators
12/02/2020 NOV/NRE 2D .1206 Hospital,Medical,and Infectious Waste Pending
Incinerators
09/25/2020 NOV/NRE 2D.1206 Hospital,Medical,and Infectious.Waste Pending
Incinerators
04/20/2020 NOV/NRE 2D.1206 Hospital,Medical,and Infectious Waste 04/30/2020
Incinerators
09/11/2019 NOV/NRE 2D .1206 Hospital,Medical,and Infectious Waste 09/11/2019
Incinerators
07/16/2019 NOV/NRE 2D.1206 Hospital,Medical,and Infectious Waste 07/31/2019
Incinerators
05/18/2018 NOV/NRE 2D .1206 Hospital,Medical,and Infectious Waste 06/04/2018
Incinerators
11/08/2017 NOV/NRE Part 60-NSPS Subpart Ec Hospital/Medical/Infectious 11/17/2017
Waste Incinerators for Which Construction is
Commenced>June 20, 1996
11/08/2017 NOV/NRE 2D.1206 Hospital,Medical,and Infectious Waste 11/17/2017
Incinerators
04/21/2017 NOV/NRE 2D .1206 Hospital,Medical,and Infectious Waste 05/19/2017
Incinerators
04/21/2017 NOV/NRE Part 60-NSPS Subpart Ec Hospital/Medical/Infectious 05/19/2017
Waste Incinerators for Which Construction is
Commenced>June 20, 1996
10/24/2016 NOV/NRE Part 60-NSPS Subpart Ec Hospital/Medical/Infectious 11/18/2016
Waste Incinerators for Which Construction is
Commenced>June 20 1996
Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
04/07/2021 Pending
Introduction
On May 18,2021,Mr.Davis Murphy of the DAQ Winston-Salem Regional Office contacted Mr.Kirk Yarbrough;Facility Manager,
and Don Nuss,Regional Compliance Manager,of Stericycle,Inc.for a targeted compliance inspection.This site is a hospital,medical,
and infections waste incineration facility that operates two identical incinerators.Mr.Yarbrough indicated that this facility operates 24
hours per day,7 days a week,and 52 weeks per year.This facility was previously inspected by former DAQ-WSRO Compliance
Supervisor Taylor Hartsfield on September 2,2020,and appeared to be in compliance with their Air Quality Permit at the time.
IBEAM contact information was confirmed as correct.Mr.Murphy reviewed the coordinates for this facility in IBEAM and found
that they were correct.
PERMITTED SOURCES
Emission Source Emission Source Description Control Control Device Description
ID No. Device
ED No.
ESOI dual chamber hospital,medical CD07 one selective non-catalytic
and infectious waste incinerator reduction(SNCR)system with
(HMIWI)firing natural gas(4.6 ammonia or urea injection(19,700
million Btu per hour primary ACFM, outlet airflow rate
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Emission Source Emission Source Description Control Control Device Description
ID No. Device
ID No.
chamber burner and 6.0 million,,. CD01 one packed bed scrubber and
Btu per hour secondary chamber,. . associated quench column
burner)
C003 venturi scrubber equipped with a
mist eliminator
CD05 one sulfur impregnated carbon bed
6,000 ACFM, inlet airflow rate
ES02 dual chamber hospital, medical CD08 one selective non-catalytic
and infectious waste.incinerator reduction(SNCR)system with
(HMIWI) firing natural gas(4.6 ammonia or urea injection(19,700
million Btu per hour primary ACFM,outlet airflow rate) .
chamber burner and 6.0 million CD02 one packed bed scrubber and
Btu per hour secondary chamber associated quench column
burner)
CD04 venturi scrubber.equipped.with a
mist eliminator
CD06 one sulfur impregnated carbon bed
(6,000 ACFM,inlet airflow rate).
EG1 diesel-fired emergency generator N/A N/A
(MACT,ZZZZ; (500 kilowatts maximum
NSPS,I1I capacity)
1}NSIGNIFICANT/EXEMPT SOURCES -
Emission Source ID No. Emission Source Description
I-CT-1 and Two cooling towers(55,200 gallons per hour water
I-CT-2 recirculation rate each
I-AMM Facility-wide storage of 19% aqueous ammonia
Safety/COVID-19 Information
Inspectors visiting this site are required to wear the following PPE: Steel-toed shoes,a reflective vest,and safety glasses.Hearing
protection may be needed in certain areas.
Due to the COVID-19 virus,the facility is implementing the following safety measures:
• Visitors are required to answer screening questions upon arrival at the property:
• Social distancing in mandatory,and facemasks are required to be worn when social distancing is not possible.
In accordance with DAQ's Regional Office Field Inspection Re-Entry Plan,Mr.Murphy took the following precautions during his
preparation for this inspection and following the inspection:
• The facility confirmed,via email,that they were following social distancing and masking precautions,
• Records review was conducted in a conference room where social distancing could be maintained.
Applicable Regulations
According to Air Permit 05896T24,this facility is subject to Title 15A North Carolina Administrative Code(NCAC)2D.0516,2D
.0521,2D.0524(40 CFR Part 60 Subpart IIII),2D.1100,2D.1111 (40 CFR Part 63 Subpart ZZZZ),2D.1206,2D.1806 and 40 CFR
Part 62, Subpart HHH.The facility is also subject to additional rules listed in the general permit conditions.This facility is not subject
to RMP requirements of the 112(r)program since it does not use or store any of the regulated chemicals in quantities above the
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threshold levels in the rule.They are subject to the General Duty Clause.It is noted that aqueous ammonia is a 112(r)listed material,
but only in concentrations of 20%or greater.Since this facility uses 19%aqueous ammonia,they are not subject.
Discussion
This facility operates two dual chamber hospital,medical,and infectious waste incinerators(HMIWI)(ESO1 and ES02).Each unit is
equipped with a 4.6 million Btu per hour natural gas burner for the primary chamber and 6.0 million Btu per hour natural gas burner
for the secondary chamber.The control system for each incinerator consists of a selective non-catalytic reduction(SNCR)system with
ammonia or urea injection(CD07&CD08),a packed bed scrubber and associated quench column(CDO1 &CD02),a venturi scrubber
equipped with a mist eliminator(CD03&CD04),and a sulfur impregnated carbon bed(CD05 and CD06).The control systems
operate in series.The following description of the process for this facility was borrowed from the previous inspection report(Taylor
Hartsfield,9/2/2020):
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/furan
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.
During the inspection Mr.Murphy observed both incinerators operating.Boxes of HMIW are brought from trucks and sorted on the
tipping floor.Any.waste that cannot be processed at this facility(such as dental waste)is flagged and sent to one of the company's
other sites for processing.These boxes represent a."charge"of material,which is scanned in and weighed prior to being incinerated.
The units may incinerate up to 10 charges per hour,weighing up to 180 pounds each.A single charge takes about 6 minutes to pass
through an incinerator.Charge rates and controls system operating parameters during the inspection are summarized in the table in the
"Permit Conditions"section of this report.Mr.Murphy observed the control system and it appeared to be in good working order..Most
of the controls operate under an induced draft,as a fan is located after the venturi scrubber on each unit,with an additional fan also
being located after the carbon beds.Following the carbon beds,emissions are ducted to a rooftop stack for each unit.Mr.Murphy
observed the stacks from the front of the facility and did not see any visible emissions,although it was noted that there was a detached
steam plume on both units on the day of the inspection.Each unit has a respective bypass stack for emergencies located prior to the
control systems,also located on the roof.
The facility has a diesel-fired emergency generator(EG 1)that was not in operation during the inspection.The engine is equipped with
a non-resettable hours meter that read 165.7 hours during the inspection.That represents an increase of 20.9 hours since the last
compliance inspection.The engine is tested weekly.In the event of an emergency the engine starts automatically to avoid incinerator
power loss,which could lead to the bypass stacks opening if power is lost for more than seven seconds.
Two exempt cooling towers(I-CT-1 and I-CT-2)provide water for the quencher,which reduces exhaust temperature.They were not
observed during this inspection.
Specific Permit Conditions/Regulations&Reporting
Condition 2.LA.1 contains the requirements for complying with 15A NCAC 02D.I 100-"Control of Toxic Air Pollutants."The
facility has modeled emissions limits for 12 TAPS in their permit.For the most part,the facility complies with these limits by
complying with permit condition 2.1.A.2,but there are a few specific requirements under this condition,including:
• The charge rate for the incinerators is limited to 1,870 pounds per hour,each.
• The stack heights are limited to 82.4 feet above ground level,
• The facility is required to take specific measures to reduce bypass events,including:
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o Installing an uninterruptible power supply for the control system.to limit reboot time for the programmable logic
controllers.
o Installing a power outage indicator as an input to the PLCs.
. o Programming the PLC such that the bypass stacks re-close within 5 minutes after,a,power failure.
o Installing a low fuel indicator on the generator fuel tank
o Installing a water pressure.indicator to,alert operators of a-loss of water supply.
o Assure continuous removal of ash from the primary chamber,
o. Reduce combustion air to the primary chamber by alternately shutting the fan off:and on in 1-minute..cycles to
achieve a 50%air flow reduction during bypass events.
The facility'is,also required to test for cadmium and mercury by permit condition 2.1.A.2.This condition also contains a requirement.
to not incinerate dental,waste.
During;the inspection the 3-hour average charge rate of ESO1 read 1,671.9 pounds per houron the data acquisition system(DAS),
utilized by the facility. The photo this inspector took of the DAS screen for ES02 during the inspection was inadvertently deleted so
the charge rate for.this incinerator is not available,however Mr.Yarbrough sent Mr.Murphy a photo of the screen during routine
operations on June-7,2021,and the charge rate for unit was 1734 pounds per hour.Photo snapshots of the DAS data from the
facility are shown at the end of this report.The stacks for.the units have been previously verified to be complaint with this condition
and appeared to be unchanged during the inspection.Previous inspection reports have documented.that the measures listed above to
reduce bypass events have been implemented.Compliance with this condition is indicated.Further,discussion regarding compliance.
with these requirements is shown below in the 2.1.A,2 discussion:
Condition 2,1;A.2 contains the requirements for complying with 15A'NCAC 02D.1206.The two HMIWI Are`subject'to the following
emission limits,as listed in Table 113 to 40 CFR Part 60,Subpart Ce:
Particulate matter 25 milligrams per dry standard cubic meter 9.97 mg/dscm 14.3 mg/dscm
(PM) (mg/dscm)
u. [0.011 (grains per dry standard cubic foot
(.gr/dscf)l ).
Carbon monoxide I Lparts per million by volume{ppmv) Not Tested Compliance demonstrated w/
CO CEMS
Dioxins/furans 9.3 nanograms per dry standard cubic meter
total dioxins/furans(ng/dscm)
[4.1 grains per billion dry standard cubic feet Nottested
(gr/109 dscf)]-or
0,054 n dscm TEQ rO.024 `r/109 dscfl
Hydrogen chloride 6.6 ppmv .0940 ppm 1.74 ppm
HCl
Sulfur dioxide 9.0 ppmv
S02 Not tested
Nitrogen oxides. 140 ppmv
Lead 0.036 mg/dscm 0.0152 mg/dscm 0.0167 mg/dscm
(Pb) [0.016 grains per thousand dry standard cubic
feet r/103 dsc
Cadmium 0.0092 mg/dscm <0.00140 mg/dscm <0.000737 mg/dscm
Cd _ 0.0040 r/103 dscfl
Mercury 0.018 mg/dscm <0.00203 mg/dscm <0.000896 mg/dscm
H 0.0079 r/103 dsc -T
*Limits based on 7%oxygen(dry basis)
"Limits based on a three-run average with a minimum sample time of one hour per run,except for dioxins/furans
which is based on a three-run average with a minimum sample time of four hours per run
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Emissions Limits and Parameter Monitoring Discussion
The facility is also subject to 6%opacity limit.Emissions testing is required annually for opacity and every three years for PM,HCL,
mercury,cadmium,and lead if compliance is indicated.If there is a violation of the PM or HCL standard,retesting is required more
frequently for those pollutants.For each stack test.conducted,the Permittee shall track and record details for the waste being burned
and the material that may be carried over into the,stack test period. Stack testing was performed at this site from April 6-'7,2021,and
a test report was received at the DAQ-WSRO on( ay 6,2021.Preliminary results(shown in the table above), indicate compliance
with these limits,however this report awaiting approval.from DAQ Stationary Source Compliance Branch.Compliance with the
opacity limits was also demonstrated during the testing in April 2021.Repeat performance testing for NOx and S02 is not required,
and compliance was demonstrated for NOx on both units during performance testing on April 29 and May 1,2015.Compliance was
demonstrated for`S02 om both units during performance testing on May 17 and May 23,2013.During performance testing(both initial
and repeat testing),the facility is required to.establish minimum and maximum operating parameter values for the incinerators and
associated control systems.These parameters must be monitored and recorded during operations.These parameters,and their
subsequent`minimums/maximums,are shown in the table below.All parameters are required to remain within the acceptable range as
measured on a 3-hour rolling'average. -
Maximum charge.rate 1,870.0 pounds per hour 1,870.0 pounds per hour
Maximum flue gas'/carbon bed inlet temper ature 168.1 OF 164.1 OF
Minimum se 6ondary chamber temperature 1,762.8°F 1,759.5°F
Minimum pressure drop across the venturi scrubber 39.0 inches of water 38.9 inches of water
Minimum packed bed scrubber liquor flow rate 65.2 gallons per minute 66.7 allons per minute
Minimum packed bed scrubber liquor pH . 4.10 4.1
Minimum SNCR reagent,flowrate urea: 1.1 gallons per hour urea: 1.2 gallons per hour
-or- -or-
ammonia: 1.0gallons per hour I ammonia: L&gallons per hour
*Parameters as defined in 40 CFR 60.5Ic:
**Each parameter is measured on a 3-hour rolling average.
'The facility is also required to install devices to monitor and record the following:
• 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 continuous monitor for both oxygen and CO in order to determine,proper operation of each HMIWI.
The facility is required to continuously monitor each parameter.The incinerator charge rate must be recorded hourly and
other parameters must be recorded every minute.Valid monitoring data must be obtained for 75 percent of the operating
`hours per day for 90 percent of the operating days per calendar quarter that the facilityy is combusting hospital waste and/or
medical/infectious-waste.
Failure to maintain these parameters for three-hour average constitutes a violation of the established operating parameter.
A violation of the emissions limits occurs if any of the operating scenarios listed below occur:
"A ME, lo : .,� .,.., .w,. _ '.,' a' ' ni�sston,�Lmlt Yilatl .F'
• Above maximum charge rate AND PM
• below minimum pressure drop across venturi scrubber
• Above maximum charge rate AND CO
• below minimum secondary chamber temperature
• Above maximum charge rate AND
• below minimum secondary chamber temperature AND Dioxin/furans
• below minimum venturi scrubber liquor flow rate
• above maximum charge rate AND HCl
• below minimum packed bed scrubber liquor pH
• above the maximum carbon bed inlet temperature
AND Hg
• above maximum charge rate
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• Uses bypass stack 'PM,dioxin/furan,HCI,Pb,Cd and H
• Above maximum charge rate AND
• below minimum secondary temperature AND NOx
No below minimum reagent flow rate
Visible emissions must be observed daily from the emission point of each HMIWI for any emissions above normal and
recorded in a:logbook.A CO CEMS.iriust be installed to determine compliance with the CO emissions lnnit and the CEMS
must be operated in accordance with Appendices B and F of 40 CFR Part 60.
Mr. Murphy.reviewed records ofvisble emissions observations for this facility and found them to be acceptable. The facility
records these inspections daily during routine maintenance activities. Mr. Murphy reviewed the facility's'continuous
monitoring data and found that their monitoring/recording system appeared to be in compliance with this permit condition.
The data required under this condition is voluminous in nature,so it was not feasible for Mr.Murphy to review this data in
its entirety. The facility also has an interlock system that prevents charging of the units if the'operating parameters are not
being met.As previously mentioned, the facility has a DAS for monitoring all required operating parameters and'use of the
bypass stack. Photo snapshots of the.DAS data from the facility are shown'at the end of this report,i and compliance with the
parametric limits is shown during these timeframes, According to the last semi-annual reportreceived February 1,2021
(PM, 01129110),for ESOI_and ES02,the facility had 0.0`hour's of inoperative monitor data for both units.Mr. Murphy
viewed the CO CEMS for each unit and discussed it operations with Mr. Yarbrough.During the inspection Unit I was
reading 0.785 PPM and 9.95%Oa while Unit 2 was reading 0.032 PPM and 11.1%02.Mr. Murphy also reviewed the most
recent calibrations for each CEMS and the gas cylinders and found them to be acceptable. Each unit has a gas conditioner
located near the ID fan above the incinerators. Compliance is demonstrated
operational Standards and Inspection and Maintenance
The facility may only incinerate waste that is defined as hospital waste or medical/infectious waste, international garbage, ,
,confidential documents generated by the healthcare industry,controlled substances captured by law enforcement agencies,
non-hazardous trace chemotherapeutic waste materials,or non-hazardous pharmaceuticals.Dental waste may not be
incinerated.
The facility is required to'perform an annual inspection of each HMIWI,and an annual inspection of each control device
associated with the HMIWI.Each control device inspection must 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 the inspections must be completed within 10 days unless an extension is
granted by DAQ.
Specific requirements apply to the carbon beds,including:
• Operating two beds in series,with the second bed serving as a guard. -
• Replacing each carbon bed or the carbon in the bed before it has reached the end of its useful life.
• Using the same type of activated carbon used during the most recent performance-test that demonstrated compliance .
with the Hg emission limit, until a subsequent performance test is conducted.A different type of carbon may be
substituted,as long as the replacement has equivalent properties compared to the carbon used in the most recent Hg
performance test.
+ Monitoring of the carbon beds shall be conducted consistent with the manufacturer's specifications and
recommendations.
•, Records of performance monitoring and monitoring procedures must be maintained.
The facility is required to develop and submit a waste management plant to DAQ by January 301h of each calendar year and must
implement the waste management plan in its entirety.The waste management plan must address the management of dental waste.
Each HMIWI may not operate unless a trained and qualified operator is accessible at the facility or within one hour,of the facility.
Operators must be trained by completing the requirements of 40 CFR 60.53c(c)through (g).The facility is required to conduct an
annual review of the requirements of 40 CFR 60.53c(h)(1)through(h)(10)with each operator.
7

As discussed above,the factlity has a procedure in place to scanllog all incoming waste and ensure that only acceptable waste is
processed. Dental waste contains a gray.label with and is coded in the system to be sent to an.autoclave for processing. Mr. Murphy
reviewed the 1&Mrecords for the facility. PMs on Unit] and its associated controls were performed on-March 25, 2021, and on Unit
2 and its associated controls on April 26,2021. The carbon bed manufacturer recommends replacement of the carbon every 2-3 years.
The facility washes the carbon every 3 weeks, when the pressure drop starts getting high.Honeywell performed calibrations of the
monitoring equipment associated with Unit 2 on April 26, 2021.Mr.Murphy reviewed the calibrations and they appeared to be
adequate. Mr. Yarbrough indicated that calibrations for,Unit 1 would be performed in a couple of weeks.Annual inspections for both
units were planned for late May and June..The facility maintains a waste management plan and submitted it as required to DAQ
WSRO on January 29, 2021. The plan was last revised on November 11,2005, and Pages 3-S of the plan specifically address the
management of dental waste. The facility currently has five operators on staff.A 24-hour refresher training was performed from
August 4 to August 6,2020.Mr.Murphy reviewed the training records and found them to be acceptable. Mr. Yarbrough indicated that
the training is'typically:an.8-hour refresher.
Recordkeening%Reporting
The facility.is required to maintain records of the following for a minimum of five years:
•. All CEMS and.monitoring parameter data listed above,on the prescribed frequency,in the permit.
• Amperage to the wet scrubber and temperature at the wet scrubber outlet during each minute of operation.
• Records of all inspection,maintenance,and repair activities for HMIWI and control device.
• Identification of days and times for which emission rates or operating parameters were not maintained or exceeded the
applicable limits,the reason for such instances,and a description of corrective actions taken.
•- The,results of any performance tests and a description of how operating parameters arere-established.
• Records of HMIWI operator training. \
• Calibration records.
• Visible emissions monitoring records.
- A semiannual report is required and must include the highest maximum and lowest minimum operating parameters recorded„for each
operating parameter for the previous calendar year.The report also must include dates where monitoring data was not collected,or
exceedances were indicated:
As previously discussed,.all records were reviewed, and.the facility appears to be maintaining the required records. The required
semiannual report was received on February 1,2021 (PM.•01129121)and it contained all the necessary elements. The facility appears
to be in compliance.
Condition 2.2.A.1 references 15A NCAC 02D ,1806,which requires that-the facility prevent odorous emissions from causing or
contributing to objectionable odors beyond the facility's boundary.Mr.Murphy did not note any objectionable odors during this
inspection.A review of DAQ records did not find any complaints pertaining to this facility.Compliance is demonstrated.
General Conditions
General Condition 3.X requires this facility to submit an emissions inventory by June 30.of each year.The CY 2020 inventory was
received on June 18;2021 and a certification page was received on June 30,2021.The inventory is currently being reviewed;
compliance is demonstrated.
General Condition 3.MM lists the 2D.0540 fugitive dust requirements.This rule states that the facility shall not cause or allow
fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary.Mr.
Murphy did not note any fugitive dust emissions during this inspection.It seems reasonable to expect compliance.
NSPS/NESHAP
This facility is subject to the following NSPS and NESHAP regulations:
NSPS:Subpart 1111
This rule applies to the emergency generator.The requirements for the engine under this rule are summarized as follows:
• The engine must comply with the emission standards 40 CFR 60.4202 and the facility must comply by purchasing
an engine certified to these emission standards for the same model year and maximum engine power.The facility
also must operate and maintain the engine according to the manufacturer's emission related-written instructions over
the entire life of the engine.
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• The engine must burn ULSD.
• The engine must be equipped with a non-resettable hour meter.
• The engine is limited to 100 hours of operation per year for maintenance.checks and readiness testing and up to 50 hours per
year for certain types of non-emergency use,which is counted as part of the 100 hours per year for maintenance and testing.
Usage during emergency situations is unlimited.
• The facility must perform I&M on the engine as recommended by the manufacturer and maintain the results of all I&M in a
logbook.
As discussed above,the engine is equipped with a non-resettable hour's meter that read 165.7 hours during the inspection.That
represents an increase of 20.9 hours since the last complianm inspection.Mr.Yarborough provided Mr.Murphy with maintenance
records for the engine.The engine was serviced on January 7,2021.Previous DAQ compliance inspections have documented that this
engine is certified.The engine burnsl5.PPM ULSD,as required.Compliance is indicated.
NESHAP:Subpart ZZZZ.
This rule applies to the emergency generator.Compliance with this rule is demonstrated by complying with.40 CFR.Part 60
Subpart IIII and no further requirements apply.
Facility Wide Emissions
The following table summarizes the facility wide actual emissions.The actual emissions are from the CY2018 and CY2019
emissions inventories that were submitted by the facility'.Differences in CY2018 and CY2019 emissions are due to the
following: 1)Increased natural gas use;2)Increased incinerator throughputs;and 3)Decreased diesel generator use.The
CY2020 emissions inventory is still under review at the time of this report.
111-1
_0.211wjL �.�. ,• _ terAN .� ,_ W11 . .__. .,
�._.._. 0.94 0.98 __ 4.3
I .1 PM!o 0:75 F. 0:78 4
PM2.5 0.52 0.54 3.8
(( r_... .023. 022 ........4.3
NOx 19.91 20.72 4.1
CO. .. 0.69.. 0.89 29
�........_....... __.. . VOC ...,.. � ..._.. 0.80..,, ... F. .._. 0:82 2.5 ...�.......�___--___.
0.036 ._ .• �_ 16.1
rei HAPTo ...:•: 0.031 _
HAPxishW 0.013 (hexane,n-) 0.019(hexane-n) 40.2
Permit Issues
Condition 2.1.A.2.c incorrectly states that Method 29 shall be used for sampling chromium (VI).Instead, SW 846 Method
0061 shall be used for chromium(VI).
There appears to be an inconsistency between the parameters listed in condition 2.I.A.2.d and the table shown in condition
2.1.A.2.n.One section requires the permittee to monitor the liquor flow across the yenturi scrubber while the other requires
the permittee to monitor the liquor flow across the packed bed scrubber.This inconsistency continues in the table under
condition 2.1.A.2.o as well.
Previous Source Tests ,
The most recent source tests for this facility are summarized below:
On April 6-7,2021,the facility performed testing on both units.Both HMIWI were tested for particulate,visible emissions
(VE),hydrogen chloride(HCI)and metals(lead,cadmium and mercury)using EPA Methods 5,9,26A,and 29.Results are
shown in the specific permit conditions section of this report and indicate compliance.This report awaiting approval from
DAQ Stationary Source Compliance Branch.
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On April 8,2020,the facility performed Method 9 testing of both incinerators for visible emissions.The testing was
performed by Alexander Johnson of TRC Solutions.The visible emissions limit as established in 15A NCAC 21i.1206
"Hospital,Medical and Infectious Waste Incinerators," 15A NCAC 2D.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"is 6%for a rolling 6-minute block average.For both incinerators,the maximum observed opacity was 0%and
the average opacity was 0%0.The results were received on time and indicated compliance with the applicable limit,as
indicated in the DAQ-WSRO memo on May 12,2020.
Compliance History(Last Five Years)
April 15,2021 -The facility received a.Notice of Violation and Notice,of Recommendation for Enforcement(NOV/NRE)due to the
facility experiencing an event on February 1,2021,with a duration of two minutes during which the control system for ESO 1 was
bypassed.The cause of the bypass was a result of a faulty feed hopper limit switch,which resulted in a programmable logic controller
(PLC)fault.At the time of the event,personnel immediately cleared the fault,restarted the air pollution control(APC)system to close
the bypass stack,and placed Unit 1 in shut down. After the shutdown.was completed,the facility investigated,identified,and replaced
a faulty feed hopper limit switch and input card within the PLC.The facility experienced another event on February 3,2021,with a
duration.of two minutes during which the control system for ES02 was,bypassed.The cause of the bypass was a result of a broken
conduit joint which was attributed to excessive hydraulic line vibration.The broken conduit joint led to an electrical short,which
caused a PLC card to fault,resulting in the bypass stack opening.The faulty conduit was replaced and rerouted to avoid vibration.The
bypass stack events were violations of 2D.1206 as referenced by Condition 2.I.A.2;o of Air Quality Permit 05896T25.A response
was not received.This enforcement case has not yet been submitted as of the date:of this report.
December 2,2020—The facility received a Notice of Violation and Notice of Recommendation for Enforcement(NOV/NRE)due to
the facility experiencing an event on October 22,2020,with a duration of three minutes during which the control system for ESO 1 was
bypassed.The bypass was caused by a fault in the programmable logic controller(PLC)which resulted in a control power loss. At the
time of the event,personnel immediately cleared the fault,restarted the air pollution control'(APC)system to close the bypass stack,
and placed Unit 1 in shut down.After the shutdown was completed,the facility investigated,identified,and replaced a faulty 1/0 card
within the PLC.The facility experienced another event on November 13,2020,with a duration of three minutes during which the
control system for ES02 was bypassed.The bypass was caused by a faulty level controller in the cooling tower which caused high
temperature in the absorber. Immediately upon detection, facility personnel restarted the APC system to close the bypass stack and
placed Unit 2 in shutdown.After the shutdown was completed,the facility investigated and identified the faulty level controller and
replaced it.The bypass stack events were violations of 2D.1206 as referenced by Condition 2.1.A.2.o of Air Quality Permit
05896T25.A response was not received.This enforcement case has not yet been submitted as of the date of this report.
April 20,2020—The facility received a Notice of Violation and Notice of Recommendation for Enforcement(NOV/NRE)
due to the facility experiencing an event.on January 31,2020,with a duration of three minutes during which the control
system for ESO1 was bypassed.The cause of the bypass was a result of a relay on the ash system shorting out,which caused
the circuit breaker to trip off..Once the circuit breaker tripped off,the ID fan stopped operating,causing the short duration
bypass.The circuit breaker was reset immediately which restarted the fan.The facility experienced another event on March
29,2020,with a duration of twelve minutes during which the control system for ES02 was bypassed.The cause of the bypass
was a result of a faulty draft transmitter.The faulty transmitter registered a positive draft when,in fact,the system was
shutting down normally.This false positive resulted in the stack cap opening.The scrubber system and ID fan continued to
run normally,but the bypass stack was open.The bypass stack events were violations of 2D.1206 as referenced by Condition
2.1.A.2.o of Air Quality Permit 05896T25.A written response letter was received by the WSRO on April 30,2020.The
enforcement case No.2020-042 has not yet been assessed.
September 11,2019—The facility received a Notice of Violation and Notice of Recommendation for Enforcement
(NOV/NRE)due to the facility experiencing an event on August 13,2019,with a duration of thirteen minutes during which
the control system for ES02 was bypassed.The event was the result of a breach in the piping in the packed bed scrubber
(Control Source ID No.CD02).The breach resulted in a sudden loss of water flow,causing temperatures in the scrubber to
rise to an unsafe level.Use of the bypass stack was necessary to prevent a catastrophic failure of other components in the
scrubber system that cannot tolerate extremely high temperatures.The bypass stack event was a violation of 2D.1206 as
referenced by Condition 2.1.A.2.o of Air.Quality Permit 05896T25.The written response letter received by the WSRO on
July 29,2019,for the July 16,2020 NOV%NRE(see below)was also applied to this violation.Per enforcement case No.
2019-079,the facility was assessed a civil penalty of$10,308.On February 28,2020,the facility filed a petition for a
contested case,and that case is still ongoing.
10

July 16,2019-The facility received a.Notice of Violation and Notice of Recommendation for Enforcement(NOWNRE)due
to the facility experiencing an event on Apri1.22,2019,with a`duration of eleven.minutes during which the control system for
ES01 was bypassed.The event was the result of a short in the light located on top of the ash hoe electrical panel,which
caused a blown fuse in the main control panel for.the stack cap.The blown fuse activated an,uninterruptable power supply
(UPS)system,which continued to deliver power to the control panel as designed. When the batteries in UPS.system were
exhausted,the control systems failed,and the bypass stack cap was opened;-The bypass:stack event was a violation of 2D
.1206 as referenced by Condition 2.1.A.2.o of Air Quality Permit 05896T25:A.written response letter was received by:the
WSRO on July 29,.2019.Per enforcement case No.2019=079,the facility was assessed a civil penalty of$10,308.On..:
February 28,2020,the facility filed a petition fora contested case,and that case is still ongoing.
February 19,2019-The facility received a Notice of Deficiency(NOD)due to the facility fails g'io perform HMIWI`
operator training in CY2018.This was a deficiency,of 2D.1206 as referenced in Condition 2.,I.A.2.ee of Air Quality Permit
05896/T25.A response was received on May 6,2019,and indicated that the training was done.'onJanuary28-30,2019.The
training will be performed in the first quarter,rather than the fourth quarter,of each year going forward:`
May 18,2018-The facility received a Notic a of Violation and Notice of Recommendation for:Enforcement(NOV/NRE)
due to the facility experien.cing an event on'April 15,2018,with a duration of eight hours during which the control system for
ESO1 was bypassed.'The event was the result of a programable logic controller(PLC)fault indicating an invalid rack:
configuration error'code.failure,thus:removing control power to the;HMIWI:The bypass stack event was.a violation of 2D
.1206 as referenced by Condition 2.1.A.2.o of Air Quality Permit05896T25.A written response letter was received by the
WSRO on June 4,2018,Per..enforcement case No:2018-025,:the facility was assessed a civil penalty of$5,256,.which was
paid in full on September 6,2018:
November 8,2017. The facility received a NOV/NRE due to the facility experiencing four discrete events on September 10,
22;26,and October 7,2017,with durations of 14, 10,2,and 3 minutes,respectively,during which the control system for one
o'f the HMIWIs was bypassed.The first and fourtli event involved ES02,and the second and third events involved ESO1.The
first three events were the result of failures of the uninterruptible`power"supply(UPS)unit,thus removing control power to
the HMIWI.The last event was the result of frayed wires causing a short,thus removing control power to the HMIWI.The
bypass stack events were violations of 2D.1206 as referenced by Condition 2.1:A.2.o of Air Quality Permit 05896T25.A
written response letter was received by the WSRO on November 21,2017.Per enforcement case No.2017-066,the facility
Was assessed a civil penalty of$20,249,which was paid in full on May 2,2018.
April 21,2017-The facility received a NOV/NRE due to the facility experiencing two events(one on February 21,2017,
with a 5-minute duration involving ES02 and one on February.26,20.17,.with an 8-hour durationinvolving ESO1)in which
the HMIWI control systems were bypassed.The two bypass stack events were violations of 2D.1206 as referenced by.
Condition 2.I.A.2.o of Air Quality Permit 05896T25.The facility preemptively responded to this NOVNRE with a letter
received on March'31,2017.Per enforcement case No.20.17-025,the facility was assessed a civil penalty'of$2,147,which
was paid in full on.August 15,2017.
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
2.1.A.1.b.4 of Air Quality Perm it05896/`I'24.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.Per
enforcement case No.2017-001,the.facility was assessed a civil penalty of$5,208,which was paid in full.on April 11.,2017..
Conclusion
Based review of records and visual observations,this facility appeared to be in compliance at the time of the inspection.
11

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