AQ_F_0100010_20200925_CMPL_NOV-NRE (4)

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ROY COOPER NORTH CAROLINA
Governor- Environmental Quality
MICHAEL S.REGAN
5ecretary
MIC,HAEL ABRACZINSKAS
Director September 25, 2020
CERTIFIED MAIL NUMBER 7019 1120 0001 5504 6561
RETURN RECEIPT REQUESTED
Kirk Yarbrough
Stericycle, Inc.
1168 Porter Avenue
Haw River,NC 27258
SUBJECT: Notice of Violation and Notice of Recommendation for Enforcement
Stericycle,Inc.
Haw River,North Carolina
Alamance County
04-0100010-Title V Air Permit No. 05896T25
Dear Mr. Yarbrough:
On July 22, 2020 and August 12,2020,this office received letters from Don Nuss detailing two
incidents that occurred at the above referenced facility. Per the correspondence, the facility experienced
an event on July 2, 2020, with a total duration of eleven minutes during which the control system for one
of the hospital, medical, and infectious waste incinerators(HMIWI) (Emission Source ID No. ESO1)was
bypassed. The bypass was a result of a malfunction in the water level controller in the primary cooling
vessel or quench chamber of the air pollution control system. This caused a low water condition that
triggered an automatic bypass to prevent a catastrophic failure related to high temperature. After the
bypass was identified, the water level was corrected, and the system was restarted.
The facility experienced another event on July 23,2020, with a total duration of five minutes
during which the control system for the other HMIWI (Emission Source ID No. ES02)was bypassed. The
bypass resulted from an ID fan vibration detection sensor initiating an ID fan shutdown sequence due to
high vibration to prevent potential catastrophic failure. The facility removed the automatic ID fan
shutdown sequence and reprogrammed the PLC for a vibration alarm only rather than automatic
shutdown.
Both bypass stack events are violations of 15A NCAC 2D .1206 "Hospital, Medical, and
Infectious Waste Incinerators"as referenced by Condition 2.1.A.2.o of Air Quality Permit 05896T25. Per
2D .1206(d)(4), the rule incorporates by reference 40 CFR 60.56c, part of 40 CFR 60 Subpart Ec
"Standards of Performance for New Stationary Sources: Hospital/Medical/Infectious Waste Incinerators."
Per 40 CFR 60.56c(0(6), "Use of the bypass stack shall constitute a violation of the PM, dioxin/furan,
HCl, Pb, Cd and Hg emission limits." The facility previously received Notices of Violation on April 20,
2020, September 11, 2019,July 16, 2019, May 18, 2018,November 7, 2017, April 21, 2017, October 24,
2016, and November 2, 2015 for uses of the bypass stacks.
-�.
Deportment of Enviivnmantai quality
North Carolina Department of Environmental Quality I Division of Air Quality
Winston-Salem Regional office 1 450 West Hanes Mill Road,Suite 300 i Winston-Salem.North Carolina 27105
336,776.9800 T ; 336.776,9797 IF

Mr. Yarbrough
September 25, 2020
Page 2
Each day that you continue to operate in violation of 15A NCAC 2D .1206 may constitute an
additional violation. Each violation is subject to enforcement action, including a civil penalty of up to
$25,000 and/or injunctive relief, pursuant to North Carolina General Statute(NCGS) 143-215.114A or
permit revocation as authorized by NCGS 143-215.108(b)(3). You may wish to contact the Division of
Environmental Assistance and Customer Service at 1-877-623-6748 if you need assistance.
We have prepared a report detailing these violations and intend to forward it to the Division of
Air Quality staff in Raleigh. The report concludes with a recommendation by this office for enforcement
action for the violations of 15A NCAC 2D .1206. If you wish to present an explanation for the cited
violations or if you believe there are other factors which should be considered, please send the
information to me in writing within 10 days following receipt of this letter. The information will be
reviewed and, if an enforcement action is still deemed appropriate,your explanation will be forwarded to
the Director with the enforcement package for his consideration.
Please contact Taylor Hartsfield at 336-776-9639 ([e-mail])or me if you
have any questions.
Sincerely
T. Ray Stewart, Jr, P.E. CPM, Regional Supervisor
Division of Air ality,NCDEQ
c: Don Nuss, Regional Compliance Manager(via email)
WSRO county file
WSRO enforcement file MTH