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Home My WebLink AboutAQ_F_0100010_20200902_CMPL_InspRpt (4) NORTH CAROLINA DIVISION OF AIR QUALITY Winston-Salem Regional Office Stericycle,Inc. Inspection Report NC Facility ID 0100010 Date: 09/16/2020 Coun /FIPS:Alamance/001 - 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)None Contact Data Facility Contact Authorized Contact Technical Contact Program Applicability Kirk Yarbrough Don Nuss Kirk Yarbrough SIP/Title V Facility Manager Regional Environmental Manager Facility Manager MACT Part 63: Subpart ZZZZ 336 578-8901 515 543-7073 336 578-8901 NSPS: Subpart Ce, Subpart Ec, Subpart IIII Compliance Data Comments: Inspection Date 09/02/2020 Inspector's Name Taylor Hartsfield Inspector's Signature: - --''' Operating Status Operating Compliance Code In Physical Compliance Date of Signature: t� �-( � Q Action Code FCE !�- On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 * HAP 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 2016 1.04 0.2300 21.67 0.8700 0.5000 0.8200 =57.04 * Highest HAP Emitted inpounds) Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 04/20/2020 NOV/NRE 2D .1206 Hospital,Medical,and Infectious Waste Incinerators 04/30/2020 09/11/2019 NOV/NRE 2D .1206 Hospital,Medical,and Infectious Waste Incinerators 09/11/2019 07/16/2019 NOV/NRE 2D .1206 Hospital,Medical,and Infectious Waste Incinerators 07/31/2019 05/18/2018 NOV/NRE 2D .1206 Hospital,Medical,and Infectious Waste Incinerators 06/04/2018 11/08/2017 NOV/NRE Part 60-NSPS Subpart Ec Hospital/Medical/Infectious Waste 11/17/2017 Incinerators for Which Construction is Commenced>June 20, 1996 11/08/2017 NOV/NRE 2D .1206 Hospital,Medical,and Infectious Waste Incinerators 11/17/2017 04/21/2017 NOV/NRE 2D .1206 Hospital,Medical,and Infectious Waste Incinerators 05/19/2017 04/21/2017 NOV/NRE Part 60-NSPS Subpart Ec Hospital/Medical/Infectious Waste 05/19/2017 Incinerators for Which Construction is Commenced>June 20, 1996 10/24/2016 NOV/NRE Part 60-NSPS Subpart Ec Hospital/Medical/Infectious Waste 11/18/2016 Incinerators for Which Construction is Commenced>June 20, 1996 11/02/2015 NOV 2D .1206 Hospital,Medical,and Infectious Waste Incinerators 11/16/2015 Performed Stack Tests since last FCE: Date Test Results Test Method(s) Source(s)Tested 04/08/2020 Compliance Method 9 ES01,ES02 04/09/2019 Com liance Method 9 ESO1,ES02 Page 1 of 15 INTRODUCTION On September 2,2020,Taylor Hartsfield,DAQ-WSRO Compliance Supervisor,visited Stericycle,Inc, in Alamance County in order to conduct a compliance inspection.Due to current DAQ policy regarding COVID-19,this inspection was scheduled in advance with the facility.The facility was targeted this year and has a facility classification of Title V.Kirk Yarbrough,Facility Manager,and Don Nuss,Atlantic Region Environmental Manager,were requested to help facilitate the inspection.Mr.Yarbrough 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. Yarbrough,the facility operates 24 hours per day,7 days a week for 52 weeks per year. The facility received its last compliance inspection on April 9,2019,by this inspector.At that time,the facility appeared to be in compliance with its Air Quality Permit (05896/T25). PERMITTED SOURCES Emission$ Control Emissions SourGe.Description Control System Dcscr pt�on Source ID System TD 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 ESO1 CD01 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 one 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), ES02 (HMIWI)firing natural gas bee CD02 one packed bed scrubber and associated quench column in series with million and 6. primary chamber CD04 one venturi scrubber equipped with a mist eliminator,and burner and ha million neu/hr CD06 one sulfur impregnated carbon bed(6,000 ACFM, inlet airflow rate) secondary chamber burner) EG 1 diesel-fired emergency generator N/A N/A 1(500 kW maximum capacity) INSIGNIFICANT/EXEMPT SOURCES Emissions Source,TD Emissions Source Description ... ,._.,m.. .... _ _._ ... I-CT-1 and I CT-2 Two cooling towers(55,200 gallons per hour water recirculation rate each) I-AMM � �mm Facility-wide storage of 19%aqueous ammonia SAFETY When inspecting this facility,DAQ personnel are required to wear reflective vests, safety shoes,safety glasses,and hearing protection. Due to COVID-19,this inspector wore a facial covering and practiced social distancing. General safety practices were also 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, PERMIT APPLICATIONS There are not any permit applications in process by DAQ-RCO for this facility at the time of this inspection. Page 2 of 15 PREVIOUS SOURCE TESTS 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 2D .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%.The results were received on time and indicated compliance with the applicable limit,as indicated in the DAQ-WSRO memo on May 12,2020. On April 9,2019,the facility performed Method 9 testing of both incinerators for visible emissions.The testing was performed by Patrick Daley Jr. of TRC Solutions.The visible emissions limit as established in 15A NCAC 2D .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%.The results were received on time and indicated compliance with the applicable limit,as indicated in the DAQ-WSRO memo on May 13,2019. The facility previously conducted testing on both units on April 10-11,2018.Both incinerators were tested for particulate matter (PM),visible emissions(VE),hydrogen chloride(HC1),and metals using EPA Methods 5,9,26A,and 29,respectively.The metals testing included lead(Pb),cadmium(Cd),and mercury(Hg).The results were received on time and indicated compliance with the applicable limits, as indicated in the DAQ-SSCB memo on June 4,2018.The following tables summarize the results: ES01 4/10/2018 Emissions Test Results 'ollutnt Emissians' Em'zissiori,Limt Re"ulntibn Cam "linnCe 0.0108 m /dscm 7%02 0.036 m /dscm 7%02 2D.1206 Yes Lead(Pb) 0.000117 lb/hr --- --- --- 1.025 lb/ r' --- --- --- 0.00227 m /dscm 7%02 0.0092 m /dscm 7%02 2D .1206 Yes Cadmium(Cd) 0.0000266 lb/hr --- --- --- 0.233 lb/ r' 63.91 lb/ r2 2D .1100 Yes <0.000994 m /dscm 7%02 0.018 m /dscm 7%02 2D.1206 Yes Mercury(Hg) <0.000011.1 lb/hr --- --- --- <0.000266 lb/day' 3.82 lb/day 2 2D .1100 Yes Filterable PM 8.78 m /dscm 7%02 25 m /dscm 7%02 2D .1206 Yes 0.0981b/hr --- --- --- HCl 0.0354 mvd 7%02 6.6 mvd 7%02 2D.1206 Yes 0.000630 lb/hr 2.2 lb/hr2 --- --- Visible Emissions 0% <6% 2D.1206 Yes ES02 4/11/2018 Emissions Test Results Pa lut nt Emissions' Emission Limit Re'ulntian Cam. 'linnce 0.0275 mg/dscmp 7%02 0.036 m /dscm 7%02 2D.1206 Yes Lead(Pb) 0.000371 lb/hr --- --- --- 3.25 lb/ r.' --- --- --- 0.000482 m /dscm 7%02 0.0092 m /dscm@ 7%02 2D .1206 Yes Cadmium(Cd) 0.00000648 lb/hr --- --- --- 0.0568 lb/ r' 63.91 lb/ r2 2D .1100 Yes <0.000973 m /dscm 7%02 0.018 m /dscm 7%O2 2D.1206 Yes Mercury(Hg) <0.0000131 lb/hr --- --- --- <0.000315 lb/day' 3.82 lb/day 2 2D.1100 Yes Filterable PM 9.21 m /dscm 7%02 25 m /dscm 7%02 2D .1206 Yes 0.124 lb/hr --- --- --- HCl 0.0976 mvd 7%02 6.6 mvd 7%02 2D .1206 Yes 0.00197 lb/hr 2.2 lb/hr2 --- --- Visible Emissions 0% <6% 2D .1206 Yes ' Assuming 24-hr operation.2 Emission limit is for ES01 and ES02 combined. Page 3 of 15 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/hr primary 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/f Trans,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 ground level.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/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. 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. The facility also has a diesel-fired emergency generator(EG 1).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 replaced on September 23,2016, and it read 144.8 hours during the inspection.It ran 23.7 hours in CY2019.Before being replaced,the old hour meter read 164.2 hours.A certification sticker for NSPS purposes is located on the engine,and it has been previously observed by this inspector. The generator uses ultra-low sulfur diesel(ULSD)fuel from Alamance Oil. Carolina CAT services the engine quarterly.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. ESO1 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 CDO6) Condition 2.LA.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-SSCB per the memo issued on June 22,2016.The facility now only tests for hydrogen chloride,cadmium,and mercury on a three-year cycle. The last three-year test was on April 10-11,2018,and the results of that test were approved by the DAQ-SSCB per the memo issued on June 4,2018.The following table summarizes the testing results.The next test will be in CY2021.The facility appears to be in compliance. Page 4 of 15 Affected LmssianIiF,7Lamissri LIrnzt 4/28 5/1✓2Q�5 Nµ 4114 11/2Q18 Toxic Ar�r Pallutant Sources) , (fatal four both) ;Test Results(fatal) Test R+esults'(tata) _;.__..._...._._...,::..._...._,_,.........,_..,_.........,........__...................w.,..._.._.....,_....__..._,..,_.,__................_........,..,........._......... .._.._...._...__.._...._.._..,.._.......:..__........_........:..._.............................................._..............::.......................:......_................,....._...........,�........_........ ..._........ j Arsenic 2.673 lbs/yr 0.1654 lbs/yr Not tested ...._.._ _.._-_ ..............................._................... - t Beryllium 47.64 lbs/yr <0.0330 lbs/yr Not tested Cadmium 63.911bs/yr �9541bs/yr 0.28981bs/yr Chlorine 24.00 lbs/day; <0.0261 lbs/day; Not tested 1.00 lbs/hr <0.00108 lbs/hr ................................._...._....._..............._.........................................................._............._............................_............._....:.................................................__......................................_........._...................................................................................._..........................-................................... . ! Chromium VI 0.964 lbs/yr 0.0670 lbs/yr Not tested Incinerators Hexachlorodibenzo-P-dioxin 0.8831 lbs/yr 5.62E-08 lbs/yr Not tested (ID Nos.ESO 1 �.. and ES02 I Tetrachlorodibenzo-P-dioxin ; 0.0349 lbs/yr 4.10E-071bs/yr Not tested E.............................................................................................................................�.............................,...............:....................,.............,.......................,.,.........................................._..:........,.,.................................,............................................................,........................................................... ............. Hydrogen Chloride 2.2 lbs/hr 0.00911 lbs/hr 0.00261bs/hr <0.02801bs/da , Hydrogen Fluoride 24.00 lbs/day; Y� Not tested 1.001bs/hr <0.00117 lbs/hr I Manganese + 8.221bs/hr <0.00131 lbs/hr �� Not tested .......a...................................._.m......-....._..._.....__.................,............,m...._-;............m.........._.....m.,......,.._-........................_.:............_�..m__...._....._T..........._...............:............-.--------............. ...._..._......,...._..:_..........._...............-............. Mercury 3.82 lbs/day <5.54E-041bs/day <5.81 E-04 lbs/day Nickel 12.00 lbs/da 0.00300 lbs/da Not tested Condition 2.1.A.Lb 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 164.17 for CD06(for ES02).During the inspection,the 3-hour average charge rates of ESO1 and ES02 read 1,715.4 and 1,724.1 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 159.07 and 160.7°F,respectively.The facility appears to be in compliance. 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 a pressure 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 previous inspection reports,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.l.d states that the facility shall not incinerate dental waste,as defined in the waste management plan required by Condition 2.1.A.2.bb. During the inspection, it was verified that the facility is not incinerating any dental waste.Any dental waste (indicated with grey labels)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 waste incineration records for the previous day,9/l/2020,were reviewed and did not indicate any dental waste.The facility appears to be in compliance. Conditions 2.LA.Le and f state that the facility shall comply with the testing requirements in Condition 2.1.A.2 j.for cadmium and mercury.The testing shall also be performed in accordance with General Condition JJ.As previously mentioned,the facility tested both units for cadmium and mercury on April 10-11,2018,and the results of that test were approved by the DAQ-SSCB per the memo issued on June 4,2018. The next test will be in CY2021.The facility appears to be in compliance. Page 5 of 15 Condition 2.1.A.1.2 states that the facility shall conduct the monitoring,maintenance,and inspections for each incinerator and each control device,as required by Condition 2.1.A.2.u.through aa. See those conditions below for a detailed discussion. The facility appears to be in compliance. 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 Condition 2.LA.2.ff. See this condition below for a detailed discussion.The facility appears to be in compliance. Condition 2A.A.l.i 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 shall be summarized and submitted as part of a stack test report.Mr.Yarbrough assured that this information will be provided with each stack test report.The facility appears to be in compliance. Condition 2.1.A.l.k states that the reporting requirements of 15A NCAC 2D.1206(Conditions 2.1.A.21h.and ii.)shall be considered sufficient for reporting compliance with 15A NCAC 2D.1100. See Conditions 2.1.A.21h.and ii.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(ESO1 and ES02)as stipulated by Table I of 40 CFR Part 60, Subpart Ce.The facility conducted source testing on the units from April 10-11,2018,and the results of that test were approved by the DAQ-SSCB per the memo issued on June 4,2018.The facility will complete repeat(every 3 years)testing on both units in CY2021. The facility appears to be in compliance. 4I10-11/2018 Test 12esu1tsA�verages) �ol�utant Em issYon Lim its .: � ES �ES02 01 ..........................................._..............................__..........._...................._.............._......................................................................_.__.._...._..................._......._........................................................................................._...._................... ..................................................................................... ............................................................._........... ........ ........... Particulate matter 25 milligrams per dry standard cubic meter(mg/dscm)OR 8.78 mg/dscm 9.21 mg/dscm 0.011 grains per dry standard cubic foot(gr/dscf) _......:..............::............__............,._.....,_..,..,........:.:...,.,...... ......::.............. _..........._......�............_....w ....._. ........._.... ._............_...._ ....._._.................................................................. ......._...._.._._.._......... .. w._..,.�..................................................._.... Carbon monoxide 11 parts per million by volume(ppmv) Not tested(GEMS) Not tested(GEMS) 9.3 nanograms per dry standard cubic meter total dioxins/furans (ng/dscm)OR Dioxins/f Trans 4.1 Ogrrains per billion dry standard cubic feet(gr/101 dscf) Not tested Not tested 0.054 ng/dscm TEQ OR 0.024 gr/109 dscf TEQ Hydrogen chloride6.6 parts per million by volume(ppmv)m. .. ._�..� ..... �..�.. ._........ .. µ0.0354 ppmvd_.. 0.0976 ppmvd Sulfur dioxide 9.0 parts per million by volume(ppmv) Not tested F—Not tested .......................................................................... ..................................................................................................................................................................................................................................................................................................... ..................................................................................... ................................................................-................ ........... Nitrogen dioxide 140 parts per million by volume(ppmv) Not tested Not tested _..._.............................................._..........,.,..,,_.......,..,..............................,,.._...........,........_............,....._....,................._.,...,... ..........._....,..,_..,......,,.........,.................._.....w,._................, ...... _ ........, ......... ,....._............ Lead 0.036 milligrams per dry standard cubic meter(mg/dscm)OR 0.0108 mg/dscm 0.0275 mg/dscm 0.016 grains per thousand dry standard cubic feet(gr/10 dscf) Cadmium 0.0092 milligrams per dry standard cubic meter(mg/dscm)OR0.00227 mg/dscm 0.000482 mg/dscm 0.0040 grains per thousand dry standard cubic feet(gr/10 dscf) , . .. .,__..._... __,._........._........ ......_.._.._..�m.,.,... .,_ .. ...._.._..__....._., �,.....µ...,,..._._.��.,........... .,,....,., ...,_.__.._. ..,. .:. .......:. ......_,. ....,_..,......._........._..... 0.018 milligrams per dry standard cubic meter(mg/dscm)OR <0.6 994 <0.000973 Mercury 0.0079 grains per thousand dry standard cubic feet(gr/101 dscf) mg/dscm mg/dscm .............................................................. .................................................................................................................................._.............................................................._..............................................................................................................................................................................................._..................................................................... Opacity 6%opacity(6-minute block average) 0% 0% *Limits based on 7%oxygen **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 The facility shall also comply with the calculated emission limits listed in Condition 2.1.A.La.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. Page 6 of 15 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 conducted source testing on the units from April 10- 11,2018,and the results of that test were approved by the DAQ-SSCB per the memo issued on June 4,2018.The facility will complete repeat(every 3 years)testing on both units in CY2021. The facility appears to be in compliance. Conditions 2.1.A.2.d through g state that the facility shall conduct an initial performance test in order to determine compliance with the emission limits in Condition 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 emissions limit(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 Condition 2.1.A.2.n still apply. The facility appears to be in compliance. Conditions 2.1.A.2.h through 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 thah'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- 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 shall 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. The facility is currently on a 3-year cycle for testing both units,except that opacity testing is annual.The most recent annual opacity testing for both units occurred on April 8,2020.The results demonstrated compliance(0% opacity for both units)and were approved on May 12,2020.The facility will complete repeat 3-year testing on both units in CY2021. The waste tracking records are to be submitted with the results for the CY2021 test.There has not been any use of the bypass stack during previous performance tests.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 Condition 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.The waste incineration records for the previous day,9/l/2020,were reviewed and appeared complete.As mentioned under Condition 2.1.A.l.d, 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.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. Page 7 of 15 �..�. �....� l�sa � l�sa2 � Operatxang Parameter based an I h.aur ratlxp av T25 4/�Q 11/18 9/2/2Q T25 4/1a-11I�$V ; 9I2C20 limit Source Test Inspection Lrmit Source Test �npection ...................................................................................................................................................................................................................................:......:..............:......................:........................:............... .....:.............:.........:....................................................................:..................................................,.................. ........_................................................... Max.charge rate(lbs/hr) � 1,870.0 I 1,704.3 1,715.4 � 15870.0 � 1,704.7 1,724.1 Min.pressure drop across venturi scrubber 39.0 44.2 MMw42.8W.._..W. M38.9 42.4 41.9 (in. W.C.) _ 1,951.2 Min.secondary chamber temperature(°F) µµ 1,762.8µ Min.venturi scrubber liquor flow rate(gpm) 65.2 73.9 74.0 66.7 r 72.6 72.5� ........................................................................................................................................................................................................................................:...............:.............................................................................................................................. ......................................:................................................................................................................................. Min.packed bed scrubber liquor pH 4.10 4.6 5.58 4.10 4.5 5.41 _........,_:..........................._..._...........,......,,_,....,.......,.......,......._....W,......,._....,.............._....,.......,..........,._......._ ...,...__.._.........,.._...,...,......,_.........................................._.....,........,.. ................,............,...,................,...,..,_.. Max. flue gas/carbon bed inlet temp. (°F) 168.1 153.5 159.0 164.1 153.1 160.7 Min. SNCR flow rate for urea(gph) 1.1- 7 F-I 2 F - - Min. SNCR flow rate for ammonia(gph) 1.0 1.2 1.18 1.0 1.2 1.18 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. _. Operating Scenario EauYssians LmYt Vaotaton Above maximum charge rate AND below minimum pressure drop across venturi scrubber PM Above maximum charge rate AND below minimum secondarychamber temperature CO E Above maximum charge rate AND below minimum secondary chamber temperature AND Dioxin/furans below minimum venturi scrubber liquor flow rate ..:.....:............_.............:...:.....:.:...:...:.:...........:.............:...:.....:....:..:...........................................:.....:_.....:........_.....:............._.........__............._.........:_.........:.:..................................... .............._............................. .............m........................................................_.................................... ........... .................................................. ...................................._........................._; Above maximum charge rate AND below minimum packed bed scrubber liquor pH HCl Above the maximum carbon bed inlet temperature AND above maximum charge rateM�ryW^ Uses bypass stack N �� w . .. w . .... .�� _.. .. _ w _ � .. �PM,dioxin/furan,461,Pb,Cd and Hg Above maximum charge rate AND below minimum secondary temperature AND below FNOx E minimum reagent flow rate Conditions 2.1.A.2.p.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 Condition 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 with 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 previously mentioned,the facility has a DAS for monitoring all required operating parameters and use of the bypass stack.According to the semi-annual report received January 31,2020(PM: 01/29/20),for ESO1 and ES02,the facility had 0.0 and 2.39 hours of inoperative monitor data,which represents 0.0 and 0.07%of the total operating time for July-Dec 2019,respectively.According to the semi-annual report received July 31,2020(PM: 07/30/20),for ESO1 and ES02,the facility had 10.0 and 1.0 hours of inoperative monitor data,which represents 0.30 and 0.03%of the total operating time for Jan-June 2020, respectively.As this is less than what is allowed,the facility appears to be in compliance. Page 8 of 15 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.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 CY2019 and CY2020 were reviewed.The facility keeps an annual calendar sheet and crosses off each day after the VE observation has been filed.All the days so far in CY2020 were crossed off on the calendar.Records for 2/10/20 and 6/11/20 were pulled at random,and the VE observations were complete for both units. 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 CEMS were operating and the 12-hour averages for ESO1 and ES02 were 1.15 and 0 ppmv,respectively,which are less than the 11 ppmv limit. [Note: The actual CO CEMS reading for ES02 was-0.67 ppmv.According to Mr.Yarbrough,if the actual number is at or near zero,then the CO reading can be represented as a low negative number due to temperature,electronic noise and drift.The CO CEMS had been calibrated that morning and demonstrated it was operating in the proper relative accuracy range.] According to the semi-annual CEM report received January 31,2020(PM: 01/29/20),ES01 and ES02 had no instances of excess CO emissions for July-Dec 2019. This CEM report was accepted by the DAQ- SSCB on March 26,2020. According to the semi-annual CEM report received July 31,2020(PM: 07/30/20),ESO1 and ES02 had no instances of excess CO emissions for Jan-June 2020.This CEM report is still pending acceptance by the DAQ-SSCB.The last quarterly CEMS audits were performed on 03/30/2020 and 06/30/2020 for ESO1 and on 03/31/2020 and 06/30/2020 for ES02. The facility appears to be in compliance. 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 HMIWI.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,ESO1 and all associated controls were annually inspected on March 24,2020,and ES02 and all associated controls were annually inspected on April 14,2020.During these shutdowns,the facility thoroughly inspects the incinerators and performs any required annual maintenance on the packed bed scrubbers(CDO1 and CD02),venturi scrubbers(CD03 and CD04),and the selective non-catalytic reduction(SNCR)systems(CD07 and CD08).All maintenance was performed in a timely manner,and other maintenance performed outside of the annual shutdown is summarized in the following table. Further discussion about the carbon beds(CD05 and CD06)is in the following condition.The facility appears to be in compliance. EmrsSron Source 1Vlantennce Date IYIaYntena�ce Descr�pt�on ESO1 Unit 1 7/24/2020 Installed SNCR chamber access door ................................. 2/23/2020 ._ Replaced mid hearth ES02(Unit 2) 6/8/2020 Installed SNCR chamber access door Replaced mid hearth f 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 January 8,2018 and February Page 9 of 15 8,2018,respectively.Both contain Calgon carbon,which was considered an equivalent replacement for Jacobi carbon.When the carbon is first charged,it is washed every 3-4 weeks to increase its useful life. When the carbon is close to the end of its useful life, washing may occur as frequently as every 3-4 days.The facility performs quarterly checks of the carbon beds to ensure breakthrough has not occurred.This was last done on 02/18/2020,04/14/2020,and 07/21/2020 for CD05 and on 03/24/2020,06/07/2020,and 08/10/2020 for CD06.The lower beds on CD06 received new carbon on 07/15/2019.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 31,2020(PM: 01/29/20)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 31,2020(PM: 01/29/20),ESO1 and ES02 had 0.0 and 0.23 hours of excess emissions,respectively,for July-Dec 2019.According to the semi-annual report received July 31,2020(PM: 07/30/20),ESO1 and ES02 had 0.87 and 2.10 hours of excess emissions,respectively,for Jan-June 2020. Some of these excess emissions occurred due to bypass stack openings,and therefore not exempt as previously mentioned.The facility was issued NOWNREs on 07/16/2019,09/11/2019,and 04/20/2020 for use of the bypass stack.Further details are contained in the Compliance History section of this report. The facility appears to be in compliance. 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 monitors 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 August 4-6,2020 for 5 operators.The prior refresher training was conducted on January 28-30,2019.The facility appears to be in compliance. Conditions 2.1.A.2.ff and gg 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. 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 exceedances,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 previous semi-annual reports were received on January 31,2020(PM: 01/29/20)and July 31,2020(PM: 07/30/20),and they contained all the necessary elements.The facility appears to be in compliance. Page 10 of 15 i 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 it is currently doing so by complying with Conditions 2.I.A.I and 2.1.A.2.The facility appears to be in compliance. - B. One diesel fuel-fired emergency generator(ID No.EG1) 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(EG 1). 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 in compliance. 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(EG 1) 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(EG I) 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%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 replaced on September 23, 2016, and it read 144.8 hours during the inspection. Before being replaced, the old hour meter read 164.2 hours. 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 quarterly. The engine was last fully serviced on July 22,2020.The previous semi-annual reports were received on January 31,2020(PM:01/29/20)and July 31, 2020 (PM: 07/30/20). According to those reports, the engine ran a total of 23.7 hours in CY2019, with all hours attributed to maintenance/testing. For Jan-June of CY2020, the engine has run 13.2 hours, with all hours attributed to maintenance/testing. The facility appears to be in compliance. Condition 2.1.B.4 contains the requirements for 2D .I I II 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(EG 1).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. EG 1 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). Page 11 of 15 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 CY2019 ACC report on January 31,2020(PM: 01/29/20).It was reviewed and accepted on February 17,2020,by this inspector.The facility did experience deviations in CY2019 that were summarized adequately.They are further 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 301 each year.The EI 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 CY2019 EI on June 15,2020.The EI is still currently under review and pending acceptance by this inspector.The facility appears to be in compliance. Condition 3.MM—This contains the requirements for 2D .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. 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(EG 1)as discussed under Condition 2.1.13.3 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. Page 12 of 15 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 2.1.A.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 2.1.B.4 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 ESOI 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 CY2017 and CY2018 emissions inventories that were submitted by the facility. Differences in CY2017 and CY2018 emissions are due to the following: 1)Updated emission factors from 2018 stack test;2)Increased natural gas use;3)Decreased incinerator throughputs;and 4)Increased generator use. The CY2019 emissions inventory is still under review at the time of this report. C'Y201'7 Actual Emxssians, CY2Q18 Actual Emissions, o Pollutant Net Change(lo) tom /year tans/year ......._._............................ _...._.;.... . ............_............ .......:. .......:......_..:_..._........_.......................,............._.............:................................_........... .. .. ............; PM 1.00 0.94 -6.0 ................. ............................. ....... ........ ...........................................................................„E.................. ............ .......................... ....... .,.......................... ..................... ..........................:.... .................................... ............................................................ ................................................................................................................................................................................ PMto 0.80 0.75 -6.3 PM2.5 0.54 0.52 -3.7 ................... ,...:... ......... ......................................................._:......,........:.......:................._.............................. :..:...............................:.....:.......:..............:......... .....:... ................._ ....................:...........:......:..._....................................................................... ..... S02 0.23 0.23 0 ...................................................._.................................................................................;.............................................._.....................,..................,..................................................:.................................................................................................................................................................................................................................................................................... NOx 21.35 19.91 -6.7 �..�.�..............�..w..w..... ..�.�..�...�.�.w............:w.�...�.�....��.._w.M...�.M..�.w...w�......M�.�M.��.��.�...�..�.. ....�..w.�., .�.....�.�.�.�.„.r��.w..._.�M...�..�.��.�.�.Mw�..��...��.�.....�......w� CO 0.50 0.69 +38.0 ' :: ..................__.........:....:.:...............................:...............:........:.::._.....:............:..:.................:.........................................................._......................._............_...................__.....:...................._._.......................:.._.....:................._.:...............__.................. VOC 0.85 0.80 ( -5.9 _.........__..................._......._........__.,._....._.......,_........._..........,_........,......._....,.._..,_.,..,..,..............,._......................._.........,_..................................._.,..,.........:...................................._......................._........._......................................................................_.................................................................................................... ............................ HAPTotal 0.047 0.031 -34.0 HAP Highest g 0.028(HCl) 0.013 (hexane,n-) NA PERMIT CONSIDERATIONS 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). COMPLIANCE HISTORY (LAST 5 YEARS) It should be noted that on July 22,2020 and August 12,2020,the WSRO received two letters from Don Nuss,Atlantic Regional Environmental Manager for Stericycle, Inc.,detailing two bypass incidents that occurred on July 2,2020 and July 23,2020, respectively,at the above referenced facility.A compliance letter is being drafted to address these violations of 2D .1206 as referenced by Condition 2.1.A.2.o of Air Quality Permit 05896T25. 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 ESO I 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 Page 13 of 15 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 NOWNRE(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. July 16,2019—The facility received a Notice of Violation and Notice of Recommendation for Enforcement(NOVNNRE)due to the facility experiencing an event on April 22,2019,with a duration of eleven minutes during which the control system for ESO 1 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 the 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 for a contested case,and that case is still ongoing. February 19,2019—The facility received a Notice of Deficiency(NOD)due to the facility failing to perform HMIWI operator training in CY2018.This was a deficiency of 2D.1206 as referenced in Condition 2.1.A.2.ee of Air Quality Permit 05896/T25. A response was received on May 6,2019,and indicated that the training was done on January 28-30,2019. 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 Notice of Violation and Notice of Recommendation for Enforcement(NOV/NRE)due to the facility experiencing 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 Permit 05896T25.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 of the HMIWIs was bypassed.The first and fourth 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 NOVNNRE 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 ESO1)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.Per enforcement case No.2017-025,the facility was assessed a civil penalty of$2,747,which was paid in full on August 15,2017. October 24,2016—The facility received a NOVNNRE 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.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.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. Page 14 of 15 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 ESO1 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.I.A.LbA 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. CONCLUSION 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 15 of 15 ESO I —Data Acquisition System snapshot j 1`7 1 10,52:28 AM "Ill"4'. W�Vu,", lu N NAPS" �jvlr, P,7,M�,, FaW,;, -I LKV _0 �._(I N 7XID MN IF 4" . _ - fV ' aC2% lIV l 7i slba _C LOSE Oif 20 a b #1-NORMAL 77'ii 7i7.7-- RC ai, i SS8, �201 4.5 2055.5- 2 'j-d-A i'd 'eage k tb b FW , 5. "Ab 17 4Z88,' 'DWAN % 42,ff 4Z)7 -J-_4 A - -------- - gpM 74�1 Xldh.W� 2 '4517 127, emp_,�. .61 .I ��7 z�-7_=-�_- 7� -.--- _____ v�l - - 0 dddf 125� lfl O,"Fan, ide. Ty' C,;o 60"M es 17 P. F15�771 Mv Ti4,71; 2� 5- 1715-0 1715-3871, -11,6�, 3 l2,-HWFAVG Tfflk",�'�AV 2033,19KIZZ-60A8,74,1261 58,1531�AZOA ;,r"Co 1z:C hah UR lit -X4 ES02-Data Acquisition System snapshot. rim 01 Ill,U I: 1,Womy"LRV v R-41 gv %-I f! r 7 Page 16 of 16