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HomeMy WebLinkAboutAQ_F_0100010_20201028_CEM_RptRvwLtr (4) oF�E STATE�Fti _ =D *E'6£OfNN N��♦ ROY COOPER NORTH CAROLINA Governor Environmental Quality MICHAEL S.REGAN Secretary MICHAEL ABRACZINSKAS October 28, 2020 Director Mr. Don Nuss Regional Compliance Manager Stericycle, Inc. 1168 Porter Avenue Haw River,North Carolina 27258-9547 SUBJECT: Review of 2020 Semiannual CO/02 CEMS Report, First Half Stericycle, Inc. —Haw River Facility Haw River, Alamance County,North Carolina Air Permit No. 05896T25 Facility ID No. 0100010 Dear Mr. Nuss: Thank you for your timely submittal of the subject report, dated July 30, 2020. The excess emissions report assessed the carbon monoxide (CO)/oxygen (02) continuous emissions monitoring systems (CEMS) operating at the Haw River Facility during the first half of 2020. Additional requested information regarding quarterly gas audits was provided by Kirk Yarbrough of your staff on October 26, 2020. The Division of Air Quality (DAQ)has completed its review of the CEMS-related information in the report and has the following comments: 1. The CO/02 CEMS were installed on Stericycle's hospital, medical, and infectious waste incinerators (HMIWI) ESO 1 & ES02 pursuant to 15A NCAC 02D .1206—Hospital, Medical, and Infectious Waste Incinerators and Air Permit No. 05896, Specific Condition 2.1.A.2.t. 2. The report was reviewed for compliance with the CO emissions limit of 11 parts per million by volume (ppmv, 7% 02, 12-hour block average) as listed in Table 1B to 40 CFR Part 60, Subpart Ce—Emission Guidelines and Compliance Times for Hospital/Medical/Infectious Waste Incinerators [15A NCAC 02D .1206(c)(3)] and Specific Condition 2.1.A.2.a. There were no exceedances reported during this time period. 3. A review was also conducted for compliance with good operation and maintenance (O&M) practices pursuant to 15A NCAC 02D .0611(d) and General Condition 3.F. When compared to the total operating time of the incinerators,percent excess emissions (%EE) and percent monitor downtime (%MD) were reported as follows: NORTHCAROHNAD_E Q�� Depart-1,of Environmental Duality North Carolina Department of Environmental Quality I Division of Air Quality 217 West Jones Street 1 1641 Mail Service Center I Raleigh,North Carolina 27699-1641 919.707.8400 Mr. Don Nuss October 28, 2020 Page 2 Unit Quarter %EE %MD HMIWI ESO1 1st 0.0 0.3 2nd 0.0 0.1 HMIWI ES02 1st 0.0 0.1 2nd 0.0 0.0 The incinerators and associated CO/02 CEMS appear to have operated using good O&M practices for minimizing emissions since quarterly%EE and%MD were less than 6% for any single calendar quarter and less than 3% for two consecutive quarters. 4. Finally, first and second quarter cylinder gas audits (CGA) conducted on the CO/02 CEMS were reviewed with respect to specifications set forth in Section 5 of 40 CFR Part 60, Appendix F—Quality Assurance Procedures and Specific Condition 2.1.A.2.t.ii. The CGA results appear to have met the 15% accuracy specification. Due to COVID-19 restrictions on DAQ staff and our office operations, the mailing of this letter may be delayed. In the meantime, an electronic copy(e-copy) is being provided for your records. If you should have any questions,please contact me at(919) 707-8493 or alan.drake@ncdenr.gov. Sincerely, 4AIankrake, E vironmental ngineer Division of Air Quality,NCDEQ c: Don Nuss, Stericycle (e-copy) Kirk Yarbrough, Stericycle (e-copy) Ray Stewart, DAQ WSRO (e-copy) Gary Saunders, DAQ SSCB (e-copy) IBEAM Documents, 0100010 (e-copy) Central File, Alamance County