AQ_F_0100010_20210415_CMPL_NOV-NRE (4)

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Governor
DIONNE DELL[-GATTIsecret
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MICHAEL ABMACZINSKAS NORTH C:.AROLINA
Director Environmental Quality
April 15, 2021
CERTIFIED MAIL NUMBER 7019 1120 0001 5504 6028
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 February 15, 2021, this office received a letter from Don Nuss detailing two incidents that
occurred at the above referenced facility. Per the correspondence,the facility experienced an event on
February 1, 2021, with a total duration of two minutes during which the control system for one of the
hospital, medical, and infectious waste incinerators(HMIWI) (Emission Source ID No. ES01)was
bypassed. The bypass was caused by 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 incinerator and APC system were restarted and resumed
normal operations.
The facility experienced another event on February 3, 2021, with a total duration of two minutes
during which the control system for the other HMIWI (Emission Source ID No. ES02) was bypassed. 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 and the incinerator
and APC system were restarted and resumed normal operation.
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
-' North Carolina Department of Environmental Quality I Division of Air Quality
Winston-Salem Regional Office 1450 West.Hanes Mill Road,Suite 300 1 Winston-Salem,North Carolina 2.7105
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Deµ»rlmeltat EnvironmeMxl�uui4ty 336,776.9800 T 1 336.776,9797 F

Mr. Yarbrough
April 15, 2021
Page 2
"Standards of Performance for New Stationary Sources: Hospital/Medical/Infectious Waste Incinerators."
Per 40 CFR 60.56c(f)(6), "Use of the bypass stack shall constitute a violation of the PM, dioxin/furan,
HCI, Pb, Cd and Hg emission limits." The facility previously received Notices of Violation on December
25 2020, September 25, 2020, 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.
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 Davis Murphy at 336-776-9644 ([e-mail]) or me if you have
any questions.
Sincerel
T. Ray Stew J E., CPM, eg' al Supervisor
Division of Air lity,NCDEQ
c: Don Nuss, Regional Compliance Manager(via email)
WSRO county file
WSRO enforcement file