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ROY COOPER NORTH CAROLINA
Governer Environmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS
Director
April 20, 2020
CERTIFIED MAIL NUMBER 7017 1450 0001 6450 4120
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 17, 2020 and April 13, 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 January 31, 2020, with a total duration of three minutes during which the control
system for one of the hospital,medical, and infectious waste incinerators (HMIWI)(Emission Source ID
No. ESO 1)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 total duration of twelve minutes
during which the control system for the other HMIWI (Emission Source ID No. 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.
Both bypass stack events are violations of 15A NCAC 2D .1206 "Hospital, Medical, and
Llfectious 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(f)(6), "Use of the bypass stack shall constitute a violation of the PM, dioxin/filran,
HC1, Pb, Cd and Hg emission limits." The facility previously received Notices of Violation on September
11, 2019,July 16, 2019, May 18, 2018,November 7,2017,April 21,2017, October 24,2016, and
November 2,2015 for use of the bypass stack.
DeµarUnent et Environnwntal puatlry
North Carolina Department of Environmental Quality 1 Division of Air Quality
Winston-Salem Regional office 1 450 West Hanes Mill Road,Suite Sot} ! Winston-Salem,North Carolina 27105
336.776.9800 T 1 336.776.9797 F
Mr. Yarbrough
April 20, 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 Condition 2.l.A.2.o. 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 or me if you have any questions.
Sincerely,
4��JX-IK qh&4�-;Zv
Lisa Edwards,P.E.,Regional Supervisor
Division of Air Quality,NCDEQ
c: Don Nuss, Regional Compliance Manager(via email)
WSRO county file
WSRO enforcement file MTH