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ROY COOPER NORTH CAROLINA
Governor- Environmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS
Director
September 11,2019
CERTIFIED MAIL NUMBER 7010 0780 0002 0107 0210
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 August 28, 2019, this office received a letter from Don Nuss detailing an incident that occurred
at the above referenced facility. Per the correspondence,the facility experienced an event on August 13,
2019, with a total duration of thirteen minutes during which the control system for one of the hospital,
medical, and infectious waste incinerators (HMIWI) (Emission Source ID No. 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, This bypass stack event is a
violation 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(f)(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 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.
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.
NCiRT-I 1.:Y.iNA � "
DaµeNnent of Environniental quality
North Carolina Department of Environmental Quality Division of Air Quality
Winston-Salem Regional office 1 450 West Hanes Mill Road,Suite 300 1 Winston-Salem,North Carolina 27105
336.776.9800 T 336.776.9797 F
Mr. Yarbrough
September 11,2019
Page 2
We have prepared a report detailing this violation 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 violation of Condition 2.1.A.2.o. If you wish to present an explanation for the cited
violation 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,
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