AQ_F_0100010_20160817_ST_RvwMemo (4)

Alamance County
DIVISION OF AIR QUALITY
Technical Services Section
August 17, 2016
MEMORANDUM
To: Lisa Edwards,P.E., Winston-Salem Regional Office
From: Gregg O'Neal, P.E., Stationary Source Compliance Branch(SSCB)
Subject: Stericycle Inc., Haw River,Alamance County,North Carolina
Facility No. 0100010,Air Permit No. 05896T24, Tracking No. 2016-063ST
Emissions Test for Metals on Medical Waste Incinerators ID No. ESO1 and ES02
Performed on April 19, 2016 by TRC Environmental Corporation
The subject test report has been reviewed. The sources tested are two dual chamber,natural gas-fired
hospital, medical, and infectious waste incinerators Unit 1 and Unit 2 (Source ID ESO1 and ES02).
Incinerators ESO1 and ES02 are each controlled respectively in series by: selective non-catalytic reduction
(SNCR) system with ammonia or urea injection(ID No. CD07 and CD08),packed bed scrubber and
associated quench column(ID No. CDO1 and CD02), with venturi scrubber(ID No. CD03 and CD04),
and sulfur impregnated carbon bed(ID No. CD05 and CD06).
Emissions testing was conducted for visible emissions(VE)on both incinerators ESOI and ES02.
Additional testing was conducted on incinerator ESO1 for mercury(Hg). The test period results for
incinerators ESO1 and ES02 are acceptable for comparison to the applicable emissions standards.
Incinerators ESO1 and ES02 are subject to 15A NCAC 2D .1206,Hospital, Medical and Infectious Waste
Incinerators; 15A NCAC 2D .1100, Control of Toxic Air Pollutants; 40 CFR 60 Subpart Cc,Emission
Guidelines and Compliance Times for Hospital/Medical/Infectious Incinerators; 40 CFR 60 Subpart Ec,
Standards of Performance,for Hospital/Medical/Infectious Incinerators for Which Construction is
Commenced After June 20, 1996; and 40 CFR 62 Subpart HHH,Federal Plan Requirements for
Hospital/Medical/Infectious Incinerators Constructed on or Before June 20, 1996.
The maximum charge rates of incinerators ESO1 and ES02 are 2,092.0 and 2,093.1 pounds per hour
(lb/hr),respectively. During the test period incinerators ESO1 and ES02 each operated at an approximate
charge rate of 1,700 lb/hr or 8 1% of maximum.
Permit Section 2 Condition 2.2.A limits toxic air pollutants under 15A NCAC 2D .1100. These limits are
for the emissions from both incinerators combined. Stericycle did not test both units simultaneously. The
air permit allows that one incinerator's test results be doubled for comparison to the toxic emissions limit.
Thus, the tabulated ESO1 mercury(Hg)results listed were doubled for comparison with the pen-nit limit.
Table: Incinerators ESO1 and ES02 Testing Results
Regulated Test Compliance
Pollutant Method Test Date Applicable Regulation Emission Limits Test Result Indicated?
ES01
Visible Emissions 9 04-19-16 15A NCAC 2D.1206 6%opacity 4.6%opacity n Yes
Mercury 29 0.018 mg/dsem <0.000580 mg/dsem Yes
ES01 Emissions Results(Note:In order to compare to the facility wide limits,the tabulated ES01 test results have been doubled.)
Mercury 1 29 1 04-19-16 1 15A NCAC 2D.l 100 1 3.82 lb/day` <0.000405 lb/day` Yes
ES02
Visible Emissions 9 04-19-16 1 15A NCAC 2D.1206 1 6%opacity 3.8%opacity' T Yes
Corrected to 7%oxygen on a dry standard basis.
Highest six-minute average
Assumes 24 hours of operation per day
If you have any questions, please contact me at(919)707-8415 or grregg.onealknedenngov.
cc: Central Files, Alamance County
IBEAM-Documents—0100010