Loading...
HomeMy WebLinkAboutAQ_F_0100010_20220913_CEM_RptRvwLtr (4) Etc STATE o o.'73 O ROY COOPER Governor ELIZABETH S.BISERf,z�M Secretary MICHAEL ABRACZINSKAS NORTH CAROLINA Director Environmental Quality September 13, 2022 Mr. Kirk Yarbrough Facility Manager Stericycle, Inc. 1168 Porter Avenue Haw River,North Carolina 27258-9547 SUBJECT: Review of 2022 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. Yarbrough: Thank you for your timely submittal of the subject report, dated July 27, 2022. 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 2022. Additional clarification regarding CO emissions was provided via conference call on September 12, 2022. 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) ESO1 & 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 I 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. The report indicated that a bypass event occurred on April 28, 2022, which resulted in a Notice of Violation/Notice of Recommendation for Enforcement being issued on May 18, 2022,by the DAQ Winston-Salem Regional Office. 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 3.17. When compared to the total quarterly operating time of the incinerators, percent excess emissions (%EE) and percent monitor downtime (%MD)were reported as follows: D Q2177 North Carolina Department of Environmental Quality I Division of Air QualityE West Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699-1641 NORTH CAROLINA oePanment of Environmental Uwi\ /� 919.707.8400 Mr. Kirk Yarbrough September 13, 2022 Page 2 Unit Quarter %EE %MD HMIWI ES01 1st 0.0 0.0 2nd 0.0 0.0 HMIWI ES02 1st 0.0 0.1 2nd 0.1 0.0 DAQ considers source to have operated using good O&M practices for minimizing emissions if quarterly%EE and%MD are less than 6% for any single calendar quarter and less than 3% for two consecutive quarters. 4. Finally, a review was conducted on periodic quality assurance (QA) tests pursuant to Section 5 of 40 CFR Part 60 Appendix F, Procedure 1 - Quality Assurance Requirements for Gas Continuous Emission Monitoring Systems Used for Compliance Determination and Specific Condition 2.1.A.2.t. Quarterly audits must be conducted—either a cylinder gas audit(CGA) or a relative accuracy audit(RAA)—with a relative accuracy test audit (RATA) being conducted at least once every four calendar quarters. During the first half of 2022, a CGA on the CO/02 CEMS was conducted on March 4, 2022, March 23, 2022, and June 23, 2022, with reported results appearing to have met the 15% accuracy requirement of Procedure 1. In addition to the mailing of this letter, 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, a rake, Environmental Engineer Division of Air Quality,NCDEQ c: Kirk Yarbrough, Stericycle (e-copy) Don Nuss, Stericycle (e-copy) Ray Stewart, DAQ WSRO (e-copy) Gary Saunders, DAQ SSCB (e-copy) IBEAM Documents, 0100010 (e-copy) Central File, Alamance County