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HomeMy WebLinkAboutAQ_F_0100010_20210415_CEM_RptRvwLtr (4) Etc STATE ROY COOPER Governor DIONNE DELLFGATTI A Secretary MICHAEL ABRACZINSKAS NORTH CAROLINA Director Environmental Quality April 15, 2021 Mr. Kirk Yarbrough Facility Manager Stericycle, Inc. 1168 Porter Avenue Haw River,North Carolina 27258-9547 SUBJECT: Review of 2020 Semiannual CO/02 CEMS Report, Second 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 January 28, 2021. The excess emissions report assessed the carbon monoxide (CO)/oxygen(02) continuous emissions monitoring systems (CEMS) operating at the Haw River Facility during the second half of 2020. Additional requested information regarding quarterly gas audits was provided on April 13, 2021. 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 1 B 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. There were no exceedances during the reporting period. 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.F. When compared to the total operating time of the incinerators,percent excess emissions (%EE) and percent monitor downtime (%MD)were reported as follows: D EQ North Carolina Department of Environmental Quality I Division of Air Quality 217 West Jones Street 1 1641 Mail Service Center I Raleigh,North Carolina 27699-1641 NORTH CAROLINA _ oeparnmem of eammameami Quality /`� 919.707.8400 Mr. Kirk Yarbrough April 15, 2021 Page 2 Unit Quarter %EE %MD HMIWI ESO 1 1st 0.0 0.0 2nd 0.0 0.0 HMIWI ES02 1st 0.0 0.0 2nd 0.0 0.0 The incinerators and associated CO/02 CEMS appear to have operated using good O&M practices for minimizing emissions since quarterly%EE and%MD were less than 6% for any single calendar quarter and less than 3% for two consecutive quarters. 4. Finally, a review was conducted on quality assurance (QA) tests pursuant to Section 5 of 40 CFR Part 60 Appendix F - Quality Assurance Procedures and Specific Condition 2.1.A.21 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 third quarter, CGAs on the CO/02 CEMS were conducted on September 30, 2020 with reported results appearing to have met the 15% accuracy requirement of Appendix F. During the fourth quarter, RATAs on the CO/02 CEMS were successfully conducted on October 28, 2020 as indicated in my review letter dated, April 8, 2021. Due to COVID-19 restrictions on DAQ staff and our office operations, the mailing of this letter may be delayed. In the meantime, 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, 47i rake, onmenta ngineer 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