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HomeMy WebLinkAbout0102_INSP_20180517FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 4 UNIT TYPE: Lined MSWLF LCID YW Transfer Compost SLAS COUNTY: Alamance Closed MSWLF HHW White goods Incin X T&P FIRM PERMIT NO.: 01-02 CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: May 17, 2018 Date of Last Inspection: June 6, 2017 FACILITY NAME AND ADDRESS: Stericycle, Inc. Medical Waste Incinerator Facility 1168 Porter Avenue Haw River, NC 27258 GPS COORDINATES: N: 36.06599 W: -79.34881 FACILITY CONTACT NAME AND PHONE NUMBER: Stericycle, Inc. A. Alan Skrzypczak, Plant Manager w. 336-578-8901 x.24 c. 336-269-2140 f. 336-578-8903 askrzypczak@stericycle.com FACILITY CONTACT ADDRESS: Stericycle, Inc. Don Nuss, Regional Environmental Manager – Atlantic Region 3614 Hoskins Court Hamilton, OH 45011 c. 513-543-7073 dnuss@stericycle.com PARTICIPANTS: John Patrone, Environmental Senior Specialist - Solid Waste Section (SWS) Bill Patrakis, Environmental Senior Specialist – SWS Don Nuss, Regional Environmental Manager - Atlantic Region – Stericycle, Inc. A. Alan Skrzypczak, Plant Manager – Stericycle, Inc. Kirk Yarbrough, Operations Supervisor – Incinerator – Stericycle, Inc. Andrea Carden, Transportation/Administration – Stericycle, Inc. STATUS OF PERMIT: Permit To Operate (PTO) issued February 17, 2017 PTO expiration date November 30, 2021 PURPOSE OF SITE VISIT: Comprehensive Inspection STATUS OF PAST NOTED VIOLATIONS: None FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 4 OBSERVED VIOLATIONS: None ADDITIONAL COMMENTS On May 17, 2018, John Patrone and Bill Patrakis met with Don Nuss, Alan Skrzypczak, Kirk Yarbrough, and Andrea Carden to conduct a comprehensive inspection of the Stericycle, Inc. Medical Waste Incinerator Facility on Porter Avenue in Haw River, Alamance County. 1. The facility is a medical waste treatment operation consisting of two incinerator units. 2. A medical waste transfer station is also operated at the facility. 3. The office is open Monday through Friday 8:00 am to 5:00 pm. Facility operation/incineration occurs 24 hours a day, 7 days a week. 4. The facility permit, site plan, operations plan, and contingency plan were discussed. 5. The facility incinerates medical waste (regulated and non-regulated), United States Department of Agriculture (USDA) Animal and Plant Health Inspection Service - Plant Protection and Quarantine (APHIS-PPQ) regulated garbage, controlled substances, chemotherapeutic waste, healthcare industry documents, and pharmaceuticals. 6. During the inspection incinerator number 1 was in operation. Incinerator number 2 was being repaired. 7. Mr. Skrzypczak stated that Stericycle, Inc. vehicles transport ~ 100 percent of the material received. 8. The facility uses Road Net to track drivers dispatched on local routes from the Haw River facility. The system uses GPS to obtain real-time information regarding route, driver status, truck location, etc. 9. Ms. Carden stated that all of the out of state trailers and customer loaded trailers are refrigerated. Local route trucks are commonly not refrigerated. 10. The facility provides training for plant personnel – annually, biennially, and as needed. Training categories include: bloodborne pathogens, emergency action plans, hazard communication, machine guarding, personal protective equipment, spill response, lockout/tagout control, confined space, waste acceptance protocol, incinerator operation, boiler operation, APHIS-PPQ waste, and dental waste management. Training for DOT hazardous materials and forklift operation is scheduled accordingly. Mr. Kirkpatrick stated that training is conducted by company personnel, on-line, and with the use of training modules. An employee training record and an incinerator operation refresher class roster were observed 11. During fiscal year 2016 - 2017, the facility accepted waste materials from numerous states, Washington, DC, and Puerto Rico. 12. The facility provides clients with boxes, totes, labels, and plastic bags. Plastic bags are imprinted with data stated to meet the requirements of 15A NCAC 13B .1204(a)(1) and DOT red bag regulations (02/14/03). 13. Medical waste boxes observed had a label with generator and transporter/treatment facility information and a barcode containing the required information. The boxes contained the universal biohazard symbol and medical waste statement. Box barcodes on client-loaded trailers (refrigerated trailers stored at businesses) are scanned upon incineration. Individual box barcode is scanned at pickup and upon incineration. Scanned information is sent to the facility database to include: date received, number of boxes per generator, weight of each box, date treated, generator billing, etc. The facility also maintains a hand-written log of when trailers are received at the facility and picked-up [medical waste transferred-out] from the facility. 14. The facility maintains records of the amount of solid waste received and origin of loads. Throughput for June 1, 2017 through May 16, 2018 is 10,566.94 tons. 15. Facility throughput is ~ 1.3 – 1.5M lbs/month. The monthly throughput includes decreased solid waste treatment during incinerator maintenance. 16. The facility maintains records of the amount of incinerator ash hauled-off site. The amount of ash removed for June 1, 2017 through May 16, 2018 is 3,107.39 tons. The item(s) listed above were observed by Section staff and require action on behalf of the facility in order to come into or maintain compliance with the Statutes, Rules, and/or other regulatory requirements applicable to this facility. Be advised that pursuant to N.C.G.S. 130A-22, an administrative penalty of up to $15,000 per day may be assessed for each violation of the Solid Waste Laws, Regulations, Conditions of a Permit, or Order under Article 9 of Chapter 130A of the N.C. General Statutes. Further, the facility and/or all responsible parties may also be subject to enforcement actions including penalties, injunction from operation of a solid waste management facility or a solid waste collection service and any such further relief as may be necessary to achieve compliance with the North Carolina Solid Waste Management Act and Rules. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 3 of 4 17. Incinerator ash is disposed of at the Upper Piedmont Regional Landfill (73-04). 18. The facility annual report (FAR) was received by the SWS dated July 7, 2017. Facility throughput for July 2016 through June 2017 is 11,900.46 tons or 23,800,921.78 lbs. The amount of ash produced from incineration during the same period is 3,376.75 tons. 19. Incinerator ash is stored on site in 20 yd3 roll-off containers. Mr. Skrzypczak stated that two containers are filled with ash daily and that two containers a day, six days a week, are hauled to the landfill. 20. During the inspection, three roll-off containers were in the dewatering area (one being filled and two empty), one empty roll-off container (tarped) was being off-loaded from transport to the landfill, and one empty container was stored on the property. 21. The facility routinely operates both incinerators. Scheduled maintenance is conducted for each incinerator ~ every other month. Incinerator maintenance records were observed for incinerator number 1 - January, March, and May 2018 and incinerator number 2 - February, April, and May 2018. 22. Facility throughput records indicate that during incinerator maintenance there is a decrease in the number of containers/amount of solid waste treated. Solid waste throughput is reduced by > 1/2 during maintenance periods. Records were observed for January 18, 2018, February 5-9, 2018, March 12-16, 2018, and April 9-13, 2018. 23. During incinerator maintenance, solid waste collected by local routes is given priority to be treated. Solid waste on refrigerated trailers is stored accordingly and/or transferred to other Stericycle, Inc. facilities. 24. A backfill manifest [loaded trailers hauled-off] is maintained for boxes transferred to other locations during incinerator maintenance and for the transfer station operation. Backfill manifests were observed pertaining to the Concord site - January, March, and April 2018 and the Baltimore site – March and May 2018. 25. The facility has two floor scales and two belt scales. The scales were tested/calibrated by Carlton Scale on February 27, 2018, November 17, 2017, and August 22, 2017. 26. The facility has a Division of Air Quality (DAQ) Title V permit, number 05896/T25, issued 12/19/16 – expiration 11/30/21. 27. The facility conducted emissions testing on April 10 – 11, 2018. Review of the emissions testing results indicates compliance. 28. The facility was inspected by the DAQ on April 10, 2018 and found in compliance at that time. 29. The incinerators are natural gas automatic feed dual chamber controlled air Joy Energy Systems, Inc. T-Series units, model number 2500 TES. 30. As initially designed, the maximum charging rate for each incinerator is 1,911 lbs/hour. 31. The DAQ permit states that the maximum charging rate for each incinerator is 1,870 lbs/hour. 32. The facility maintains continuous monitoring records of the primary and secondary chamber temperatures. Records were observed for both incinerators for: 04/10-11/18, 09/16-17/17, and 12/15-16/17. The primary chamber is required to be > 1200 °F and the secondary chamber > 1800 °F [for a minimum of > 1 second]. 33. During the inspection incinerator unit No. 1 was operating at 1628 °F in the primary chamber and 2109 °F in the secondary chamber and 72 inches water column (W.C.). Incinerator unit No. 2 was not in operation. 34. Mr. Skrzypczak stated that the incinerator reduces material in ~ 3 – 4 hours, is batch-fed ~ every 6 minutes, and the ash represents a 70 percent volume reduction. 35. The facility has an Industrial User Pretreatment Permit (IUP, No. 0030) from the City of Graham issued July 1, 2016 – expiration June 30, 2021. 36. Reusable containers are washed with a mycobactericidal disinfectant. The containers are washed on the floor adjacent to the incinerators. Mr. Skrzypczak stated that the process water is routed to the municipal sewer/the City of Graham WWTP. 37. Vehicle trailers are cleaned with a pressure washer and mycobactericidal disinfectant in the truck wash bay, when required. Floor drains for the truck wash bay are piped for reuse in the incinerator ash water-quench process. 38. Each incinerator is equipped with an ash removal process. Ash drops from the rear of the incinerator into a water- quench tank. A mechanical arm rakes the ash from the quench tank dragging it up a dewatering ramp. The ash is deposited into a 2 yd3 container. Facility personnel sort-out large pieces of ash (2 - 4 times/hour), raking it into a 30-gallon cart. The sorted ash is re-incinerated. 39. The 2 yd3 containers of ash are dumped into 20 yd3 roll-off containers. The roll-off containers are dewatered on a covered cement slab. Floor drains for the dewatering process are piped for reuse in the incinerator ash water- quench process. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 4 40. The facility takes two representative ash samples annually. Composite samples are gathered from a 20 yd3 roll-off container. The facility has a toxicity characteristic leaching procedure (TCLP) for the eight RCRA metals [arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver], paint filter test, and pH analysis conducted. Records were observed for samples analyzed by Environmental Conservation (ENCO) Laboratories taken on [received] January 5, 2018 and July 27, 2017. The results indicate compliance. 41. The facility waste screening process consists of: generator requirements to properly package and label boxes, drivers trained to reject boxes if inaccurately packaged and/or labeled, client contract requirement to abide by waste acceptance rules, Stericycle, Inc. sales personnel educating clients, related information available - printed and online, employee training regarding unacceptable waste, routine screening of ash, and the reburning of ash when applicable. 42. A contingency plan for the transport of regulated medical waste is maintained in each vehicle. 43. The universal biohazard symbol was displayed on trailers stored at the facility. 44. During the inspection, the facility had 15 refrigerated trailers on site containing medical waste. Trailer temperatures ranged from 35 °F to 45 °F. 45. Solid waste received pertaining to the medical waste transfer station, operated on the receiving floor of the facility, is sorted and loaded into a refrigerated transfer trailer. Ms. Carden stated that a transfer trailer is shipped-out to other Stericycle, Inc. facilities ~ twice a week. At the time of the inspection, no solid waste boxes/totes were on the facility floor awaiting transfer and a transfer trailer was observed on site. The trailer temperature was 41 °F. 46. Transit time was verified for two medical waste boxes observed on the receiving floor/processing line. One box was shipped on a refrigerated trailer and was picked-up on May 4, 2018 and received at the facility on May 10, 2018 and the other box was picked up on May 16, 2018 by a local route truck [unloaded May 17, 2018]. 47. Access roads are of all-weather construction. 48. The facility is secured by a locked gate. 49. The facility permit number is posted on the gate. An intercom system is accessible. Personnel are at the facility 24 hours, 7 days a week. 50. The permit to operate (PTO) expiration date is November 30, 2021. 51. The PTO renewal application shall be submitted to the SWS by May 30, 2021. Please contact me if you have any questions or concerns regarding this inspection report. Phone: 336-776-9673 John Patrone Environmental Senior Specialist Regional Representative Sent on: May 24, 2018 X Email Hand delivery US Mail Certified No. [ _] Copies: Deb Aja, Western District Supervisor – SWS Adam Ulishney, Environmental Compliance Branch Head - SWS Bill Patrakis, Environmental Senior Specialist – SWS A. Alan Skrzypczak, Plant Manager – Stericycle, Inc. Kirk Yarbrough, Operations Supervisor – Incinerator – Stericycle, Inc. (c. 336-380-7440, kirk.yarbrough@stericycle.com) Andrea Carden, Transportation/Administration – Stericycle, Inc. (c. 317-504-8848, acarden@stericycle.com)