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HomeMy WebLinkAbout0102_INSP_20210608FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 5 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: June 8, 2021 Date of Last Inspection: March 10, 2020 FACILITY NAME AND ADDRESS: Stericycle, Inc. Medical Waste Incinerator Facility 1168 Porter Avenue Haw River, NC 27258 GPS COORDINATES: Lat.: 36.06599 Long.: -79.34881 FACILITY CONTACT NAME AND PHONE NUMBER: Stericycle, Inc. Kirk Yarbrough, Plant Manager w. 336-578-8904 x 39 c. 336-380-7440 f. 336-578-8903 kirk.yarbrough@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: Chuck Kirchner, Environmental Senior Specialist – Solid Waste Section (SWS) Susan Heim, Environmental Senior Specialist – SWS Kim Sue, Environmental Senior Specialist – SWS Don Nuss, Regional Environmental Manager - Atlantic Region – Stericycle, Inc. Kirk Yarbrough, Plant Manager – Stericycle, Inc. Jimmy Overton, Operational Supervisor – 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 5 OBSERVED VIOLATIONS: None ADDITIONAL COMMENTS On June 8, 2021, Chuck Kirchner, Susan Heim and Kim Sue met with Don Nuss, Kirk Yarbrough and Jimmy Overton 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. Non-conforming medical waste received at this facility, that is not suitable for processing at this facility, is transferred from this facility to other Stericycle facilities that are able to accept that waste stream. 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, both incinerators were in operation. 7. Mr. Yarbrough 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. Mr. Yarbrough stated that 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. Overton stated that training is conducted by company personnel, on-line, and with the use of training modules that include testing. Mr. Overton stated that a STEM (Safety & Environmental Management) system was used to train employees at facility training computers. Several employee online training records and an incinerator operation refresher class rosters were observed. Program also tracked how many employees had completed the trainings and when training refresher classes were due. A spreadsheet showing who had completed trainings for the month and who still had trainings to do is posted each week by Mr. Overton. 11. All employee training requirements appear to be up to date and in compliance with permit requirements. 12. The facility provides clients with boxes, totes, labels, and plastic bags to conform with packaging and transportation of regulated medical waste. 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 5 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. The current trailer log was observed this inspection. 14. Three boxes were selected at random on the facility floor. Stericycle was able to locate the origin of the box and show the boxes current location. 15. The facility maintains records of the amount of solid waste received, origin of loads and disposition of ash. Throughput for March 1, 2021 through March 31, 2020 is 1,089.94 tons of material was incinerated. A total of 346.11 tons of ash were sent to the Upper Piedmont Regional landfill (73-04) during this timeframe. 16. The Facility Annual Report (FAR) was last submitted on July 01, 2020. Medical Waste incinerated at the facility from July 1, 2019 to June 30, 2020 was 6,301.66 tons from in state and 5,126.27 tons from out of state (11,427.93 tons total). The amount of ash hauled to Upper Piedmont Regional Landfill (73-04) is 3,158.30 tons. 17. Mr. Yarbrough stated that facility throughput is ~2.0 million pounds per month which is up ~ .3 million lbs/month since last inspection. The monthly throughput decreases during incinerator maintenance. 18. Dental and Mercury containing waste is shipped to another autoclave Stericycle facility (13-05) in Concord, NC. 19. Incinerator ash is stored on site in 20 yd3 roll-off containers. Mr. Yarbrough stated that one or two containers are filled with ash daily and hauled to the landfill. 20. During the inspection, four roll-off containers were in the dewatering area (one being filled and three empty). 21. The facility routinely operates both incinerators. Scheduled maintenance is conducted for each incinerator approximately every other month. Mr. Nuss stated that each incinerator will run for eight to nine weeks and then be shut down for maintenance for three to four days. 22. A major overhaul of the incinerators was conducted in 2020. The incinerators were overhauled one at a time and were down for about eight weeks each. 23. The facility has two floor scales and two belt scales. The scales were tested/calibrated by JA King on July 22, 2020. JA King was at the facility during this inspection recalibrating the scales. 24. The facility has a Division of Air Quality (DAQ) Title V permit, number 05896/T25, issued 12/19/16 – expiration 11/30/21. Maximum charge rate for the incinerators is 1,870 lbs. per hour per incinerator. Stericycle is in the process of renewing their DAQ permit. 25. The facility was inspected by the DAQ on May 18, 2021. 26. The incinerators are natural gas automatic feed dual chamber-controlled air Joy Energy Systems, Inc. T- Series units, model number 2500 TES. 27. As initially designed, the maximum charging rate for each incinerator is 1,911 lbs/hour. 28. The DAQ permit states that the maximum charging rate for each incinerator is 1,870 lbs/hour. 29. Facility has set the charge rate of each incinerator at 1,860 lbs/hour. 180 pounds of waste is loaded into each incinerator at the rate of 10x/hour to achieve this charge rate. 30. The facility maintains continuous monitoring records of the primary and secondary chamber temperatures. The primary chamber is required to be > 1200 °F and the secondary chamber > 1800 °F [for a minimum of > 1 second]. 31. During the inspection incinerator unit No. 1 was operating at 1611 °F in the lower chamber and 2149 °F in the upper chamber and incinerator unit No. 2 was operating at 1807 °F in the lower chamber and 2034 °F in the upper chamber. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 5 32. Mr. Yarbrough 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. 33. The facility has an Industrial User Pretreatment Permit (IUP, No. 0030) from the City of Graham issued July 1, 2016 – expiration June 30, 2021. 34. Reusable containers are washed with a mycobactericidal disinfectant. The containers are washed on the floor adjacent to the incinerators. Mr. Yarbrough stated that the process water is recycled in the incinerator ash water-quench process and any wastewater is routed to the municipal sewer/the City of Graham WWTP. 35. 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. 36. 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. 37. 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. 38. 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. Mr. Nuss stated that Stericycle has recently started testing for sulfur as well. Records for the last sample taken on February 12, 2021 were observed. Samples were analyzed by Environmental Conservation (ENCO) Laboratories. 39. The initial facility waste screening process consists of: generator requirements to properly package and label boxes, drivers are trained to reject boxes if inaccurately packaged and/or labeled, client contract requirement to abide by waste acceptance rules, Stericycle, Inc. sales personnel educate clients about medical waste requirements, additional related information available online or in print and employees undergo training regarding unacceptable waste, routine screening of ash, and the reburning of ash when applicable. 40. The universal biohazard symbol was displayed on trailers stored at the facility. 41. During the inspection, the facility had 5 refrigerated trailers on site containing medical waste. An additional ~25 empty trailers were observed on site. Two trailers containing medical waste were observed this inspection. Trailer 53046R was at 40 °F with a full tank of fuel and trailer 48021R was at 43 °F with a ¾ tank of fuel. Both trailers observed were properly labeled and secured. 42. 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. A transfer trailer of non-conforming waste is shipped-out to other Stericycle, Inc. facilities ~ twice a week. Non-conforming waste holding area was observed during this inspection. 43. All trailers observed this inspection appeared to be processed within regulation timeframes. 44. The facility has three back up facilities that can be used in the event waste is not able to be handled at this facility. 45. No leaking containers were observed this inspection. 46. No putrescent odors were noted this inspection. 47. No exposed or improperly packaged waste was observed this inspection. 48. Mr. Yarbrough stated that Orkin Commercial Services comes out on a monthly schedule to provide vector control. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 5 49. Spill kits were observed around facility. 50. Access roads are of all-weather construction. 51. The facility is secured by a locked gate. 52. The facility had a proper signage. 53. 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. 54. The permit to operate (PTO) expiration date is November 30, 2021. 55. The PTO renewal application submitted to the SWS on May 12, 2021. Permit renewal currently under review. Please contact me if you have any questions or concerns regarding this inspection report. ________________________________________ Phone: 336-776-9633 _ Chuck Kirchner Environmental Senior Specialist Regional Representative Sent on: June 9, 2021 X Email Hand delivery US Mail Certified No. [ _] Copies: Deb Aja, Western District Supervisor - Solid Waste Section