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HomeMy WebLinkAbout0102_INSP_20170606FACILITY 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 6, 2017 Date of Last Inspection: May 18, 2016 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 Lee Hill, Environmental Senior Specialist – SWS Amanda Freeman, Environmental Senior Specialist – SWS Al Burson, Director of Incinerator Compliance – Stericycle, Inc. 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 – 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 FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 2 of 5 STATUS OF PAST NOTED VIOLATIONS: None OBSERVED VIOLATIONS: None ADDITIONAL COMMENTS On June 6, 2017, John Patrone, Bill Patrakis, Lee Hill, and Amanda Freeman met with Al Burson, 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 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. 4. The facility permit, site plan, operations plan, and contingency plan were discussed. 5. 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. 6. During the inspection both incinerators were in operation. 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. Driver data is displayed on a large monitor. The system uses GPS to obtain real-time information regarding route, driver status, truck location, etc. 9. It has been stated that all out of state trailers and customer loaded trailers are refrigerated. Local route trailers 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 spaces, 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. It has been stated that training is conducted by company personnel, on-line, and with training modules. An employee training record was verified. 11. During fiscal year 2015 - 2016, the facility accepted waste materials from numerous states and Washington, DC. 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 from the facility. 14. The facility maintains records of the amount of solid waste received and origin of loads. The number of containers received for June 2016 through May 2017 is 945,911 and the amount of solid waste treated is 23,791,839.26 lbs. 15. Facility throughput is ~ 2M lbs/month. The monthly throughput includes decreased solid waste treatment during incinerator scheduled maintenance. 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 16. The facility maintains records of the amount of incinerator ash hauled-off site. The amount of ash removed for June 2016 through May 2017 is 6,730,280 lbs or 3,365.14 tons. 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 8, 2016. Facility throughput for July 2015 through June 2016 is 11,454.05 tons or 22,908,101.02 lbs. The amount of ash produced from incineration during the same period is 3,383.70 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 two containers a day, six days a week, are hauled to the landfill. 20. During the inspection, four roll-off containers were in the dewatering area (two full and two empty) and two full roll-off containers (tarped) were stored in the parking lot. 21. The facility routinely operates both incinerators. Scheduled maintenance is conducted for each incinerator. Incinerator maintenance occurred: 05/29/16 – 06/02/16, 06/26/16 – 06/30/16, 07/11/16 – 07/13/16, 07/24/16 - 07/29/16, 08/27/16 – 08/30/16, 09/13/16 – 09/15/16, 09/26/16 – 09/30/16, 10/17/16 – 10/23/16, 11/13/16 – 11/19/16, 12/04/16 – 12/06/16, 12/12/16 – 12/16/16, 01/06/17 – 01/11/17, 01/15/17 – 01/19/17, 02/04/17 – 02/11/17, 02/25/17 – 02/28/17, 03/20/17 – 03/24/17, 03/28/17 – 03/31/17, 04/10/17 – 04/13/17, and 05/21/17 – 05/30/17. 22. Facility throughput records indicate that during scheduled 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. 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 and redirected to other Stericycle, Inc. facilities. 24. A backfill manifest is maintained for boxes transferred to other locations during incinerator maintenance and for the transfer station operation. The backfill manifest was verified for the following months (loaded trailers hauled- off): June 2017, February 2017, December 2016, and October 2016. 25. The facility has two floor scales and two belt scales. The scales were tested/calibrated by Carlton Scale on April 5, 2017, January 9, 2017, October 14, 2016, and July 18, 2016. 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 18, 2017. Preliminary review of the test results indicates compliance. 28. The facility was inspected by the DAQ on April 18, 2017 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 verified for both incinerators for: 04/30/17, 02/22/17, 10/15/16, 08/05/16, and 08/06/16. 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 1563 °F in the primary chamber and 2015 °F in the secondary chamber and 44.3 inches water column (W.C.). Incinerator unit No. 2 was operating at 1743 °F in the primary chamber and 2023 °F in the secondary chamber and 42.3 inches W.C. 34. It has been 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 treated on site and 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. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 5 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. 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, paint filter test, and pH analysis conducted. Records were reviewed for samples analyzed by Environmental Conservation (ENCO) Laboratories taken on January 12, 2017 and August 12, 2016. 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. Mr. Skrzypczak stated that a contingency plan for the transport of regulated medical waste is maintained in each vehicle and that drivers are familiar with the plan. The contingency plan was verified in a Stericycle truck. 43. The universal biohazard symbol was displayed on trailers stored at the facility. 44. During the inspection, the facility had 12 refrigerated trailers on site containing medical waste. Trailer temperatures ranged from 35 °F to 45 °F or were actively being unloaded. 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 two transfer trailers were observed on site. The trailer temperatures ranged from 35 °F to 45 °F. 46. Transit time was verified for four medical waste boxes observed on the receiving floor/processing line. Two of the boxes were shipped on refrigerated trailers and were picked-up on June 2 and June 5, 2017. Two of the boxes were received from client loaded refrigerated trailers and were in the process of being scanned-in prior to treatment. 47. Facility financial assurance has been submitted to the SWS. 48. Access roads are of all-weather construction. 49. The facility is secured by a locked gate. 50. The facility permit number is posted on the gate. An intercom system is accessible. Mr. Skrzypczak stated that personnel are at the facility 24 hours, 7 days a week. 51. The facility permit was recorded with the Alamance County Register of Deeds on February 24, 2017, Book: 03635 and Page: 0056-0065. 52. The permit to operate (PTO) expiration date is November 30, 2021. 53. The PTO renewal application shall be submitted to the SWS by May 30, 2021. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 5 of 5 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: June 9, 2017 X Email Hand delivery US Mail Certified No. [ _] Copies: Deb Aja, Western District Supervisor - SWS Jessica Montie, Compliance Officer - SWS Bill Patrakis, Environmental Senior Specialist – SWS Lee Hill, Environmental Senior Specialist – SWS Amanda Freeman, 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 – Stericycle, Inc. (c. 336-417-1472, acarden@stericycle.com)