Document em1oBbOn29a5mKymMXKyYOb1E

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Stericycle, Clinton, Illinois FROM: Charles Zeman, Physical Scientist AECAB (MN/OH) THRU: Brian Dickens, Section Supervisor AECAB (MN/OH) TO: File BASIC INFORMATION Facility Name: Stericycle Facility Location: 5815 Weldon Springs Rd, Clinton, IL, 61727 Date of Inspection: July 23, 2024 EPA Inspector(s): 1. Charles Zeman, Physical Scientist 2. Aileen Drum, Physical Scientist 3. Justin Smith, Environmental Engineer Other Attendees: 1. Robert Porter, Operations Supervisor (Stericycle) 2. Douglas Clark, Facility Manager (Stericycle) 3. David Corsa, Maintenance Manager (Stericycle) Contact Email Address: Wade VanZee, Regional Manager (Stericycle) - wvanzee@stericycle.com Purpose of Inspection: Clean Air Act compliance evaluation Facility Type: Large Hospital, Medical, and Infection Waste (HMIW) Incinerator Regulations Central to Inspection: 40 CFR 60 Subpart Ce, NSPS for HMIW incinerators. 35 Ill. Adm. Code Part 229, state plan for HMIW incinerators. The facility's Title V permit. Arrival Time: 11:30 am Departure Time: 1:40 pm Inspection Type: Unannounced Inspection Announced Inspection Facility Name: Stericycle, Inc. Facility Location: 5815 Weldon Springs Rd, Clinton, IL, 61727 Date of Inspection: July 23, 2024 OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Provided CBI warning to facility The following information was obtained verbally from Douglas Clark, David Corsa, and Robert Porter unless otherwise noted. Company Ownership: At the time of the inspection, Stericycle has not experienced any change in ownership within the past 5 years. Process Description: Stericycle receives and processes medical waste by incineration, achieving mass reduction by 85% before shipping ash to an offsite landfill. The facility houses two identical incinerators labeled as "Unit 1" and "Unit 2." For each incinerator, medical waste is first loaded into the primary chamber where it is reduced to ash, which then drops out of a chute to a water bath. Smoke that is internal to the primary chamber is directed upwards to a second, oxygen-rich chamber. Gas and smoke from the secondary chamber are exhausted to a series of control devices, beginning with an atomizer that injects water mist. The pre-quenched exhaust is directed to a selective non-catalytic reduction (SNCR) system before passing through the quench tower. Water is used to reduce temperature and achieve pH control with sodium hydroxide (NaOH). Demisted gases are then pulled through carbon beds and 1-micron filters by an induced-draft fan before being boosted to atmosphere. Staff Interview: The facility operates 24 hours per day, 7 days per week, in 4 staggered shifts and employs approximately 50 workers at their Clinton, IL location. An estimated 3-5 trailers deliver more than 10,000 lbs of hospital, medical, or infectious waste per day, each, and the deliveries are logged on a manifest. Pallets of waste are batch-loaded into the primary chamber at a rate of 135 lbs/minute and an interlock system precludes feed rates greater than 1400 lbs/hour. The facility's Title V permit limits Page 2 of 6 Facility Name: Stericycle, Inc. Facility Location: 5815 Weldon Springs Rd, Clinton, IL, 61727 Date of Inspection: July 23, 2024 the feed rate to approximately < 1430 lbs/hour for each unit. Charge fed to the incinerator spends 4-6 hours in the primary chamber at temperatures of > 1400 F, fueled by the heating value of the feed material. Exiting smoke and gas spend several seconds in the secondary chamber at > 1800 F. Between the atomizer and SNCR system, there is an emergency vent to the bypass stack, which is capable of exhausting uncontrolled combustion products directly to atmosphere. Urea in the SCNR system controls for nitrogen oxides while NaOH controls for hydrogen chloride (HCl). Particulate matter is captured by water mist and droplets, additionally facilitated by a venturi scrubber. The quench tower reduces the temperature of incinerator exhaust to a target of 178 F, referred to as the "quench temperature." The remaining carbon beds and 1-micron filters are intended to act as a final control before venting the exhaust to atmosphere. The emergency bypass stack, located between the atomizer and SNCR system, is automatically activated in the event of a total power failure, malfunction of the induced-draft fan, or if the quench temperature reaches > 300 F, and feed is immediately stopped. The facility recalls two such events in which the bypass stack was used within the past 5 years (February 2022 and February 2023). In both cases, the use of the bypass stack was triggered by quench temperatures reaching > 300 F as a result of a quench belt failure. 35 Ill. Adm. Code Part 229 stipulates that the facility's emission limitations apply at all times, including during malfunctions. Both events were isolated to Unit 1. The facility now replaces the quench belts every 2 months for both units. The last performance stack test was conducted in September of 2022 for the emission of particulate matter, HCl, and carbon monoxide for both units. EPA notes that Unit 2 was found to emit 0.0098 gr/dscf of particulate matter. 40 CFR 60 Subpart Ce limits large HMIW incinerators to 0.011 gr/dscf of particulate matter emissions. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: During a tour of the facility, EPA observed boxes of medical waste being loaded into Unit 1. When the door to the incinerator was open, large amounts of smoke billowed out of the primary chamber. Facility staff explained that this happens occasionally as a result of paper or cardboard getting stuck near the entrance to the incinerator. Control displays showed the temperatures of the primary chamber, secondary chamber, and quench tower as a 3-hour average. Quench temperatures for Units 1 and 2 were 178 F and 158 F, respectively. Precise logs of the quench temperature were recorded on paper at 1-hour intervals. EPA noted the magnehelic for the lower carbon bed on Unit 2 displayed a reading below 0 in. WC. Facility personnel stated that was below the recommended range of 3-3.5 in. WC and that the line may be clogged. Outside of the facility, each incinerator unit had 2 stacks: the bypass stack and process stack. The facility's Title V permit limits opacity to 6% as measured on a 6minute block average. No visible emissions were seen to be exiting the stacks. Page 3 of 6 Facility Name: Stericycle, Inc. Facility Location: 5815 Weldon Springs Rd, Clinton, IL, 61727 Date of Inspection: July 23, 2024 Photos and/or Videos: were taken during the inspection and are listed in Appendix A. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Semi-annual reports to IEPA for the past 5 years Records of quench temperature for February of 2022, 2023, and 2024 Results of the 2022 performance stack test 2023 incinerator condition report Process flow diagram Concerns: EPA noted concerns of multiple uses of the bypass stack within the past few years and the out-of-range magnehelic for Unit 2. DIGITAL SIGNATURES Zeman, Digitally signed by Zeman, Charles Date: 2024.09.11 Report Author: _C_h__a_rl_e_s_______07_:5_1:0_3_-0_5'_00_' ____________ Section Supervisor: BRIAN Digitally signed by BRIAN DICKENS Date: 2024.09.11 _D_I_C_K__E_N_S_____0_7:_57_:4_2 _-05_'0_0'______________ Page 4 of 6 Facility Name: Stericycle, Inc. Facility Location: 5815 Weldon Springs Rd, Clinton, IL, 61727 Date of Inspection: July 23, 2024 APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log Page 5 of 6 Facility Name: Stericycle, Inc. Facility Location: 5815 Weldon Springs Rd, Clinton, IL, 61727 Date of Inspection: July 23, 2024 APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Inspector Name: Charles Zeman Archival Record Location: Inspection ERC Folder Image Number 1 File Name IMG_0600.JPG Date and Time (incl. Time zone and DST) 7-23-2024 12:35 pm CST Description of Image Unit 1 Parameter Monitor IMG_0601.JPG 7-23-2024 Unit 1 Hourly Readings 2 12:39 pm CST IMG_0602.JPG 7-23-2024 Unit 2 Parameter Monitor 3 12:41 pm CST IMG_0603.JPG 7-23-2024 Unit 2 Hourly Readings 4 12:41 pm CST IMG_0604.JPG 7-23-2024 Bypass Stack 5 12:50 pm CST IMG_0605.JPG 7-23-2024 Magnehelic gages of Unit 2 6 12:52 pm CST IMG_0606.JPG 7-23-2024 Magnehelic gages of Unit 1 7 12:54 pm CST IMG_0607.JPG 7-23-2024 All 4 stacks as seen from outside. 8 12:58 pm CST Page 6 of 6