4124_INSP_20180212

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 1 of 4

UNIT TYPE:
Lined
MSWLF LCID YW Transfer X Compost SLAS COUNTY: Guilford
Closed
MSWLF HHW White
goods Incin T&P X FIRM PERMIT NO.: 41-24
CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: February 12, 2018 Date of Last Inspection: January 17, 2017

FACILITY NAME AND ADDRESS:
Image First Services, LLC Medical Waste Treatment Facility and Transfer Operation
639 Alton Place
High Point, NC 27263

GPS COORDINATES:
N: 35.93231 W: -79.97224

FACILITY CONTACT NAME AND PHONE NUMBER:
Billy Helms, Director of Medical Waste Services – Image First Services, LLC
w. 800-368-3676 x3348
c. 336-414-3770
[e-mail]

FACILITY CONTACT ADDRESS:
Image First Services, LLC
Billy Helms, Director of Medical Waste Services
639 Alton Place
High Point, NC 27263

PARTICIPANTS:
John Patrone, Environmental Senior Specialist - Solid Waste Section (SWS)
Billy Helms, Director of Medical Waste Services – Image First Services, LLC

STATUS OF PERMIT:
Permit To Operate (PTO) issued May 8, 2017
PTO expiration date July 2, 2022

PURPOSE OF SITE VISIT:
Comprehensive Inspection

STATUS OF PAST NOTED VIOLATIONS:
None

OBSERVED VIOLATIONS:
None

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 4

ADDITIONAL COMMENTS
On February 12, 2018, John Patrone met with Billy Helms to conduct a comprehensive inspection of Image First
Services, LLC Medical Waste Treatment Facility and Transfer Operation on Alton Place in High Point, Guilford
County.

1. The facility is a medical waste treatment facility consisting of an autoclave.
2. The facility also operates as a medical waste transfer station.
3. The facility receives regulated and non-regulated medical waste.
4. A healthcare uniform laundering service is operated within the same building. The operations do not share the
same space. The medical waste treatment operation is fully enclosed within its own sector of the building.
5. The facility operates Monday through Friday 6:00 am to 4:00 pm, two or three days a week.
6. The facility permit, site plan, operations plan, and contingency plan were discussed.
7. During the inspection, the autoclave was not in operation.
8. Image First Services, LLC uses a non-refrigerated truck to transport medical waste to the facility. Truck routes that
originate from High Point serve North Carolina, South Carolina, and Virginia. The Image First Services, LLC –
[Atlanta] Georgia location also delivers medical waste to the facility.
9. Mr. Helms stated that the date of medical waste pick-up from the generator is commonly two or three days prior
to the date the medical waste is treated.
10. The facility uses a refrigerated transfer trailer to store medical waste that it cannot process. The medical waste is
transported to Curtis Bay Energy [Incinerator] in Baltimore, MD for treatment.
11. The facility has Sci-Med Waste Systems (Virginia location) pick-up medical waste that it cannot process. Sci-
Med Waste Systems hauls Image First Services, LLC’s medical waste to Curtis Bay Energy with its own
shipments. Sci-Med Waste Systems sends Image First Services, LLC documentation containing its statement of
certificate of destruction. Records were observed for February, July, October, and December 2017.
12. It was suggested that Mr. Helms inquire re. obtaining certification of destruction from Curtis Bay Energy, etc.
13. During the inspection, medical waste boxes were observed on the receiving floor and stored in the refrigerated
transfer trailer.
14. Medical waste boxes observed on the receiving floor were picked up from the generator on February 8, 2018. Mr.
Helms stated that the medical waste will be treated in the next day or two.
15. The refrigerated transfer trailer refrigeration unit was in operation at 38.4 °F and had universal biohazard symbol
placards.
16. The facility provides training for employees. Mr. Helms stated that personnel receive certificates of completion
for various trainings. Training is provided for: bloodborne pathogens, exposure control, transportation
management plan, North Carolina regulations, regulated medical waste handling, personal protective equipment,
operation of the autoclave, etc. Image First Services, LLC provides a company-wide training manual.
17. Mr. Helms stated that he has been trained by the manufacturer of the autoclave in its operation and to conduct
routine biological indicator tests. He also stated that another employee will take-on a more involved role
pertaining to the medical waste treatment and transfer operation as he [Mr. Helms] also manages other
responsibilities.
18. The facility provides clients with medical waste boxes and plastic bags.
19. Medical waste boxes received have a barcode and contain written generator, transporter, and treatment facility
information. Boxes contain the universal biohazard symbol and infectious waste/medical waste statement. Plastic
bags are imprinted with data (sample bag observed).
20. The facility has received medical waste from Georgia, North Carolina, South Carolina, and Virginia.
21. The facility maintains records of medical waste received by package [number and weight], generator information,
date received, date treated, and disposal facility. Records of medical waste transferred are also maintained.
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

22. The amount of medical waste received for July 2017 through February 12, 2018 (time of inspection) is 75.49 tons
and the amount transferred is 11.9 tons.
23. The facility annual report (FAR) was received by the SWS, dated July 24, 2017. Facility throughput for July
2016 through June 2017 is 100.73 tons. The amount of medical waste transferred is 21.87 tons and the amount
of treated medical waste disposed of is 100.74 tons.
24. The facility has a roll-off container for the storage of treated medical waste. The roll-off container is an enclosed
unit attached to the building via shoot accessed by a through-the-wall cart tipper. Treated medical waste is hauled
to the disposal facility once every seven days. When the roll-off container is removed, the autoclave is not
operated until it is returned.
25. Treated medical waste is hauled to the Great Oak Landfill (76-07) in Randolph County (primary disposal site as
of March 16, 2017) and to Uwharrie Regional Landfill (62-04) in Montgomery County. Disposal records were
observed. Generally, 2.2 – 2.6 tons a week is hauled to the disposal facility.
26. The facility uses the BONDTECH autoclave model number BTT6X13 for the treatment of medical waste.
27. The autoclave manufacturer conducts annual inspection and calibration of the steam sterilization unit. Records
were observed for October 18, 2017.
28. Weekly biological indicating tests are conducted on the autoclave using Bacillus stearothermophilus spores.
Records for date, time, and result were observed for tests conducted October 12, 2017 through February 5, 2018.
29. Medical waste is exposed to pressurized saturated steam for a minimum of 45 minutes at 15 psi and 250 °F.
30. The autoclave has a pressure (psi) gauge.
31. Mr. Helms stated that the autoclave emits steam to the atmosphere.
32. The autoclave cycle time, temperature, and pressure are continuously recorded via chart recorder.
33. Autoclave chart recorder process cycle records are maintained. Chart recorder records were observed for 2017.
34. A floor drain is located under the autoclave door and another near the employee entrance/future location of the
second autoclave.
35. Medical waste spill kits, a water hose, and absorbent material are accessible and can be used to clean a spill,
leaking box, etc. The floor can be hosed down and the liquid directed to the floor drains.
36. Mr. Helms stated that facility personnel conduct routine maintenance checks of the autoclave during operation.
37. The facility maintains an autoclave monthly maintenance log. Records were observed for January 2017 through
January 2018.
38. The facility conducts quality control tests four times a month. Records were observed for January 2017 through
January 2018.
39. The facility has a scale. The scale was calibrated by J.A. King and Company, LLC on July 10, 2017.
40. Medical waste received is off-loaded and inspected, weighed, scanned/logged-in, and placed on pallets in a
receiving line. Each box is rescanned and a radiation test conducted. Ten boxes are loaded into a roll-off tipper
cart, of which up to three carts are loaded into the autoclave per process cycle.
41. When the autoclave process cycle has completed, a treated medical waste tipper cart is rolled to the through-the-
wall cart tipper where the material is dumped into the enclosed roll-off container. The treated medical waste that
enters the enclosed roll-off container is compacted.
42. The facility has installed one of two autoclaves and currently runs 5 - 10 process cycles a week.
43. Contact the SWS-Permitting Branch prior to installation of the second autoclave. A new/modified permit will be
required.
44. Mr. Helms stated that in the event of an unscheduled shutdown medical waste will be transferred to other medical
waste treatment facilities or direct-hauled to medical waste treatment facilities upon pickup.
45. Mr. Helms stated that the Image First Services, LLC truck contains a copy of the contingency plan and has universal
biohazard symbol placards.
46. Mr. Helms stated that the facility waste screening process consists of: generator requirements to properly package
and label boxes, drivers trained to reject boxes if leaking, inaccurately packaged, or incorrectly labeled, client
contract requirement to abide by waste acceptance rules, and company sales personnel educating clients.
47. Access roads are of all-weather construction.
48. The autoclave process area is locked.
49. The facility has a proper sign.
50. The PTO expiration date is July 2, 2022.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 4 of 4

Please contact me if you have any questions or concerns regarding this inspection report.

Phone: [phone]

John Patrone
Environmental Senior Specialist
Regional Representative

Sent on: February 13, 2018 X Email Hand delivery US Mail Certified No. [ _]

Copies: Deb Aja, Western District Supervisor - SWS