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HomeMy WebLinkAbout4126_INSP_20170110FACILITY 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.: 41-26 CDLF Tire T&P / Collection Tire Monofill Industrial Landfill DEMO SDTF FILE TYPE: COMPLIANCE Date of Site Inspection: January 10, 2017 Date of Last Inspection: January 13, 2016 FACILITY NAME AND ADDRESS: Ozone Waste Solutions Medical Waste Treatment Facility 7353-A West Friendly Avenue Greensboro, NC 27410 GPS COORDINATES: N: 36.08545 W: -79.92655 FACILITY CONTACT NAME AND PHONE NUMBER: Todd Kaufman, Site Manager – Ozone Waste Solutions w. 336-550-4037 c. 336-337-1389 tkaufman@ozonewastesolutions.com FACILITY CONTACT ADDRESS: Ozone Waste Solutions Todd Kaufman, Site Manager 7353-A West Friendly Avenue Greensboro, NC 27410 PARTICIPANTS: John Patrone, Environmental Senior Specialist - Solid Waste Section (SWS) Todd Kaufman, Site Manager – Ozone Waste Solutions Sheila Gambardella, Office Manager – Ozone Waste Solutions STATUS OF PERMIT: Permit To Operate (PTO) issued January 2, 2015 PTO expiration date March 25, 2019 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 January 10, 2017, John Patrone met with Todd Kaufman and Sheila Gambardella to conduct a comprehensive inspection of the Ozone Waste Solutions Medical Waste Treatment Facility on West Friendly Avenue in Greensboro, Guilford County. 1. The facility is a medical waste treatment and processing operation consisting of an ozonator. 2. The facility also operates a medical waste transfer station. 3. The facility receives regulated medical waste, non-regulated medical waste, and biomedical waste. 4. The facility is open Monday through Friday 9:00 am to 5:00 pm. When applicable, the receiving department could operate from 6:00 am to 5:00 pm. 5. The facility permit, site plan, operations plan, and contingency plan were discussed. 6. During the inspection the ozonator was not in operation. The ozonator has not operated since May 18, 2016. The facility has conducted repairs and is performing upgrades to the ozonator. Mr. Kaufman stated that the ozonator may be ready to resume operation in four or six months. 7. The facility informed the SWS about the ozonator shutdown via letter dated June 1, 2016. The facility shall notify the SWS when the ozonator resumes operation. 8. Currently, the facility is operating as a medical waste transfer station. 9. During the inspection there was no medical waste awaiting transfer at the facility or stored in vehicles. 10. The facility generally receives medical waste twice a week. 11. The facility picks up medical waste from clients and hauls it to the facility within a day or two. The medical waste is picked up at the facility by Assured Waste Solutions LLC and brought to the Assured Waste Solutions LLC Medical Waste Treatment Facility (Permit No. 36-15). The Assured Waste Solutions LLC facility treats medical waste via autoclave. 12. Medical waste picked up at the facility by Assured Waste Solutions LLC that cannot be treated via steam sterilization is transported to Curtis Bay Energy – Incinerator in Baltimore, MD. 13. The facility owns a refrigerated truck. However, the facility rents a non-refrigerated truck to transport medical waste. Mr. Kaufman stated that the refrigerated truck is available to store medical waste when necessary per the 13B .1200 Medical Waste Management rules. 14. The facility service area is North Carolina and contiguous states. 15. Mr. Kaufman stated that he has had manufacturer training in the operation and service of the ozonator in addition to having assisted with its construction. 16. The facility provides training for personnel (Todd Kaufman and Zach Marsula). Facility personnel have completed HAZWOPER and DOT Hazmat Carrier Requirements (certificates verified). The facility provides in- house trainings (operations plan pg 22), to include operation of the ozonator. 17. Mr. Kaufman stated that there is no factory recalibration/maintenance service interval required to be conducted by the manufacturer for the ozonator. 18. Mr. Kaufman stated that the ozonator software ensures its procedural startup, operation, and shutdown. 19. Medical waste received has a barcode containing generator, transporter, and treatment facility information (sample label verified). The boxes contain the universal biohazard symbol and infectious waste/medical waste statement (sample box verified). Plastic bags are imprinted with data stated to meet the requirements of DOT red bag regulations (sample bag verified). 20. Mr. Kaufman stated that when boxes are picked up the barcode is scanned and the date of receipt is written on each box. 21. The facility provides clients with medical waste boxes and plastic bags. 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 facility maintains records of the amount of medical waste received by package, generator information, date received, date treated, and disposal facility. Records of medical waste transferred are also maintained. Records were verified for July through December 2016. The amount of medical waste received during that time period is 4,955.91 lbs. 23. The facility annual report (FAR) was received by the SWS, dated June 28, 2016. Facility throughput for July 2015 through June 2016 is 2.50 tons. The initial roll-off container of treated medical waste (2.50 tons) was hauled to the Curtis Bay Energy – Incinerator in Baltimore, MD as a precaution due to the ozonator requiring repair in May 2016. 24. Disinfected shredded medical waste will be hauled to the Uwharrie Regional Landfill (62-04) in Montgomery County. 25. The facility has a contract with Curtis Bay Energy – Incinerator in Baltimore, MD to pick up medical waste that cannot be treated by ozonation and medical waste requiring transfer. Curtis Bay Energy subcontracts the medical waste pick up to Assured Waste Solutions LLC. 26. The facility uses the Ozonator Industries model number NG-3000 for the disinfection of medical waste. It is a sealed processing unit. The ozonator shreds then treats medical waste with up to 10,000 ppm of ozone achieving 99.9999 percent disinfection in ~ 15 minutes (process run time is ~ 30 minutes) and a reduction in volume by up to 90 percent. Disinfected shredded medical waste is stored in the sealed roll-off container. 27. The facility has one roll-off container for the containment of disinfected shredded medical waste. The roll-off container is a vacuum sealed unit attached to the ozonator. Mr. Kaufman stated that when the ozonator is in operation the shredded medical waste in the roll-off container is infused with ozone, thus continually being disinfected. This process furthers the breakdown of latex, plastics, and other compounds. 28. The sealed roll-off container has a small window used to verify when it is full. When the roll-off container is hauled to the landfill the ozonator does not operate. The disinfected shredded medical waste in the attached sealed roll-off container is integral to the ozonator. Disinfected shredded medical waste is not considered stored until the roll-off container is removed from the ozonator, at which time it is hauled-off for disposal. 29. The ozonator is designed to treat medical waste containing 20 percent liquids. An absorbent material can be added to the feed-hopper for medical waste containing > 20 percent liquids. Ozone Waste Solutions client service agreement requires that medical waste contain the required percent liquids. 30. Ozonator processing efficacy is verified via a 3M 1924 rapid readout test and a MesaStrip test. Each test uses biological indicators containing bacillus atrophaeus spores. The rapid readout tests are conducted at the facility. Mr. Kaufman stated that he was trained to conduct the rapid readout test by their company chemical technician who was trained by the ozonator manufacturer. Rapid readout tests are conducted monthly. Records were verified for January 29, February 28, March 7, April 17, and May 13, 2016. The MesaStrip test will be sent off periodically to a certified microbiology laboratory. Mr. Kaufman stated that the facility has not conducted a test to date, other than at initial startup. It is suggested that the facility conduct MesaStrip tests quarterly or biannually. 31. Mr. Kaufman was asked to ensure that the 3M 1924 rapid readout test and the MesaStrip test are conducted when the ozonator resumes operation. 32. The facility has a scale. The scale was calibrated by J.A. King and Company, LLC on January 14, 2016. 33. Medical waste received is off-loaded and inspected, weighed, logged-in, and placed on a manual roller conveyor. Each box is opened, one at a time, at the processing table. The plastic bag is placed in the ozonator feed-hopper and the box is flattened and placed on top. The percent liquid of the medical waste is estimated by the weight and feel of the bag and absorbent material is added if necessary. 34. Facility personnel wear a Tyvek suit and facemask during the medical waste treatment process. Solid Waste Section staff can observe facility operations from large office windows overlooking the processing floor. 35. The ozonator processing cycle maximum feed-hopper weight is < 500 lbs of medical waste. Each feed-hopper commonly contains ~ 120 lbs per processing cycle. Mr. Kaufman stated that the processing cycle feed rate will likely be increased during the current ozonator shutdown period. 36. The controls for the ozonator are automated and the process will stop if a sensor fails. The feed hopper moves hydraulically up to the ozonator and dumps medical waste into a secondary hopper to be treated. 37. Mr. Kaufman stated that the ozonator unit emits ozone that is converted back to oxygen and does not require an air permit. FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 4 of 4 38. Mr. Kaufman stated that the ozonator unit and the medical waste processing operation does not require floor drains/drainage to a treatment tank or city sewer. Medical waste spill kits and absorbent material will be used to clean plastic trays and liquids in the event of a spill, leaking box, etc. The waste material will then be placed in the ozonator to be disinfected. 39. Mr. Kaufman stated that if medical waste leaks or spills in the refrigerated transport truck it will be cleaned with a medical waste spill kit and the waste material placed in the ozonator to be disinfected. 40. Mr. Kaufman stated that the facility trucks contain a copy of the contingency plan and have universal biohazard symbol placards. 41. The facility waste screening process consists of: generator requirements to properly package and label boxes, driver(s) trained to reject boxes if leaking, inaccurately packaged, or incorrectly labeled, client contract requirement to abide by waste acceptance rules, company sales personnel educating clients, and the removal of plastic bags from boxes prior to ozonation allowing staff to deduce the contents by weight and feel. 42. 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. 43. The building is locked to secure the medical waste ozonator and processing/storage area. 44. The PTO expiration date is March 25, 2019. 45. The PTO renewal application shall be submitted to the SWS by September 25, 2018. 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: January 12, 2017 X Email Hand delivery US Mail Certified No. [ _] Copies: Deb Aja, Western District Supervisor - SWS Jessica Montie, Compliance Officer – SWS Ming-Tai Chao, Environmental Engineer – SWS Sheila Gambardella, Office Manager – Ozone Waste Solutions (w. 336-550-4037, sgambardella@ozonewastesolutions.com)