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HomeMy WebLinkAbout4124_INSP_20170117FACILITY COMPLIANCE INSPECTION REPORT Division of Waste Management Solid Waste Section Page 1 of 3 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: January 17, 2017 Date of Last Inspection: February 3, 2016 FACILITY NAME AND ADDRESS: IFS Services, LLC Medical Waste Treatment Facility 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 – IFS Services, LLC w. 800-368-3676 x3348 c. 336-414-3770 bhelms@imagefirst.com FACILITY CONTACT ADDRESS: IFS 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 – IFS Services, LLC STATUS OF PERMIT: Permit To Operate (PTO) issued July 2, 2012 Permit To Construct (PTC) issued in conjunction with PTO PTO expiration date July 2, 2017 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 3 ADDITIONAL COMMENTS On January 17, 2017, John Patrone met with Billy Helms to conduct a comprehensive inspection of IFS Services, LLC Medical Waste Treatment Facility on Alton Place in High Point, Guilford County. 1. The facility is a medical waste treatment and processing operation 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. IFS Services, LLC uses a non-refrigerated truck to haul medical waste to the facility. Truck routes that originate from High Point serve North Carolina, South Carolina, and Virginia. The IFS Services, LLC – (Atlanta) Georgia location delivers medical waste to the facility. 9. Mr. Helms stated that the date of pick-up is commonly two or three days prior to the date treated. 10. The facility uses a refrigerated transfer (storage) trailer to store medical waste that will be shipped to Curtis Bay Energy – Incinerator in Baltimore, MD. 11. During the inspection medical waste boxes were stored on the receiving floor and in the refrigerated transfer trailer. 12. Medical waste boxes held for treatment were picked up from the generator on January 16, 2017. The refrigeration unit was in operation on the transfer trailer. 13. The facility provides training for employees. 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. IFS Services, LLC provides a company-wide training manual. 14. Mr. Helms stated that he has been trained by the manufacturer of the autoclave in its operation and to conduct routine biological indicating tests. 15. The facility provides clients with medical waste boxes and plastic bags. 16. Medical waste received has a barcode containing generator, transporter, and treatment facility information. The boxes contained the universal biohazard symbol and infectious waste/medical waste statement. Plastic bags are imprinted with data stated to meet the requirements of DOT red bag regulations (sample bag verified). 17. The facility has received medical waste from Virginia, North Carolina, South Carolina, and Georgia. 18. 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 2016. The amount of medical waste treated during that time period is 86.02 tons. 19. The facility annual report (FAR) was received by the SWS, dated July 21, 2016. Facility throughput for July 2015 through June 2016 is 97.68 tons. 20. The facility has a roll-off container for the storage of disinfected medical waste. The roll-off container is a sealed unit located outside of the building attached to a through-the-wall cart tipper. Disinfected 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. 21. Treated medical waste is hauled to the Uwharrie Regional Landfill (62-04) in Montgomery County. Records were verified for July 2016 through January 11, 2017. 22. The facility uses the BONDTECH autoclave model number BTT6X13 for the disinfection of medical waste. 23. The autoclave manufacturer conducts annual inspection and calibration of the steam sterilization unit. Records were verified for November 8, 2016. 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 3 24. Weekly biological indicating tests are conducted on the autoclave using Bacillus stearothermophilus spores. Records for date, time, and result were verified for January 2016 through January 16, 2017. 25. Medical waste is exposed to pressurized saturated steam for a minimum of 45 minutes at 15 psi and 250 °F. 26. The autoclave has a pressure (psi) gauge. 27. The autoclave emits steam to the atmosphere. 28. The autoclave cycle time, temperature, and pressure are continuously recorded via chart recorder. 29. A floor drain is located under the autoclave door and another near the employee entrance from within the building. 30. Medical waste spill kits and absorbent material will be used to clean a spill, leaking box, etc. The floor can be hosed down and the liquid directed to the floor drains. 31. The autoclave chart recorder process cycle records were verified for March 2016 through January 16, 2017. Ensure all recorded information on the process cycle chart recorder is legible. 32. Mr. Helms stated that facility personnel conduct routine maintenance checks of the autoclave during operation. 33. The facility maintains an autoclave monthly maintenance log. Records were verified for 2016. 34. The facility has a scale. The scale was calibrated by J.A. King and Company, LLC on July 15, 2016. 35. 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. When the process cycle has completed the disinfected medical waste tipper cart is rolled to the through-the-wall cart tipper where the material is dumped into the sealed roll-off container. 36. The facility has installed one of two autoclaves and currently runs 5 - 6 process cycles a week. 37. When the second autoclave is installed contact the SWS prior to operation. Initial biological indicating testing shall be documented. 38. 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. 39. Mr. Helms stated that the IFS Services, LLC truck contains a copy of the contingency plan (transportation security plan) and has universal biohazard symbol placards. 40. The refrigerated transfer (storage) trailer had 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, and company sales personnel educating clients. 42. Access roads are of all-weather construction. 43. The building is locked, securing the autoclave and processing area. 44. The facility has a proper sign. 45. The PTO expiration date is July 2, 2017. 46. The facility has contacted the SWS Permitting Branch regarding the permit renewal application. 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 23, 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