4124_Image First Services, LLC MWP_Comment_PermitApp_DIN27435_20170220pdf

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Chao, Ming-tai
From:Chao, Ming-tai
Sent:Monday, February 20, 2017 3:56 PM
To:'[e-mail]'
Cc:Patrakis, William
Subject:Comments on the Permit Application, IFS Services, LLC, 41-24, DIN 27435
Dear Mr. Helms: DIN 27435

The Solid Waste Section completed a review of the permit renewal application (DIN 27299) and has several
comments stated below. Please review the comments and provide your written responses.
1. Throughout the permit application please use the correct title of the department – North Carolina
Department of Environmental Quality (NCDEQ).

2. (Section 3) Please describe the approaches/ methods to treat blood and body fluid in individual
containers in volume greater than 20 milliliters [Rule 15A NCAC 13B .1203(a)]. If blood and body
fluid is directly drain to the on-site sewage system, please respond the Comment No. 8.

3. (Section 3.28) Please provide the info of the transporter (s), such as the contact info & physical address
that ships the treated medical wastes to the permitted landfill facilities.

4. (Section 3.30, Part b) Autoclave Standard Operation Procedure is located in Attachment D, not
Attachment F. Please correct the typo.

5. (Section 3.32) According to the descriptions in the permit application, the selected autoclave system is
likely a steam sterilization. If so, please describe the minimum duration of the minimum temperature
and pressure shall be constantly maintained in the course of treating each batch of medical waste in this
Section [Rule 15A NCAC 13B .01207(2)(a)].

6. (Attachment F) Please provide the completed and updated Landowner Authorization / Certification.

7. (Attachment G) Please provide a copy of the Certificate of Occupancy issued by the City of Highpoint
or Guilford County as applicable.

8. (Attachment G) A 1,000-gallon holding tank is located on the south side of the facility. If this tank is
storing wastewater generated from the on-site cleaning activities including wash-down liquid that
contacts any collected and treated wastes, the wastewater is considered as leachate as defined in
N.C.G.S. 130A-290(a)(16a). The holding tank is subjected to the routine inspection, maintenance, and
repair. Please provide a leachate management plan including personnel to conduct the management
activities – requirements for training and credential, inspection & cleaning frequency, and records to
document the activities.
Please contact me or Bill Patrakis at 919-707-8290 if you have any questions of the above-mentioned
comments. Thanks and have a wonderful evening.

Ming Chao
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Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.

From: Chao, Ming-tai
Sent: Thursday, January 26, 2017 2:59 PM
To: Billy Helms <[e-mail]>
Subject: Re: IFS Services, LLC - Permit Renewal

Please send in the hard copy to Mr. Bill Patrakis at the following address:

Solid Waste Section
1646 Mail Service Center
Raleigh, NC 27699-1646

Thank you.

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

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E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.

From: Billy Helms <[e-mail]>
Sent: Thursday, January 26, 2017 11:16 AM
To: Chao, Ming-tai
Cc: Patrakis, William
Subject: RE: IFS Services, LLC - Permit Renewal

Thank you for letting me know that you received it. I will send the hard copy to your mailing address. Should I send it to
your attention or to the attention of Mr. Patrakis?

Billy Helms
Director of Medical Waste Services
ImageFIRST – Providing Worry-Free Regulated Medical Waste Services
336-414-3770 - Cell

From: Chao, Ming-tai [mailto:[e-mail]]
Sent: Thursday, January 26, 2017 10:55 AM
To: Billy Helms
Cc: Patrakis, William
Subject: FW: IFS Services, LLC - Permit Renewal

Dear Mr. Helms:

The Solid Waste Section received the permit application document which is uploaded to the tracking system with a DIN
27299. The application document will be reviewed by Mr. Bill Patrakis who can be reached at 919-707-8290. Thank you
for the submittal and have a wonderful day.

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

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E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.

From: Billy Helms [mailto:[e-mail]]
Sent: Thursday, January 26, 2017 9:37 AM
To: Chao, Ming-tai <[e-mail]>
Cc: Patrone, John <[e-mail]>
Subject: IFS Services, LLC - Permit Renewal

Good Morning Mr. Chao,

Attached is the permit renewal paperwork for IFS Services, LLC – Medical Waste Treatment Facility, Solid Waste Permit
No. 4124-MWP-2012.

As requested below, I will also send you a hard copy of the renewal document today.

After you review, please let me know if any additional information that is needed for our permit renewal to be
approved.

Thank you for your help.

Billy Helms
Director of Medical Waste Services
ImageFIRST – Providing Worry-Free Regulated Medical Waste Services
336-414-3770 - Cell

From: Chao, Ming-tai [mailto:[e-mail]]
Sent: Tuesday, January 17, 2017 5:19 PM
To: Billy Helms
Cc: Patrone, John
Subject: Re: Contact Info

Hi Billy:

I got your contact info. Please send me a copy (one electronic copy and one hard copy) of the permit renewal
application for your facility IFS Services, LLC - Medical Waste Treatment Facility, Solid Waste Permit No. 4124-
MWP-2012. The current Permit to Operate will expire 07/02/2017. To assist you in preparing the permit
application document, please let me just briefly recap our pone conversations about the permit amendment
(renewal) requirements.

1. The Solid Waste Section web site provide some useful info. The web
link: https://deq.nc.gov/about/divisions/waste-management/waste-management-permit-guidance/solid-
waste-section/medical-waste
2. The facility has a current and valid permit; therefore, you don't have to send in Zoning Approval Letter &
property deeds.
3. Please submit the update Operations Plan which must meet the requirements stated in the
APPLICABLE Solid Waste Management Rules 15A NCAC 13B .1201 through .1207 or .1301. If the DOT
license or NC Air Quality Permit (if applicable to you facility) will be expired or expired in the next 5-yr permit
cycle, please provide the copy of the new permit(s) to the permit application.
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4. Please provide a scaled drawing (s) to show the facility layout, fencing/gates/security, in-plant roads/paths,
and the units/room for storage, processing, treatment, and other supporting structures.
5. Other pertaining info such as update forms, contact info of the personnel in charge of operations,
emergency contact info, fire/spill prevention and countermeasures.

Your company may have to pay the permit fee and the Solid Waste Section will invoice your company after
receiving the permit application.

I will provide you other necessary info if required upon completion of the review of the permit amendment
application. Please feel free to contact me if you have any question of the permitting processes.

Best regards,

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

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E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.

NC DEQ: Medical Waste
deq.nc.gov
The North Carolina Medical Waste Rules cover all aspects of medical waste management including:
packaging, storage, transportation, treatment and disposal.

:

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
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NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.

E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.

From: Billy Helms <[e-mail]>
Sent: Tuesday, January 17, 2017 4:34 PM
To: Chao, Ming-tai
Subject: Contact Info

Hello Ming,

Thanks for calling me back. Below is my contact info for future use.

Billy Helms
Director of Medical Waste Services
ImageFIRST – Providing Worry-Free Regulated Medical Waste Services
336-414-3770 - Cell
[e-mail]