solid waste storage and processing units · refresher training based on their position. both key...

Med-Turn Inc. Registration Application

4332 Empire Road Part IV

Fort Worth, Texas

W&M Environmental Group, LLC (W&M Project No. 1509.001) December 2015

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PART IV

4.0 Site Operating Plan [§330.65]

Part IV of the registration application is referred to as the “Site Operating Plan” and it provides general

operating procedures for the management of the day-to-day operations at the proposed application

activities. The site operating plan will be retained onsite during the active life of the MSW Type V

medical waste transfer station. In addition, Part IV is prepared in compliance with Title 30 TAC Chapter

330 Subchapter E Sections 330.201 through 330.249 as related to Operational Standards for Municipal

Solid Waste Storage and Processing Units, and Title 30 TAC Chapter 330 Subchapter Y Sections

330.1201 through 330.1221 as related to Medical Waste Management. Portions of the requirements

relating specifically to municipal solid waste landfills, medical waste generators, and mobile medical

waste treatment units are not applicable and are not included in the registration application.

Part IV does not include procedures for recirculating leachate gas or gas condensate into a landfill unit

since Med-Turn is not a generator of leachate or landfill gases. In addition, Med-Turn will not receive

grease trap waste, grit trap waste, or septage processing materials and will not be subject to TPDES

permitting requirements and any permit requirements imposed by other agencies (e.g., local government

pretreatment or discharge authorization requirements).

Part IV contains information about how Med-Turn will conduct operations associated with this

authorization at the project site, but it is not a comprehensive operating manual. However, general

instructions for management and personnel are provided to operate the site in a manner consistent with

the proposed application activities and TCEQ’s rules to protect human health and the environment and

prevent nuisances.

In addition, as part of the site operations, Med-Turn has prepared several Standard Operating Procedures

(SOPs) related to the management, identification and shipment of the pharmaceutical waste and other

drugs/special waste expected to be received at the project site. These SOPs will not be included with the

registration application, but can be made available for inspection by TCEQ representatives or other

interested parties at the project site.



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4.1 Site Personnel [§330.127]

The site operating plan includes the provisions for site management and site personnel to meet the general

and site-specific requirements related to the proposed application activities.

4.1.1 Personnel Function and Qualifications

Med-Turn will have four categories of key personnel for the day-to-day operations of the project site to

include: a site manager, a supervisor, several operators and workers. The number of site personnel will

vary depending on the type and quantities of waste streams received at the site, and market demands.

Site personnel will complete several training requirements to be able to conduct their day-to-day duties in

compliance with the requirements of the site operating plan. These will include instructions related to

waste management procedures and the implementation of several of the site-specific plans (i.e. Health and

Safety Plan, Contingency Plan …, etc.). Site personnel training records will be maintained onsite and in

accordance with Section 4.7 below. Site personnel operator licenses issued in accordance with 30 TAC

§30, Subchapter F, Municipal Solid Waste Facility Supervisors, will also be maintained.

Med-Turn will ensure that the transfer station supervisor at the site is knowledgeable in the proper

operation of a medical waste transfer station and the current operational standards as required by the

TCEQ. The supervisor will be experienced in waste management procedures and will maintain a Class B

license as defined in §30.210. The supervisor will ensure that personnel are properly trained and are

operating the transfer station in accordance with the site operating plan and operational standards required

by the registration and the TCEQ medical waste regulations.

New employees will receive a comprehensive overview of all aspects of transfer station operations,

focusing on information that is necessary to protect the health and welfare of the new employees. Initial

training subject matter will include applicable requirements found in the site development plan,

attachments to the site development plan, the site operating plan and general safety procedures.

Following the initial training, the new employee training will continue during monthly training sessions,

during on-the-job training, and during the annual review of their initial training.

The key personnel involved in waste management at the site are the Regulatory Compliance Supervisor

and the Hazardous Waste Forklift Operator. These roles will receive initial pre-assignment, ongoing, and

refresher training based on their position. Both key personnel receive RCRA and state (e.g., 30 TAC §

335.586 as applicable) Hazardous Waste training and DOT training in accordance with the applicable

federal and state regulations. In addition, Med-Turn will ensure that those key personnel will obtain a

MSW facility supervisor license as required for Type V storage and processing facilities. The license will

be renewed as specified by the TCEQ at least 60 days before expiration.

More detailed job descriptions will be maintained in the site operating record.

4.1.2 Equipment

As part of the processing and storage operations, Med-Turn initially will be adding approximately 60

processing stations and installing approximately 2,000 ft. of belt conveyor system; will add two forklifts,

one order picker, one reach truck; additional warehouse pallet racking; and storage shelving as needed.

Section 4.18 below addresses backup equipment per § 330.127(2).

No equipment of the type that requires a registration modification will be added or changed without first

obtaining the necessary approval(s) from TCEQ.



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4.2 Waste Acceptance and Analysis [§330.203(a)]

Med-Turn has been operating at 4332 Empire Road, Fort Worth, Texas, 76155 as a provider of

pharmaceutical reverse distribution management services and is in the process of expanding those

services to include a MSW Type V medical waste transfer station. Waste generated from the reverse

distribution activities and waste received pursuant to the MSW Type V medical waste transfer station

may be stored separately and in the same waste storage areas as shown on Attachment III-C of Part III

of this application.

The transfer station will receive process and store the following waste streams:

Medical waste: Unused sharps. This will only include unused hypodermic needles and

hypodermic syringes with attached needles.

Municipal Solid Waste: Non-hazardous pharmaceutical waste, drugs/special waste and unused

medical and surgical supplies (e.g., solids, powders, off-spec manufacturing waste, and

compounding chemicals) This will include controlled substances (All schedules I-V) and the

Cactus Smart Sink® cartridges (flyer is included in Attachment IV-A); and

Recyclable Material: Other source separated recyclable items from health care providers (paper

and cardboard boxes) will be received and recycled, but will not be subject to the MSW Type V

medical waste transfer station authorization.

Other special waste streams generated from health care related facilities such as animal waste, bulk blood,

bulk human blood, bulk human body fluids, microbiological waste, pathological waste, used sharps, and

other healthcare related items that may have come in contact with bodily fluids or blood will not be part

of the proposed application activities, and will not be accepted at the project site.

The various waste streams will be received from generators located across the nation. The regulated

medical waste will be received in federal and state approved packaging as required under 30 TAC

330.1207; Title 49 Code of Federal Regulations (CFR) (relating to the United States Department of

Transportation) Section 178; and Title 29 CFR (relating to Occupational Safety and Health

Administration) Section 1910.

Med-Turn will only be transferring the associated waste streams received at the project site from the

various health care providers and will not be performing any treatment or onsite disposal activities.

Except as discussed earlier in the application, and as required under 30 TAC §330.133(c), the following

waste streams will be prohibited from storage at the project site authorized by the MSW Type V medical

waste transfer station:

Regulated hazardous waste;

Polychlorinated biphenyls (PCBs) wastes;

Lead acid storage batteries;

Used motor vehicle oil; used-oil filters from internal combustion engines;

Whole used or scrap tires;

Items containing chlorinated fluorocarbons (CFC's), such as refrigerators, and freezers;

Regulated asbestos containing materials (ACM); and

Industrial solid waste.



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Med-Turn will implement the following procedures to control the receipt of prohibited wastes:

Informing customers of prohibited wastes;

Informing drivers of incoming waste hauling vehicles of prohibited wastes; and

Training for site personnel responsible for inspecting and observing incoming waste streams.

If site personnel identify prohibited waste or portions of prohibited waste within a collection vehicle, then

that waste will be rejected and immediately sent back to the waste generator.

4.2.1 Quantities and Transfer Rate

Initially, Med-Turn is estimating to receive and process approximately 6,000 pounds (lbs.) per day of

waste as detailed in the table below. Med-Turn is projecting growth of 15% - 20% per year for five years.

The waste acceptance rate will vary over the life of the transfer station depending on market conditions,

but, in general, Med-Turn is estimating to manage over 15,000 lbs. in 2021.

Most collection vehicles transporting the waste will have a capacity of 10 – 20 cubic yards per truck. On

certain occasions, larger vehicles may be used, depending on need. It is estimated that, of the average

amount of waste received, approximately 95 percent will be medical waste and non-hazardous

pharmaceutical waste as described above, with the remaining 5 percent being a mix of paper and

recyclable material. Recyclable material may include documents, paper, plastics, cardboard, and other

miscellaneous items.

The various waste streams managed and quantities anticipated as a result of this authorization, initially

and projected in five years, are shown in the table below. Additional information related to the table is

also included in Part II of this application.



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Waste Stream

Daily Estimates Projected Daily Estimates

in 5 yrs.

Lbs. Tons CY Lbs. Tons CY

Medical waste

(unused sharps) 2,000.0 1.0 6.7 5,000.0 2.5 16.7

Non-hazardous pharmaceutical waste

(controlled substances, drugs/special waste,

and unused medical and surgical supplies)

2,000.0 1.0 6.7 5,000.0 2.5 16.7

Non-hazardous pharmaceutical waste

(Cactus Smart Sink® Cartridges) 500.0 0.3 1.7 1,200.0 0.6 4.0

Other Non-hazardous pharmaceutical waste

(unused and expired drugs) 1,500.0 0.8 5.0 3,700.0 1.9 12.3

Other recyclable items

(paper and cardboard boxes) 300.0 0.2 1.0 700.0 0.4 2.3

Estimated Total Waste Stream 6,300.0 3.2 21.0 15,600.0 7.8 52.0

Based on the above, the anticipated maximum daily rate of waste managed ranges from 3.2 tons in the

first year, to 7.8 tons in the fifth year (including recyclable material generated as a result of the activity).

For the purposes of this registration, it is assumed that the maximum mass of waste that will be on-site at

any given time is about 100 tons. This is based on the 30-day waste storage capacity at the project site

during the initial year. The maximum amount of 100 tons may include unprocessed waste, waste and

other recyclable material temporarily stored onsite, and waste and recyclable material located in the

loading/unloading areas.



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4.2.2 Processing and Storage of the Waste

A waste flow diagram and a schematic flow map indicating the processing, and storage of the waste

streams and recyclable materials anticipated at the site is included in Attachment III-A and Attachment

III-C in Part III of this application. Med-Turn will not conduct any on-site disposal activities, and the

waste received will be processed and stored prior to offsite disposal or recycling.

Once the Med-Turn site receives a shipment from the health care providers, authorized and trained

personnel will inspect the waste within each delivery for compliance with regulations, and to prevent

unauthorized wastes from entering the site.

After the shipment is accepted, Med-Turn will unload the waste from the designated temporary parking

area, through the bay doors and into the medical waste transfer station. The receiving process will

include the staging of received waste for further processing at scanning stations, which will separate the

various wastes, materials, and containers received into their appropriate process stream. As part of the

processing activities, Med-Turn will be adding approximately 60 processing stations and will install

approximately 2,000 ft. of belt conveyor system; will add two forklifts, one order picker, one reach truck;

additional warehouse pallet racking; and storage shelving as needed. The waste streams will be

segregated and stored indoors until sufficient quantities are collected for offsite disposal.

Then, the waste will be sorted and segregated as appropriate. It is estimated that the average processing

time from the arrival of the waste through completion of the process will be approximately seventy two

hours. After sorting and processing the waste, Med-Turn will store the waste within designated areas on

site for an average duration of 7 days, but for no longer than 30 days, until a truck is ready to transport it

offsite for disposal. In addition, recyclable material will not be stored on-site for longer than 90 days.

The site will not accumulate waste in quantities that cannot be processed within such time, or that may

result in odors, insect breeding, or attracting other vectors.

Med-Turn has already contracted with Covanta Tulsa Renewable Energy, LLC. (Covanta) for the disposal

and incineration of the waste. The Covanta facility is located at 2122 South Yukon Avenue, Tulsa, OK

74107 (also known as the Walter B. Hall Resource Recovery Facility) and it is a waste-to-energy facility

that accepts solid waste for energy production, which is sold to Public Service Company of Oklahoma

and/or other independent entities. As a secondary alternative, Med-Turn has also contracted with Covanta

Huntsville Inc. located at 5251 Triana Boulevard, Huntsville, AL 35805 for the disposal and incineration

of the waste.

Med-Turn will comply with TCEQ reporting requirements as applicable, including requirements under 30

TAC §330.675, and as related to the amount of waste received at the transfer station for processing and

offsite disposal.

4.3 Facility-Generated Wastes [§330.205(a)]

Med-Turn has been operating as a provider of pharmaceutical reverse distribution management services at

4332 Empire Road, Fort Worth, Texas, 76155 since June 2003, and as part of this operation, Med-Turn

generates several waste streams including hazardous waste. Med-Turn’s reverse distribution operation is

regulated under EPA’s RCRA program as required under 40 CFR part §262, and has obtained an EPA ID

Number TXR000053306. In addition, Med-Turn has notified the TCEQ and registered the site under

Solid Waste Registration Number 87199 as a Large Quantity Generator (LQG) for activities associated



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with the reverse distribution operations. As part of the current reverse distribution activities, and in

maintaining compliance with TCEQ requirements, Med-Turn submits the Annual Waste Summary

reports and pays the annual waste generation fee. This activity will continue to operate at Med-Turn

concurrently with the activity authorized under this registration.

As part of the MSW Type V medical waste transfer station registration application, Med-Turn will not be

receiving, processing or storing hazardous waste or any of the other waste listed in Section 4.1 above.

Med-Turn will not be generating hazardous waste as part of the proposed application activities and the

waste will be classified as either non-hazardous medical waste or municipal solid waste.

Med-Turn will not generate process water or wastewater as part of the proposed application activities.

4.4 Contaminated Water Management [§330.207(a)]

The proposed application activities do not include onsite treatment of the waste steams received onsite

nor the generation of processed wastewater that may require treatment and/or offsite disposal. Due to the

nature of waste streams allowed onsite pursuant to the MSW Type V transfer facility registration (unused

sharps, medical/surgical supplies, non-hazardous pharmaceutical wastes and controlled substances), spills

and leaks are not anticipated from the operation of the medical waste transfer station.

There will be no surface water runoff onto or off the floors of the medical waste transfer station

processing and storage areas. The warehouse building is completely enclosed and there are no interior

floor drains. Based on that, the proposed application activities will not generate or result in wastewater

that will require collection and offsite disposal or result in the potential for ground water contamination.

Since, the proposed application activities will be conducted indoors within the existing warehouse

building, storm water runoff will not be impacted, and a TPDES Permit will not be required for storm

water discharges from the project site.

The site in currently connected to the City of Fort Worth public sanitary sewer collection system and the

existing connections are sufficient to drain the kitchen and bathrooms in the office area. No additional

modifications are expected to the existing utilities as part of the proposed application activities.

As mentioned above, Med-Turn will not generate process water or wastewater as part of the proposed

application activities. If, for any reason, the project site has to discharge impacted water, Med-Turn will

obtain the necessary authorizations from the state and local agencies as necessary and will update the

registration application.

4.5 Storage Requirements [§330.209(a) and §330.1209]

The waste streams received at the transfer station will be stored in appropriate containers, within

designated areas according to the type of waste managed at the project site. The storage areas will be

managed in a manner that the waste will not constitute a fire, safety, or health hazard or provide food or

harborage for animals and vectors. Med-Turn will utilize storage containers of an adequate size and

strength, and in sufficient numbers, to contain all waste streams received at the project site.

Waste generated from the reverse distribution activities and waste received pursuant to the MSW Type V

medical waste transfer station may be stored separately and in the same waste storage areas as shown on

Attachment III-C of Part III of this application.



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As indicated earlier, the transfer station will be located inside the existing warehouse building and the

processing and storage areas will not be exposed to wind, temperature variation, or storm water runoff.

If for whatever reason there has been a delay in unloading the waste from the vehicles into the processing

area, the waste can be stored in the collection vehicles parked outdoors in the parking lot area.

4.6 Approved Containers [§330.211]

The waste streams will be transported to the transfer station in cardboard boxes directly from the various

health care facilities located across the nation. As part of the processing stage, the waste streams will be

segregated then placed in appropriate containers (i.e. drums, other cardboard boxes) for storage and

offsite disposal.

In addition, unused hypodermic needles, syringes with attached needles will be placed in containers

designed for sharps that are marked or labeled as containing treated waste.

4.7 Recordkeeping and Reporting Requirements [§330.219]

Med-Turn will maintain TCEQ’s authorization, the registration application, the operating record for the

proposed application activities and any other documents that are part of the operating record as listed in

Attachment IV-B. These documents will be made available for inspection by TCEQ representatives or

other interested parties. Med-Turn will retain all information contained with the operating record of the

project site and all plans required for the life of the site until after certification of closure.

Med-Turn or a duly authorized representative may sign reports or other information requested by the

TCEQ as described in 30 TAC 305.44(a). In case of a change of individuals or position, the previous

authorization will no longer be accurate and a new authorization satisfying all requirements will be

submitted together with any information or reports signed by the new authorized representative, in

compliance with 30 TAC 330.219(c). Any person signing a report or other information will complete a

certification as required in 30 TAC 305.44(b).

Med-Turn, as an operator of MSW Type V medical waste transfer station, will maintain shipping

documents as required under 30 TAC 330.1211, and ensure that the following requirements are met:

The shipping document accompanies the shipment;

The shipping document specifies the receiving facility;

The operator signs the shipping document and provides a copy to the transporter; and

The operator retains one copy and provides the generator with a copy of the shipping document.

4.8 Fire Protection Plan [§330.221]

Emergency fire service for the project site is provided by the City of Fort Worth Fire Department. The

local water source provided by the City of Fort Worth will be used to supply the water during a fire. The

fire hydrants are located along Empire Road, adjacent to the project site; one is located at the north

entrance and the second is located at the far south entrance.

Portable fire extinguishers will be located throughout the building to use for small emergencies. Each fire

extinguisher will be inspected on an annual basis and recharged as necessary. A map showing escape



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routes for the building and assembly points will be posted in several locations. A list of procedures for

fire protection will be posted and will be kept in the operating record.

Personnel will receive fire protection training at least annually, or in the case of new employees, during

orientation. The training will include: good housekeeping practices; proper response and notification

procedures; instructions on the use of portable fire extinguishers; and recognition of potential fire hazards.

Personnel will be familiar with the use and limitations of firefighting equipment available onsite. The

training records will be included in the operating record for the site.

4.8.1 Procedures in the Event of a Fire

Med –Turn will implement the following steps in the event of a fire:

The first person noticing a fire will alert the Emergency Coordinator (EC) or an Alternate

Individual (AI) to the situation;

The EC or AI will alert the site personnel of fire and possible danger using the intercom system

within the building;

A qualified and trained personnel, may attempt to extinguish the fire, if it’s small, and safe to do;

If the fire cannot be extinguished using a portable fire extinguisher, the EC or the AI will notify

the local police and fire departments by dialing 911;

Site personnel will evacuate the building into the designated assembly points located in the

parking lot;

In the assembly points, the EC or AI will account for site personnel and visitors (if any); and

No one re-enters the site without being cleared by the EC or AI.

Site personnel will not attempt to fight the fire alone, or without adequate personal protective equipment.

If a fire occurs in a vehicle or equipment, the operator will bring the vehicle or equipment to a safe stop.

The engine will be shut off and the brake engaged (as applicable) to prevent movement of the vehicle or

equipment.

4.8.2 TCEQ Notification

After any fire (related to waste management activities that cannot be extinguished within 10 minutes of

discovery) occurs, the TCEQ Region 4 will be contacted. The verbal notification will be conducted as

soon as possible, but no later than four hours following the fire discovery. In addition, a written report of

the cause and extent of the fire and the resulting fire response will be submitted within 14 days of fire

detection.

Med-Turn will provide TCEQ Region 4 with as much information as possible regarding the fire and fire-

fighting efforts, as soon as possible after the fire occurs. The fire prevention and fire control procedures

for the site will be revisited following the occurrence of a significant fire to determine if modifications are

warranted.



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4.9 Access Control [§330.223]

The site can be accessed using the existing driveways that are located on Empire Road, which leads to

either FAA Boulevard to the north, or Trinity Boulevard to the south. Vehicular traffic to and from the

project site may occur via SH 183, SH 161 or SH 360. In general, the access roads are paved with

concrete and are well maintained. All vehicular traffic will remain on the impervious surfaces within the

parking lot area. The unloading area is set back from the entrances to allow for adequate vehicular

stacking.

4.9.1 Site Access and Security

Contractors and visitors must access the property through the main entrance area located on the

northwestern corner of the building. The doors to the building are always closed and secured, and can

only be accessed using a company issued badge. Contractors and visitors will be issued a visitors badge

and accompanied by a Med-Turn employee at all times. Access to waste processing areas will be

determined by the visitor’s role to the site’s operations and will be escorted at all times. Regulatory

agency representatives will be given access to site operations in compliance with the authority granted to

the agency representative under federal, state and/or local laws.

The waste processing and storage activities will take place indoors within the existing section of the

warehouse building. Public access will be controlled to minimize unauthorized entry, unauthorized and

illegal dumping, and public exposure to hazards associated with the site operations. Access to certain

areas of the site, such as the Controlled Substances Area, is only available to employees whose position

requires them access.

4.9.2 Vehicle Access

The waste hauling vehicles will access the site through one of the main entrances located on Empire

Road. These access routes are not gated or secured, but the bay doors on the warehouse building will

remain closed and locked when not in use.

Entrances, turning radii and current building setbacks, provide adequate vehicle access to the project site

and without adversely affecting traffic on the access roads. Signs will be placed along the entrance roads

at a frequency adequate to guide users to the transfer station and associated parking lot area.

4.10 Unloading of Waste [§330.225]

For activities related to this authorization, once a shipment from health care providers arrives at the

facility, authorized and trained site personnel will inspect the waste within each delivery for compliance

with regulations, and to prevent unauthorized wastes from entering the building. If unauthorized wastes

arrive at the site, the waste will be rejected and returned immediately to the transporter or generator of the

waste. The site manager will direct the site personnel to remove and manage the prohibited wastes

appropriately and in accordance with federal and state regulations.

After the shipment is accepted, Med-Turn will unload the waste from the designated temporary parking

area, through the bay doors and into the medical waste transfer station as shown in Attachment III-A in

Part III of this application. The warehouse building has eighteen bay doors; initially four bay doors will

be used for the medical waste transfer station, and are located on at the southern end of the warehouse

building. After that, the waste will be sorted, processed and segregated as appropriate.



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The cardboard boxes received will be opened and the waste streams will be manually removed and placed

on the belt conveyor system for processing and segregation. The cardboard boxes will be broken down

and stored separately and in the same waste storage areas as shown in Attachment III-C in Part III of

this application.

Site personnel will be attentive to maintain compliance with the proposed project activities and will be

trained as required in order to manage the various waste streams received onsite appropriately.

Med-Turn will install several signs to indicate the unloading area for the medical waste transfer station for

incoming vehicles, so not to confuse it with the reverse distribution activities.

4.11 Spill Prevention and Control [§330.227]

The processing and storage of the waste streams received at the site will take place indoors within the

warehouse building. The proposed application activities do not include onsite treatment of the waste

steams received onsite nor the generation of processed wastewater that may require treatment and/or

offsite disposal. Due to the nature of the waste streams allowed onsite (unused sharps, medical/surgical

supplies, non-hazardous pharmaceutical wastes and controlled substances), spills and leaks are not

anticipated from the operation of the medical waste transfer station. If spills or leaks are to occur, the

enclosed building is sufficient to control and contain the worst case discharge scenario and to prevent

contamination from leaving the building.

As a precaution, Med-Turn will store absorbent pads and spill containment kits within the warehouse

building to be used as necessary. If a spill or leak is to occur, the following steps will be implemented:

The first person noticing a spill or leak will notify the EC or AI to the situation;

The EC or AI will alert the site personnel of possible danger using the intercom system;

A qualified and trained personnel, may attempt to contain and clean the spill/leak;

Site personnel will evacuate into the designated assembly points located in the parking lot;

In the assembly points, the EC or AI will account for site personnel and visitors (if any); and

No one re-enters the site without being cleared by the EC or AI.

4.12 Operating Hours [§330.229]

Initially, the site will operate in two shifts, the first between 7:00 AM and 3:30 PM and the second shift

will be between 3:30 PM and 12:00 AM, five days a week. However, Med-Turn may need to operate

twenty-four hours a day depending on market conditions.

In addition, other non-waste management activities including administrative and maintenance activities

may occur twenty-four hours a day, seven days a week.

Since the waste processing activities associated with the transfer station will be performed inside the

existing warehouse building, the operations at the project site will be screened from the public. Based on

that, the generation of noise and other nuisance are not anticipated at the project site due to the type of

wastes managed at the site; Med-Turn following adequate packaging and storage procedures; and

implementing general sanitation procedures, which will limit the generation of odors.



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4.13 Site Sign [§330.231]

A visible sign measuring a minimum of four feet by four feet will be displayed at the entrance to the

project site. The sign will include the name of the site, the type of site, hours and days of operations,

TCEQ’s registration number, and site rules as applicable. The sign will be legible from the site entrance.

A sign prohibiting smoking will also be posted at the transfer station unloading area.

4.14 Windblown Waste [§330.233]

The processing and storage of the waste streams received at the site will take place indoors within the

warehouse building. The transfer station’s operation is enclosed, and the bay doors used to receive the

waste will not be left open once the waste has been delivered. Since the waste streams received at the site

will be properly unloaded and managed by trained personnel, windblown waste and litter will be

controlled at the project site. If windblown waste or litter is to leave the project site, it will be collected by

site personnel to minimize unhealthy, unsafe or unsightly conditions and managed as appropriate.

4.15 Materials along Route to the Site [§330.235]

The vehicles hauling the waste streams to the project site are enclosed, and the wastes received are

secured inside a cardboard box. Med-Turn will take the necessary steps to ensure the safe delivery of the

waste streams to the project site, and to report offenders to the proper law enforcement officers.

Even though Med-Turn does not anticipate any waste to spill during transportation, Med-Turn will

provide for the cleanup of waste materials spilled as needed and as necessary along roads used to access

the project site and within two miles from the site entrance. In addition, Med-Turn will consult with

TCEQ, TXDOT, and other local entities regarding cleanup of roads and right-of-ways as required.

4.16 Site Access Roads [§330.237]

As discussed in the earlier parts of this application, the project site can be accessed using the existing

driveways that are located on Empire Road, which leads to either FAA Boulevard to the north, or Trinity

Boulevard to the south. Vehicular traffic to and from the project site may occur via SH 183, SH 161 or

SH 360. The entrance and access roads to and from the project site are paved with concrete.

Due to the nature of the proposed application activities, the tracking of mud and/or debris is not

anticipated onto the public roadways. In addition, the entrance and parking lot area will be maintained in

a clean and safe condition as necessary.

4.17 Noise Pollution and Visual Screening [§330.239]

As discussed in Part III of this application, the potential for noise at the site may be generated from the

operation of the collection vehicles and the operation of the existing compacting equipment (for

cardboard boxes). The remaining waste processing activities associated with the transfer station will be

performed inside the existing warehouse building and will be screened from the public.

The project site is located in a commercial/industrial area, and the average anticipated noise level for the

proposed application activities will be comparable to that of the existing commercial and industrial



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neighbors. If peak noise levels associated with the existing compaction operation become an issue, Med-

Turn will reschedule the packing operations as needed.

There are no residential developments within 500 feet of the proposed application activities, and the

nearest residential neighborhood is located approximately 0.33 miles east of the property boundary.

4.18 Overloading and Breakdown [§330.241]

The design capacity of the transfer station will not be exceeded during site operation, and the project site

will not receive waste that may result in the creation of odors, insect breeding, or harbor vectors. If such

accumulations are to occur, the site will not accept any additional waste until the adverse conditions are

resolved.

It is estimated that the average processing time from the arrival of the waste through completion of the

process will be approximately seventy two hours. After sorting and processing the waste, Med-Turn will

store the waste within designated areas on site for an average duration of 7 days, but for no longer than 30

days, until a truck is ready to transport it offsite for disposal.

In the event that the belt conveyor system malfunctions, replacement parts and/or repair activities will be

handled by the onsite maintenance department. If repairs will require more than two days to complete,

the waste streams will be processed manually without utilizing the conveyor system. Med-Turn will not

accept wastes that cannot be handled within the allocated time as detailed in this application.

4.19 Sanitation [§330.243]

The waste streams received and shipped offsite will be contained inside appropriate containers and will

not come into contact with working surfaces. Site personnel will process the waste streams wearing the

appropriate personal protective equipment such as gloves and protective eyewear, and will not have direct

contact with the waste.

Med-Turn will routinely sweep the transfer station floors and will not generate wash water since there are

no drains inside the warehouse building. In addition, the equipment units used in the processing area will

be cleaned in accordance with manufacturer’s recommendations.

As indicated earlier, and due to the nature of the waste streams allowed onsite, spills and leaks are not

anticipated from the operation of the medical waste transfer station.

4.20 Ventilation and Air Pollution Control [§330.245]

The processing and storage of the waste received at the site will take place indoors within the warehouse

building. Med-Turn will operate the site to ensure adequate ventilation for odor control and employee

safety. . There are no air emissions associated with the operation of the medical waste transfer station, and

Med-Turn will comply with the air emissions’ regulations as required under the TCEQ, and obtain the

necessary authorizations if needed.

The generation of nuisance odors is not anticipated at the project site due to the type of wastes managed at

the site; following adequate packaging and storage procedures; and implementing general sanitation

procedures, which will limit the generation of odors. Odor control is accomplished by routine cleanup,

proper storage, and following proper housekeeping measures.



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If nuisance odors are found to be present, Med-Turn will suspend operations until the nuisance is abated,

or immediately take action to abate the nuisance.

4.21 Health and Safety Plan [§330.247]

The health and safety plan has been developed to comply with the application requirements and

the Occupational Safety and Health Administration (OSHA). Additional health and safety

requirements related to Med-Turn operations are maintained onsite. Site personnel will be

trained on this health and safety plan, and additional training will be provided in accordance with

330.247, which currently requires training on an annual basis.

4.21.1 Training

Med-Turn will provide site personnel with adequate training to be able to perform the specific

jobs assigned to them in an efficient and safe manner. Med-Turn will provide each employee

with an orientation of the entire site operations and the location of fire extinguishers, emergency

contact information, and safety equipment.

Site-specific training will include:

Site Operating Plan;

Health and Safety Plan;

Fire Protection Plan;

Emergency procedures and alarm system;

Identification of prohibited wastes including hazardous wastes;

Waste handling procedures;

Equipment operation and maintenance;

Proper housekeeping; and

Recordkeeping requirements.

Other training related to site-specific job requirements will be provided to site personnel as

needed. In addition, Med-Turn will have the appropriate individuals experienced with municipal

solid waste transfer stations as discussed earlier in this application.



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The table below provides a summary of minimum training and qualifications of site personnel:

Title / Position Job Description Qualifications

Site Manager Overall site management.

Assuring that adequate staff and

equipment are available for site

operations.

Site manager.

Regulatory compliance.

Supervisor

Daily operations and serving as the

“Emergency Coordinator”.

Maintaining the operation records

and associated logs.

Delegating work and

responsibilities to staff

Site personnel safety.

Emergency Coordinator

Obtain and maintain a license

consistent with requirements in 30

TAC 330 and 30.207.

High school diploma or equivalent.

Experience with MSW processing

operations.

Hazardous waste identification.

Health and safety.

Identification of prohibited wastes

Operators Monitoring and directing

loading/unloading procedures.

Performing load inspections.

Maintenance and housekeeping.

Safe operation of equipment.

Experience with operation of

equipment.

Ability to be trained in MSW

processing operations.

Identification of prohibited wastes.

Workers Processing and storage of waste

streams received.

Directing vehicles.

General housekeeping activities.

Ability to be trained in completing

tasks efficiently and in a safe

manner.

4.21.2 Meetings

Med-Turn will provide monthly health and safety meetings to review safety procedures and to

emphasize the importance of safety in the workplace. Med-Turn will maintain personnel training

and safety records onsite for at least three years, and will be made readily available for

inspections by the appropriate federal, state, and local agency personnel.

4.21.3 Personnel Protective Equipment

Site personnel will be supplied with the appropriate personal protective equipment required to

safely execute their job responsibilities. This equipment may include: gloves, protective

eyewear; protective coveralls; and protective footwear as appropriate.

4.21.4 Emergency Procedures

Any employee detecting an emergency will inform the EC or AI in order to inform the proper agency of

the emergency situation. The EC is the individual responsible for the management of any emergency

situation that may occur at the project site. If the EC is not available, the AI is the designated EC.



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In addition, Med-Turn has prepared an Emergency Contingency Plan (ECP) designed to minimize

hazards to human health and the environment from fires, explosions, and any unplanned sudden or non-

sudden release of hazardous waste as required under 40 CFR 265. A copy of the ECP is maintained onsite

and can be made readily available to federal, state and local agency personnel upon request. In addition,

several emergency eye wash stations are located inside the warehouse building.

The closest 24-hour emergency care service is the Texas Health Springwood Hospital which is located

approximately six miles west of the project site at 2717 Tibbets Drive, Bedford, Texas, 76022, and phone

number is (817) 355-7777.

4.21.5 Inspections and Maintenance

Various site personnel will be responsible for regularly inspecting and maintaining the project site, and

the associated documentation will be retained in the operating record. The table below provides a

summary of inspection and maintenance tasks:

Item Task Frequency

Signs Signs will be inspected for

damage, location, and accuracy of

posted information.

Weekly

Odor Odors will be assessed to evaluate

the performance of site operations. Daily

Spilled Waste Not anticipated, but will be

cleaned up as needed. As needed

Windblown Waste Not anticipated, but will be

cleaned up as needed. As needed

4.22 Employee Sanitation [30 TAC §330.249]

The property is currently connected to the City of Fort Worth public water, storm, and sanitary sewer

systems, and the existing utilities are sufficient to support the proposed application activities. The kitchen

and bathrooms are located in the office portion of the building and are made available to site personnel

and visitors. In addition, bottled water is provided to site personnel and visitors at the transfer station.

4.23 Treatment of Medical Waste [§330.1219(a)]

Med-Turn will not be conducting treatment of medical waste at the project site. The only medical waste

stream received will include unused sharps (i.e. unused hypodermic needles and hypodermic syringes

with attached needles). The nonhazardous pharmaceutical waste, drugs/special waste, and unused medical

and surgical supplies, including controlled substances and the Cactus Smart Sink® cartridges do not

require further treatment when received at the project site. These waste streams are classified as municipal

solid waste and will be stored onsite then transported for offsite disposal and incineration.

Med-Turn will maintain proper recordkeeping documents related to the type and quantity of waste

streams received at the project site as part of the operator record as listed in Attachment IV-B.



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4.24 Disposal of Medical Waste [§330.1219(b)]

Unused hypodermic needles, syringes with attached needles will be disposed of as treated sharps and will

be placed in containers designed for sharps that are marked or labeled as containing treated waste. These

containers and their contents will be designed to withstand an applied pressure of 40 pounds per square

inch without disintegration. Other waste streams received at the project site may be managed as municipal

solid waste and will be marked or labeled as such. The necessary shipping papers will accompany each

waste load transported offsite for disposal and incineration.

Med-Turn will not conduct any on-site disposal activities, and the waste streams received at the project

site will be processed and stored prior to offsite disposal and incineration.

As indicated earlier, Med-Turn has already contracted with Covanta for the disposal and incineration of

the various waste streams at their facility located at 2122 South Yukon Avenue, Tulsa, OK 74107 and it is

a waste-to-energy facility that accepts solid waste for energy production, which is sold to Public Service

Company of Oklahoma and/or other independent entities. As a secondary alternative, Med-Turn has also

contracted with a Covanta facility located at 5251 Triana Boulevard, Huntsville, AL 35805 for the

disposal and incineration of the waste.

4.25 Storage of Medical Waste [§330.1209(a) and §330.1219(a)(3)(E)(iv)]]

As indicated earlier, the processing, and storage of the waste streams and recyclable materials anticipated

at the project site will be conducted indoors within the existing warehouse building. After sorting and

processing the waste, Med-Turn will store the waste within designated areas on-site, for an average

duration of 7 days, but for no longer than 30 days, until a truck is ready to transport the waste load offsite

for disposal. In addition, recyclable material will not be stored on-site for longer than 90 days. The

storage areas are secured from theft, vandalism, inadvertent human or animal exposure, rain, water, and

wind. The waste will be managed so as not to provide a breeding place for food or insects or rodents, and

not generate noxious odors.


CACTUS SMART SINK®

ATTACHMENT IV-A

EXP Pharmaceutical Services Corp. | 48021 Warm Springs Boulevard | Fremont, California 94539

Securely Captures Raw Pharmaceutical Waste

The Cactus® Smart Sink® securely captures raw pharmaceutical waste and renders it acutely “unrecoverable” and “unusable”, so discarded drugs do not end up in the wrong hands or negatively impact our environment.

In compliance with regulatory guidelines, the Cactus® Smart Sink® provides a better the Cactus® Smart Sink® provides a better solution to disposing raw pharmaceutical waste in a sink or toilet. It̓s tamper-proof technology includes automatic alarms and secure locking systems. Alerts will sound when containers are full or reach expiry. It̓s easy to use and easy to install.

a better solution

Introducing Our New Strategic Business Partner!

Rx DISPOSAL

W&M Environmental Group, LLC (W&M Project No. 1509.001)

OPERATIONAL RECORD

REQUIREMENTS

ATTACHMENT IV-B

Med-Turn Inc.

4332 Empire Road

Fort Worth, Texas

Registration Application

Part IV

RECORDS TO BE MAINTAINED RULE CITATION

All location-restriction demonstrations §330.219(b)(1)

Inspection records and training procedures §330.219(b)(2)

Closure plans and other data relating to closure requirements §330.219(b)(3)

All cost estimates and financial assurance documentation relating to financial assurance for closure §330.219(b)(4)

Copies of all correspondence and responses relating to the operation of the facility, modifications to the

permit/registration, approvals, and other matters pertaining to technical assistance§330.219(b)(5)

All documents, manifests, shipping documents, trip tickets, etc., involving special waste §330.219(b)(6)

Any other document(s) as specified by the approved permit/registration or by the executive director §330.219(b)(7)

Trip tickets, shipping documents, manifests §330.219(b)(8)

Records and summary reports as related to the amount of waste (and other recyclable material) received at the

transfer station for processing and offsite disposal for past calendar year §330.219(b)(9)

Alternative schedules and notification requirements if applicable §330.219(g)

Inspection records and training procedures relating to fire prevention and facility safety §330.221

Access control breach and repair notices §330.223

Waste unloading/ prohibited waste discovery §330.225

Record of alternative operating hours if applicable §330.229(b)

Batch records and equipment operating records §330.1219(a)(3)

ATTACHMENT IV-B

OPERATIONAL RECORD REQUIREMENTS


solid waste storage and processing units · refresher training based on their position. both key...

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