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TEXAS DECON\FINAL\19022\NOD RESPONSE\ L191202_NOD SUBMITTAL.DOCX

December 2, 2019

Mr. Jaspinder Singh, Project Manager Waste Permits Division Texas Commission on Environmental Quality P.O. Box 13087 Austin, TX 78711-3087 (VIA HAND DELIVERY)

Re: Texas Decon LLC – NOD Response for Medical Waste Registration Application # 40305

Dear Mr. Singh:

On behalf of Texas Decon LLC and in response to your November 4, 2019 email transmitting Notice of Deficiency (NOD) items, Cook-Joyce, Inc. (CJI) is submitting an original and three copies of the following enclosed documents:

1. Revised application form pages;

2. A revised document that provides supplemental information required by Section 5.0 of theapplication form;

3. A revised Attachment 2 (Facility Access and Facility Layout Map); and

4. An application form Applicant Certification and Signature page that was signed by theTexas Decon Owner/Operator on November 27, 2019.

Included below are instructions for replacing pages. Also included below is a list of the NOD items and a response for each item.

REPLACEMENT PAGE INSTRUCTIONS

Regarding the previously submitted application form, the application form pages should be replaced as follows:

1. The cover page and the Table of Contents page should be replaced with the enclosedcover page and Table of Contents Page that are denoted with a revision date of November26, 2019.

2. Pages 8 through 11, which include Sections 2.1, 2.2, 2.3, 2,4 and a portion of Section 2.5,should be replaced with enclosed pages 8 through 12 that are denoted with a revisiondate of November 26, 2019 in the header.

3. Pages 13 and 14, which include Sections 3.1 and 3.2, should be replaced with enclosedpages 14, 15, and 16 that are denoted with a revision date of November 26, 2019 in theheader.

Mr. Jaspinder Singh December 2, 2019 Page 2


4. Pages 17 through 19, which include Sections 4.2 through 4.5, should be replaced with enclosed pages 19 through 21 denoted with a revision date of November 26, 2019 in the header.

Please note that due to the automatic pagination in the TCEQ form, revisions to the document on November 26, 2019 resulted in there now being two page 12s, two page 15s, two page 16s, two page 20s, two page 21s, no page 13, no page 17, and no page 18.

The document entitled “Section 5 – Other Site Operating Plan, Financial Assurance, and Closure Requirements” should be replaced in its entirety with the enclosed document that has a revision date of November 26, 2019 denoted in the footer.

Attachment 2 “Facility Access and Facility Layout Map” should be replaced with the enclosed Attachment 2 that was signed and dated November 26, 2019.

NOD ITEMS

NT1, Section 2.1, §326.71(a)(5)(A) and (B), Page 8 of 28. Explain the sources used to obtain the Impact on Surrounding data.

Response:

Section 2.1 has been updated to include the sources used to obtain the Impact on Surrounding Area. These sources include the Land Use Map in Attachment 3 to the application and historical aerial photos. Additional information has also been added in Section 2.1.

NT2, Section 2.2, §326.71(e), Page 9 of 28, Table 2. Provide vehicle types for expected volume increase.

Response:

Table 2 in Section 2.2 has been updated to provide the vehicle types for the “Projected Vehicle Traffic Generated by Facility.”

NT3, Section 2.5, §326.71(i), Page 11 of 28, Table 3. Revise to specify number of units for both phases.

Response:

Table 3 in Section 2.5 has been updated to specify the number of units for both Phase I and Phase II.

T1, Section 3.2, §326.71(m)(1)(B), Page 13 of 28, Table 4, Item 7. Provide closure cost estimates for each phase.



Response:

Table 4 has been updated to provide a closure cost estimate for each phase.

T2, Section 4.2, §326.75(b), Page 17 of 28. Provide information to include any changes in waste acceptance plan in Phase II.

Response:

Section 3.2 has been revised to show: the maximum amount of waste to be received daily for both Phase I and Phase II and the maximum amount of waste to be stored at any point in time for both Phase I and Phase II.

T3, Section 4.5, §326.75(i), Page 19 of 28. Revise the operating hours to 4 a.m. – 8 p.m. and explain what market conditions and business demands are to be expected to justify operating outside 7 a.m. to 7 p.m. or remove the statement.

Response:

The operating hours have been changed to 7:00 a.m. to 7:00 p.m. Monday through Friday.

NT4, Section 5.0, §326.69(c)(3), Page ii and iii. Provide correct section numbers in the table of contents.

Response:

All section numbers in the document entitled “Section 5 – Other Site Operating Plan, Financial Assurance, and Closure Requirements” have been revised to all start with “5.” The section numbers in the document and the table of contents have been revised.

NT5, Section 5.0, §326.75(d), Page 2, Section 5.2.0. Provide Phase I and Phase II storage information include storage in vehicles if applicable.

Response:

Section 5.2.0 in the document entitled “Section 5 – Other Site Operating Plan, Financial Assurance, and Closure Requirements” has been revised to indicate that all untreated medical waste will be stored inside the building during Phase I and Phase II under normal operating conditions. As discussed further in the revised Section 5.2.0, refrigerated storage will only be required if there is an extended problem with an OMW-400. Minor revisions have also been made to Sections 5.5.3 and 5.12.2 so that these sections are consistent with the revised Section 5.2.0.

NT6, Section 5.0, §326.75(h)(1), Page 10, Section 5.6.1. Revise to indicate that signs will be used to indicate where vehicles are to unload.



Response:

Section 5.6.1 in the document entitled “Section 5 – Other Site Operating Plan, Financial Assurance, and Closure Requirements” has been revised to indicate that signs will be used to indicate where vehicles are to unload inside the overhead door on the northwest corner of the building. Additional information has also been added to Section 5.6.1 to clarify that, before entering the locked gate that provides access to both the secure fenced area and to the unloading area inside the northwest corner of the building, drivers for all incoming vehicles will be required to report to the office. Signs will be placed on the locked gate that state “Report to Office Prior to Entry.” Entry will be allowed once all documentation has been verified by Texas Decon personnel.

T4, Section 5.0, §326.75(h)(1), Page 10, Section 5.6.2. Explain what measures the facility will take to prohibit unloading of unauthorized waste.

Response:

Section 5.6.2 in the document entitled “Section 5 – Other Site Operating Plan, Financial Assurance, and Closure Requirements” has been revised to include some of the same information described above for Section 5.6.1 with respect to the requirement that drivers of all incoming vehicles are required to report to the office. Section 5.6.2 has also been revised to include a reference to the security cameras located inside and outside the building that record video and send motion alerts to the Owner/Operator and General Manager’s cell phones.

NT7, Attachment, §326.71(f).

Response:

Additional information has been added in bold to Section 2.3 of the application form to describe compliance with 30 TAC §326.71(f)(1), §326.71(f)(2), and §326.71(f)(3).

T5, Attachment 2, §326.71(a)(6) and §326.75(g), Facility Layout Map and Access Control. Provide loading/unloading, truck/container/trailer storage, general parking area location details.

Response:

Attachment 2 has been revised to provide the requested information. There will be no truck/container/trailer storage under normal operating conditions. The location of refrigerated storage, should it be required due to an extended problem with an OMW-400, has been added.

T6, Section 12.1, §326.75(n), Facility Design Capacity. Provide the throughput flow (design capacity) for processing waste as it relates to waste acceptance rates, processing (OMW units), storage, and transferring for disposal for each phase.



ENCLOSURES


ENCLOSURE 1

REVISED APPLICATION FORM PAGES



Initial Application Submittal Date 9/12/2019 Revision 11/26/2019

TCEQ–20789, Application for a Medical Waste Registration (09-28-18) Page 8 of 28

Section 2—Facility Design Information

2.1 Impact on Surrounding Area [30 TAC §326.71(a)(5)(A) & (B)]

This section addresses the facility’s impacts on cities, communities, groups of property owners, or individuals (attach additional pages to answer the following questions, if necessary):

Describe the character of the surrounding area land uses within one mile of the facility:

Attachment 3 (Land Use Map) shows the proposed registration boundary and the land uses within one mile of the facility. The land use within one mile is predominately agricultural. There are some scattered residential uses within one mile, including on property immediately west and southwest of the property where the facility will be located. There are also some scattered commercial uses within one mile. There is a café located across Dennis Drive from the property where the facility will be located. A pediatric office is located behind the café.

Identify growth trends within five miles of the facility with directions of major development:

Based on an analysis of historical Google Earth aerial photos, there has been little growth in the last few years within five miles of the facility. The Avery Park subdivision off of Highway 46 and within the New Braunfels City limits has increased in size and is located approximately 4.5 miles southwest of the facility. New Braunfels is located west of the facility and Seguin is located to the south of the facility. Based on evaluation of past historical aerial photos, it does not appear that expansion of these cities into the five mile radius and toward the facility will be rapid. Based on the websites for the City of Seguin and the City of New Braunfels, the proposed facility is located inside the Seguin ETJ approximately 0.25 miles east of the boundary between the Seguin and New Braunfels ETJs. The Guadalupe Valley Electric Cooperative (GVEC) website indicates the number of housing units in Seguin is projected to increase from 11,658 in 2019 to 12,449 in 2024. The proposed facility is located on a portion of a 3.00 acre property that is likely to undergo further development. The Guadalupe County Appraisal District lists the "Property Use Description" for the property that includes the proposed facility as "Industrial Bldg-Flex."

Indicate the approximate number of residences and other uses (e.g. schools, churches, cemeteries, historic structures and commercial sites, etc.) within one mile of the facility:

Based on a review of Attachment 3 (Land Use Map), within one mile of the facility, there approximately 75 residences (including an RV park) and approximately four commercial sites. No schools, churches, cemeteries and historic structures were identified within one mile of the facility.

Indicate the distance to the nearest residence(s):Approximately 175 feet miles

Provide directions to the nearest residence(s):

Located across Dennis Drive on the property adjacent to the restaurant that is immediately across the street from the entrance road to the facility.



Indicate the distance to the nearest commercial establishment(s): Approximately 145 feet miles

Provide directions to the nearest commercial establishment(s):

Located across Dennis Drive from the facility.

2.2 Transportation [30 TAC §326.71(e)]

Access Roads

Complete Table 1 regarding the roads that will be used to access the site.

Table 1. Roads That Will be Used to Access the Site.

Name of Road Surface Type and Number of Lanes

Dennis Drive Asphalt - 2 Lanes

SH 123 Asphalt - 4 Lanes

FM 758 Asphalt - 2 Lanes

Daily Traffic Volume

Complete Table 2 regarding existing and expected volume of vehicular traffic on access roads within one mile of the facility, and the projected volume of traffic expected to be generated by the facility on access roads within one mile of the facility.

Table 2. Traffic Volume.

Vehicle Traffic Volume (vehicles per day)

Existing Vehicle Traffic SH 123 2018 AADT = 10,924

FM 758 2018 AADT = 1,412

Expected Vehicle Traffic SH 123 2037 Estimated AADT = 14,260

FM 758 2037 Estmated AADT = 2,350

Projected Vehicle Traffic Generated by Facility

Eight personal vehicles, two company pickup trucks, and seven waste transport

trucks (maximum size truck allowed will be a 26-foot box truck with an overall vehicle

length of 34 feet) per day

Describe the source of or method used to obtain the volumes (attach additional pages to answer this question if necessary):



Texas Department of Transportation Statewide Planning Map https://www.txdot.gov/apps/statewide_mapping/StatewidePlanningMap.html

If traffic volume was determined by counts in the field, indicate the locations where the counts were conducted (attach additional pages to answer this question if necessary):

At the above link, TxDOT Station Flag 95H126 located on FM 758 just west of SH 123 was used to get the TxDOT count for FM 758. The counts for SH 123 were taken from TxDOT Station Flag 95D3 located on SH 123 north of FM 758 and Station Flag 95H6 located on SH 123 south of FM 758. For SH 123 the maximum 2018 Average Annual Daily Traffic (AADT) was basically equivalent at 95H6 and 95D3. The maximum 2037 estimated AADT for SH 123 was at 95D3.

2.3 Floodplain and Wetlands [30 TAC §326.71(f)]

Will the facility be located within a 100-year floodplain?

Yes No Identify the floodplain zone Zone X

Attach a copy of the Federal Emergency Management Administration administrator (FEMA) flood map for the area.

If the facility will be within a 100-year floodplain, attach documentation demonstrating that the facility is designed and will be operated in a manner to prevent washout of waste during a 100-year storm event, or that the facility has obtained a conditional letter of map amendment from the FEMA.

Will the facility be located in wetlands?

Yes No

If yes, attach documentation to the extent required under Clean Water Act, §404 or applicable state wetlands laws.

The facility will comply with the requirements of 30 TAC §326.71(f)(1) & (2) because all unloading, storage and processing of untreated waste will be inside the enclosed building and storage of treated waste will be inside the self-contained compactor. Therefore, the facility will be constructed maintained and operated to manage run-on and run-off during the peak discharge of a 25-year rainfall event and to prevent the off-site discharge of waste and feedstock material, including but not limited to, in-process and/or processed materials. Surface water drainage in and around the facility will not run onto, into, or off the storage and processing area within the enclosed building or the contents of the self-contained waste compactor.

Per 30 TAC §326.71(f)(3), Texas Decon will obtain the appropriate Texas Pollutant Discharge Elimination System storm water coverage when required.



2.4 Buffer Zones and Easement Protection [30 TAC §326.71(h)(3)]

Is the buffer zone in any location at the facility less than 25 feet wide?

Yes No

If yes, describe your alternative buffer zone and how it will allow access for emergency response and maintenance (attach additional pages to answer this question if necessary):

As shown on the layout in Attachment 2, an alternative buffer zone of 15 feet is requesed for the fenced area of the facility located outside the building. As shown on the layout in Attachment 2, an alternative buffer of 0 feet is requested for the portion of the facility where the wall of the enclosed building is the facility boundary. This includes the eastern and southern sides of the building and a portion of the western side of the building. A buffer zone of 25 feet is not feasible due to the limited size of the property that Texas Decon was able to lease from the landowner and the need to have enough room within the facility boundary to maneuver vehicles.

No solid waste unloading, storage or processing operations will occur within the buffer zones. As shown on Attachments 2 and 5, there are no easements or right-of-ways that cross the facility. The alternative buffer zone of 0 feet will allow the building to have adequate space for storage and processing of waste. The alternative buffer zone of 15 feet will allow adequate room for vehicle access and will also allow more space for waste storage within locked transport vehicles. Unloading of unprocessed waste will be typically be done inside the building. Waste may also be transfered from vehicle to vehicle.

The requested alternative buffer zones do not prevent adequate access to the facility by firefighting and other emergency vehicles. The Geronimo Volunteer Fire Department (VFD) has access to a lock box that allows them to enter the facility via the building's overhead doors and via the slide gate on the south fence.

2.5 Waste Management Unit Designs [30 TAC §326.71(i)]

Waste Management Unit Details

List each waste management unit in Table 3. Include attachments documenting manufacturer specifications.

Table 3. Design Details and Manufacturer Specifications for Waste Management Units.

Unit Type Minimum

Number of Units

Design Details Approximate Dimensions

Approximate Capacity per

Unit

Ozone Medical Waste Treatment System - OMW

Phase I: one unit

See Attachment 15

21.7 ft L X 7.5 ft W X 8.0 ft H

400 lbs/hour per unit



Unit Type Minimum

Number of Units

Design Details Approximate Dimensions

Approximate Capacity per

Unit 400 by Clean Waste Systems

Phase II: one additional unit for a total of

two units

Air compressor skid

One for each OMW 400 so -

Phase I: one unit


two units

See Attachment 15

2.8 ft L X 5 ft W x 5.7 ft H

NA

Oxygen Concentrator Skid

One for each OMW 400 so -

Phase I: one unit


two units

See Attachment 15

4.7 ft L X 2.3 ft W X 6.3 ft H

NA

Self-contained waste compactor

One (total for both Phase I

and Phase II - no additional

units added for Phase II)

See Attachment 15

for an example

Up to 22.4 ft L X 8.5 ft W X 8.3

ft H

Up to 30 cubic yards

Foundations and Supports

Provide a generalized description of construction materials for slab and subsurface supports of all storage and processing components (attach additional pages to answer this question if necessary):

The equipment and containerized waste will sit directly on a reinforced concrete slab on grade foundation with adequate strength.



Section 3—Facility Closure

3.1 Closure Plan [30 TAC §326.71(k)]

The operator must comply with the closure requirements listed in 30 TAC §326.71(k).

List other activities that the facility will conduct during closure, if any (attach additional pages to answer this question if necessary):

The operator will comply with all closure requirements listed in 30 TAC §326.71(k). All waste and material on-site will be removed and transported to a TCEQ permitted treatment facility (for unprocessed waste) or a TCEQ permitted disposal facility for processed waste. The facility units and the processing area will then be disinfected if necessary. Certification of final closure will be performed in accordance with 30 TAC §326.71(l).

3.2 Closure Cost Estimate [30 TAC §326.71(m)]

Provide itemized closure cost estimates in Table 4. The cost estimates must meet the requirements listed in 30 TAC §326.71(m).

Attach documents detailing any additional unit closure costs not itemized. Enter the total of those additional unit closure costs on line 13 of the closure cost worksheet in Table 4.

Table 4. Closure Cost Estimates Worksheet.

CLOSURE COST ESTIMATE FOR PHASE I

Item No. Item Description

Unit of Measure-

ment Quantity Unit

Cost Total Cost

1 Site Evaluation and Engineering Review NA 1 $1,750 $1,750

2 Bid Document and Procurement NA 1 $2,100 $2,100

3 Contract Award and Administration NA 1 $1,400 $1,400

4 Clean-Up, Removal and Transport of Waste Stored On-Site

Ton 10 $50 $3,000

5 Disposal of Waste at an Authorized Facility Ton 10 $50 $500

6 Waste Treatment Ton 10 $430 $4,300




Unit of Measure-

ment Quantity Unit

Cost Total Cost

7 Process Units Dismantling NA 1 $2,000 $2,000

8 Wash Down and Disinfection of Facility and Processing Units

NA 1 $2,000 $2,000

9 Vector Control NA 1 $300 $300

10 Site Security NA 1 $200 $200

11 Signs, Newspaper Notice and TCEQ Notice

NA 1 $3,000 $3,000

12 Facility Inspection and Closure Certification by Licensed Engineer

NA 1 $2,100 $2,100

13 Additional Storage and Processing Unit Closure Cost Items (describe in attachments)

Identify Attachments

- NA NA NA NA

14 Storage and Processing Unit Closure Costs Subtotal

NA NA NA $22,650

15 Contingency Cost 15% NA NA NA $3,398

16 Total Closure Cost Estimate NA NA NA $26,048

CLOSURE COST ESTIMATE FOR PHASE II


Unit of Measure-

ment Quantity Unit

Cost Total Cost

1 Site Evaluation and Engineering Review NA 1 $1,750 $1,750

2 Bid Document and Procurement NA 1 $2,100 $2,100

3 Contract Award and Administration NA 1 $1,400 $1,400

4 Clean-Up, Removal and Transport of Waste Stored On-Site

Ton 20 $50 $6,000




Unit of Measure-

ment Quantity Unit

Cost Total Cost

5 Disposal of Waste at an Authorized Facility Ton 20 $50 $1,000

6 Waste Treatment Ton 20 $430 $8,600

7 Process Units Dismantling NA 2 $2,000 $4,000

8 Wash Down and Disinfection of Facility and Processing Units

NA 1 $2,000 $2,000

9 Vector Control NA 1 $300 $300

10 Site Security NA 1 $200 $200

11 Signs, Newspaper Notice and TCEQ Notice

NA 1 $3,000 $3,000

12 Facility Inspection and Closure Certification by Licensed Engineer

NA 1 $2,100 $2,100

13 Additional Storage and Processing Unit Closure Cost Items (describe in attachments)

Identify Attachments

- NA NA NA NA

14 Storage and Processing Unit Closure Costs Subtotal

NA NA NA $32,450

15 Contingency Cost 15% NA NA NA $4,868

16 Total Closure Cost Estimate NA NA NA $37,318



If the site operator becomes aware that hazardous wastes have been inadvertently accepted, he will immediately contain the accepted waste by terminating waste flow and will return it to the transporter or generator if practical, or contact a company licensed and permitted to handle and dispose of such wastes. The TCEQ will be immediately notified if any prohibited or unauthorized wastes are accidentally accepted. Records of the notification will be kept in the site operating record and will include the date and time of notification, the individual contacted, and the information reported.

4.2 Waste Acceptance [30 TAC §326.75(b)]

Describe all sources and characteristics of medical wastes to be received for storage and processing or disposal (attach additional pages to answer this question if necessary):

This medical waste processing facility will accept medical waste as defined in 30 TAC §326.3(23) (and may include treated and untreated special waste from health care-related facilities that is comprised of animal waste, bulk blood, bulk human blood, bulk human body fluids, microbiological waste, pathological waste, sharps, and other health care-related items that come into contact with body fluids and/or blood). Sources of wastes include hospitals, surgical centers, doctor's offices and other medical facilities, nursing and rehab facilities, veterinary facilities, medical spas, dialysis centers, medical testing laboratories, and dental offices. The facility may also accept trace chemotherapeutic waste and non-hazardous pharmaceuticals. Where required by regulations, trace chemotherapeutic waste and certain non-hazardous pharmaceuticals will be stored at the facility prior to transfer to another facility for authorized treatment/disposal such as incineration.

Describe the sources and characteristics of recyclable materials, if applicable, to be received for storage and processing (attach additional pages to answer this question if necessary):

No recycling activities are planned at this time.

Maximum amount of waste to be received daily: 5 pounds/day tons /day-Phase I

10 pounds/day tons /day-Phase II

Maximum amount of waste to be stored at any point in time: 10 pounds tons-Phase I

20 pounds tons-Phase II

Note: Phase II operations, which will include a second OMW 400 system, will not begin until: i) additional financial assurance is in place; ii) a TCEQ inspection is requested by Texas Decon; iii) an inspection is conducted by TCEQ; and iv) TCEQ approval is received.

Maximum length of time waste is to remain at the facility: 30 hours days

Specify the maximum time that unprocessed and processed wastes will be allowed to remain on-site:

Processed: 30 hours days



Unprocessed: 72 hours if unrefrigerated or 30 days if refrigerated

Identify the intended disposition of processed and unprocessed waste received at the facility (attach additional pages to answer this question if necessary):

Unprocessed waste will be treated at the facility unless it is trace chemotherapeutic waste or certain non-hazardous pharmaceuticals. Processed waste will be disposed of at a TCEQ permitted municipal solid waste landfill. Where required by regulations, trace chemotherapeutic waste and certain non-hazardous pharmaceuticals will be stored at the facility prior to transfer to another facility for authorized treatment/disposal such as incineration.

4.3 Generated Waste [30 TAC §326.75(c)]

Describe how all liquids and solid waste resulting from the facility operations will be disposed of in a manner that will not cause surface water and groundwater pollution (attach additional pages to answer this question if necessary):

Rainwater contact with medical waste will be prevented. Unloading of waste will typically be completed within an enclosed building or by vehicle to vehicle transfer. All treatment will be within an enclosed building. Storage will be within the enclosed building or the enclosed, locked trucks, containers or trailers. Liquids are not expected to be generated by facility operations. However, if any wash waters are generated from cleanup or wash down activities associated with unprocessed waste unloading or treatment, the liquids will be managed as medical waste and absorbent materials will be used to eliminate the liquids. The absorbent materials will then be processed through the treatment unit. Any liquids generated from cleanup of processed waste handling or storage equipment will either be discharged to the septic system or absorbent materials will be used to eliminate the liquids. The absorbent materials would then be placed in the processed waste self-contained compactor for transport to a TCEQ permitted municipal solid waste landfill. The septic system was permitted by Guadalupe County. There will be no off-site discharge of contaminated waters or off-site discharge to a wastewater treatment facility. Transfers of processed waste to the self-contained compactor will be done using covered carts and will not be done during rain events.

4.4 Access Control [30 TAC §326.75(g)]

Describe how public access to the facility will be controlled (attach additional pages to answer this question if necessary):

Access will be controlled to prevent entry of livestock, to protect the public from exposure to potential health and safety hazards, and to prevent unauthorized entry or uncontrolled disposal. A perimeter fence will be located at the Registration Boundary and will tie into the building as shown on Attachment 2. A gate will be located at the fence entrance. The processing building doors will have locks. The medical waste facility gate and processing building locks will be controlled by Texas Decon personnel and will be kept closed when the waste operations are closed and not attended. Access to the treatment/processing building is limited to employees and authorized visitors. Non-affiliated users, shippers, and visitors are allowed access only when employees are present. All users must present personal or



company identification when asked. The facility will display an entrance sign stating the site name, registration number, hours and days of operation.

Describe how access roads and parking areas will be maintained to control dust and prevent mud from being track off-site (attach additional pages to answer this question if necessary):

The access road from Dennis Drive to the processing building is paved with concrete and is two lanes wide. Parking areas at the facility are either paved with concrete or have a road base surface. Due to the use of these all-weather surfaces, generation of dust and mud is not expected. If necessary to control dust, water can be applied. Safe on-site access for all vehicles will be provided and adequate turning radii will be provided for the types of vehicles that will utilize the facility. This will prevent disruption of normal traffic patterns.

Access to the facility will be controlled by a perimeter fence, with lockable gates. Identify or describe the type of fence that will be installed at the facility:

A four-foot-high barbed wire fence;

A six-foot-high chain-link fence; or

Other:

4.5 Operating Hours [(30 TAC §326.75(i)]

Provide the operating hours of the facility; include justification for hours outside of 7:00 a.m. to 7:00 p.m., Monday through Friday:

The operating hours of the facility will be 7:00 a.m. to 7:00 p.m. Monday through Friday.

List the alternative operating hours, if any, of up to five days in a calendar-year period:

Texas Decon does not expect that alternative operating hours will be required to accommodate special occassions, special purpose events, holidays, or other special occurrences.


ENCLOSURE 2

SUPPLEMENTAL INFORMATION REQUIRED BY SECTION 5.0 OF THE APPLICATION FORM





TEXAS DECON\FINAL\19022.01. 1 REVISION 1 R191126_SECTION 5.DOCX NOVEMBER 26, 2019

5.1.0 INTRODUCTION

This document provides the information required by Section 5.0 of TCEQ-20789 (Application for

a Medical Waste Registration). Sections 5.2.0 through 5.18.0 are organized to provide the

additional pages describing how the facility will comply with the requirements listed on Section 5

of the application form.


5.2.0 STORAGE – 30 TAC §326.75(d)

All solid waste will be stored properly so that it does not create a nuisance. Source-separated

recyclable materials from medical waste facilities will not be received.

Waste will be stored in a secure manner and location that affords protection from theft, vandalism,

inadvertent human or animal exposure, rain, water, and wind. Waste will be managed and stored

in a manner that does not cause fire, safety or health hazards, that does not provide food or

harborage for animals, rodents, insects and other vectors, and that does not generate noxious

odors. All untreated medical waste will be stored inside the 4,000 square foot processing building

under normal operating conditions. The processing building will be expanded to 4,800 square

feet in the future for Phase II. Untreated putrescible or biohazardous medical wastes that must

be stored more than 72 hours will be placed in a refrigerated truck or trailer located outside of the

treatment building. The refrigerated truck or trailer will maintain a temperature of 45oF or less.

Refrigerated storage will not be required under normal operating conditions. For both Phases I

and II, refrigerated storage will only be required if there is an extended problem with an OMW-

400. Texas Decon currently owns one refrigerated transport truck. Texas Decon will also rent a

28-foot refrigerated trailer from a local vendor if necessary. If refrigerated storage is required, the

Texas Decon refrigerated truck and rented 28-foot refrigerated truck would be parked inside the

secure fenced area as shown on Attachment 2.

As further described in Section 5.12.1.1, the available storage area inside the 4,000 square foot

building for Phase I will be 1,476 square feet. After expanding the building to 4,800 square feet

for Phase II, the available storage capacity will increase slightly to 1,500 square feet. Therefore,

there is more than adequate storage capacity for medical waste transport boxes to be stored

inside the building.

All containers will be maintained in a clean condition so that they do not constitute a nuisance.

Containers to be mechanically handled will be designed to prevent spillage or leakage during

storage, handling or transport.

A stationary, self-contained compactor will be operated and maintained in such a way as not to

create a public nuisance through material loss or spillage, odor, vector breeding or harborage, or

other condition.


5.3.0 RECORDKEEPING AND REPORTING - 30 TAC §326.75(e)

5.3.1 REGISTRATION AND REGISTRATION APPLICATION - 30 TAC §326.75(e)(1)

A copy of the registration, the approved registration application, and any other required plan or

other related document will be maintained at the medical waste facility at all times. These plans

will be made available for inspection by agency representatives or other interested parties. These

documents will be considered a part of the operating record for the facility.

5.3.2 OPERATING RECORD - 30 TAC §326.75(e)(2)

The following documents and records will be promptly recorded and retained on site by the

owner/operator in the facility’s operating record during the life of the facility until after certification

of closure:

A. All location-restriction demonstrations;

B. Inspection records and training procedures;

C. Closure plans, cost estimates, and financial assurance documentation relating to

financial assurance for closure;

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

modifications to the registration, approvals, and other matters pertaining to technical

assistance; and

E. All documents, manifests and any other document(s) as specified by the approved

authorization or by the TCEQ executive director.

5.3.3 SIGNATORIES TO REPORTS - 30 TAC §326.75(e)(3)

For signatories to reports, the following conditions apply.

A. The owner or operator or a duly authorized representative will sign all reports and other

information requested by the executive director as described in §305.128 (relating to

Signatories to Reports) and §305.44(a) (relating to Signatories to Applications). A

person is a duly authorized representative only if:


i. the authorization is made in writing by the owner or operator as described in

§305.44(a);

ii. the authorization specifies either an individual or a position having

responsibility for the overall operation of the regulated facility or activity or for

environmental matters for the owner or operator, such as the position of plant

manager, environmental manager, or a position of equivalent responsibility. A

duly authorized representative may be either a named individual or any

individual occupying a named position; and

iii. the authorization is submitted to the TCEQ executive director.

B. If an authorization is no longer accurate because of a change in individuals or position,

a new authorization will be submitted to the executive director prior to, or together with,

any reports, information, or applications to be signed by an authorized representative.

C. Any person signing a report shall make the certification in §305.44(b) of this title:

"I certify under penalty of law that this document and all attachments were prepared

under my direction or supervision in accordance with a system designed to assure that

qualified personnel properly gather and evaluate the information submitted. Based on

my inquiry of the person or persons who manage the system, or those persons directly

responsible for gathering the information, the information submitted is, to the best of

my knowledge and belief, true, accurate, and complete. I am aware there are

significant penalties for submitting false information, including the possibility of fine

and imprisonment for knowing violations."

5.3.4 FURNISHING RECORDS - 30 TAC §326.75(e)(4)

All information contained in the operating record will be furnished upon request to the TCEQ

executive director and will be made available for inspection by the TCEQ executive director.

5.3.5 RECORDS RETENTION - 30 TAC §326.75(e)(5)

The owner or operator will retain all information contained within the operating record and the

different plans required for the facility for the life of the facility.


5.3.6 ALTERNATE SCHEDULES FOR RECORDKEEPING AND REPORTING - 30 TAC

§326.75(e)(6)

The TCEQ executive director may set alternative schedules for recordkeeping and notification

requirements than those described in Sections 5.3.1 through 5.3.5 above.

5.3.7 WASTE SHIPMENT DOCUMENTS - 30 TAC §326.75(e)(7)

The owner or operator of this medical waste processing facility, when accepting delivery of

untreated medical waste for which a shipping document is required for processing, will ensure

that each of the following requirements are met:

A. A shipping document accompanies the shipment, which designates the facility to

receive the waste;

B. The owner or operator signs the shipping document and immediately gives at least

one copy of the signed shipping document to the transporter;

C. The owner or operator retains one copy of the shipping document; and

D. Within 45 days after the delivery, the treatment facility owner or operator sends a

written or electronic copy of the shipping document to the generator that includes the

total weight of waste received and a statement that the medical waste was treated in

accordance with 25 TAC §1.136 (relating to Approved Methods of Treatment and

Disposition).


5.4.0 FIRE PROTECTION - 30 TAC §326.75(f)

5.4.1 WATER SUPPLY - 30 TAC §326.75(f)(1)

An adequate supply of water under pressure will be available for firefighting purposes. Water is

available from a well that provides water to the facility. Additionally, the Geronimo Volunteer Fire

Department (VFD) has a tanker truck and will respond in the event of a fire. The Geronimo VFD

has a lockbox at the facility that allows them access at any time.

5.4.2 AVAILABILITY OF FIREFIGHTING EQUIPMENT - 30 TAC §326.75(f)(2)

Fire extinguishers will be located at appropriate locations within the facility and the Geronimo VFD

will provide additional response capabilities.

5.4.3 FIRE PROTECTION PLAN - 30 TAC §326.75(f)(3)

The facility and its fire protection plan will comply with applicable local fire codes. The sources of

fire protection are fire extinguishers and the Geronimo VFD. In an emergency, the Geronimo

VFD can be reached by dialing 911. Neighboring business phones and mobile phones can be

used in the event of phone system failure. The Geronimo VFD is located approximately three

miles south of the facility at 6551 North Texas 123 and can be reached for non-emergency items

at 830-372-4208. Type ABC hand-held fire extinguishers will be located at the facility, readily

available for use on trash, flammable liquid or electrical fires.

All facility personnel will be trained in the contents of the fire protection plan, fire extinguisher use,

and in communications and response in the event of a grass, structural or equipment fire. During

waste handling, generation of heat or flammable vapors is not significant.

Other measures and precautions to be followed at the facility to minimize the occurrence of fires

include:

Clean up any flammable liquid spills immediately, and keep work areas free of any extra paper,

boxes or rags.

Don't string electrical cords across floors or walkways where they can be stepped on and frayed,

exposing the facility up to the possibility of an electrical fire. De-energize machinery before any


maintenance work is started and thoroughly inspect that equipment before the power is turned

back on.

Use caution when using tools that cause friction or sparks near flammable materials.

Procedures in the Event of a Fire

Staff will take the following steps if a fire is discovered:

Contact the Geronimo VFD by calling 911. Alert other facility personnel. Assess extent of fire, possibilities for the fire to spread, and alternatives for extinguishing

the fire. If it appears that the fire can be safely fought with available firefighting devices until

arrival of the VFD, attempt to contain or extinguish the fire. It is not advisable to attempt to fight the fire alone. Personal protective equipment could

be needed. Be familiar with the use and limitations of firefighting equipment available onsite.

Upon arrival of Geronimo VFD personnel, direct them to the fire and provide assistance as

appropriate.


5.5.0 ACCESS ROADS, VEHICLE PARKING, AND SAFETY MEASURES - 30 TAC §326.75(g)

5.5.1 PUBLIC ACCESS CONTROLS - 30 TAC §326.75(g)(1)

Public access to the facility will be controlled by means of a six-foot-high chain link fence with a

lockable gate. This will protect human health and safety and the environment. Uncontrolled

access to operations at the medical waste facility will be prevented. The building has lockable

doors. Additionally, security cameras are located inside and outside the building. These security

cameras record video and send motion alerts to the Owner/Operator and the General Manager’s

cell phones. The camera and recorded video can be accessed remotely.

5.5.2 FACILITY ACCESS ROAD - 30 TAC §326.75(g)(2)

The facility access road from a publicly owned roadway (Dennis Drive) is a two-lane concrete

paved road that is adequate for the expected traffic flow. Safe on-site access for all vehicles is

provided. There are adequate turning radii off Dennis Drive and the driveway intersection at

Dennis Drive is approximately 45 feet wide. Driveway access to loading/unloading, operations

and parking areas is via a paved concrete or road base surface. The facility provides vehicle

parking for equipment, employees and visitors on either a concrete surface or a road base

surface. Facility traffic will travel on the all-weather access surfaces and should not track mud

onto area roadways. If mud accumulates on the road from the site, it will be removed by the end

of the day.

Safety bumpers are not required because incoming waste will be unloaded directly into the

building or transferred into another vehicle. The area of the building where waste will be unloaded

is not where the processing equipment will be located.

5.5.3 PERIMETER FENCE - 30 TAC §326.75(g)(3)

Access to the facility will be controlled by a six-foot high chain link fence and a gate across the

driveway. The gate will be controlled by Texas Decon personnel and will be kept closed when

not in use. The operations area will be inside the building. The fence will tie-in to the building as

shown in Attachment 2 to the application and will enclose any refrigerated transport unit storage


areas should they be required. The gate and building will be locked at all times when the waste

operations are closed and not attended.


5.6.0 UNLOADING OF WASTE – 30 TAC §326.75(h)

5.6.1 WASTE UNLOADING AREA - 30 TAC §326.75(h)(1)

The unloading of the waste will be confined to as small an area as practical. Texas Decon

personnel will monitor all incoming loads of waste and will conduct unloading operations.

Appropriate signs will be used to indicate where vehicles are to unload inside the overhead door

on the northwest corner of the building. However, before entering the locked gate that provides

access to both the secured fenced area and to the unloading area inside the northwest corner of

the building, drivers for all incoming vehicles will be required to report to the office. Signs will be

placed on the fence adjacent to the locked gate that state “Report to Office Prior to Entry.” Once

all documentation has been verified by Texas Decon personnel, entry will be allowed. Texas

Decon personnel will be aware that they are not required to accept any waste that they determine

will cause or may cause problems in maintaining full and continuous compliance with TCEQ

requirements.

5.6.2 UNLOADING OF WASTE IN UNAUTHORIZED AREAS - 30 TAC §326.75(h)(2)

The unloading of waste in unauthorized areas is prohibited. As mentioned above, drivers of all

incoming vehicles must report to the office before entering the locked gate that provides access

to the fenced area and to the unloading area. Entry through the locked gate will only be allowed

by Texas Decon personnel after documentation has been verified. Also, as described in Section

5.5.1, security cameras are located inside and outside the building. These security cameras

record video and send motion alerts to the Owner/Operator and the General Manager’s cell

phones. The camera and recorded video can be accessed remotely. Although it is unlikely to

occur, Texas Decon will ensure that any waste deposited in an unauthorized area is removed

immediately and disposed of properly.

5.6.3 UNLOADING OF PROHIBITED WASTES - 30 TAC §326.75(h)(3)

The unloading of waste in unauthorized areas is prohibited. Texas Decon will ensure that any

waste deposited in an unauthorized area is removed immediately and disposed of properly.


5.7.0 RECORDING OF APPLICABLE ALTERNATIVE HOURS – 30 TAC §326.75(i)(3)

Texas Decon does not expect that alternative operating hours will be required to accommodate

special occasions, special purpose events, holidays, or other special occurrences. If approval for

alternative operating hours is received in the future, the facility will record in the site operating

record, the dates, times, and duration when any alternative operating hours are utilized.


5.8.0 SIGNS AT FACILITY ENTRANCES – 30 TAC §326.75(j)

The facility sign will be conspicuously displayed at the entrance to the facility through which

wastes are received. It will measure at least four feet by four feet with letters at least three inches

in height stating:

a) Facility site name;

b) Facility type;

c) The hours and days of operation;

d) The authorization number; and

e) Facility rules.

The posting of erroneous or misleading information shall constitute a violation.


5.9.0 CONTROL OF WINDBLOWN MATERIAL AND LITTER – 30 TAC §326.75(k)

Medical waste unloading does not involve materials that are susceptible to becoming windblown

litter, so special litter control practices would not be suitable or effective at the site. All driveways

and other areas within the facility boundary, however, will be inspected daily for litter and other

debris and if present, will be collected to minimize unhealthy, unsafe or unsightly conditions.


5.10.0 FACILITY ACCESS ROADS – 30 TAC §326.75(l)

5.10.1 ALL WEATHER ACCESS ROADS - 30 TAC §326.75(l)(1)

A concrete paved and gravel road is provided to the unloading area located inside the building.

This unloading area inside the building will be used for wet-weather and dry weather operation.

The facility provides vehicle parking for equipment, employees and visitors on either a concrete

surface or a road base surface. Facility traffic will travel on the all-weather access surfaces and

should not track mud onto public roadways. If mud accumulates on the road from the site, it will

be removed by the end of the day.

5.10.2 DUST CONTROL - 30 TAC §326.75(l)(2)

Dust from on-site and other access roadways will not become a nuisance to surrounding areas.

No activities or traffic at the site should generate dust due to the type of road surface. However,

if necessary, water from a hose can be applied to control any dust.

5.10.3 ROAD MAINTENANCE - 30 TAC §326.75(l)(3)

The on-site access roads controlled by Texas Decon will be maintained to minimize depressions,

ruts, and potholes on a regular basis. If any maintenance is required for Dennis Drive, Texas

Decon will coordinate with the Guadalupe County Road and Bridge Department. If any

maintenance is required on State Highway 123 or FM 758, Texas Decon will coordinate with the

Texas Department of Transportation.


5.11.0 NOISE POLLUTION AND VISUAL SCREENING – 30 TAC §326.75(m)

Medical waste will typically only be unloaded inside the building or by truck to truck transfer, which

will minimize noise pollution and screen adverse visual impacts. Additionally, regulated medical

waste has strict DOT and TCEQ packaging requirements which provides for further screening of

waste from view.


5.12.0 OVERLOADING AND BREAKDOWN – 30 TAC §326.75(n)

5.12.1 FACILITY DESIGN CAPACITY - 30 TAC §326.75(n)(1)

The design capacity of the facility will not be exceeded during operation. If the facility receives

waste quantities that cannot be processed within a time frame to prevent the creation of odors,

insect breeding or vector harboring, additional waste will not be received until the problem

conditions are abated.

5.12.1.1 Untreated Waste Storage

As indicated in Section 4.2 of the application form, the maximum amount of waste to be stored at

any time is 10 tons during Phase I and 20 tons during Phase II. Each medical waste transport

box weighs an average of 40 pounds and occupies approximately 2 square feet. Medical waste

boxes can be stacked 4 high. For Phase I, 10 tons of stored medical waste will occupy

approximately 250 square feet of storage space. This calculation is shown below:

Number of boxes = 10 tons of waste X 2,000 lbs/ton X 1 box/40 lbs = 500 boxes

Area required for boxes (stacked 4 high) = 500 boxes X 2 ft2/box /4 = 250 ft2

For Phase II, 20 tons of stored medical waste will occupy approximately 500 square feet of storage

space. This calculation is shown below:

Number of boxes = 20 tons of waste X 2,000 lbs/ton X 1 box/40 lbs = 1,000 boxes

Area required for boxes (stacked 4 high) = 1,000 boxes X 2 ft2/box /4 = 500 ft2

For Phase I, the maximum available storage area in the 4,000 square foot building is 1,476 square

feet. After expending the building to 4,800 square feet for Phase II, the maximum available

storage capacity will be 1,500 square feet. Therefore, there is adequate storage capacity for both

phases.

5.12.1.2 Processing

The capacity of one OMW-400 Ozone Medical Waste Treatment System is 400 pounds/hour of

untreated waste. For a 12-hour day, one OMW-400 can process 4,800 pounds (2.4 tons) of waste


per day (equal to 400 pounds/hour X 12 hours). The average waste acceptance rate for Phase I

will be 2.5 tons per day with a minimum of 0.1 tons per day of waste (such as trace

chemotherapeutic and certain non-hazardous pharmaceuticals) on average being unloaded,

stored and eventually transferred without treatment to an authorized processing/disposal facility.

Therefore, the maximum amount of waste that will be processed by the OMW-400 for Phase I is

2.4 tons per day. Although the maximum amount of waste to be received daily during Phase I is

5 tons as described in Section 4.2 of this application, the average amount of waste to be received

daily during Phase I will be 2.5 tons.

Once a second OMW-400 is added, the maximum amount of waste that will be processed by

Texas Decon during Phase II will be 4.8 tons per day. Although the maximum amount of waste

to be received daily during Phase II is 10 tons as described in Section 4.2 of this application, the

average amount of waste to be received daily during Phase II will be 5 tons with a minimum of

0.2 tons per day of waste (such as trace chemotherapeutic and certain non-hazardous

pharmaceuticals) on average being unloaded, stored and eventually transferred without treatment

to an authorized processing/disposal facility.

5.12.1.3 Treated Waste Storage and Disposal

The density of untreated waste that will be processed by the OMW-400 is approximately 194

pounds per cubic yard. The OMW-400 shreds the waste during the treatment process. After

treatment by the OMW-400, the treated waste will be transferred to the self-contained compactor

for storage prior to transfer to a disposal facility. The shredding process is expected to reduce

the waste volume by 70%. Compaction ratios for waste compactors typically range from 3 to 1 to

6 to 1. For shredded medical waste, a compaction ratio of 4 to 1 should typically be achievable.

Therefore, the expected self-contained compactor storage volume consumed per day on average

is calculated as follows:

Phase I

Volume of treated waste from one OMW-400 = 2.4 tons of waste treated/day X 2,000

pounds/ton X 1 cubic yard/194 pounds X 0.30 = 7.4 cubic yards/day


Volume of compactor storage capacity consumed = 7.4 cubic yards/day x 0.25 = 1.85

cubic yards per day

Phase II

Volume of treated waste from two OMW-400s = 4.8 tons of waste treated/day X 2,000

pounds/ton X 1 cubic yard/194 pounds X 0.30 = 14.8 cubic yards/day

Volume of compacted storage capacity consumed = 14.8 cubic yards/day x 0.25 = 3.7

cubic yards per day

The capacity of the self-contained waste compactor will be 30 cubic yards. For Phase I, it will

take 16.1 days to consume the 30 cubic yards of storage capacity. For Phase II, it will take 8.1

days to consume the 30 cubic yards of storage capacity. However, Texas Decon will typically

transfer the contents of the self-contained compactor to a TCEQ permitted municipal solid waste

landfill at least once per week.

5.12.2 SIGNIFICANT WORK STOPPAGE - 30 TAC §326.75(n)(2)

If a significant work stoppage should occur at the facility due to a mechanical breakdown or other

causes, putrescible medical waste will be refrigerated so that the maximum 72-hour

unrefrigerated storage limitation is not exceeded. Refrigerated storage may occur in waste

storage units that include trucks or trailers that operate on electrical or self-contained refrigeration

systems. The refrigerated units will be locked and will maintain waste at a temperature of 45

degrees Fahrenheit or less. As mentioned in Section 5.2.0, a Texas Decon refrigerated truck and

a 28-foot refrigerated trailer rented from a local vendor will be used if there is an extended problem

with an OMW-400 and untreated putrescible or biohazardous material must be stored for longer

than 72 hours.

If the breakdown is anticipated to last long enough to create objectionable odors, insect breeding,

or harborage of vectors, the facility shall accordingly restrict the receipt of waste until repairs have

been performed and take steps to remove the accumulated solid waste to an approved processing

or disposal facility.


5.12.3 ALTERNATIVE PROCESSING OR DISPOSAL PROCEDURES - 30 TAC §326.75(n)(3)

If the facility becomes inoperable for periods longer than 24 hours, alternative processing or

disposal procedures will be implemented. These could include restricting the receipt of waste

until operations commence again, transferring putrescible waste to refrigerated storage units, and

diverting or transporting waste to an approved processing or disposal facility.


5.13.0 SANITATION – 30 TAC §326.75(o)

5.13.1 POTABLE WATER AND SANITARY FACILITIES - 30 TAC §326.75(o)(1)

Potable water and sanitary facilities are provided for all employees and visitors. There is a

restroom facility serviced by a septic system. Potable water is supplied by a water well.

Additionally, drinking water is provided by a commercial entity that supplies five-gallon containers

to the facility.

5.13.2 WASH DOWN OF WORKING SURFACES - 30 TAC §326.75(o)(2)

All working surfaces that come into contact with wastes will be mopped on a weekly basis at the

completion of processing.

5.13.3 WASH WATERS - 30 TAC §326.75(o)(3)&(4)

Wash waters shall not be allowed to accumulate on site without proper treatment with disinfectant

or bleach to prevent the creation of odors or an attraction to vectors. Mopping of working surfaces

is not expected to generate a significant quantity of wash water. Any water generated that may

have come into contact with waste will be absorbed. The absorbent will then be treated in the

medical waste processing unit.


5.14.0 VENTILATION AND AIR POLLUTION CONTROL – 30 TAC §326.75(p)

If applicable, all facilities and air pollution abatement devices will obtain authorization, under

Texas Health and Safety Code (THSC), Chapter 382 (Texas Clean Air Act) and Chapter 106 or

116 of this title (relating to Permits by Rule; and Control of Air Pollution by Permits for New

Construction or Modification), from the Air Permits Division prior to the commencement of

construction, except as authorized in THSC, §382.004. Additionally, all facilities and air pollution

abatement devices will operate in compliance with all applicable air related rules including

Chapter 101 of this title (relating to General Air Quality Rules) related to prevention of nuisance

odors, minimizing maintenance, startup and shutdown emissions, and emission event reporting

and recordkeeping.


5.15.0 HEALTH AND SAFETY – 30 TAC §326.75(q)

Prior to initiating operations, safety procedures will be developed and adapted for the facility, and

training will be provided for all employees. All the activities will be overseen by the

Owner/Operator to ensure the safety of all persons on the site. At least one of the operators or

the Owner/Operator will have a solid waste facility supervisor license in accordance with TCEQ

requirements.

Facility personnel must successfully complete a program of classroom instruction or on-the-job

training that teaches them to perform their duties in a way that ensures the facility's compliance

and their safety. This training will be performed before an individual is qualified to inspect

incoming loads.

At minimum, the training program will ensure that personnel are able to respond effectively to

emergencies by familiarizing them with emergency procedures, emergency equipment, and

emergency systems, including:

a) procedures for using, inspecting, repairing, and replacing facility emergency

equipment;

b) response to fires; and

c) shutdown of operations.

Topics for training may include:

a) all aspects of the operation of the facility;

b) waste acceptance procedures and recordkeeping;

c) fire protection, prevention, and evacuation;

d) fire extinguisher use;

e) emergency response;

f) hazardous waste and PCB waste detection and control; and

g) characteristics and appearance of accepted wastes and unauthorized wastes.


5.16.0 DISPOSAL OF TREATED MEDICAL WASTE – 30 TAC §326.75(r)

Wastes will be treated in accordance with 25 TAC 1.136 using an “approved alternate treatment

process” that consists of an Ozone Medical Waste Treatment Technology that has been approved

by the Texas Department of State Health Services (TDSHS). Refer to Appendix 1 to this Section

5.0 document for a copy of the approval from the TDSHS.

Medical wastes that have been treated in accordance with the provisions of 25 TAC §1.136 may

be managed as routine municipal solid waste unless otherwise specified in 30 TAC §326.75(r).

Treated microbiological waste, blood, blood products, body fluids, laboratory specimens of blood

and tissue, and animal bedding may be disposed of in a permitted landfill. As part of the treatment

process, the waste will be shredded inside the OMW-400. Therefore, the waste will be

unrecognizable and it will not be necessary to cover any markings that identify the waste as a

medical waste or to identify the waste as treated.

Treated carcasses and body parts of animals designated as a medical waste may, after treatment,

be disposed of in a permitted landfill in accordance with Chapter 330 of this title. The collection

and transportation of these wastes shall conform to the applicable local ordinance or rule, if such

ordinance or rule is more stringent than this subsection.

Treated recognizable human body parts, tissues, and organs shall not be disposed of in a

municipal solid waste landfill. These items shall be disposed of in accordance with the provisions

of 25 TAC §1.136(a)(4). As part of the approved alternate treatment process, the waste will be

shredded inside the OMW-400. Therefore, these items will be unrecognizable after treatment

and may then be deposited in a municipal solid waste landfill as allowed by 25 TAC §1.136(a)(4).

As part of the approved alternate treatment process, sharps will be treated and shredded inside

the OMW-400. Therefore, the sharps will be rendered unrecognizable and no longer capable of

causing puncture wounds. As allowed by 25 TAC §1.136(a)(5), the sharps will be disposed of in

a municipal solid waste landfill. Unused sharps shall be disposed of as treated sharps.


5.17.0 FINANCIAL ASSURANCE – 30 TAC §326.71(n)

A copy of the documentation required to demonstrate financial assurance as specified in Chapter

37, Subchapter R of 30 TAC (relating to Financial Assurance for Municipal Solid Waste Facilities)

will be submitted at least 60 days prior to the initial receipt of waste. Continuous financial

assurance coverage for closure will be provided until all requirements of the final closure plan

have been completed and the facility is determined to be closed in writing by the TCEQ executive

director.


5.18.0 CERTIFICATION OF FINAL CLOSURE – 30 TAC §326.71(l)

5.18.1 PUBLIC NOTICE - 30 TAC §326.71(l)(1)

No later than 90 days prior to the initiation of a final facility closure, Texas Decon, shall, through

a public notice in the newspaper(s) of largest circulation in the vicinity of the facility, provide public

notice for final facility closure. This notice shall provide the name, address, and physical location

of the facility, the registration number, and the last date of intended receipt of waste. Texas Decon

shall also make available an adequate number of copies of the approved final closure plan for

public access and review. The facility will also provide a written notice to the TCEQ Executive

Director of the intent to close the facility and will place this notice in the operating record.

5.18.2 SIGNS AND BARRIERS - 30 TAC §326.71(l)(2)

Upon notification to the TCEQ Executive Director, Texas Decon will post a minimum of one sign

at the main entrance and all other frequently used points of access for the facility notifying all

persons who may utilize the facility or site of the date of closing for the entire facility or site and

the prohibition against further receipt of waste materials after the stated date. Suitable barriers

shall be installed at all gates or access points to adequately prevent the unauthorized dumping of

solid waste at the closed facility.

5.18.3 PROFESSIONAL ENGINEER CERTIFICATION - 30 TAC §326.71(l)(3)

Within ten days after completion of final closure activities for the facility, Texas Decon shall submit

to the TCEQ executive director by registered mail:

A. A certification, signed by an independent licensed professional engineer, verifying that

final facility closure has been completed in accordance with the approved closure plan.

The submittal to the executive director shall include all applicable documentation

necessary for certification of final facility closure; and

B. A request for voluntary revocation of the facility registration.

TEXAS DECON\FINAL\19022.01. REVISION 1 R191126_SECTION 5.DOCX NOVEMBER 26, 2019

APPENDIX 1

TEXAS DEPARTMENT OF STATE HEALTH SERVICES ALTERNATIVE WASTE TREAMENT TECHNOLOGY APPROVAL



ENCLOSURE 3

ATTACHMENT 2 REVISED (FACILITY ACCESS AND FACILITY LAYOUT MAP)



ENCLOSURE 4

APPLICANT CERTIFICATION AND SIGNATURE PAGE


Documents

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