RATIONALE FOR ISSUANCE
Trash Doctors LLC Medical Waste Processing Facility
Hancock County
Solid Waste SW0230050584
Date Application Received: December 19, 2017

I.	FACILITY INFORMATION

Facility Name:  	Trash Doctors LLC Medical Waste Processing Facility
Facility Owner:	Trash Doctors, LLC
Facility Address:	13233 Webre Road
Bay St. Louis, MS 39520
Permit No.:		SW0230050584
Permit Writer:		Ryan Case

II.	NATURE OF BUSINESS AND CURRENT CONDITIONS

Trash Doctors, LLC proposes to operate a new medical waste processing facility.  The facility will process infectious medical waste as defined by the Mississippi State Department of Health as well as other medical wastes from health care facilities and will process regulated Animal and Plant Health Inspection Service (APHIS) wastes as defined by Title 7 Code of Federal Regulations 330.400 – 330. 403 and Title 9 Code of Federal Regulations 94.5. The facility will utilize multiple autoclave units to process the waste through steam sterilization to render it non-infectious.  The processed waste will be transported to a permitted municipal solid waste landfill for disposal. 

III.	PROPOSED PERMITTING ACTION

Trash Doctors, LLC has submitted a solid waste permit application for an individual solid waste management permit to operate a new medical waste processing facility. MDEQ has developed a draft solid waste management permit based on our review of the application and supporting documentation provided by the applicant.  

IV.	LOCATION AND TOTAL PROPERTY AREA

The processing facility will be located in an enclosed building owned by Trash Doctors, LLC.  The property is located at 13233 Webre Road near Bay St. Louis, Mississippi in the Port Bienville Industrial Park in Section 30, Township 9S, Range 15W of Hancock County. The total property area consists of approximately 7 acres. The enclosed building is approximately 10,000 square feet. 

V.	LOCAL SOLID WASTE PLANNING AND ZONING INFORMATION

The proposed permit action is consistent with the Hancock County Solid Waste Management Plan. An amendment to the Hancock County plan was formally approved by the Hancock County Regional Solid Waste Management Authority on May 8, 2017. The revised plan was approved by MDEQ under Administrative Order No. 6837 18 issued on March 6, 2018 to include the proposed medical waste processing and APHIS waste processing facility to be owned and operated by Trash Doctors, LLC in Bay St. Louis, MS. Additionally, a letter from the Hancock County Building and Zoning Office dated February 7, 2017 states that the proposed facility meets all of the zoning requirements as outlined in the Hancock County Zoning Ordinance.

VI.	APPROVED SERVICE AREA

The Hancock County Solid Waste Management Plan describes the service area for the proposed solid waste processing facility as approved by the Hancock County Regional Solid Waste Management Authority. This approved service area for the facility includes the states of: Arkansas, Texas, Georgia, Mississippi, Louisiana, Alabama, and Florida.

VII.	DISCLOSURE STATEMENT

In accordance with State Law, the applicants filed a disclosure statement describing the company’s structure, key officers and members, other affiliated businesses, and any civil or criminal violations. The MDEQ Legal Division determined the disclosure statement for Trash Doctors, LLC to be complete on April 11, 2018.

VIII.	SITING CRITERIA

MDEQ’s review of the permit application indicates that the proposed processing facility meets all applicable siting criteria as required by the Mississippi Nonhazardous Solid Waste Management Regulations.  There are no variances to this siting criteria proposed for this facility.

IX.	WASTE ACCEPTANCE INFORMATION

A.	TYPE OF WASTE

Authorized wastes include infectious medical wastes, medical wastes, associated facility wastes, and regulated APHIS Waste. Infectious medical wastes include solid and liquid wastes that may contain pathogens of sufficient virulence and quantity that exposure by a susceptible host may result in an infectious disease. Medical wastes include wastes generated in direct patient care or in diagnostic or research areas that is non-infectious and non-hazardous but may be aesthetically repugnant if found in the environment.  Associated facility wastes include other small amounts of solid wastes derived indirectly from patient care, diagnostic, or research activities. Regulated APHIS Waste includes any waste regulated by APHIS as defined by Title 7 Code of Federal Regulations 330.400 – 330. 403 and Title 9 Code of Federal Regulations 94.5.
B.	 QUANTITY AND STORAGE CAPACITY

The designed throughput of the facility can handle approximately 136 tons of authorized waste a day for processing. The facility will maintain up to three commercial autoclave units. Two autoclaves measuring 6 feet x 30 feet can each handle 4,000 pounds per cycle while the third unit measuring 5 feet x 20 feet can handle 1,500 pounds per cycle. The complete cycle time from beginning to end will typically be forty-five (45) to fifty (50) minutes.  The facility will not allow accumulation of authorized waste or processed waste (each) more than the equivalent of the three-day throughput capacity of the processing system.

X.	BUILDING DETAILS

The treatment facility is enclosed within a 10,000 square foot building The application indicates that the enclosed building will house a waste unloading area, staging/storage areas, autoclave treatment area, cleaning equipment and shredder area.  The treated waste storage containers will be staged outside of the building.

XI.	PROCESSING SCHEDULE

APHIS wastes received on-site will be processed through the autoclave units within 72 hours of delivery to the facility.  Medical wastes received on-site will be processed through the units within 7 days of delivery to the facility. Any untreated medical waste that remains stored longer than 7 days will be stored in a refrigerated area or a refrigerated truck or trailer located in the unloading area. The refrigerated unit will maintain the stored waste at a temperature of 38 degrees Fahrenheit or less. The facility may conduct operations for maintenance and housekeeping, as needed 24 hours per day, seven days per week.

XII.	TREATMENT METHODOLOGY

The autoclave units will each be calibrated and undergo a quality assurance program to maintain compliance with the sterilization standards contained within the “ADOPTED STANDARDS FOR THE REGULATION OF MEDICAL WASTE” developed by the Mississippi State Department of Health as well as manufacturer standards for operation of the units. The treatment process will be as follows:

1.	Authorized wastes will be loaded for treatment into the autoclave system.
2.	A minimum temperature of 250oF is maintained for a minimum of 30 minutes inside the sterilization vessel.
3.	The treated waste is cooled and then compacted for transport and disposal at a permitted municipal solid waste landfill. The waste may potentially be sent through a shredder prior to compaction.

XIII.	OTHER REQUIRED ENVIRONMENTAL PERMITS

No other environmental permits appear to be necessary for the operation. Process waters resulting from the autoclave process and equipment wash will be collected and placed back into the processing unit or will be discharged directly to Port Bienville Industrial Park’s waste water treatment system via drain lines in the warehouse/building. MDEQ has determined that a pretreatment permit is not required at this time for the management of these process waters. In addition, there are no activities being conducted at the site that will require storm water management permit coverage. Also, the proposed operations do not trigger air emissions control permitting requirements.

XIV.	FACILITY CONTACT INFORMATION

Ms. Kelly Brouillette, Managing Partner
Trash Doctors, LLC
4400 Poche Ct. W.
New Orleans, LA 70129
(504) 222-2471