Good afternoon,

My concerns in regards to the proposed regulations are as follows:

9VAC20-121-40 Applicability, Paragraph B.

The cost involved with re-permitting were in the $10,000-$20,000 range, just for the engineering firm to certify the facility, format and submit the application.  This is an extremely high cost for small medical waste transporters with a small transfer station.  The only change in our permit would seem to be the addition of radiation detectors.  This brings me to my next concern.

9VAC20-121-220 Design and construction requirements, Number 12.

Ludlum Radiation Monitoring Systems were running about $11,000.00 in 2020.  With inflation I am sure that price has climbed to close to $15,000.00.  Installation is not included in the cost but, would run at least another $5,000.00.  For transfer stations that only accept waste from customers, whose businesses they are familiar with, through transporter collection, radiation monitors seem like an unnecessary burden.  I could understand if the medical waste transfer station was accepting waste from haulers that were not associated with the transfer station.  

Another issue not addressed in the regulations is the difficulty in finding licensed operators.  Since the Board of Waste Management Facility Operators went to a closed book test, very few individuals have been able to pass the test, leaving a shortage of operators.  Many had hoped that the requirement for Medical Waste Transfer Station Operators, to be licensed, would be going away.  In most Medical Waste Transfer Stations containers are not even opened, just transferred from collection vehicles to long-haul trailers.  The license requirement, (as long as the Board of Waste Management Facility Operators continues to not allow open book tests) for Medical Waste Transfer Stations may end up being the reason transfer stations begin to close.

I appreciate the opportunity to voice our concerns and look forward to receiving the final rule.

Regards,

Curtis Knisley