6303_MooreCoHHW_PermitMod_App_Fid1457239_20200929

From:David Lambert
To:Chao, Ming-tai
Cc:Hammonds, Andrew; Powell, David C; Stanley, Sherri
Subject:RE: [External] Re: 6303-HHW-2020 Initial Inspection 2020
Date:Tuesday, September 29, 2020 10:18:49 AM
Attachments:image001.pngimage002.pngimage003.pngimage004.pngimage005.pngimage006.pngimage007.png2020 Moore County Contingency Plan.docx2020 Moore County HHW Operational Plan.docx
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Ming-

Please see the revised operational and contingency plans. They are revised to reflect the changes
the previous revisions before permit issuance—(that I did not have copies of) and also the specific
changes we discussed. These changes include the outdoor storage area, addition of acidic and basic
cleaners, contact information, and the frequency of pick-up for material. The frequency includes a
formulation as discussed with Ms. Stanley and would require a pick up upon reaching 20 pallets in
the outdoor area. This was determined by the capacity of the storage area. This will account for
variations in the amount and type of waste received throughout the year. Again, the assumption is
that we will have a pickup quarterly, but it might allow us a few extra weeks in slower collection
times and more frequency pick ups in busier times.

For context--We had a scheduled pick up in August and we have another scheduled for this
Thursday. Last year we had five pickups total—exceeding quarterly frequency standard—but they
were sporadic and the interval between pick ups was 4 months (instead of 3) for one of the pick-ups.
This standard will better account for those differences.

Best,

David
From: David Lambert
Sent: Wednesday, September 2, 2020 1:52 PM
To: Chao, Ming-tai <[e-mail]>
Cc: Hammonds, Andrew <[e-mail]>; Powell, David C
<[e-mail]>; Stanley, Sherri <[e-mail]>
Subject: RE: [External] Re: 6303-HHW-2020 Initial Inspection 2020

Thank you for catching that. I got the digital copies from our consultant and they must have sent me
the wrong version. They did not have the updated version so I have spliced it together on a new
document.

Please see the attached operational plan updated from the July version. I already submitted the
drawing in the earlier email. Thank you!

Best,

From: Chao, Ming-tai <[e-mail]>
Sent: Friday, August 28, 2020 10:51 PM
To: David Lambert <[e-mail]>
Cc: Hammonds, Andrew <[e-mail]>; Powell, David C
<[e-mail]>; Stanley, Sherri <[e-mail]>
Subject: RE: [External] Re: 6303-HHW-2020 Initial Inspection 2020

Dear Mr. Lambert:
The Solid Waste Section (SWS) found out the submitted documents – Operational Plan andContingency Plan dated May 01, 2019, which are not the currently approved version dated
07/05/2019.
After completing a review processes in May 2019, the SWS made comments on the 05/2019plans and requested additional information which were incorporated into the plans dated
07/05/2019. The approved application is attached to this e-mail message. Please use thecurrently approved documents as the basis to make modification to the plans. Thank you for
your corporation on this matter.

From: David Lambert <[e-mail]>
Sent: Monday, August 24, 2020 11:24 AM
To: Chao, Ming-tai <[e-mail]>
Cc: Hammonds, Andrew <[e-mail]>; Powell, David C
<[e-mail]>; Stanley, Sherri <[e-mail]>; Scott Peele
<[e-mail]>
Subject: RE: [External] Re: 6303-HHW-2020 Initial Inspection 2020

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Sherry and Ming,

Thank you for your conversation the other day. I have attached the 2020 Operations Plan
(describing the paint storage area), allowing acid/alkaline cleaners to be accepted, and a drawing
showing the area (as requested). I think we wanted to remove confusing language in the permit
about aerosols. We are allowed to take aerosols in the operations plan, but there is a discrepancy in
one area of the permit.

Please let me know if there are any other questions.

Best,

From: David Lambert
Sent: Thursday, August 20, 2020 10:47 AM
To: Chao, Ming-tai <[e-mail]>
Cc: Hammonds, Andrew <[e-mail]>; Powell, David C
<[e-mail]>; Stanley, Sherri <[e-mail]>; Scott Peele
<[e-mail]>
Subject: RE: [External] Re: 6303-HHW-2020 Initial Inspection 2020

Ming,

Thank you for your response. The shelter we propose would be similar to an open air carport. (See
email attached about the timing of these discussions) Also, the dimensions of the carport are listed
on the attached quote. (The only thing different on the original quote is the fact that the prices
went up from last year ) The Open Air carport would cover the entirety of the fenced in outdoor
space—which is pretty small (two small dog lot fences combined). The paint/materials are stored on
pallets—not on grade with the ground. I was aware that there are no rules for HHW on federal/state
levels—which made me wonder which rules would apply. Our wastes are picked up quarterly at this
point—Usually no more than 4 months stored on site before pick up.

I look forward to chating with you all tomorrow.

From: Chao, Ming-tai <[e-mail]>
Sent: Thursday, August 20, 2020 10:27 AM
To: David Lambert <[e-mail]>
Cc: Hammonds, Andrew <[e-mail]>; Powell, David C
<[e-mail]>; Stanley, Sherri <[e-mail]>
Subject: RE: [External] Re: 6303-HHW-2020 Initial Inspection 2020

Dear Mr. Lambert:
According to e-mail messages cc to me, I would assume the shed will be used as a cover or a
house the collected paints at the above-referenced HHW site. I would like to provide you
several concerns prior to ordering the “shed.”
1. Is this a temporary or permanent structure? what the shed looks like? A tool shed,
canopy? A building permit may or may not be required, and you have to confirm the
requirement from the local government – the city, the town or the county. Because the
waste storage period is up to one year, can it resist any storm event including hurricane
from blowing away/collapse or from rain water coming into contact the stored wastes
from the sides? If not, how are you going to handle the potential problem?
2. The secondary containment system. The definition of the system can be found in 40
CFR Part 264. The NC Solid Waste Rule 15A NCAC 13B .0101(24) defines “leachate”
as any liquid, including any suspended components in liquid, that has percolated
through or drained from solid waste. Any leachate must be collected and treated before
discharged according to a permit. If the “shed” can stop rainwater/stormwater to contact
any stored wastes, it servers the purpose of preventing rain water (from the sky) to
contact wastes. But the wastes are stored on the grade without any impermeable barrier
to prevent any spillage from contacting environment media – soil, sheet flow/run-in
(surface water). You might want to consider the potential leachate treatment/disposal or
assessment/correction activities due to a waste spill incident.
3. The dimensions of the “shed” should be compatible with the amount of stored HHW;
otherwise, you may have to increase the waste pickup frequency and reduce the storage
duration. I would think the shelves may be required to properly stack up/store the
paints.
4. Ventilation.
There is no HHW law or rule at both federal or state levels. Moore County is absolutely
responsible for operating the facility for collection, storage, treatment, and/or disposal ofHHW.

From: David Lambert <[e-mail]>
Sent: Thursday, August 20, 2020 9:27 AM
To: Powell, David C <[e-mail]>; Stanley, Sherri <[e-mail]>;
Chao, Ming-tai <[e-mail]>
Cc: Hammonds, Andrew <[e-mail]>
Subject: RE: [External] Re: 6303-HHW-2020 Initial Inspection 2020

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@Stanley, Sherri & @Chao, Ming-tai

I have ordered a shed to cover the outside portion of the collection site at Eagle Springs. Would it be
permissible to install as we work on these changes to the permit?

From: Powell, David C <[e-mail]>
Sent: Thursday, August 20, 2020 9:13 AM
To: David Lambert <[e-mail]>; Stanley, Sherri <[e-mail]>;
Chao, Ming-tai <[e-mail]>
Cc: Hammonds, Andrew <[e-mail]>
Subject: RE: [External] Re: 6303-HHW-2020 Initial Inspection 2020

I gotcha….always have permitting approval and documentation on everything. Always before you
act or change something as well on any permitted operation.

Thanks,

From: David Lambert [mailto:[e-mail]]
Sent: Thursday, August 20, 2020 8:50 AM
To: Powell, David C <[e-mail]>; Stanley, Sherri <[e-mail]>;
Chao, Ming-tai <[e-mail]>
Cc: Hammonds, Andrew <[e-mail]>
Subject: RE: [External] Re: 6303-HHW-2020 Initial Inspection 2020

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attachment to [e-mail]

Ok, just wanted to make sure I had all the information I could get. #6 Said “Additional secondary
containment will be necessary if this area is approved for additional storage” which made me think
that you were wanting something outside of what would be approved in the permitting process.
Our HHW consultant and I were just seeking more clarification, if available, since this is something a
little different than their other sites.

Thank you.

From: Powell, David C <[e-mail]>
Sent: Thursday, August 20, 2020 8:36 AM
To: David Lambert <[e-mail]>; Stanley, Sherri <[e-mail]>;
Chao, Ming-tai <[e-mail]>
Cc: Hammonds, Andrew <[e-mail]>
Subject: RE: [External] Re: 6303-HHW-2020 Initial Inspection 2020

Well its really not for me as an inspector to say what you should get or do exactly….that’s what you
need a consultant for, I just inspect according to permit, rules and what we see in field at your site.
Its up to you, the permittee, to decide how to address and fix. Wish could be more helpful but we
have to be careful on saying “you need to buy this or install this” etc. Secondary containment is just
a good idea and backup in case there I an issue. With the material being stored outside in barrels,
what would happen if these had a leak or became punctured etc….that’s what that modified cargo
container is for but not being used for the material outside. So if you got just a roof over the
material and that was approved by permitting you still need something to catch any leaks, spill or
accidents so its just not on ground. So consultant a permit and permitting on your ideas /plans to
see if that route has potential.

Thanks,

From: David Lambert [mailto:[e-mail]]
Sent: Thursday, August 20, 2020 8:23 AM
To: Powell, David C <[e-mail]>; Stanley, Sherri <[e-mail]>;
Chao, Ming-tai <[e-mail]>
Cc: Hammonds, Andrew <[e-mail]>
Subject: RE: [External] Re: 6303-HHW-2020 Initial Inspection 2020

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attachment to [e-mail]

David,

I spoke with EcoFlo and we will be working on some of these things. I had a couple of questions:

#6 What sort of secondary containment would be looking for? EcoFlo has around 20 of these
facilities with outside fencing but, from my understanding, none of them have secondary
containment for the paint materials. I think EcoFlo works around 20 facilities including facilities in
Charlotte, Durham, etc. We just want and idea of what you might be looking for in terms of the
outdoor collection facility.

#9 The contact information was already submitted to permitting (see attachment from February)
The book did not have that single sheet changed out—It is updated now. We will be working with
Permitting to get the other items taken care of.

#10 We absolutely will be putting origination dates on the stickers. We trained on this yesterday.
However, just to clarify- we had no instances where materials were actually there beyond the
permitted time. We can fix the dateing of stickers to ensure this will never be a problem as well—
but wanted to make sure that it was clear that our materials were collected regularly.

@Chao, Ming-tai @Stanley, Sherri—When would be a good time for us to communicate on the next
steps and expectations for changes in the permit? I could set up a Teams Meeting or something to
discuss.

Best,

David Lambert
From: David Lambert <[e-mail]>
Sent: Wednesday, August 19, 2020 9:11 PM
To: Powell, David C <[e-mail]>
Cc: Stanley, Sherri <[e-mail]>; Chao, Ming-tai <[e-mail]>;
Hammonds, Andrew <[e-mail]>
Subject: Re: [External] Re: 6303-HHW-2020 Initial Inspection 2020

Thank you. I think we will just work on making sure the site is fully permitted first and foremost. At
this point we will not taking those cleaners but they would be a good product to start taking for
citizens. Will reach out to the permitting team soon.

David A. Lambert, J.D., M.P.A
Solid Waste Manager
Post Office Box 1927
Carthage, NC 28327-1927
P: 910.947.3637| C: 910.986.5005
F:910.947.1992
www.moorecountync.gov/public-works/solid-waste

E-mail correspondence to and from this address may be subject to the North Carolina Public Records
Law and may be disclosed to third parties.
From: Powell, David C <[e-mail]>
Sent: Wednesday, August 19, 2020 9:02:23 PM
To: David Lambert <[e-mail]>
Cc: Stanley, Sherri <[e-mail]>; Chao, Ming-tai <[e-mail]>;
Hammonds, Andrew <[e-mail]>
Subject: RE: [External] Re: 6303-HHW-2020 Initial Inspection 2020

OK sounds good. Thanks for informing and please do reach out to them in fixing the paperwork
side. I am unsure what the possibilities of having acid cleaners being approved for disposal at your
site if that’s is indeed an need you have. Either way if I can assist you know I will do what I can.

Thanks,

From: David Lambert [mailto:[e-mail]]
Sent: Wednesday, August 19, 2020 7:15 PM
To: Powell, David C <[e-mail]>
Cc: Stanley, Sherri <[e-mail]>; Chao, Ming-tai <[e-mail]>;
Hammonds, Andrew <[e-mail]>
Subject: [External] Re: 6303-HHW-2020 Initial Inspection 2020

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attachment to [e-mail]
David, your timing is excellent. We had a training today with eight staff in attendance. We
discuss these issues, and the acid cleaners, in particular. tThis was a misunderstandingbetween echo flow and the employees at the site. EcoFlo collects this material at other
facilities And staff communication with the drivers led to excepting these materialsinappropriately. This has stopped.
We have addressed the date of origin issues. I have also ordered a shed for the outdoor area. I
will contact Ming and Sherry regarding permitting options.
Thanks!
David A. Lambert, J.D., M.P.ASolid Waste Manager
Post Office Box 1927Carthage, NC 28327-1927
P: 910.947.3637| C: 910.986.5005F:910.947.1992
www.moorecountync.gov/public-works/solid-waste
E-mail correspondence to and from this address may be subject to the North Carolina PublicRecords Law and may be disclosed to third parties.
From: Powell, David C <[e-mail]>
Sent: Wednesday, August 19, 2020 6:51:08 PM
To: David Lambert <[e-mail]>
Cc: Stanley, Sherri <[e-mail]>; Chao, Ming-tai <[e-mail]>;
Hammonds, Andrew <[e-mail]>
Subject: 6303-HHW-2020 Initial Inspection 2020

Hello,

Here is the link to your inspection. Please be sure to print and review and keep a copy in your
records. There are some corrective actions that are necessary so please read carefully. Acid
cleaners are an unapproved waste being accepted at this facility. Please cease accepting of this
waste. There are some other documents that need updating and resubmitting as well. Permitting
can assist with these issues.

HHW Inspection 2020

Thanks,

MOORE COUNTY HHW
OPERATIONAL PLAN
Revised 09/29/2020
This Operational Plan contains general procedures for the safe operation of the Moore County Household Hazardous Waste Collection Center.

Moore County Operattional Plan Page 1 Revised 9/29/2020
Introduction The Moore County Household Hazardous waste (HHW) Collection center is intended to
serve Moore County residents. It is located at 364 Eagle Springs Road, Eagle Springs,
NC 27242. The facility will only accept residential HHW and will not accept any wastes from other industrial generationers (e.g. very small quantity generators). Any wastes brought to the collection center from households outside of the county will be considered for acceptance on a case-by-case basis based on County guidance. County
personnel will conduct a brief survey with each resident dropping material off at the
Collection Center and may also check for proof of residency. The survey is designed to determine the types, quantities, and sources of delivered waste. Site Description

As shown on Figure 1, the site is located just south of NC Highway 211, and is largely surrounded by sparse commercial and residential development, agricultural, and undeveloped land. The nearest surface water body appears to be located adjacent to the northwest property boundary based on National Wetlands Inventory mapping (see
Facility Plan).
As shown on the site detail in Figure 2, the site is largely situated on pavement, with some gravel north of the municipal waste collection containers. There are no sumps, drains, sewers, or ditches on the property. Based on information from County
personnel, surficial flow is generally to the northwest in the waste receiving area. The
frontage of the property facing the road access is fenced with a gate, which is secured during non-operating hours. Additionally, many HHW materials are stored under roof and the structure is loced when not in use. The adjacent storage area for empty consolidation containers is secured with a fence.

Ingress to the facility is on Eagle Springs Road from the easternmost access with egress traffic through the westernmost access to Eagle Springs Road. The HHW materials are collected and temporarily stored under cover on the paved area (labelled as HHW Collection Center on Figure 2) onto rolling utility carts, until they are picked up
by the contractor for disposal. The operating areas for the HHW are located greater
than 50 feet from the property boundaries and there are no other structures on site. Hours of Operation:
The HHW facility normal operating hours are every Saturday from 7:00am to 7:00pm.
Facility Staffing: County personnel will be on site at all times during collection of HHW materials. The
contractor (currently ECOFLO) will schedule pick-ups after each waste event as
needed, deepening on the type and amount of waste received. The collection frequency will be at least quarterly and waste will be transported to a permitted Treatment Storage
Moore County Operattional Plan Page 2 Revised 9/29/2020
and Disposal Facility (TSDF) by the County’s contractor. The contractor will be responsible for training their employees on the appropriate waste types collected. County personnel will inspect the area where waste is temporarily stored until each
pick-up and make correct any issues (e.g., leaking containers) as described below and
perform maintenance as needed for the storage area. The storage area will be inspected during each collection event, and records kept as part of the facility files. County Staff Training:

County Staff who will be operating the facility during HHW hours will receive training appropriate for the materials to be collected. Training will include the following items:
• Waste screening and identification of acceptable and unacceptable wastes
• Waste handling segregation, packing/labeling/marking, and storage
• Use of personal protective equipment (PPE)
• Unstable waste signs
• Waste moving/handling equipment
• Waste transfer (e.g., consolidation)
Screening and Collection of Wastes Residents will drive onto the paved receiving apron where the HHW can be safely removed from the vehicle. The occupants of the vehicle will be asked to remain in the
vehicle by County personnel. If it is necessary to unlock the trunk for waste removal,
County personnel will request the keys and accomplish this task. County personnel will visually check the waste prior to removing it from the vehicle. Only acceptable HHW will be removed from the vehicle. Unacceptable material will not be removed and will remain in the vehicle.

Most HHW can be identified and classified by visually inspecting the materials labeling, container type and condition, physical characteristics, and survey comments and responses. County personnel will conduct inspections, label each waste type and initial accumulation date, and maintain records of materials collected. Materials will be
manifested as appropriate by the contractor prior to transport off-site.
County personnel will maintain safe operations by immediately responding to any leaking or damaged containers and every effort will be made to identify those items that are leaking or susceptible to leaking prior to removal from the vehicle. Rolling utility
carts with containment trays will be utilized as the primary method of moving containers
from the vehicle to the segregation and packaging area. In addition, overpack containers will be available if leaking drums are discovered. Each cart is stored under cover to prevent rain from entering the carts util the pick-up occurs.
Acceptable Waste
The following categories of wastes are acceptable and will be collected from Moore County residents:
Moore County Operattional Plan Page 3 Revised 9/29/2020
1. Aerosols; 2. Fluorescent Lamps;
3. Latex & Oil Paint;
4. Pesticides; and 5. Paint Related Material. 6. Acidic or Alkaline Cleaners
Unacceptable Waste
The following categories of wastes will not be accepted and will not be collected from Moore County residents:
1. Radioactive wastes (Smoke Detectors);
2. Biologically active or infectious wastes and pharmaceuticals 3. Explosives and ammunition; 4. Unknown wastes; 5. Batteries (Lead Acid, Alkaline, NiCad, Lithium, etc.);
6. Cylinders (Propane, Helium, Oxygen, etc.);
7. Mercury (Thermometers, devices, etc.); 8. Non-Hazardous Solid and Liquids (Caulk, Putty, etc.); 9. Oil and Oil Filters; 10. Fire Extinguishers;
11. Fertilizers;
12. PCB-containing materials (e.g., light ballasts) 13. Asbestos wastes (friable or non-friable) 14. Light bulbs other than fluorescent bulbs.
Abandoned Materials
Should material be left outside of the secured facility outside of normal acceptance hours (i.e., abandoned outside the gate/fence), the County staff will be responsible for moving these materials to the appropriate secured area, if appropriate, or will contact
the contractor to remove them, if not included in the acceptable items as clarified below
as described in the Contingency Plan. Signage and education will be utilized to discourage the abandonment of materials at the Collection Center outside the hours of operation.
Personal Protective Equipment
Personal Protection Equipment (PPE) will be used as appropriate to protect personnel from spills, broken containers, and sharp objects. The following task-oriented PPE is required:

Removing HHW from Vehicles
Moore County Operattional Plan Page 4 Revised 9/29/2020
• Safety glasses with side shields;
• Chemical resistant inner gloves with leather outer gloves (optional); and
• Safety shoes/boots. Segregating HHW

• Safety glasses with side shields;
• Chemical-resistant inner gloves and leather outer gloves.
• Safety shoes/boots; and
• Chemical protective clothing;
Storage
The Collection Center consists of a storage building with an attached paved receiving apron and is designed and constructed to ensure safe and efficient operation and a covered outdoor collection area secured by a fence. As required for proper safety and
environmental protection, the storage building is:
1. Designed to contain leaks and spills; 2. Covered to exclude rain water; 3. Secured to control access; and
4. Constructed in accordance with all applicable National Fire Protection
Association (NFPA) codes. The outdoor area is secured with a locked chain link fence and is covered by a metal carport roof. Paint is stored on top of pallets and inside lined Ballard boxes. Theses
boxes are designed to contain leaks/spills, and the area is designed to exclude
rainwater and control access to the collection area. County personnel preparing wastes for storage will only use containers that are compatible with the wastes to be stored in them and will segregate incompatible wastes
as appropriate. Paint, paint-related materials, pesticides, and aerosols will be packaged
in cubic yard boxes or 55-gallon steel drums, with variable amounts of materials stored at any given time depending on the waste received. Fluorescent lamps will be packaged in fiber boxes and 5-gallon plastic pails. Oil and Latex paint cans will be palletized.
Any HHW that is not transported offsite will be stored in the permitted storage areas at
the County’s site with appropriate labeling. Contractor pick-ups must occur within a year of accumulation date. At no point, however, should the outdoor storage area exceed twenty (20) pallets of waste. County staff must schedule a contractor pick up once twenty (20) pallets of waste are received in the outdoor storage area. As a general
practice, it is assumed that contractor pick-ups will occur on a quarterly basis, but the
this 20 pallet check point will better account for variations in the amount and type of waste received throughout the year. All applicable Federal, State and local regulations will be strictly followed. Safety concerns, space demands and County expense will also be taken into consideration.
Moore County Operattional Plan Page 5 Revised 9/29/2020
All containers holding accumulated HHW will be checked at least weekly to ensure that they haven’t been stored more than 365 days or other deadlines as defined by the
County. This will be verified by checking the initial accumulation date for each
container. These inspections, to be conducted by County personnel will be used to detect any leaks or deterioration caused by corrosion or other factors. Results of these inspections will be recorded. If a container holding HHW is found to be in poor condition or if it begins to leak, County personnel will either transfer the wastes from the defective
container to one that is in good condition or overpack the container in a suitable salvage
drum. County personnel will also ensure that containers are kept closed during storage, except when it is necessary to add or remove waste. Caution will be taken in the
movement of all containers to prevent them from being tipped over or punctured.
Furthermore, the containers will not be opened, handled, or stored in a manner which may rupture them or cause them to leak. Segregation and Packaging of Materials

As the HHW is received, County personnel will perform initial waste identification and segregation. County personnel will conduct or directly supervise the packaging, document preparation, and transportation of the HHW collected at the Collection Center.

All containers will be of the Department of Transportation (DOT) specification, type, and size most appropriate for the specific waste type and planned treatment or disposal method. Wastes will be packaged in fiber, plastic, or steel containers of open or closed-head types, in sizes ranging from 5-gallon pails to cubic yard boxes, to 55-gallon drums,
to cubic yard boxes.
Filled drums will be closed, labeled, and marked in accordance with DOT and Environmental Protection Agency (EPA) shipping requirements.
Regarding incompatible wastes, the following special provisions apply:
1. Incompatible wastes will not be placed in the same container; 2. HHW will only be placed in new, unused containers or in containers cleaned and reconditioned by a licensed manufacturer; and
3. A storage container holding HHW that is incompatible with any waste or other
materials stored near will be separated from them by containment structures such as built-up curbs or will have secondary containment such as drip pans constructed of steel or polyethylene.
As a rule, the handling and storage of all HHW (especially any that are ignitable,
reactive, or incompatible) will be conducted so that it does not:
Moore County Operattional Plan Page 6 Revised 9/29/2020
1. Generate extreme heat or pressure, fire of explosion, or violent reaction; 2. Produce uncontrolled toxic mists, fumes, dusts, or gases in enough quantities to threaten human health;
3. Produce uncontrolled flammable fumes or gases in enough quantities to pose a
risk of fire or explosions; 4. Damage the structural integrity of the waste container; or 5. Threaten human health or the environment.
The procedures to comply with these provisions depend upon:
1. Proper identification of waste materials as they are received; 2. Segregated storage according to compatibility; and 3. No commingling or bulking of incompatible hazard classes.
Provisions for Ignitable Wastes County personnel will use special precautions to protect ignitable wastes from sources of ignition. These wastes will be segregated from other wastes being stored in the
Collection Center. Ignitable waste will be protected from possible sources of ignition,
including but not limited to: open flames, hot surfaces, frictional or radiant heat, and spontaneous ignition (e.g., from heat-producing chemical reactions). Any tools used in areas containing ignitable wastes will be of a non-sparking type.

Policy will prohibit smoking or open flame within or near the storage building. “No Smoking” signs will be placed at the entrance to unloading and storage areas and will be conspicuously placed wherever there is a direct hazard from ignitable or reactive wastes.

Areas in which ignitable materials are stored will require the use of explosion-proof equipment and lighting. Proper grounding will be maintained to dissipate any accumulation of static charges generated by the movement of hazardous liquids in pouring or bulking operations.
Personnel Training County personnel will successfully complete a training program that teaches them to perform their duties in a way that ensures the Collection Center is operated in a manner
that protects the public from potential health and safety hazards. The program includes
the following: 1. The training program is taught by a person trained in HHW management procedures and includes instruction which teaches County personnel HHW
management procedures (including contingency plan implementation) relevant to
the positions in which they are employed. The program will include a review of the following protocols:
Moore County Operattional Plan Page 7 Revised 9/29/2020
a. Waste screening and identification of acceptable and unacceptable wastes b. Waste handling, segregation, packing, labeling, and storage.
c. Donning, use, and disposal of protective equipment (PPE)
d. Determination of unstable conditions of stored wastes e. Waste moving and handling and proper equipment f. Proper waste transfer for consolidation to condense storage space/volume.
2. The training program has been designed to ensure that County personnel are
able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment, and emergency systems, including where applicable:
a. Procedures for using, inspecting, repairing, and replacing emergency and
monitoring equipment; b. Communication or alarm systems; c. Response to fires or explosions; d. Response to discharges to the land surfaces; incidents; and
e. Shutdown of operations.
3. County personnel will successfully complete the program within six months after the date of their employment or assignment to the Collection Center. County personnel will not work in unsupervised positions until they have completed the
training. County personnel will take part in an annual review of the initial training.
Preparedness and Prevention The Collection Center will contain the necessary equipment for protecting County and
local government personnel. The Collection Center will also contain the equipment
needed to implement the contingency plan and the County Staff person will be equipped with an immediately available telephone from which emergency assistance can be summoned. Internal communications will be carried out by voice as the most practical method given the restricted size of the Collection Center. A hand-held, pressurized air
horn will also be available to signal an emergency.
Aisle space will be maintained to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of the Collection Center in an emergency.

Other equipment to be kept at the Collection Center will include portable ABC dry chemical and CO2 fire extinguishers, spill control equipment including clay and/or inert absorbents, pads, booms, shovels, brooms, containers, and various commercial decontamination solutions. These materials will be kept in the structure on site, or an
adjacent storage structure, and easily accessible. Arrangements with Local Authorities
Moore County Operattional Plan Page 8 Revised 9/29/2020
Moore County representatives will plan to familiarize local authorities with all pertinent aspects of the Collection Center and its operations. In Moore County, the primary
emergency authority is assigned to Moore County Emergency Management, with other
agencies in supporting roles. The responsible agency will therefore work with the Emergency Management office to ensure that all appropriate local authorities are properly prepared.
Emergencies
A contingency plan has been developed for the Collection Center with County contacts as well as emergency response phone numbers and the location of the closest hospital and emergency medical facility.

All Collection Center communications or alarm systems, fire protection, equipment, spill control equipment, and decontamination equipment will be maintained as necessary to ensure its presence and proper operation. Fire protection equipment will be tested according to manufacturer specifications. Results of all inspections will be recorded.
Recordkeeping The County will keep records for the main County offices at 1 Courthouse Square in Carthage NC for the life of the facility as part of the facility operating records. Records
may be kept electronically. The following will apply to facility records:
• They will be kept and furnished upon request of the NC Division of Waste Management (DWM) within a reasonable time frame
• Records will include the HHW permit upon issuance and all approved document issued by State or local government, as appropriate.
• Records will include waste tracking reports, recycling certifications, and records of treatment/disposal
• Any incident reports (See Appendix A, for example)
• Training Records of County Personnel
• Inspection Reports
• Emergency responding equipment inspections
• NC DWM inspections

Thorough and accurate records will be generated and maintained to ensure the accurate tracking of HHW including the following:
• Uniform Hazardous Waste Manifest; and
• Material Characterization Forms.
Transportation
Moore County Operattional Plan Page 9 Revised 9/29/2020
When the contractor arrives at the HHW Collection Center for a scheduled pickup, they will ensure that all containers are properly packaged, labeled, and manifested. The Contractor will then load the containers onto their vehicle and transport the waste to a
permitted facility for final treatment, recycling, or disposal.
The Contractor will be responsible for having an identification number issued by the NC DOT and USEPA. The Contractor will be responsible for the transporting vehicle will have the appropriate labels and placards. The Contractor’s driver and vehicle will meet
all applicable NC DOT requirements. The contractor will use Household Hazardous
Waste Generator Identification Number NCPH06319001 to ship materials to a permitted TSDF. Emergency phone numbers will be available to the driver in the event of incident during
transportation. 24-Hour emergency response contractors will be available for
immediate response to any hazardous material release during transportation.

MOORE COUNTY HHW
COLLECTION CENTER
CONTINGENCY PLAN
Revised 09/29/2020
This plan is designed to minimize hazards to human health and the environment from fires, explosions, or any unplanned, sudden or non-sudden release of hazardous constituents to air, soil, or surface water.

Page 1 of 6 Moore County Contingency Plan Revised 09/29/2020
Contingency Plan for the Moore County Household Hazardous Waste Collection Center
Site Information
Responsible Agency: Moore County Solid Waste 1 Courthouse Square P.O. Box 905
Carthage, NC 28327
Office: [phone] Collection Center Address: 364 Eagle Springs Road Eagle Springs, NC 27242
Office: [phone] Emergency Coordinators (listed in the order they should be contacted): Primary Contact: David Lambert
Solid Waste Director 1 Courthouse Square P.O. Box 905 Carthage, NC 28327 Office: [phone]
Secondary Contact: Jimmy Brown Collections Supervisor 5227 Hwy 15-501 P.O. Box 1927
Carthage, NC 28327 Office: [phone] Eagle Springs Fire Department: [phone]
First Health Moore Regional: [phone] NC Emergency Response: [phone] MC Emergency Management: Scot Brooks
Emergency Manager/Deputy Director [phone] Emergency Clean-up Contractor: A&D Environmental [phone]
National Spill Response Center: [phone] Online:www.nrc.usg.mil/apex/f?p=201:1:515423446630596
Page 2 of 6 Moore County Contingency Plan Revised 09/29/2020

Contingency Plan Purpose and Implementation This plan is designed to minimize hazards to human health and the environment from fires, explosions, or any unplanned, sudden or non-sudden release of hazardous
constituents to air, soil, or surface water. The provisions of this plan will be carried out immediately whenever there is an emergency at the Collection Center. Contingency Plan Contents
This plan contains emergency procedures for four types of incidents: spills, fires, explosions and non-project related disaster (as defined below).
Page 3 of 6 Moore County Contingency Plan Revised 09/29/2020
• A spill is an unintentional release of materials in a quantity that is enough to cause environmental or personal harm;
• A fire is the ignition or conflagration of either waste materials or paper and wood trash;
• An explosion is a sudden detonation of waste materials; and
• Non-project-related disasters include unlikely events such as tornadoes, earthquakes, floods, or bomb threats. Collection Center Staffing and Emergency Responsibilities

County personnel will operate the Moore County HHW Collection Center. In the event of an emergency, all appropriately trained personnel who are available will participate in the response as directed by the designated emergency coordinator.
Arrangements with Local Authorities
Moore County representatives will plan to familiarize local authorities will all pertinent aspects of the Collection Center and its operations. The Moore County primary emergency authority is assigned to Moore County Emergency Management, with other
agencies in supporting roles. The responsible agency will therefore work with this
Emergency Management office to ensure that all appropriate local authorities are properly prepared. Contingency Plan Revisions

This contingency plan will be kept at the Collection Center and will also be distributed to local authorities (as described above). The contingency plan will immediately be revised whenever:
1. The plan fails in an emergency;
2. There are significant changes in Collection Center design, construction, operation, or maintenance; 3. The list of emergency contacts is changed; or 4. The list of emergency equipment is changed.
Emergency Response Materials and Equipment A variety of emergency response materials and equipment will be kept at the Collection Center. These materials will include:

• Spill control equipment (described in a subsequent section);
• Fire extinguishers;
• Personal protective equipment
• Emergency eyewash station; and
• First aid kit.
Page 4 of 6 Moore County Contingency Plan Revised 09/29/2020
Designation of Emergency Coordinator At all times, there will be at least one Moore County representative either on the
Collection Center premises or on call with the responsibility for coordinating all
emergency response measures. This coordinator will be familiar with all aspects of the Collection Center’s contingency plan, all operations and activities at the Collection Center, location and characteristics of wastes to be handled, location of all Collection Center records, and Collection Center layout. In addition, this person will have the
authority to commit the resources needed to implement the contingency plan. The
emergency coordinator will coordinate all emergency response with the contractor’s Project Supervisor or designee and will supervise the implementation of emergency procedures described in the following sections of this plan.
Spill Response Equipment and Procedures
Normal spill prevention techniques will be used at the Collection Center, and standard spill control equipment will be available. This equipment will include the following:
• Absorbent boom or pillows;
• Containers for contaminated absorbent; and
• Non-sparking tools;
If a release occurs, the following procedures will be used: 1. The individual who notices the spill will alert other personnel by voice or three
blasts of an air horn;
2. All personnel will stop work and secure their areas of responsibility; 3. The emergency coordinator will direct all residents/ participants to a safe area if necessary; 4. The emergency coordinator will identify the character, exact source, amount and
real extent of any released materials. The coordinator will assess the possible
hazards to human health and the environment, considering both direct and indirect; 5. The emergency coordinator will determine the proper protective equipment (PPE) needed and will monitor for leaks, pressure buildup, gas generation, or ruptures
in equipment as appropriate;
6. If the release is serious enough to affect human health or the environment outside of the Collection Center, the emergency coordinator will immediately contact local authorities and will also notify the National Response Center, or the government official designated as the on-scene coordinator for the area. This
report will include: name and telephone number of the reporter, name, address,
and telephone number of the responsible agency; name, address, and telephone number of the Collection Center; date and time of the incident; type of incident; name and quantities of materials involved; extent of injuries; and possible hazards to human health and the environment;
Page 5 of 6 Moore County Contingency Plan Revised 09/29/2020
7. Personnel will be assigned to control the spill and prevent its spread or other complications. If necessary, personnel can be assigned to isolate storm drains and sewers. Personnel will don their protective equipment and take appropriate
steps for cleaning up the spill. Any incompatible materials located near the spill
will be removed. A fire watch will be established, and the local fire department will be notified. Reasonable measures will be taken to ensure that the problem does not recur or spread to other wastes; 8. If the emergency coordinator determines that outside assistance is needed, then
appropriate calls will be made using the emergency phone list;
9. Once the spill is contained and cleaned up, any response equipment used will be decontaminated, inspected, and put back in service when returned to an acceptable condition; 10. Immediately after an emergency, the emergency coordinator will provide for
treating, storing, or disposing of recovered waste, contaminated soil or surface
water, or any other material that results from a release, fire, or explosion at the Collection Center; 11. The affected areas of the Collection Center will not be placed in operation again until the responsible agency listed at the beginning of this plan has notified the
appropriate authorities that the Collection Center is once again functional; and
12. The responsible agency will make a report of the incident in the operating record and will also notify the NCDEQ’s Division of Solid Waste Management within 24 hours. A written report will be filed with the Division within 15 days, and it should include all the information in item 5 above, plus the estimated quantity and
disposition of recovered material from the incident.
Fire/Explosion Response Procedures Emergency procedures to be used in the event of a fire or explosion are as follows:

1. The individual who notices the fire or explosion will alert other personnel by voice or a long blast (at least 10 seconds) of an air horn; 2. All personnel will stop work and secure their areas or responsibility; 3. The emergency coordinator will alert the local fire department and will move
public participants to a secure location;
4. Personnel will be assigned to contain and halt the fire unless an explosion is possible (in which case the emergency coordinator will call for evacuation). If the fire is chemical in nature or spreads to the chemical waste, personnel will don positive pressure self-contained breathing apparatus. Personnel will fight the fire
using fire extinguishers and/or soil and absorbents. Water will generally not be
used if the fire is due to the ignition of a flammable liquid; 5. If the fire goes beyond the incipient stage and cannot be controlled with extinguishers, the emergency coordinator will notify appropriate authorities and prepare to evacuate the work area. Personnel will assist local responders when
necessary. Such assistance may include: helping to evacuate residents;
blocking off storm drains and berming water sources; removing all unnecessary personnel and vehicles from the area; and removing waste material if possible;
Page 6 of 6 Moore County Contingency Plan Revised 09/29/2020
6. If the fire or explosion is serious enough to affect human health or the environment outside of the Collection Center, the emergency coordinator will immediately contact local authorities and will also notify the National Response
Center, or the government official designated as the on-scene coordinator for the
area. This report will include: name and telephone number of the reporter, name, address, and telephone number of the responsible agency; name, address, and telephone number of the Collection Center; date and time of the incident; type of incident; name and quantities of materials involved; extent of
injuries; and possible hazards to human health and the environment;
7. Once the fire has been extinguished, cleanup of the area will commence. During cleanup activities, the emergency coordinator will monitor for leaks, pressure buildup, gas generation, or ruptures in equipment as appropriate. If the fire was chemical in origin or spread to the waste area, all potentially contaminated
cleanup materials will be disposed of as waste; and
8. Further response to a fire will proceed according to steps 8 through 11 described under the preceding spill response section of this contingency plan. Procedures for Non-Project Related Disasters

In the unlikely event of disasters such as floods, tornadoes, earthquakes, and bomb threats, the following procedures will be used: 1. The individual who notices the situation will alert other personnel by voice or a
long blast of an air horn;
2. All personnel will stop work and secure their areas of responsibility; 3. The emergency coordinator will alert the appropriate authorities and move personnel to a secure location. The affected area will be secured to prevent access; and
4. If necessary, further procedures will be determined and implemented as
appropriate given the specific nature of the emergency. Evacuation Plans
Whenever there is an emergency incident at the Collection Center, the emergency
coordinator will decide if evacuation is necessary. In making this decision, the emergency coordinator will consider various factors, including the following:
• Potential for the fire and/or explosion to intensify or spread;
• Potential for release of toxic fumes; and
• Quantity of released material.

Page 7 of 6 Moore County Contingency Plan Revised 09/29/2020
If evacuation of the Collection Center is necessary, personnel will be immediately notified by an air horn. The following procedures will then be implemented:
1. All personnel will leave the Collection Center as quickly as possible through the
nearest exit and proceed directly to a designated assembly area at a safe distance from the Collection Center. All site personnel will be accounted for. If any personnel are missing, attempts to find them will not involve endangering the lives of others. No personnel or vehicles will be allowed to reenter the Collection
Center unless specifically authorized by the emergency coordinator. Normally,
the only persons allowed to reenter will be emergency response personnel; 2. After the emergency is over, reentry will not be allowed until the emergency coordinator has determined that the Collection Center is safe and has given appropriate notification to personnel; and
3. Drills will periodically be held to practice these evacuation procedures and will be
treated with the same seriousness as an actual emergency.