26FH_CumberlandCoHHW_finalPermitApplication_DIN28619_20171103

1
Chao, Ming-tai
From:Weispfenning, Aaron <[e-mail]>
Sent:Friday, November 03, 2017 3:10 PM
To:Chao, Ming-tai
Cc:Jerod Roberts
Subject:[External] RE: Comments on Cumberland County HHW Permit Renewal, 26FH, DIN
28171
Attachments:HHW Permit Application.pdf
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
[e-mail].

Ming,

The revised application is attached. Please see responses to your comments below in red.

Thanks and have a good weekend,
Aaron

Aaron M. Weispfenning, P.E. | Engineer | CDM Smith | 5400 Glenwood Avenue, Suite 400 Raleigh, NC 27612 | T: 919-325-3532 | F: 919-781-5730
| www.cdmsmith.com

From: Chao, Ming-tai [mailto:[e-mail]]
Sent: Wednesday, July 12, 2017 2:31 PM
To: Weispfenning, Aaron <[e-mail]>
Cc: [e-mail]; '[e-mail]' <[e-mail]>;
Hammonds, Andrew <[e-mail]>; Patrakis, William <[e-mail]>
Subject: Comments on Cumberland County HHW Permit Renewal, 26FH, DIN 28171

Hi Aaron:

The Solid Waste Section (SWS) completed a review of the permit amendment application (DIN 27975) for
Cumberland County Household Hazardous Waste (HHW) Collection Facility, Permit Number 26FH-
HHW. The application was received on 06/16/2017. After reviewing the document, the SWS has several
comments on the application which are stated below:

- (Operational Plan - Facility Staffing on Page 1 of 15) ECOFLO is the current contractor for bulking,
over-packing, transporting and disposal/recycling of the collected HHW. Please provide a copy of the
contact agreement between Cumberland County and ECOFLO, Inc. Note added to page 1 and contract
(valid through June 30, 2019) is provided in Appendix E

- (Operational Plan – Hospital on Page 14 of 15) The rout to the designated hospital is shown on Figure
3, please make the reference to the section. Reference added

The SWS currently allows the NC HHW Collection Facility to collect and temporarily store permitted
hazardous waste from conditionally exempt small quantity generators (CESQGs) as defined in 40 CFR 261.5.
However, hazardous waste (s) that collected from a CESQG shall be accounted for and reported separately from the
HHW. A copy of the report shall be sent annually to the Hazardous Waste Section of the NCDEQ Division of Waste
Management. If Cumberland County intends to use the facility to collect hazardous waste (s) from a CESQG (s)
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within the county’s service area – Cumberland County, please add the waste management approaches to the revised
permit application. It is advised that the County may need to discuss this new business with ECOFLO, should the
changes result in increasing waste quantity or other concerns and consequently amending the existing contract deem
necessary. Hazardous waste from CESQGs will not be temporarily stored at the County’s HHW Facility.

Please contact me if you have any questions on the comment. Have a wonderful day.

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

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.

5400 Glenwood Ave, Suite 400
Raleigh, North Carolina 27612
tel: [phone]
fax: [phone]

June 16, 2017

Mr. Ming Chao
North Carolina Department of Environment and Natural Resources
Division of Waste Management
Solid Waste Section
1646 Mail Service Center
Raleigh, North Carolina 27699-1646

Subject: Cumberland County Solid Waste Management
Permanent Household Hazardous Waste Collection Facility
Permit No. 26-FH-HHW
Permit Renewal Application

Dear Mr. Chao:
On behalf of Cumberland County, CDM Smith Inc. is pleased to submit one copy of the Cumberland
County Permanent Household Hazardous Waste Collection Facility permit renewal application and
updated operational, contingency, and closure plans.
If you have any questions regarding this application, please call me at [phone].
Sincerely,

Aaron M. Weispfenning, P.E.
CDM Smith Inc.

cc: Jerod Roberts, Cumberland County

Cumberland County
Solid Waste Management
Household Hazardous Waste
Collection Facility
Permit Renewal for
Permit No. 26-FH-HHW
Operational, Contingency &
Closure Plans
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OPERATIONAL PLAN
This plan describes the normal operating procedures for the permanent Cumberland County
Household Hazardous Waste (HHW) Collection Facility. Additional procedures for emergency
situations are contained in the Contingency Plan.
Throughout this plan, the Cumberland County Household Hazardous Waste Collection Facility is
referred to as the “HHW Collection Facility”, personnel from the waste transportation and disposal
contractor are referred to as "contractor personnel" and operators of the facility are referred to as
“County personnel.”
The HHW Collection Facility was established to more effectively manage household hazardous
waste for residents of Cumberland County (County) and to help prevent improper disposal; it
involves a program of HHW collection, source reduction, and public education. The facility is
maintained and operated to promote personnel safety and to minimize the possibility of a fire,
explosion, or any unplanned release of hazardous waste or hazardous waste constituents to air,
soil, surface or ground water which could threaten human health or the environment. The
appropriate provisions and procedures necessary to ensure safe and efficient operations are stated
in this plan.
The HHW Collection Facility is located at 923 Wilkes Road, Fayetteville, NC 28306 as shown on
Figure 1. The property deed for the facility is provided in Appendix A. HHW accepted at the facility
includes oil/latex paint, motor oil & oil filters, anti-freeze, pesticides & herbicides, cleaners, acids,
gas & diesel fuel, batteries, solvents, mercury (thermometer, thermostat), pool chemicals,
photography chemicals, other oxidizers, and brake & transmission fluid. Waste not accepted at the
facility includes flares, PCB’s, explosives, butane gas cylinders, ammunition, infectious waste,
fireworks, household garbage, and yard waste.
FACILITY STAFFING
The HHW Collection Facility is operated and staffed by county personnel and when available a
temporary employee will assist. Because of accident and liability concerns, temporary employee
responsibilities are limited to controlling traffic, conducting surveys, interaction with customers,
and providing general assistance, such as emptying trash and running errands. County personnel
are responsible for the identification, collection, and placement of waste into appropriate areas for
temporary storage. A contractor is used for bulking, over-packing, transporting and
disposal/recycling of the collected HHW. The current contractor is EcoFlo (see Appendix E).
PERSONNEL AND DUTIES
The HHW Collection Facility is staffed by trained, qualified County personnel under the direct
supervision of the Solid Waste Director. Positions with responsibilities at the HHW Collection
Facility are described below.
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The Solid Waste Director directs onsite operational efforts. This individual has primary responsibility
for:
• assuring that onsite County and contractor personnel have met the training
requirements appropriate for their duties;
• assuring that County and contractor personnel are aware of the provisions of the
Contingency Plan;
• assuring that onsite County and contractor personnel are aware of the potential hazards
associated with site operations;
• correcting any work practices or conditions that may result in injury or exposure to
hazardous substances; and
• notifying the Safety Officer and NCDEQ of any incident or accident.
The Safety Officer is responsible for:
• preparing any accident/incident reports;
• verifying that County and contractor personnel work in a safe manner;
• ensuring that any necessary equipment is properly maintained and in good operating
order; and
• establishing guidelines for and assuring that appropriate personal protective equipment
is available and that County personnel have been instructed in their proper use and
decontamination (if necessary).
County Personnel (On-Site Operators) are responsible for:
• opening the site and securing the site at the end of each day the facility is open;
• the safe removal of acceptable materials from vehicles;
• the initial identification and segregation of materials;
• proper storage of materials for pick up by the contractor;
• directing traffic, conducting surveys, determining user eligibility, and distributing
educational materials;
• inspections of equipment, containers, buildings, and fire extinguishers;
• immediately reporting any unusual or unsafe conditions to the Solid Waste Director; and
• implementing the Contingency Plan in case of emergency.

HOURS OF OPERATION
The HHW Collection Facility is open the
second and fourth Saturday of each
month from 8 a.m. until 4 p.m. If there is
a need to adjust the days per month or
extend these hours to better match user
demand, NCDEQ Solid Waste Section will
be notified in writing.
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ACCESS CONTROL AND SECURITY
Access to the facility is controlled by two locked gates to prevent unnecessary public exposure to
potential harmful substances. The first gate is located at the top of the hill with the second gate
located at the facility entrance. The facility is surrounded by a six-foot-high chain link fence topped
with barb-wire. A warning sign “DANGER – Unauthorized Personnel Keep Out” is posted on the
entrance gate. Areas where chemicals are handled or stored are clearly marked using caution signs.
The signs contain appropriate warnings such as "No Smoking," and "Authorized Personnel Only." All
buildings containing hazardous materials have locked doors and placards indicating the type of
waste stored in the building. Night security is provided by lights that are automatically activated at
sundown. Two personnel are on-site at all times the facility is open.
TRAINING
The Solid Waste Director is responsible for ensuring that County personnel assigned to the HHW
Collection Facility are properly trained to the hazards associated with the job that they will be
performing. Upon hire, County personnel will:
• attend a mandatory 40-hour HAZWOPER course with an 8-hour refresher course
annually thereafter;
• be trained on the proper day-to-day operation of the HHW facility (completing forms,
proper handling/placement of waste in buildings/tanks, labeling/marking of waste,
record-keeping, semi-weekly inspections, Contingency Plan implementation, etc.);
• receive specific training from the Safety Officer in the use of fire extinguishers,
emergency equipment, general safe work practices, accident prevention, personal
protective equipment (PPE), spill management, and what to do in case of a fire or other
emergency.
The contractor is responsible for training all contractor personnel. Both the County’s and the
contractor's training programs are designed to enable appropriately trained personnel to receive
and handle wastes in a safe, environmentally sound manner and to work in compliance with
applicable regulations.
County personnel assigned to the facility do not work in unsupervised positions until they have
received appropriate training. As required, complete training records are kept at the facility;
training records for contractor personnel are kept at the contractor's office.
STORAGE BUILDING SPECIFICATIONS
The HHW Collection Facility is designed and constructed to ensure safe and efficient operation. The
facility consists of a storage building with fire suppression system containing three separate areas
divided by walls for flammable, corrosive, and oxidizer storage, a building for paint, a building for
pesticides, a covered anti-freeze tank, a covered motor oil tank, a covered receiving/unloading area,
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a storage building for supplies, an eye wash building, and a small trailer used as an office.
Additional details of the facility structure are provided on Figure 2.
According to state guidance concerning storage of ignitable and reactive wastes, the storage
structure is required to be located at least 50 feet from the facility's property line. The location of
the ignitable and reactive waste storage unit relative to other site structures is shown on the site
map (Figure 1). As required for proper safety and environmental protection, the structure is: 1)
designed to contain leaks and spills; 2) covered to exclude rainwater; 3) secured to control access;
and 4) constructed in accordance with all applicable National Fire Protection Association codes.
Fire extinguishers are located on the left inside of all site buildings except for the flammable,
corrosive, oxidizer storage building which has a fire suppression system.
Mercury thermostats, thermometers, and TV bulbs are placed in a pail with a lid which is placed in a
secondary hard plastic cube that is appropriately labeled and stored in the pesticide building.
All buildings containing hazardous waste have signs/placards indicating the type of waste stored
inside.
EMERGENCY EQUIPMENT, PERSONAL PROTECTION EQUIPMENT AND FIRST AID
The HHW Collection Facility has the necessary equipment for protecting contractor and County
personnel and implementation of the Contingency Plan. The facility has a telephone for use in the
event of an emergency. The most practical method of internal communications, due to the size of
the facility, is voice.
Other equipment kept at the facility includes portable ABC dry chemical and carbon dioxide fire
extinguishers, spill control equipment including absorbents, pads, brooms, shovels, containers, and
various commercial decontamination solutions.
All facility communication, fire protection equipment, spill control equipment, and decontamination
equipment/supplies are inspected the 2nd and 4th Saturday of each month and maintained as
necessary to ensure its presence and proper operation in case of emergency. Fire protection
equipment is tested according to manufacturer specifications. Results of all inspections are
recorded on a checklist that includes inspection dates and a list of all systems/equipment inspected
and is kept on file at the facility. A copy of the check sheet and inspection log are provided in
Appendix B.
PPE is used as appropriate to protect contractor and County personnel from spills, broken
containers, and sharp objects. The level of PPE required for particular tasks is described below:
• Persons Removing/Segregating Waste from Vehicles:
safety glasses;
white tyvek with vinyl apron;
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chemical-resistant safety shoes/boots;
nitrile gloves or chemical-resistant inner glove and puncture-resistant outer glove.
• Persons Opening Containers and Bulking Waste:
white tyvek with vinyl apron or chemical-resistant coveralls;
safety glasses;
polyurethane or other chemical-resistant safety boots;
respirator with organic vapor cartridge and high-efficiency particulate air filter, if
required;
nitrile gloves or chemical-resistant inner glove and outer puncture-resistant glove.
• Persons Sampling HHW
full-face shield and safety glasses;
chemical-resistant coveralls;
chemical-resistant safety shoes/boots;
respirator, if required;
chemical-resistant inner glove and outer puncture-resistant glove.
• Persons Lab Packing HHW
safety glasses;
white Tyvek with vinyl apron or chemical resistant coveralls;
chemical-resistant safety boots;
respirator, if required;
chemical-resistant inner glove and puncture-resistant outer glove.
(Note: Contractor or County personnel handling or moving drums may require metatarsal safety shoes. Regular
safety shoes may be substituted for chemical-resistant safety shoes when no chemical exposure hazard exists.)
First aid kits are available and on-site at all times. In case of an injury, local emergency services will
be notified. There is an eye wash/shower station located next to the pesticide storage building for
use in emergencies which is inspected each day the facility is open.
The evacuation plan including directions to Cape Fear Valley Medical Center is provided on Figure 3
and is posted in the on-site office.
USER ELIGIBILITY
The HHW Collection Facility is intended to serve the residents who live within Cumberland County
and its municipalities.
Only HHW is accepted at the HHW Collection Facility. Businesses needing to dispose of hazardous
wastes are referred to vendors who offer programs for picking up wastes at business locations.
When the HHW Collection Facility is open, County personnel check all vehicles entering the facility
for proof of residency and have the resident complete a Material Inventory Sheet. The Material
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Inventory Sheet is designed to keep track of the type, quantity, weight, and source of each user's
waste. A copy of the material inventory sheet is provided in Appendix C.
SCREENING AND COLLECTION OF WASTES
There is one entrance and exit at the HHW Collection Facility as shown on the site map (Figure 1).
County personnel direct the flow of traffic to ensure safe and efficient operations. The vehicle at
the front of the line is directed to drive into the receiving/unloading area, where wastes are
checked and can be safely removed from the vehicle. Occupants of the vehicle are asked to remain
in the vehicle. If it is necessary to unlock the trunk for removal of wastes, County personnel request
the keys and accomplish this task. County personnel immediately deal with any leaking, damaged,
unlabeled, or potentially shock sensitive or explosive materials by informing the vehicle operator
and attending to the problem in the appropriate manner.
County personnel also provide educational materials that include information on less hazardous
alternative products and other HHW topics. The public education effort at this facility informs users
that the collection facility is designed to handle HHW from the following general categories: 1) yard
and garden products (herbicides, pesticides, etc.); 2) automotive products; 3) paints and solvents; 4)
household cleaning products; and 5) miscellaneous HHW. In the event that a citizen brings
unacceptable wastes to the facility, they are told why the waste is unacceptable and given a HHW
Contractor list with additional information concerning options for proper disposal.
WASTE IDENTIFICATION AND PACKAGING
As the wastes are collected, County personnel perform initial waste identification and segregation.
Some materials that can be managed by County personnel (such as latex paint, motor oil, other
automotive fluids, anti-freeze, oil filters, and batteries) are segregated from the hazardous wastes
at this time and handled according to policy.
· Latex paint is poured into a 55-gal drum which is then pumped into a 500-gal tank that is
labeled with “Latex Paint” on both sides. Oil based paint is poured into a 5-gal bucket and
then poured into a 55-gal drum located in the paint building, which is picked-up and
disposed of by the contractor. Empty paint cans are placed into a 20-yard container box
that is located in front of the pouring area. The 20-yard container box is tarped when not in
use to prevent rainwater accumulation within the box.
· Used motor oil and anti-freeze containers are opened and then poured into the appropriate
500-gal tank. The 500-gal tanks are located within concrete secondary containment areas
which have signs with the appropriate wording “Used Oil” or “Used Anti-freeze”, depending
on the containment area. Empty containers are then placed in the 20-yard container box for
disposal.
· Used oil filters are placed in a 55-gal drum located in the secondary containment area with
the anti-freeze tank.
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· The 20-yard container box is picked up and taken to the landfill for disposal prior to the next
opening of the facility.
County personnel conduct the collection, storage, and document preparation of hazardous wastes
collected at the facility. Records are kept on wastes brought in, and these records contain
information on the types, quantities and weight, their origin, and the operator handling the waste.
A copy of the building inventory sheet is provided in Appendix D.
If bulking of wastes is required, contractor personnel will accomplish these tasks on the date of
pick-up. For both lab pack and bulk packaging, all containers used will be Department of
Transportation (DOT) specification, type, and size most appropriate for the specific waste type and
planned treatment or disposal method. Wastes will be packed in either fiber, plastic, or steel
containers of open or closed-head types, in sizes ranging from 5-gallon pails to one cubic yard
boxes.
Whether lab pack or bulk, the filled drums will be closed, labeled, and marked in accordance with
DOT and Environmental Protection Agency shipping requirements, and the proper information will
be recorded on the manifest. The generator's notification and certification will also be prepared, as
required under the land-ban regulations if applicable. Copies of all forms received from contractor,
for each pick-up, are retained in the Administration Office located at the Ann Street Landfill. The
HHW Collection Facility’s North Carolina Generator Identification Number (ID) NCPH0269201 shall
be used to ship wastes off site for recycling, treatment, and/or disposal.
If hazardous waste is left at the HHW Collection Facility outside of normal operating hours, a Solid
Waste Environmental Enforcement Inspector will take waste into the receiving/unloading area,
segregate, label, weigh, complete a Material Inventory Sheet and place waste in the appropriate
building or tank. If waste is unacceptable, appropriate measures will be taken to ensure safe
storage or disposal of the waste.
ACCUMULATION TIME
The storage buildings at the HHW Collection Facility are designed to accommodate temporary
accumulation of several classes of hazardous materials brought in from households. In accordance
with state requirements for temporary storage, the date the waste was brought in is clearly marked
and visible on each container using a HHW label (below).

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Additionally, a complete inventory log of materials (Appendix D) is kept on-site for each building or
area containing hazardous waste. Furthermore, while being stored on-site, all containers are clearly
labeled with the words, "Hazardous Waste," unless the material is recyclable (e.g. used oil, latex
paints, batteries) and is separated from other hazardous waste.
Time in storage may vary according to the volume of waste received. Removal of wastes by the
contractor is scheduled as necessary to minimize expense to the local government while still
complying with applicable regulations and safety considerations. Wastes are not stored longer than
180 days, with a pick-up normally scheduled at least once per quarter to remain in compliance with
the permit.
PROVISIONS FOR IGNITABLE, REACTIVE, OR INCOMPATIBLE WASTES
County and contractor personnel use special precautions to protect ignitable or reactive wastes
from sources of ignition or reaction. These wastes are separated from other wastes being stored in
the HHW Collection Facility. Any ignitable or reactive wastes are protected from possible sources of
ignition or reaction, 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 for
equipment maintenance in areas containing ignitable wastes are of a non-sparking type.
Maintenance activities such as welding or cutting, which potentially could generate sparks or open
flame, is allowed only by special permission of the Cumberland County Solid Waste Management
Director. Permission will be granted only after the area has been inspected and tested for
flammable vapors, and all ignitable or reactive materials have been removed or protected. Policy
prohibits smoking or open flame within or near the storage building. "No Smoking" signs are placed
at the entrance to unloading and storage areas and are placed wherever there is a direct hazard
from ignitable or reactive wastes. Areas in which ignitable materials are stored require the use of
explosion-proof equipment. Proper grounding is maintained in order to dissipate any accumulation
of static charges generated by the movement of hazardous liquids in pouring or bulking operations
by the contractor.
Regarding incompatible wastes, the following special provisions apply:
• incompatible wastes will not be placed in the same container;
• hazardous wastes will only be placed in new, unused containers or in containers cleaned
and reconditioned by a licensed manufacturer (and labeled as such);
• a storage container holding a hazardous waste that is Incompatible with any waste or
other materials stored in close proximity is separated from them by containment
structures such as drip pans constructed of steel or polyethylene.
As a general role, the handling and storage of all hazardous wastes (especially any that are ignitable,
reactive, or incompatible) will be conducted so that it does not:
• generate extreme heat or pressure, fire or explosion, or violent reaction;
• produce uncontrolled toxic mists, fumes, dusts, or gases in sufficient quantities to
threaten human health;
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• produce uncontrolled flammable fumes or gases in sufficient quantities to pose a risk of
fire or explosion;
• damage the structural integrity of the device or facility containing the wastes; or
• 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 compatible hazard class; and 3)
no co-mingling, bulking, or combining of incompatible hazard classes.
USE AND MANAGEMENT OF CONTAINERS
County personnel preparing wastes for storage use containers that are compatible with the wastes,
so that containment ability is not impaired. All containers holding accumulated HHW are checked
when the facility is open to ensure integrity and that they haven't been stored for more than 180
days. These inspections, conducted by County personnel, are used to detect any leaks or
deterioration caused by corrosion or other factors. Results of these inspections are recorded and
filed at the HHW Collection Facility (Appendix B). If a container holding hazardous waste is found to
be in poor condition or if it begins to leak, County personnel will transfer the wastes from the
defective container to one that is in good condition.
County personnel will also ensure that any containers holding hazardous waste are kept closed
during storage, except when necessary to add or remove waste. Caution is taken in the movement
of all containers to prevent them from being tipped over or punctured. Furthermore, the containers
are not opened, handled, or stored in a manner which may rupture them or cause them to leak.
Unobstructed aisle space is maintained, at all times, to allow movement of personnel, containers,
and emergency equipment within the storage buildings.
RECYCLING OF WASTE
HHW collected at this facility is recycled or treated whenever economically practical. The following
wastes are collected for recycling or BTU recovery: motor oil and other automotive fluids, lead-
acid/nickel-cadmium/lithium/dry-cell batteries, latex paint, fuels and solvents.
TRANSPORTATION AND DISPOSAL
When the transportation and disposal contractor arrives at the HHW collection facility for a
scheduled pickup, the contractor ensures that all containers are properly packaged, labeled,
documented, and manifested. Contractor personnel load the containers onto a contractor vehicle
and transport them to a licensed facility for final treatment, recycling, or disposal. Waste Disposal
Manifests are on file in the Administration Office located at the Ann Street Landfill.
REPORTING AND DOCUMENTATION
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Thorough records are maintained at the facility to ensure the accurate tracking of hazardous
materials from the generator to final disposal sites. Additional records generated to ensure
accurate record keeping include the following:
• Drum Tracking Sheet (contractor's in-house form);
• Uniform Hazardous Waste Manifest;
• Contractor's Material Profile Sheet (for wastes in bulk, 5 gallons or more);
• Waste Certification/Notification (to meet requirements of land-ban requirements if
applicable);
• TC Rule Certification/Re-certification (to meet the TCLP Rule requirements if applicable);
• Certificates of Disposal.
An annual report on household hazardous waste collected, disposed of, and recycled is sent to
NCDEQ and a copy is kept in the Administration Office located at the Ann Street Landfill.
Reports of inspections are kept on-site.
POLICY FOR DEALING WITH UNACCEPTABLE WASTE
Radioactive Waste – Smoke detectors are the most likely household waste to contain radioactivity.
Residents are advised to mail the used smoke detector back to the manufacturers if they are still in
business. If the company is no longer in business, then the Nuclear Regulatory Commission
recommends landfilling the smoke detector in a municipal solid waste landfill. Other household
wastes are unlikely to have any measurable radioactivity except statis eliminators from record
players which have a very short life. The Radiation Protection Office of the University of North
Carolina recommends landfilling these when they become unusable.
Explosives/Flares/Ammunition/Fireworks – If explosives are brought to the facility, the first step is
to immediately assess the possible danger and close the site if necessary until these materials are
removed. Cumberland County Sheriff's Office will handle any flares, fireworks, or small arms
ammunition brought in. For any military type explosives, the Sheriff's Office is contacted and they
will call the Explosives Division at Fort Bragg.
Infectious Waste – The HHW Collection Facility does not accept any medical waste. Residents are
instructed to take sharps, placed in rigid plastic containers, to the Ann Street landfill operations
area where they are placed into a barrel, which buried in the landfill when full.
Gas Cylinders – Residents are instructed to return the cylinders to place of purchase or if empty,
take them to the Ann Street Landfill for recycling.
Polychlorinated Biphenyls (PCBs) – PCBs as defined in 40 CFR 761 are not accepted at the HHW
Collection Facility.

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CONTINGENCY PLAN
RESPONSIBLE AGENCY

Cumberland County Solid Waste Management
698 Ann Street
Fayetteville, NC 28301
910-321-6920
FACILITY ADDRESS

Cumberland County Household Hazardous Waste Collection Facility
923 Wilkes Road
Fayetteville, NC 28306
910-433-0978
EMERGENCY COORDINATORS (LISTED IN THE ORDER THEY SHOULD BE CONTACTED)

Primary Contact:
Jerod Roberts
Solid Waste Director
910-321-6920 – work phone
757-535-2480 – cell

Secondary Contact:
Karen S Hall
Administrative Program Officer
910-321-6929 – work phone
910-308-6380 – work cell
910-257-7213 – cell

Additional Contacts:
Janice Daniel, Safety Officer
910-321-6914 – work phone
910-977-5392 – cell
910-424-5143 – home

PURPOSE AND IMPLEMENTATION
This plan is used for preplanning of potential emergencies such as spills, fires, explosions and
natural disasters. It is not anticipated that an emergency situation will occur. However, preplanning
is important to minimize the effects of an emergency during the handling of hazardous materials.
The provisions of this plan will be carried out immediately whenever there is an emergency at the
HHW Collection Facility. A map of the site is provided on Figure 1. County personnel have made
arrangements to familiarize local authorities with all pertinent aspects of the facility and its
operations. In Cumberland County, primary emergency authority is assigned to the Cumberland
County Emergency Management, with other agencies in supporting roles. The responsible agency
will therefore work with the Emergency Management office to ensure that local fire department,
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County Sheriff’s Office, Cape Fear Valley Medical Center, and other appropriate emergency
agencies are provided with a copy of the Cumberland County HHW Contingency and Operational
Plans. A copy of the Contingency Plan is available for site personnel in the facility office.
FACILITY STAFFING AND EMERGENCY RESPONSIBILITIES
The Cumberland County HHW Collection Facility is operated by County personnel and a private
company is contracted for the bulking, over-packing, transportation, and disposal/recycling of
materials. County personnel receive appropriate training prior to undertaking related tasks. In the
event of an emergency, all personnel who are available would participate in the response.
CONTINGENCY PLAN REVISIONS
The contingency plan will be revised whenever:
• the plan fails in an emergency;
• there are significant changes in facility design, construction, operation, or maintenance;
• the list of emergency contacts is changed; or
• the list of emergency equipment is changed.
EMERGENCY RESPONSE MATERIALS AND EQUIPMENT
A variety of emergency response materials and equipment is kept at the facility. These materials
include some or all of the following, as deemed necessary by the Solid Waste Director and
Emergency Management personnel for this facility: spill control equipment (described in a
subsequent section), decontamination solutions, fire extinguishers, PPE, emergency eyewash
station, and first aid kits. Fire extinguishers are located in all site buildings except for the flammable
building which is equipped with a fire suppression system. Spill kits are located in the pesticide
building. First aid kits are located in the unloading and office areas.
DESIGNATION OF EMERGENCY COORDINATOR
When the HHW Collection Facility is open County personnel have the responsibility of notifying 9-1-
1, Emergency Management, and the Solid Waste Director in the event of an emergency. The Solid
Waste Director is familiar with all aspects of the facility's Contingency Plan, all operations and
activities at the facility, characteristics of wastes handled, location of all facility records, and facility
layout. In addition, this person has the authority to commit the resources needed to implement the
Contingency Plan.
SPILL RESPONSE EQUIPMENT AND PROCEDURES
Normal spill prevention techniques will be used at the facility and standard spill control equipment
is available. This equipment includes some or all of the following: bulk absorbents such as oil-dry,
absorbent booms or pillows, containers for contaminated absorbent, decontamination products
and non-sparking tools. The Fayetteville Fire/Emergency Management Department Hazardous
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Material Team is currently assigned to Fire Station 1 at 607 Person Street and will be contacted via
9-1-1 in the event of a major spill.
INCIDENT PROCEDURES
In the event that an incident occurs, the following procedures will be used:
• The individual who notices the hazard incident will alert other personnel by voice.
• All personnel will stop work and secure their areas of responsibility.
• Residents in the area at the time of an incident will be evacuated.
• If the incident is a small spill, County personnel will don appropriate PPE and take the
appropriate steps for cleaning up the spill. If the incident is a small fire, County
personnel will don appropriate PPE and use site fire extinguishers to extinguish the fire
or use soil to smother the fire. Under no circumstances will water be used on a fire
involving flammable liquid as this can worsen the situation as the water spray may cause
spattering or allow the liquid to spread.
• If the spill or fire cannot be contained or put out, one on-site operator will call 9-1-1 and
the other on-site operator will evacuate the area.
• Once assembled at the designated area in the event of an incident, the on-site operator
that called 9-1-1 will notify Emergency Management. The other operator will notify the
Solid Waste Director. When making these calls the on-site operators will provide the
type of incident, name and quantities of materials involved, extent of injuries if any, and
possible hazards to human health and the environment.
• Personnel will secure the area and await emergency responders.
• If it is determined that a significant amount of waste escaped from the facility's
secondary containment structures, soil and or surface-water samples will be collected to
determine the extent of contamination. A remedial action plan will be developed and
submitted to the appropriate agency as necessary. All potentially contaminated cleanup
materials will be properly disposed of.
• Once the incident is contained and cleaned up, any equipment used will be
decontaminated, inspected, and put back in service when returned to an acceptable
condition.
• The affected areas of the facility will not be placed in operation again until the
responsible agency listed at the beginning of this plan has notified the appropriate
authorities, either the County’s Emergency Management Department, the Sheriff’s
Office, or the local NCDEQ Solid Waste Environmental Specialist, that the facility is once
again functional.
• The responsible agency will make a report of the incident in the operating record and
will also notify NCDEQ's Solid Waste Section within 24 hours. A written report will be
filed with the Solid Waste Section within 15 days and will include:
· Name, address, and telephone number of the facility operator,
· Date, time, and type of incident,
· Name and quantity of each type of HHW involved,
· The extent of injuries and property damages, if any,
· An assessment of actual or potential hazardous to human health or the
environment, when applicable,
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· Estimated quantity and disposition of recovered HHW resulting from the
incident, and
· Measures and actions taken to avoid or prevent repeating a similar incident
again in the future.
EVACUATION PLANS
Whenever there is an emergency incident at the facility the on-site operator will implement the
Contingency Plan and:
• All personnel will evacuate the facility as quickly as possible through the exit and
proceed directly to a designated assembly area at a safe distance from the facility. All
on-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 re-enter the facility unless specifically authorized by Emergency
Management. Normally, the only persons allowed to re-enter will be the emergency
response personnel. The designated assembly area is the primary gate located on Wilkes
Road as shown on the emergency evacuation map (Figure 3).
• After the emergency is over, re-entry will not be allowed until the County’s Emergency
Management Department has determined that the facility is safe and has given
appropriate notification to personnel.
HOSPITAL
The closest hospital to the facility is Cape Fear Valley Medical Center and is located at 1638 Owen
Drive, Fayetteville, NC. Directions and contact information for the hospital are summarized below.
· Turn right when leaving the site onto Wilkes Road
· Drive 1.3 miles and turn right onto Owen Drive
· Arrive at hospital on left in 2.8 miles.
o Total Distance: 4.3 miles
o Estimated Drive Time: 11 minutes
· Contact Number: 910-615-4000
The route from the facility to the hospital is provided on the evacuation plan (Figure 3) and is
posted in the office building.

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CLOSURE PLAN
PURPOSE AND IMPLEMENTATION
Once it is determined that a Permanent Household Hazardous Waste Collection Facility is no longer
needed for the residents of Cumberland County the facility will be closed.
Cumberland County Solid Waste Management will inform the NCDEQ Solid Waste Section of its
decision to close the HHW Collection facility in writing, 30 days prior to starting the planned closure
activities. This notification will provide a detailed schedule of each closure activity and will include
a final closure date so a site inspection can be made by a NCDEQ Solid Waste Section representative
to determine compliance with closure procedures.
All containers of hazardous waste will be picked-up by a certified Hazardous Waste Contractor, any
remaining equipment, structures, or buildings containing household hazardous waste residue will
be decontaminated or removed. Any waste or material that is decontaminated or removed shall be
disposed of in accordance with current regulations.

Figure 2

Figure 3

APPENDICES
Appendix A – Property Deed
Appendix B – HHW Check Sheet and Inspection Log
Appendix C – Material Inventory Sheet
Appendix D – Building Inventory Sheet
Appendix E – Contract between County and EcoFlo

APPENDIX A – PROPERTY DEED

APPENDIX B – HHW CHECK SHEET AND INSPECTION LOG

APPENDIX C – MATERIAL INVENTORY SHEET

APPENDIX D – BUILDING INVENTORY SHEET

APPENDIX E – CONTRACT BETWEEN COUNTY AND ECOFLO