HomeMy WebLinkAboutCorrespondence Miscellaneous 4/1/2000
'U. 6831346
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TRANSMITI'ALDA1E: April 1, 2000
FR: WilliamC. carpenter Jr.
TO: 1118. Sar'ah summers/ 1'Ir. Greg Mott
OF: Springfield Utility Bd.
PHONE NUMBER: 726-3753'
FAX NUMBER: 7215-3689
CARPENTR/GOLD-SL
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l"A~: OIfLY [1\X]
VAX AND VIRST CLAS~ KAIL ( )
FAX l\IW OVWRRIGHT MIUL [ ]
TOTAL ~.. O~ P&QB8 (1~a1u4i~9 tbi. p.qe) I 3
MEMO:
Absent Public Hearinq 'l'"stimony for' 4/3/00 On Drinkinq WIlter
Protection Overlay ordinance
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RECEIVED
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-a 6831346
CARPENTR/GOLD-SL
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. April I, 2000
Springfield City Council- via Ms. Sarah Summers
225 5'" Srreet
Sprln81lcld, Oregon
Re: Additional Public Hearing Testimony On Drinking Water Overlay District S'olely to Address .
Issues Raised by Chrome World, 'l'hrough Poynters inc,
Via Fax
Dear Council Members:
This testimony supplements my earlier testimony given in the March 6th public hearing.
Unfortunately, 1 am currently in Washington D',C, siningoil a working group formed by the
National Drinking Water Advisory Council. Ironically, the working group is determining
procedures that .will allow EP A to evaluate potential future drinking water contaminams using
scientifically defensible methods.
Mr, Poynter raises three issues critical of the proposed protection program, The initial issue is
that the ordinance will have serious impacts on Chrome World's presenllllld furore po~slble .
operations, including possible sellout. This results from its location and its hazardous "~bemical
'use, The second is thAt the ordinance is too lax on itS regulation of retllil 01.ltlets. And finally, that . .
a blllllket exclusion should exist for businesses with environmental settsitive iPId safe pr~tices.
Ail to the first issue, Chrome Wodd doe not disclose what chemicals of concern it uses, causing
restrii;:tive regulation, but because the plant is located on a one year lime of Ira vel zone ooulldlu'y,
it can be surmised that it is an extensive user of the most polluting of all the gtoundwater .
chemicals. the de!1se, non-aqueous, phase liquids ("DNAPLs"). . . .
In determining to restrict this most difficult of chemicals, DNAPLs, in the one year time of travel
. zone, the Citizen Advisory Commitl~, which members Included engineers frO!'lll~al in4uSlry, as
well as myself, detennined that such restrictive controls were necessary because of the rllpid, .
extensive and prolonged dalIlllges these chemicals cause to drinking water supplies. Theile
c~emicals types often migrate and pocket themselves in t~ less active parts of the aquiF'*s,
making treatment and i;:ontainmentvirtually impossible. However, because of their high mobility
and solubility, they simultaneously disperse themselvell, polluting the aquifer ili very short order
and for a very long time. Exceptions for these type of chemicals in the one year zone, because of
the magnitude of their impacts on drinking water supplier even to the extent of disabling a single
. or multiple drinkittg water wells, should not be included in the ordinance,
It should be noted that the Overlay District requirements were revised once to insure that no type
of business would be prohibited, but rather the ordinance was used to regulate chemicals
determined harmfUl to the public resource of the drinking water aquifers. The iSSlle of rostrictive
controls on DNAPL use in the' one year time of travel was discussed extensively at al11evels ofthe
process. "Further, because the boundaries for time oftrsvel zones are not precise, the ordinai1ce
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allows any impacted business to prove scientifically that the boundary is inaccurate and .thus have
the time of travel zone modified to a longer. time of travel, thus resulting in less restrictions. .
Next, Mr. Poynter raises the issue that the ordinance is too lax on sale of other kinds of chemicals
which may have some effect on the aquiter. W. Poynter overlooks TWO Important poims when
criticizing this portion of the ordinance. First, the containers in which these small volume
chemicals are packaged in undergo extensive procluct design to ensure the leakproof nature of
them is high, Second: the types of chemicals sold at theseretailoutlets, because of genenll health
and safety Considerations, do not pose the risk of DNAPLs or other high concentration industrial
strength products, Mr. Poynter again fail8 to name any specific "loophole" retail chemicals.
Finally, and most importantly, Mr. Poynter argues fora blanket grandfathering clause where
"exemplary" businesses, whatever that means, would be allowed to operate and expand without
regulation, even in the one yeM tilt)e Of travel zones. Such a vague clause, coupled with the broad
definition of"excmp1ary'''woulcl make it impossible to impiement the exemption with any
consistent standards. Every business owner believes their business is exemplary. Also, it takes
only one event, even from a diligent company, to cause 'catastrophic, long term, groundwater
pollution disaster. The operating r~ord of a company with orily seven years experience is '
insufficient to use to judge I\J1Y kind ofri~1< reductiol1 to allow for an exemption. Furthllr, the
information that Chrome World provides concerns its air pollution compliance program. But,
many industries may have certain control systems for one environmental media that actulllly create.
additional pollution lIIld risks for other environmental media..
I wholly agree that all of us value our natural resources and wlsh to protect the environment. , But,
rather than attempt to dismantle k~ provi~jons ofthe proposed ordinance through'blanket
. exceptions, Chrome World should be revic;wing ways to further delineate its one year time of
travCl boundary lIIld test adequlItll substitutes. and production techniques for replacing its use of
DNAPLs at its faCility. The ordinance, as drafted, isa major step forward to ensure 10118 term
future protection of growth in Springfield by insuring safe drinking water and protecting the
health and property values of thll citizens of Springfield Thank You
~il1 Carpenter.Jg, (?
680 T .St,- Springfield
Memberofthll Citizen's Advisory Connrullee on Drinking Water COIIccrns
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