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HomeMy WebLinkAboutCorrespondence Miscellaneous 4/1/2000 'U. 6831346 " '!.'"""- Wl!lL.UAMc. ~.L~m. 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 POI 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 . . . , . RECEIVED -.--4~-{j" J.iJ()[)' By: fj0N/J~.~ lAM~ .. ,!;, -a 6831346 CARPENTR/GOLD-SL P02 . 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 . -'6' '8831348. CARPENTR/GOLD-SL P03 .~ i' 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 ,,'\