HomeMy WebLinkAboutNotice PLANNER 12/30/2008
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AFFIDAVIT OF SERVICE
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STATE OF OREGON)
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County of lane )
I, Karen laFleur, being first duly sworn, do hereby depose and say as follows:
1. I state that I am a Program Technician for the Planning Division of the
Development Services Department, City of Springfield, Oregon,
2. I state that in my capacity as,Progra~.-!echnician,!l1rel1ared and caused tl? be .
mailed copies of ))R('2()()"j~l\rX"1',71~('.:2Mf(,,-ooo3~7- /)wP~ ~ .
(See attachment "A") on - _J.:J /~ . 2008 addressed to (see ~
Attachment B"), by causing said letters to be placed in a U.S. mail box with 0
postage fully prepaid thereon. -
l;;<w~ _~j~
~~~N LaFLEUR I
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STATE OF OREGON, County of lane
J:x.Ce./Y1.)u/J _ 30 . 2008. Personally appeared the above named Karen laFleur,
Program Technician, who acknowledged the foregoing instrument to be their voluntary
act. Before me:
/
OFFICIAL SEAL
DEYETTEKELLY
NOTARY PUBLIC. OREGON
COMMISSION NO. 420351
MY COMMISSION EXPIRES AUG. 15, 2011 !
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My Commission Expires: _ gj;s-:/ II
DRINKING WATER PROTECTioN
OVERLAY DISTRICT EXEMPIJON
Case Number: Addendum to DRC200S-00027/DRC2008-00033
Project Name: Oregon Medical Laboratories (OML) CWoroform Exemption
Owner: Oregon Medical Laboratories
Applicant: Dr. Stephen Erfurth, PhD, OM~ Director of Science and Technology
Mr. Mark Dwyer SLS (ASCP), OML Safety Coordinator
Project Location: OML/River Bend Annex, 123 International Way, Springfield, OR 97477
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Date of Decision: December 30, 2008.
Nature ofthe Proposal: The applicant is requesting to exempt cWoroform from the DNAPL
prohibitions of the Drinking Water Protection Overlay District at the subject site for limited use
in life saving neo-natal medical tests. The standards of Springfield Development Code Section
'3.3-230(B)1 for Exemptions within the Drinking Water Protection Overlay District must be met
in order to authorize the proposed use. The proposal is to demonstrate that the requested use
poses no threat to the drinking water aquifer; chloroform will not be added to the use of
exempted hazardous materials.
Site Information: The site is within the 1-5 year Time Of Travel Zone (TOTZ) from the
Springfield Utility Board's Sports Way Drinking Water Well Head. Nearly one hundred percent
of Springfield's drinking water comes from wells. Springfield's drinking water supply and water
quality protection is a critical part of Springfield's Drinking Water Protection Plan. A Drinking
Water Protection (DWP) Overlay District application or exemption is required in conjunction
with any new development or introduction of activity that will affect the potential storage, use
and/or production of hazardous materials thatpose a risk to groundwater.
Applicable Criteria: Springfield Development Code (SDC) Drinking Water Protection Overlay
District, Section 3.3-230-Exemptions. .
Decision: Exemption Granted, as of the above date, subject to strict compliance with the
submitted proposal and the conditions of approval contained in SUB Correspondence Dated July
21, 2008, Chinitz, attached.
Other Uses Authorized By The Decision: None. Any change of use or future development will
be in accordance with the provisions of the Springfield Development Code and all applicable
local, state and federal regulations.,
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I. APPLICABLE CRITERIA
Springfield Development Code Section 3.3-230(B)1 states:
"U se, storage and handling of specific hazardous materials that do not
present a risk to the aquifer, as determined and listed by the Director in
consultation with SUB, are exempt from all regulation under this Section
with the exception of the potential requirement to list these hazardous
materials on the Hazardous Materiallnventory Statement as found in the
most recent Fire Code regulations adopted by the City. A Hazardous
Materials Exemption Request may be submitted to the Director for
Hazardous Materials that can be demonstrated to pose no threat to the
'aquifer. These materials may be exempted from regulation and added to
the list. The demonstration of no threat is the responsibility of the
Springfield Development Code, Chapter 3 Page 123 of203 ,
~pplicant seeking the exemption and will be subject to review by technical
experts. "
II. APPLICANT SUBMITTAL
Finding: The applicant submitted materials supporting the request for exemption including,
but not limited to: reason for request, risk-mitigation, inspection procedures and handling of
materials (attached).
III. FINDINGS, DECISION AND CONDITIONS
Finding: The SUB Water Quality Protection Coordinator has reviewed the submitted materials
and has recommended approval of the Exemption request in accordance with SDC 3.3-
230(B)1 (July 21, 2008, Chinitz).
Finding: The Development Services Directorhas reviewed the submitted materials and the
recommendation of the SUB Water Quality Protection Coordinator.
Finding: The Director finds that the request is for a potentially life saving neo-natal procedure
for which there is no reasonable substitute at this time. The Director concurs with the Water
Quality Protection Coordinator's conclusion that the aquifer will be protected by strict
adherence to the submitted management plan.
Conclusion: The test of SDC 3.3-230(B) I for protection of the aquifer has been met; the
operational conditions contained iil the SUB Drinking Water Protection Coordinator'sTeview
shall be attached as conditions under this amendment to the original approval(s). Chloroform
,will not be added to the list of hazardous materials exempted under the Code.
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IV. CONDITIONS OF APPROVAL
The request is granted subject to the following operational conditions for the handling; use and
storage of chloroform on the subject site:
1) OML will adhere to the management plan outlined in the Proposalfor Limited Use of
Chloroform exactly as it is written. OML will obtain approval from SUB before making
any changes to the management plan.
2) OML will not have any cWoroforrn on site until the SUB Water Quality Protection
Coordinator has conducted a successful inspection of the delivery, storage, and work
areas and reviewed the procedure oil site.
3) OML will notify notify SUB if any amount of cWoroform is spilled or otherwise released.
Following any accidental release of chloroform, use of chloroform mustcease until OML
works with SUB to rectify failures in the management protocol and receives approval
from -SUB to resume use of cWoroform.
4) SUB retains the right to require that the keeping and use of chloroform cease at any. time.
5) On a quarterly basis during the first year of cWoroform use, OML will submit copies of
the completed inspection sheets for the previous three months. At the end of the fust year
and annually thereafter, OML will contact the SUB Water Quality Protection Coordinator
to conduct an on-site inspection.
6) The exemption applies solely to the use of chloroform'as outlined ih the Proposal for
Limited Use of Chloroform and to no other DNAPL chemicals now orin the future.
V. ADDITIONAL INFORMATION
Please call Jim Donov'!ll in the Development Services Department at 726-3660 or Chuck Davis
in the SUB Water Department at 744-2396 if you have questions regarding this process.
Preoared bv
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0- =-:?~.~.~
ames P. Donovan
City of Springfield
. DSD Urban Planning Supervisor
C: Dr. Stephen Erfurth, PhD, OML Director of Science and Technology
Mr. Mark Dwyer SLS (ASCP), OML Safety Coordinator
SUB Water Quality Protection Coordinator
Notice of Decision -Drinking Water Protection Overlay
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Project Name: Pathology Consultants
Project Proposal: Tenant improvement for a medical laboratory.
Case Number: DRC2008-00033
Project Location: 123 International Way
Base Zone: Campus Industrial
Overlay District(s): Drinking Water Protection Overlay (1-5 yr TOTZ)
Application Submitted Date: May 12, 2008
Decision Issued Date: June 18, 2008 '
City Staff: Steve Hopkins
Owner: Phil Farrington, PeaceHealth, 123 International Way, Springfield OR 97477
Applicant: Joyce Siamon, Pathology Consultants PC, 755 E 11th Ave, Eugene OR 97401
Representative: Matt Matthews, TBG Architects and Planners, Inc. 132 East Broadway, Suite
200, Eugene OR 97401.
Review Process: This application is reviewed under Type I procedures listed in SDC 5.1-125,
and the Drinking Water Protection Overlay regulations in SDC 3.3-200.
SDC 3.3-235 (B): 1-5 YEAR TOTZ STANDARDS FOR APPROVAL
1) The storage, handling, treatment, use, application, or production or otherwise keeping on
premises of more than 20 gallons of hazardous materials that pose a risk to groundwater
in aggregate quantities not containing DNAPLs shall be allowed only upon compliance
with containment and safety standards set by the most recent Fire Code adopted by the
City.
Finding: The property lies within the 1-5 year Time of Travel Zone to the Sports Way
wellhead. In accordance with SDC 3.3-220 C(3), the property will be governed by the
standards of the 1-5 year TOTZ.
Finding: The HMMP submitted with the application adequately addresses product and
container labeling, provision of spill kits, spill prevention, and spill clean-up procedures.
2) Unless exempted, all hazardous materials that pose a risk to groundwater shall be stored
in areas with approved secondary containment in place (Uniform Fire Code Articles 2 and
8003.1.3.3)
Finding: Section 5.1 of the applicant's HMMP adequately addresses the secondary
containment requirement. Hazardous materials in storage will be stored in hazardous
materials cabinets or commercial, plastic secondary containment devices (as dictated by
NFP A- hazardous materials storage rules). The secondary containment in the cabinets or
commercial plastic devices will include adequate volume to ensure 110% of the volume in
Pathology Consultants
Case Na, DRClOOB-00033
o
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the largest container, Hazardous materials in use in the laboratory will be contained by
sealing the laboratory floor according to the specifications described in the HMMP and by
the secondary containment floor plan submitted to the SUB Water Quality Protection
Coordinator on June 11, 2008 by Matt Matthews of TBG Architects.
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3) All new use of DNAPLs are prohibited.
Finding: The HMIS submitted with the original application included three DNAPL-
containing products: (1) Krystalon, Toluene 56.3% Butyl Benzyl Phthalate 7% (DNAPL is
butyl benzyl phthalate); (2) Toxi-tubes A; and (3) Toxi-tubes B. These products were
removed from an updated HMIS submitted to the SUB Water Quality Protection
Coordinator over e-mail on June 12, 2008, by Ken Taylor of KTA associates. None of the
other products on the updated HMlS were found to contain DNAPLs.
Finding: To prevent reintroduction to the inventory, it is important to maintain a current list
of all DNAPL products that have been reviewed and/ or eliminated from the HMIS.
Finding: Procedure 2 in Annex C of the HMMP outlines a Hazardous Material Review
Procedure designed to evaluate new chemicals for DNAPLs before they are purchased.
Conditions of Approval:
1. Chemicals used/ stored on-site must be consistent with those listed on the HMIS
submitted on June 12, 2008,
2. On an annual basis, provide SUB,with an updated HMIS that highlights all products
added since the last submittaL
3. Maintain a current list of all DNAPL products that J:tave been reviewed arid/ or
eliminated from the HMIS, Include the product name, manufacturer, and DNAPL
components. The log should include Krytalon, Toxi-Tube A, and Toxi-Tube B. For
procedure 2 of Annex C of the HMMP, include a sample of the log that includes
these three products.
4. Prior to occupanCy, an inspection to verify physical'aspects and processes of the site
is required. Please contact Amy Chinitz at 744-3745 to schedule this inspection.
4) Any change in the type of use or an increase in the maximum daily inventory quantity of
any DNAPL is considered a new use and is prohibited.
See Section (3) above.
5) The following certain typesiof facilities or changes in chemical use and/or storage of
hazardous materials that pose a risk to groundwater are prohibited:
a. Hazardous material product pipelines used to transport the hazardous material off of
the tax lot where it is produced or used;
b. Injection wells, except dry wells for roof drainage;
c. Solid waste landfills and transfer stations;
d. Fill materials containing hazardous materials;
Pathology Consultants
Case No, DRClOOB-00033
2
e. Land uses and new facilities that will use, store, treat, handle, and/ or produce DNAPLs.
Finding: The applicant has not proposed any of these activities.
6) RequiIements found in Uniform Fire Code Appendix II-E Section 3.2.6 for a monitoring
program and in 8003.1.3.3 for monitoring methods to detect hazardous materials in the
secondary containment system shall be met for all amounts of hazardous materials that
pose a risk to groundwater unless exempted.
Findings: Section 11.0 of the HMMP describes the facility's policy for monitoring secondary
containment areas.
7) Requirements found in Uniform Fire Code Appendix II-E Section 3.2.7 for inspection and
record keepiIlg procedures for monthly in-house inspection and maintenance of
containment and emergency equipment for all amounts of hazardous materials that pose
a risk to groundwater shall be met unless exempted.
Finding: Sections 11.0 and 12.0 of the HMMP describe the facility's policy for inspection and
record keeping procedures. '
Finding: The HMMP follows the standard procedure for notification of a hazardous
material release in Springfield, to call 911, which dispatches information to SUB. Following
this procedure is important because SUB needs to be notified as soon as possible if a
chemical release has the potential to contaminate our welles).
DETERMINATION: Based on the evidence in the record, the Director determines the
urooosal comolies with SDC 3.3-200. subiect to the Conditions of Aooroval.
SUMMARY OF CONDITIONS
1. Chemicals used/ stored on-site must be consistent with those listed on the HMIS
submitted on June 12, 2008.
2. On an annual basis, provide SUB with an updated HMIS that highlights all products
added since the ~ast submittal.
3. Maintain a current list of all DNAPL products that have been reviewed and/ or
eIiminated from the HMIS. Include the product name, manufacturer, and DNAPL
components. The log should include Krytalon, Toxi- Tube Ai and Toxi- Tube B. For
procedure 2 of Annex C of the HMMP, include a sample of the log that includes
these three products.
4. Prior to occupancy, an inspection to verify physical aspects and processes of the site
is required. Please contact Amy Chinitz at 744-3745 to schedule this inspection.
Pathology Consunonts
Cose No, DRQ008-00033
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Additional Information: The application, all documents, and evidence relied upon by the
applicant, and the applicable criteria of approval are available for free inspection and copies are
available for a fee at the Development Services Department, 225 Fifth Street, Springfield,
Oregon.
Questions: Please call Steve Hopkins in the Planning Division of the Development Services
Department at (541) 726-3649.
Prepared by:
Steve Hopkins, AICP
Planner II
Development Services - UrbanPlanning Division
Pathology Consultants
Case No, DRQOOB-00033
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SPRINGFIELD UTILITY BOARD
WATER SERVICE CE:-:TER 202 South 18th Street Springfield, OR 97477-5240 Tel 541.726.2396 Fax 541.747.7348 www.subutil.com
July 21,2008
Jim Donovan
Development Services
City of Springfield
225 5th Street
Springfield, OR 97477
Date Received:
'JUL 21 2008
Original Submittal
RE: Request to Store and Use Chloroform,
Oregon Medical Laboratories, 123 International Way
Dear Jim,
I have received a request from Dr. Stephen Erfurth of Oregon Medical Laboratories (OML) to obtain
an exemption from the DNAPL prohibition found in SDC 3.3-200 in order to use chloroform at the
facility at 123 International Way, OML has requested to use chloroform for the purpose of
conducting two tests that measure the amount of pulmonary surfactant in amniotic fluid obtained
by amniocentesis. The tests help determine whether a fetus has mature enough lungs to breathe on
its own at birth, According to Dr, Erfurth, no other solvent can be substituted for the chloroform,
OML is located in the PeaceHealth Annex and is subject to the standards ofSDC 3.3-235 (B) 1-5 year
TOTZ Standards, SDC 3,3-235 (B)(3) states that all new use of DNAPLs are prohibited, Chloroform
is a recognized DNAPL and appears on the list of DNAPLs adopted by the Springfield Utility Board
on March 28, 2005, SDC 3.3-230 (B) (1) establishes a process for an applicant to seek exemption
from regulation for hazardous materials that can be demonstrated to pose no threat to the aquifer,
The demonstration of no threat is the responsibility of the applicant seeking the exemption and will
be subject to review by technical experts,
Because the chloroform is used for a potentially life-saving medical test and because no alternative
solvent exists, SUB agreed to consider the applicability ofSDC 3,3-230 (B) (1) to the chloroform
exemption request. As a recognized DNAPL, chloroform poses a threat to the aquifer and can never
be added to the exempt chemical list nor removed from the DNAPL list. Therefore, in order to meet
the criteria ofSDC 3,3-230 '(B)(l), OML must demonstrate that its process of handling, storing,
using, and disposing of the chloroform will prevent the release of any amount of chloroform,
The attached Proposal for Limited Use of Chloroform, submitted by OML on July 9,2007, describes in
detail the procedures and protocols OML will use to manage the chloroform. The total quantity of
chloroform kept on site will be limited to two liters of chloroform reagent and five liters of waste,
The reagent will be stored in tertiary containment, and OML personnel will inspect the storage and
work area on a daily basis, OML personnel will deliver the chloroform from the Eugene facility in
order to control the quantities and so that OML personnel, rather than a third party vendor, will be
responsible for its packaging and handling, OML has developed a stringent chloroform
management program that, if carried out exactly as written, would eliminate risk to the aquifer.
S:\Amy Chinitz\Busincsses_DWP apps\Pcace Health Annex (OML)\Chloroform use proposaJ_6-08\Chloroform proposal_Jetter to Jim
Donovan_7-21-08.doc
I recommend that the Director grant OML's exemption request contingent an the following
conditions:
. OML will adhere to the management plan outlined in the Proposal for Limited Use of Chloroform
exactly as it is written, OML will obtain approval from SUB before maki:.1g any changes to the
management plan,
. OML will not have any chloroform on site until the SUB Water Quality Pmtection Coordinator
has conducted a successful inspection of the delivery, storage, and, work areas and reviewed the
procedure on site. I
. OML will notify SUB if any amount of chloroform is spilled or otherwise released, Following any
accidental release of chloroform, use of chloroform must cease until OM'L works with SUB to
rectify failures in the management protocol and receives approval from SUB to resume use of
chloroform, I
. SUB retains the right to require that the keeping and use of chloroform cease at any time,
. On a quarterly basis during the first year of chloroform use, OML will submit copies of the
completed inspection sheets for the previous three months, At the end of the first year and
annually thereafter, OML will contact the SUB Water Quality Protection:oordinator to conduct
an on-site inspection,
. The exemption applies solely to the use of chloroform as outlined in the Proposal for Limited Use
of Chloroform and to no other DNAPL chemicals now or in the future,
I
Please feel free to contact me with any questions regarding the OML request: and my
I
recommendations (541-744-3745), I look forward to hearing your respons,~,
Sincerely,
~c,~
Amy E, Chinitz
Water Quality Protection Coordinator
Enclosure
D:,:lte Received:
I
JUl 21 2008
,
Original Submitt~1
S:\Amy Chinitz\Busincsscs_DWP apps\Peacc Health Annex (OML)\Chloroform,use proposa[_6~08\Ch]ororon'n proposaUetter to Jim
Donovan _7 .21-08.doc
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1-" 11'1; 202 South 18th Street Springfield. OR 97477-5240 T~ 541.726.2396 l=<JX 541.747.7348... ;UOL,! co",
June 15, 2008
Gregory Clark, Ph,D.
Chief Operations Officer
Oregon Medical Laboratories
123 International Way
Springfield, OR 97477
RE:
USE OF TOXI-LAB SYSTEM AT 123 INTERNATIONAL WAY, SPRINGFIELD
Dear Dr, Clark,
In a letter dated April 14, 2006, you provided information regarding a Toxi-A tube
experiment conducted by Dr. Stephen Erfurth. Based on the results of this experiment, you
concluded that the solvent contained in the tube does not meet the definition of a DNAPL
according to the criteria adopted by the Springfield Utility Board. As you know, the use,
storage, or production of DNAPLs is prohibited at the OML facility as per Section 3.3-200 of
the Springfield Development Code (SDC).
The ingredient list on the most recent product MSDS, dated 9/7 lOS, includes two DNAPL chemicals,
1,2-dichloroethane (15-20% w/w) and dichloromethane (15-20% w/w), We have considered your
conclusion that the dichloromethane does not behave as a DNAPL in this mixture; however, our
evaluation did not yield the same conclusion. Though the organic phase floats on top of the
aqueous test mixture, which contains urine and therefore has a density greater than 1.0, the organic
component from this test would be the bottom layer if it were mixed with pure water. We do not
concur that the DNAPL ingredients could never separate from the mixture. .
We are unable to grant your request for an exception to the DNAPL prohibition in SDC 3.3-200. The
Toxi-A tube prodllct will need to be removed from the OML inwmtory list and from the premises.
Feel free to contact me at 541-744-3745 if you have questions or would like to discuss the matter
any further.
Sincerely,
Date Received:
u'^?-('. ~
Amy E, Chinitz
Water Quality Protection Coordinator
JUL 2 1 2008
Original Submittal
AEC:mk
cc: Mark Dwyer, Oregon Medical Laboratories
Andy Limbird, City of Springfield
Jim Donovan, City of Springfield
S:\Amy Chinitz\Businesses_DWP apps\Peace Health Annex (DML)\ Toxl.Lab question..6.15.0B,doc
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The request by Oregon Medical Laboratories for the limited use of
chloroform at the RiverBend.Annex Building is presented here in five
sections:
!
1) Request from Oregon Medical Laboratories for limited chloroform use
2) Policy detailing actions to be taken to eliminate a risk to the aquifer
3) Log sheet for daily inspection of work area
4)Suppo~ng Imag~s
a) Label for chloroform.transporta.tion container
b) Photographs of,packaging system for chloroform transportation container
Please let me know if there are questions about the materials gathered for this
proposal.
Mark Dwyer, SLS(ASCP)
Safety Coordinator
Oregon Medical Laboratories
E-mail: mdwyer@omlabs.com
Phone: 541 341-8087
Fax 541 984-8255
Date Received:
JUL 212008
Original Submittal
J
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J"~l
:egon Medical
Laboratories
July 9, 2008
Ms, Amy Chinitz
Water Quality Protection Coordinator
Springfield Utility Board
202 S, 18th Street
Springfield, Oregon 97477
RE: A request to have a small volume of chloroform (a DNAPLS solvent) at
OML's Springfield laboratory,
Dear Ms Chinitz,:
Oregon Medical Laboratories (OML) is a full service clinical laboratory serving
Eugene/Springfield and many other healthcare facilities throughout the Pacific
Northwest with complex laboratory tests, Due to the restrictions on using DNAPLS
solvents in Springfield, OML left two critical fetal lung maturity tests called
'coJ Lecithin/Sphingomyelin (LIS) ratio and phosphatidyl glycerol (PG) at the small
Sacred Heart Medical Center (SHMC) campus laboratory on Hilyard when the main
laboratory was moved to 123 International Way in January of 2006,
These two tests measure the amount of pulmonary surfactant in amniotic fluid
obtained from amniocentesis by obstetricians, These fetal lung maturity tests help
determine whether a fetus has mature enough lungs to breath on their own at birth,
Infants born with a deficiency of pulmonary surfactant are at increased risk of
developing respiratory distress syndrome (RDS), The risk of RDS from immature
lung maturity increases the earlier the delivery, The test methods for LIS ratio and PG
require small amounts (milliliters) ofehloroform, UnfOl1unately, other solvents can
not be substituted,
,~
Thc performance of these two high-complexity tests require significant training and
experience by cel1ified Mcdical Technologists and the professional oversight by
doctorate level clinical scientists and physician pathologists to maintain high quality
and providc intcrprctation of the test results before release to obstetricians, Although
these two tests are low volume, the acuity of the tests rcquirc they be performed daily,
scvcn days per wcck, Normally these tests are performed in a special chemistry
dcpartment of a large central laboratory where experienced, specializcd chemistry
technologists perform complex tests requiring special skills in more m,uiual
laboratory testing and the availability of doctorate level scientists and physicians are
available for interpretation and consultation,
123 International Way
Spr;ngf;eld. OR 97477
P.O. Box 77003
Eugene, OR 97401
TF 800,826,3616
PH 541.687,2134
FX 541.341.8064
WWIN.omlabs.com
PATHOLOGISTS
David S. Meyers, M.D.
BrentD. Kehn,M.D.
Michael J. Hahn, M.D.
Jeffrey A. Houck, M.D.
John P. DiTomasso, M.D.
Douglas A. Honsen, M.D.
Daniel P. Kerrigan, M.D.
Michael E. Hea, M,D.
Denis M. McCarthy, M.D.
CLINICAL CHEMIST
StephenC. Erfurth, Ph.D.
CUA #3800626706
Date Re-ceived:
JUL 21 2008
Originai SubrniHal
,
Ms, Amy Chinitz
Springfield Utility Board
July 9,2008
Page 2
The level of expertise at the OML Hilyardlab'has been di/lieult to maintain due to the small size
of the lab'and sub-optimal ~lvailability of doctoral level professionals who reside at the large
OML core laboratory on International Way, The availability of staff expertise 011 the Hilyard
OML lab will become more critical wilen SHMC moves to the Springfield RiverBend Hospital
campus in August. With the SHMC move (0 Springfield the Hi Iyard lab will dmvnsize and the
physician pathologists will move next to the OML core central laboratory on 1ntel11ational Way,
OML is requesting permission to have a small quantity of chlorofol111 available at the core OML
Riverbend Annex labonitory, 123 International Way, This would allow OML to perform these
two critical care tests, LIS ratio and PG, in an environment that will provide the'appropriate
professional staff to maintain high quality, Appropriate secondary containment of the chloroform
that meets recognized laboratory inspection requirements'would be maintained to prevent,this
DNAPL solvent from contaminating the local water supply,
Mark Dwyer, OML's on-site manager of chemical safety, and I would be happy to further
discuss this issue with the Springfield Utility Board at their convenience, Thank you for your
consideration and guidance on this issue, Mark can be reached at 341-8087 (pager 341-2750) and
I can be reached at 341-8092 (cell 520-3346),'
Sincercly,
~~
Stephen Erfurth, PhD
Director for Science & Technology
cc: Jeffrey Houck, MD (Laboratory Director)
Ran Whitehead (CEO)
Date Received: '
JUl 2'1 :2008
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Original Submitta'
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Prooosal for use of chloroform bv Oregon Medical Laboratories at the
RiverBend Annex facility in Soringfield. Oregon.
, Chloroform is a recognized DNAPL that can cause harm to the local aquifer
and affect the drinking water supply for the City of Springfield. Oregon
Medical Laboratories (OML) has requested that chloroform be used for the
purpose of LIS ratio and PO testing at the RiverBend Annex (RBA) location
at 123 International Way.
In order to eliminate chlorofohn creating a risk to the aquifer, OML will
implement the steps listed belOw. The system will,be put into place and SUB
Water Quality Protection personal will be able to inspect before any
chloroform is brought on-site~ " .
EDUCATION and MONITORING
I) Additional staff education about the Drinking Water Protection
District for any person involved in the LIS ratio and PO testing
process, including reagent and waste transportation.
a. Annual education updates will be provided.
b. Documentation of training, including the list of participants,
their role in the process and the training content will be
submitted to Springfield. Utility Board annually,
2) Perform daily inspection of chloroform containers and work area.
Inspections will be recorded on a log sheet and any action items
noted. (See attached log sheet, tab 3), .
3) The medical technologists responsible for LIS ratio and PO testing
will perform the daily inspections, after receiving education about the
DWPD and the particular risks of chloroform. The OML Special
Chemistry Technical Specialist will ensure that the inspections are
performed daily and also receive this education. The OML Safety
Coordinator will review the inspection form at the end of each month,
and perform random, unannounced audits that will be entered on the
monthly log in the "Comments" section.
Date Received:
JUL 2'12008
Original Submittal
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14) The inspections forms and training records will be maintained in a log
book at the LIS ratio and PG'work bench, The records will be held for
three years.
5) The log book will be availabJe for inspection SUB Water Quality
Protection personal at any time.
6) A summary of the policy for the limited use of chloroform at the
OML RiverBend Annex lab will be posted at the LIS ratio and PG
workbench. '
DELIVERY. HANDLING. PROCESS AND USE
1) Implement ease of handling by ordering one-liter containers of
chloroform in place of four-liter containers.
2) Limit inventory to two liters,of chloroform reagent at the RBA site at
any time,
3) Larger shipments of chloroform will go directly tothe OML location
at Eugene, which is out of the Drinking Water Protection District.
These will be re-packaged for safe transportation to RBA.
a. One-liter bottles of chloroform will be package at the OML lab
in Eugene in a secondary container that includes cushioning and
spill absorbent material with a capacity greater than the
chloroforrll volume.
The container will be labeled "Chloroform Enclosed - to be
opened by LIS and PG testing staff only" along with contact'
phone numbers for emergency response, the sending and
receiving labs and the OML safety coordinator. (See attached
documents and photographs, tab 4)
b. The chloroform transport package will be transported by OML
Courier services to th~ dispatch area at RBA. Courier staff
currently transport lab reagents and are educated on safety
practices. These staff will be part of the additional training
program for the chloroform use at RBA.
Date Received:
JUL 21 2008
2
Original Submittal
,
J
c. Lab staff using a ,cart with spill containment will transport the
chloroform transpo~ package to the testing area.
4) Enhanced containment for storage at workbench will be provided in
the form of an additional polyethylene tray within the chemical
storage cabinet. The cabinet has self-closing doors and is built into the
fume hood unit. This will be the only location for on-site storage of
chloroform reagent.
5) Secondary containment labeled "for chloroform use" will be provided
for all vessels that cont~in chloroform while in use, such as
developing jars and waste vessels, Test tubes with very low volumes
of chloroform wilL be handled using tube racks over absorbent paper
under the fume hood. :
6) Explanation of staff use during LIS Ratio and PG testing:
a, Chloroform container 'is opened and contents are handled by
Medical Technologists who are certified in laboratory testing,
which includes training in safe chemical use,
b. Testing is limited to two patient samples per plate. Normally
there is only one plate' and two runs per day.
,
c. The maximum volume used during the testing process is
normally less than 200 milliliters per day. '
d, The chloroform is used under the fume hood except during
centrifugation. The work surface under the hood has a lip to
capture any spills. '
e. If the fume hood where the work is performed has a built-in
sink, that sink will be disconnected from the sanitary sewer
system and the pipes sealed at the workbench.
f. There are no floor drains within 25 feet of the work area or
along the path of transportation for delivery, The closest floor
drains have a metal dyke to prevent accidental spills to the
sanitary sewer system.
Date Received:
JUl 2 12008
3
Original Submitt"'l
--'
g. Spill response material is located within 10 feet of workbench.
h. Test tubes containing two milliliters of chloroform each in
. labeled secondary containment are brought to centrifuge located,
within 20 feet offum~ hood. A cart with a substantial lip must
be used to transport materials away from the hood.
1. Centrifuge cups will a~t as secondary containment while in the
centrifuge,
J. Waste chloroforrp is captured in a flask and transferred to
hazardous waste container located under fume hood,
7) Explanation of waste production,
a. Chloroform waste is captured and retained in a labeled
hazardous waste container located at the immediate point of
generation. The container is in secondary containment.
b. Waste will be transported from point of generation in secondary
containment with spill absorption capacity greater than the
volume of the waste container.
DISPOSAL
1) Waste container will be packaged in DOT approved hazardous waste
transport packaging with spill absorbent materials until waste pick-up
occurs. Containers stored in Hazardous Materials room with
additional secondary containment. The container is labeJe,d to indicate
that chloroform in present in the waste.
2) Hazardous waste collected from the process will not exceed five liters.
The full four-liter waste container will be package for off site disposal
and pick-up service will be arranged as soon as waste container if fulL
3) Waste pick-up will occui at bay with spill containment.
4) OML uses a licensed hazardous waste service for hazardous waste
disposaL
Date Received:
JUL 21 '20D8
4
Original Submittal
i
.. -
OML' at RBA: CHLOROFORM CONTA!NERS AND WORK AREA DAILY INSPECTION SHEET
Month
Year
All chloroform
reagent
containers and
waste containers
have secondary
containment
INSPECTION TOPIC
Containers are not leaking, Spill control
rusted, bulging or equipment
damaged, The base under accessible, Phone
containers is in good accessible.
condition (free of cracks, Emergency
gaps and impervious to numbers posted
leaks,) next to phone,
All persons
handling
chloroform reagent
containers and
waste containers
have received
proper training,
'ATE INITIALS
I 1st
I 2nd
I 3rd
14th
15th
16th
17th
18th
19th
I 10th
I 11th
I 12th
I 13th
I 14th
) 15th
6th
I 17th
I 18th
19th
20th
21st
22nd
I 23rd
I 24th
I 25th
I 26th
I 27th
I 28th
I 29th
130m
31st
5DiII ReDortina;, The Springfield Utility Board is to be notified if any amount of chloroform is spilled at
any time; The OML Safety Coordinator or designee will contact SUB and work together to improve
the process and eliminate the risk of accidental release of chloroform,
I Comments and action items (indicate issue, date discovered and resolution) Date ReCAivjCl~
I
JUL ? f 'nnll
Reviewed by Date
ungrnall:iubmitlal
Place completed form in chloroform log book"at LIS and PG testing bench, Maintain for three years,
Handle With Snecial Caution: Chloroform Enclosed
To Be Opened By LIS Ration and PG testing staff only.
t' .',-
)
Chloroform is known to harm drinking water and can cause other health concerns.
In the event of an accid~nqhat couJd lead to damage to this package: ,
1. Do not bring container to the RiverBend Annex Building and attempt to st8.)
out of the Drinking Water Protection District. .
2. Call Northwest HazMat. at 1-800-597-1323 for 24 hour spill response.
3. Call 911 if no response.
\.
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ca' Packaged shipped from OML University District Lab: 541 687-_2134 extension 8185
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~ :Pa~aged shipped to OML RiverBend Annex Lab: 541 687-2134 extension 8139
a ' CD
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g01i!L Safety Coordinator: 542 341-8087.
CXl CD
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Proposed Oregon Medical Laboratories Chloroform Transportation Packaging
One-liter bottles of chloroform will be carefully repackaged at the OML lab in Eugene. OML
believes that packaging this reagent in a screw top container with cushioning and absorbent
material will eliminate any risk to the aquifer during delivery to the RiverBend Annex.
OML is very familiar with the proposed packaging system, as it is the same method used by
OML to secure hazardous waste for off-site disposal.
The over pack drum is type I H2/Y30/S, and is DOT approved for highway transportation.
OML Courier service will transport the package. They currently transport other laboratory
reagents, A copy of the drum label, with delivery contact numbers as well as emergency
response instructions. will accompany the driver and also be available at the Courier
Dispatcher's desk. See attached copy of drum label.
Below are images of the packaging system
I) A one-liter bottle besides the transport drum. Drum is labeled "Handle with Special
Caution: Chloroform Enclosed". Delivery contact numbers as well as emergency response
instructions are included on the label.
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Date Received:
JUL 2 I 2008
Original Submittal
2) A one-liter bottle will be well cushioned and absorbent material in drum will handled four
times the volume of the chloroform container.
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3) Image of drum filled with packing material.
ed:
JUL 2 I 2008
2
Original Submittal
4) Drum has tight fitting screw top lid and is easy to handle. Couriers will use a cart to
transport the drum from the vehicle to the Courier Dispatch area at the RiverBend Annex.
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Date Received:
JUL ? 1 2008
Original SuOrMtal_
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OML Director of Science and
River Bend Annex
123 International Way
Springfield, OR 97477
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123 International Way
Springfield, OR 97477
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