HomeMy WebLinkAboutCorrespondence SUB 5/9/2007
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SPRINGFIELD UTILITY BOARD
\VATER SERVICE CENTER 202 South 18th Street Springfield, OR 97477-5240 TeI541.726.2396 Fax541.747.7348 www.subutil.com
May 9, 2007
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By 5- Q-07
Linda Pauly
Development Services
City of Springfield
225 Fifth Street
Springfield, OR 97477
SUBJECT:
PACIFICSOURCE HEALTH PLANS OVERLAY DISTRICT APPLICATION
DRC2007-00028
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Linda,
I have reviewed all documents provided for PacificSource Health Plans in light of the items required for
a City of Springfield DWP Overlay District Application (hereafter DWP application) as outlined in
Article 17 of the Springfield Devetopment Code (SDC). The property lies within the 1-5 year Time of
Travel Zone to the Sportsway wellhead. Please note that the DWP application should address hazardous
materials used throughout the entire facility, not just those associated with the generator.
Areas that still need to be addressed are explained below:
SDC 17.050(4): REVIEW
a) Hazardous Materials Inventory Statement and MSDS sheets
INCOMPLETE. The application did not include a Hazardous Materials Inventory Statement
(HMIS), The HMIS serves as the official documentation for all hazardous materials to be used or
stored on site. It should include all products associated with the generator as well as any other
hazardous materials used or stored on site, including cleaning and landscaping products, The
applicant submitted MSDSs for the diesel fuel, coolant, and lubricating oil but not for any other
products used or stored on site.
b) List of the chemicals to be monitored through the analysis of groundwater samples and a
monitoring schedule if groundwater monitoring is anticipated to be required
GROUNDWATER MONITORING NOT REQUIRED -
c) Detailed description of the activities conducted at the facility that involve the storage, handling,
treatment, use or production of hazardous materials in qnantities greater than the maximnm
allowable amounts as stated in SDC 17,070(1)
COMPLETED. The applicant reports that "Fuel will be brought to the site via approved fuel
transport equipment, pumped into the double-walled fuel tank located under the generator assembly,
and utilized by the generator for emergency power to both the existing and proposed future
buildings,"
S:\Amy Chinitz\Dusinesscs_DWP apps\PaciticSource Health P!ans\PacificSource app response_5-9-07.doc
d) Descriptiori of the primary arid any secondary contain merit devices proposed, and, if
applicable, clearly identified as to whether the devices will drain to the storm or sanitary sewer
INCOMPLETE. The applicant described adequate secondary containment for the generator tank,
which will be double-walled.' No secondary containment was described for other. hazardous .
materials, such as cleaning p~oducts, used or stored on site. See Section (b) below.
Ii) Proposed Hazardous Material Management Plan for the fa~i1ity that indicates procedures to be
. followed'to prevent, control, collect and dispose' of any unauthorized release of a hazardous
material , . ,
INCOMPLETE. The applicant must submit a'HMMP using the Springfield Fire and Life'Safety
template or an acceptable equivalent. The HMMP should. also describe the facility's policies for
preventing groundwater contamination (e.g., that all haza~dous materials be stored in secondary
containment, protocol for preventing spills while pumping fuel into the generator tank, spill clean-up
procedures, inspection and monitoring, signage, DNAPL prohibition, employee iraining;listing of
individuals responsible for emergencies associated with.generator tank or any other hazardous
materials). The HMMP shoutd follow the standard procedure for notificatimi ofa 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). ' ..
I) Description of the procedures for inspection and maintenance of containment devices and
emergency equipment
INCOMPLETE. See Section (e) below,
g) Description of the plan for disposition of unused hazardous materials of hazardous material
waste products over the maximum allowable amounts including the type of transportation, and
proposed routes
COMPLETE,
SDC 17.070(2): 1-5 YEAR TOTZ STANDARDS FOR APPROVAL
a) The storage, handling, treatment, use, application, or production or otherwise keeping on
premises of more than 20 gallonso,f hazardous materials that pose a risk to groundwater in
aggregate quantities not containing DNAPLs shall be itllowed only upon compliance with
containment and safety standards set by the most recent Fire Code adopted by the City.
DWP approval is contingent on a successful inspection by Springfield Fire and Life Safety.
The applicant states that "The area surrounding the emergency generator as well as all housekeeping
service rooms and facilities storage areas will be signed with safety information and cleanup
procedures,in accordance with PacificSource's company policy as well as all tocal, state, and federal
standards" and,that a spill containment kit will be stored in the generator enclosure. Spill kits should
also be available in other hazardous material storage areas. All containers' with hazardous materials
should be labeled so that the contents are clearly identified~
b) Except those exempted, all I!azardous materials that pose as risk 'to groundwater shall be
stored in areas with approved secondary containment ,in place (Uriiform Fire Code Articles 2
and 8003.1.3.3)
. The applicant proposes to use a Cummins Power Generation Diesel Generator Set (Model DFEK
Nonroad 60 Hz) with a single, 850-gallon, above ground, doubte-walled fuel tank. The double wall
provides adequate secondary containment for the diesel fuet.
No secondary containment was described for other hazardous materials, such as cleaning products,
Secondary containment devices will be needed for all hazardqu~ materials on site. 'The applicant _
should (1) submIt a ltst of all haz~rdous matenal storage areas on sIte and descnb~lite\~r\!l1 \fl ~ ~
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containment used '[or each, and (2)provi,de a facility sketch that identifies all hazardous material
storage areas.
All new use of DNAPLs shall be prohibited
The three MSDSs submitted have been evaluated and determined not to contain DNAPLs. Please
submit MSDSs for all products that will be listed on the HMIS,including lawn care, pesticide, and
cleaning products, so 1hey can be reviewed for DNAPLs.
I
Throughout the course of operations, any new.chemicals proposed 'for use/storage need to be
evaluated for DNAPLs: Please submit MSDSs for any such products'before purchase and document
this requirement in company policy. SUB shoul~ be provided with an updated HMIS,on at teast an
annual basis.
d) Any chaAge in the type of use or.an increase in the maximum daily inventory qnantity of any
DNAPL shall be considered a new use and shall be prohibited.
See. Section (c) above. .
The following certain types of facilities or changes in chemical use and/or storage of hazardous
materials that pose a risk to groundwater shall be prohibited:
1. Hazardous material product pipelines used to transpori the. hazardous material off of th~tax lot
where it is produced or used; ,
2. Injection wells,.except dry wells for roof drainag~;
. 3. Solid waste landfills and transfer stations;
4.. Fill materials'containing hazardous materials;
.5. Land uses and new facilities that will use, store; treat, handle, and/or produce DNAPLs,
Requirements found in UiIiform Fire Code Appendix II-E Section 3.2.6 for a monitoring
proghim and in 8003.1,3.3 for monitoring methods to detect hazardous materials in the
secondary containment system shall be met for all amonnts of haiardous materials that pose a
risR to groundwater except those exempted.
Theapplicantstates that "Emergency equipment, as requited for building and fire code compliance,
will be inspected at the direction and on a schedute established by the fire marshal. Facilities staff
will be responsible for weekty inspection of the generator tank and associated equipment."
c)
. e)
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All other secondary containment devices must be monitored as.well. Please include a detailed
description of the monitormg methods and policies in the HMMP. The monitoring program should
also include the location of each secondary containment device to be inspect~d and any specific
instructions about each device.
g) Requirements found in Uniform Fire Code AppendixII-E Section 3,2.7 for inspection and
record keeping procedures for monthly in-house inspection and maintenance of containment
and emergency eqnipment for all amounts of hazardous materials that pose a risk to
groundwater except those exempted shall be met.
The generator set includes a spill detection system that alerts the facilities staff of any leaks and/or
failures. The HMMP should provide a detailed description of how the alatm system,works, who is.
responsible for responding to it, how and by whom the system is maintained and serViced, and the
protocots for responding to an emergency.
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Monthly inspection of all. other areas where products on theHMIS are storedh.ised should be
performed and documented, The schedule,and procedure for inspecting and maintaining containment
and emergency equipment should be described in the HMMP. The HMMP should also include an .
inspection checklist that provides for the date, time, and location of inspection; problems and dates
and times of corrective actions taken; the n~me of the inspector and the countersignature of the
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. OTHER AREAS THAT NEED TO BE ADDRESSED
a) Matetiais used for, tandscape maintenance purposes should be. used only according to manufacturer's
specifications, .
b) An inspection to verify physical aspects and processes of the site is required. Please Contact Amy
.Chinitz at 744-3745 to schedule a site visit. . '
c) Ifnot atready posted, signage that uses the sign standard provided by SUB should be placed in
conspicuous locations (generator pad area, parking lot, outside of structure, truck entrance) to alert
staff and visitors to notify 9 n in the.event of an unauthorized release of hazardous materials (please
contact Amy Chinitz at 744-3745 to purchase signs directly from SUB),
d) Employee training should promote awareness of the sensitive area that the facility occupies and
special precautions that need to be taken to protect the dtinkingwater supply, Please include in the'
HMMP, a list of topics to be included in employee training. The applicant may contact Amy Chinitz
at 744-3745 if he/she would like to schedule a briefdfin~ing water protection presentation for
employees. . .
Please, feel fr~e to contact me at 744"3745 if you have any questions.
Sincerely,
.~
Water Qu~lity Protection Coordinator
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By . -5 4~D7
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S:\Afny C~initz\Bllsiness~s_DWP apps\PacificSource Health Plans\PacificSource.app response_5~9~07.doc