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Home My WebLink AboutComments SUB 6/2/2009 "r ,. ~- ~ SPR1NGFlELD UTILITY BOARD \\'ATERSERvrCE CE:\'TEJ{ 202 South 18th Street Springfield, OR 97477-5240 Tel 541.726.2396 Fax 541.747.7348 www.subutil.com June 2, 2009 Andy Limbird Development Services City of Springfield 225 Fifth Street Springfield, OR 97477 SUBJECT: WALGREEN'S CLINICAL PHARMACY AT RIVERBEND MEDICAL PAVILION DRINKING WATER PROTECTION OVERLAY DISTRICT APPLICATION Andy, I have reviewed all documents submitted For the Walgreen's Clinical Pharmacy Drinking Water Protection Overlay District Application (hereafter DWP application) in relation to the criteria outlined in Section 3.3-200 of the Springfield Development Code (SDC). The property lies within the 1-5 year Time of Travel Zone to the Sportsway wellhead. SDC 3.3-225 (D): REVIEW 1) Hazardous Materials Inventory Statement and Material Safety Data Sheets. COMPLETE. 2) 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 3) Detailed description of the activities conducted at the facility that involve the storage, handling, treatment, use or production of hazardous materials in quantities greater than the maximum allowable amounts as stated in Section 3.3-235 A. NOT APPLICABLE 4) Description of the primary and any secondary containment devices proposed, and, if applicable, clearly identified as to whether the devices will drain to the storm or sanitary sewer. MORE INFORMATION REQUIRED. See Item (2) below. 5) Proposed Hazardous Material Management Plan (HMMP) for the facility that indicates procedures to be followed to prevent, control, collect and dispose of any unauthorized release of a hazardous material. COMPLETE. DatE, Hoceived: Planner: AL 0/J;o9 S:\Amy Chinitz\Businesscs_DWP apps\Walgreen's_Riverbend !'1P\2005-06-02_ Walgreen's app response. doc 6) Description ofthe procedures for inspection and maintenance of containment devices and emergency equipment. COMPLETE. See Sections (6) and (7) below, 7) Description ofthe plan for disposition of unused hazardous materials or hazardous material waste products over the maximum allowable amounts including the type of transportation, and proposed routes. COMPLETE. 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 aIlowed only upon compliance with containment and safety standards set by the most recent Fire Code adopted by the City. Findings: The HMMP submitted with the application adequately addresses product and container labeling, provision of spill kits, spill prevention, and spill clean-up procedures. Conditions: If the Springfield Fire Marshall's office requires a physical inspection, DWP approval will be contingent on successful completion of that inspection. 2) Unless exempted, all hazardous or other materials that pose a risk to groundwater shaIl be stored in areas with approved secondary containment in place (Springfield Fire Code 2702.1 and 2704.2.2). Findings: Section 5.1 of the applicant's HMMP addresses the secondary containment requirement. All liquid hazardous materials and hazardous materials that could be dissolved in water will be stored in secondary containment. The secondary containment tubs or trays will have sufficient depth to contain at least 110% of the volume of the largest container. Appendix C of the HMMP identifies ten hazardous material and pharmaceutical storage area locations. Section 3.4 of the HMMP states that pharmaceuticals may be hazardous materials and will be managed appropriately. The HMMP states that the facility is unlikely to generate hazardous waste at this time. Conditions: All stored medicines and pharmaceuticals shall be kept in secondary containment that meets the definition of secondary containment as described in the HMMP. De' I "'",--;,}."d?!l~J S:\Amy Chinitz\Busincsses_DWP apps\Walgreen's_Riverbend MP\2005-06.02_ Walgreen's app respon.f!b2 . Section 5.1 of the HMMpshall clearlystate that all stored pharmaceuticals will be kept in secondary containment and should describe how secondary containment will be provided. The description shall included provisions for securing secondary containment devices to prevent materials from falling or spilling onto the floor. The HMMP shall state that secondary containment shall be provided for any,amount of hazardous waste. kept at the facility, regardless of quantity. 3) All new use of DNAPLs are prohibited. Findings: ~[. The HMIS lists products to be used and stored on-sj.te. None of the products listed were found to contain DNAPLs. . Section 3,4 of the HMMP states that Walgreen's Clinical Pharmacy will not p\lrchase, store, or use any DNAPLs. Prior to purchasing new hazardous materials, Walgreen's will submit MSDSs to SUB for review to ensure that the products do no~ contain any DNAPLs. Thefacility will maintain a log of all products ,reviewed for potential DNAPLs. Section 3.4 of the HMMP states that the Facility will'submit an updated HMIS to SUB when new hazardous materials are added to or removed from"the HMIS. " 4) Any change in the type of use or an increase in the maximum daily inve,ntory quantity of any DNAPL is considered a new use and is prohibited. See Section (3) above. 5} The following certain types offacilities or changes in chemical use and/or storage of hazardous or other materials that pose a risk to:groundwater are prohi'bited: 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; , e, Land uses and new facilities that will use, store, treat, handle, and/or produce DNAPLs. Findings: The application does not propose any of the above listed activities. j ~a[el Received:: ,~~? planner: AL II"" ~-. '" ~ ' , ., S:\Amy.Chinitz\Busin:sses_ DWP apps\Walgreen's.c..Riverbena MP\2005-06-02_ y./algreen's app resP9ose,doc 6) Requirements found in Uniform Fire Code Appendix I1-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 7.0 of the HMMP describes the facility's policy for monitoring secondary containment areas, Monthly inspections of hazardous materials will use inspection forms attached to the HMMP. 7) The following requirements for inspection and record keeping procedures for monthly in-house inspection and maintenance of containment and emergency equipment for all amounts of hazardous or otlier materials that pose a risk to groundwater shall be met unless exempted: Schedules and procedures for inspecting safety and monitoring and emergency equipment. The applicant shall develop and follow a written inspection procedure acceptable to the Director for inspecting the facility for events or practices which could lead to unauthorized discharges or hazardous materials. An inspection check sheet shall be developed to be used in conjunction with routine inspections. The check sheet shall provide for the date, time, and location of inspection; note problems and dates and times of corrective actions taken; and include the name of the inspector and the countersignature of the designated safety manager for the facility. Findings: Sections 7.0 and 8.0 of the HMMP describe the facility's policy for inspection and record keeping procedures. Monthly inspections of hazardous materials will use the inspection form attached to the HMMP. Section 7.0 of the HMMP states that the facility is unlikely to generate regulated hazardous waste at this time and, therefore, only the hazardous material monthly inspections will be required, 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 well(s), Conditions: The HMMP shall state that the facility will conduct hazardous waste inspections for any amount of hazardous waste kept at the facility, when applicable, SDC 3.3-240 CONDITIONS 1) Section 1.0 of the HMMP states that the facility is "unlikely to generate regulated hazardous waste at this time; therefore, hazardous waste management is not addressed within this Plan." Item #7 on page 3 of the application narrative describes a protocol for disposing of hazardous waste. The ~MMP should include this protocol and describe proper management of . Oat!:.; Heceived' S:\Amy Chinitz\Businesses_DWP apps\W::ilgreen's_Riverbend MP\2005-06-02_ Walgreen's ilpp response.doc Planner: AL ~/3/~'1 , I pharmaceutical waste (including prohibition on disposing of pharmaceutical waste via the sanitary sewer).' 2) The HMMP shall include names and contact inform~tion for individuals responsible for implementing the HMMP, overseeing hazardous. materials management, and responding to hazardous material spills or emergencies. 3) An inspection is required to verify that the standards for and conditions of approval are being met and that the measures described in the HMMP.and other DWP material~ submitted are being followed at the facility. Please contact Amy Chinitz at 744-3745 to schedule a site visit. Please feel free to contact me at 744-3745 if you have any questions. Sincerely, ~.~ Amy Chinitz Water Quality Protection Coordinator Datel Neceived' Planner: AL 6P~'j , ' S:\Amy Chinitz\Busincsscs_DWP apps\Walgreen's_Riverbend MP\2005-06-02...:;. Walgreen's app responsc;doc