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Home My WebLink AboutComments SUB 5/13/2009 ...'., ,,' . ~" I' SPRINGFIELD UTILITY BOARD WATER SEII.VICE CENTER 202 South 18th Street Springfield, OR 97477-5240 Tel 541.726.2396 Fax 541.747.7348 www.subutil.com May 13, 2009 Andy Limbird Development Services City of Springfield 225 Fifth Street Springfield, OR 97477 SUBJECT: WILLAMETTE VALLEY CANCER CENTER AT RIVERBEND MEDICAL PAVILION DRINKING WATER PROTECTION OVERLAY DISTRICT APPLICATION Andy, I have reviewed all documents submitted for the WVCC 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. COMPLETE. 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 Received: S/,~/:J4Q9 Planner: AL S:\Amy Chinitz\Businesses_DWP apps\Willamctte Valley Cancer Center\2005~05-13_ WVCC app response.doc 6) Description of the procedures for inspection and maintenance of containment devices and emergency equipment. COMPLETE. See Sections (6) and (7) below. 7) Description of the 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 allowed 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. Z) Unless exempted, all hazardous or other materials that pose a risk to groundwater shall 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 adequately 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. Annex B of the HMMP identifies six hazardous material storage area locations. Section 4.4 of the HMMP states that pharmaceuticals may be hazardous materials and will be managed appropriately. Conditions: Stored medicines and pharmaceuticals must be kept in secondary containment. Data Received: Planner: AL 5-j18/~01 I I S:\Amy Chinitz\Businesses_DWP apps\Willamcttc val1ey Cancer Center\2005~05-13_ WVCC app response. doc 3) All new use ofDNAPLs are prohibited. Findings: The HMIS lists products to be used and stored on-site. None of the products listed were found to contain DNAPLs. " Section 4.4 of the HMMP states that WVCC will not purchase, store, or use any DNAPLs. Prior to purchasing new hazardous materials, WVCC will submit MSDSs to SUB for review to ensure that the products do not contain any DNAPLs. The facility will maintain a log of all products reviewed for potenti<il DNAPLs. Section 4.4 of the HMMP states that the Facility will submit an updated HMlS 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 inventory quantity of any DNAPL is S!lnsid~red 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 prohibited: , a. Hazardous material product pipelines used to transport the hazardous material off ofthe . tax' lot where it is produced or used; b. Injection wells, except dry wells for roof drainage; c. Solid waste landfills and tr'ansfer stations; " " .' ",'", " ",:, d. Fill materials containing hazardous materials; "" ,.''': " " ,,:'!' e. Land uses and new facilities that will use, store, treat, handle, and/or produce'DNAP'Ls.... , .~,! Findings:, The application d~es not prop~se any of the above listed activities. 6) Requirements f~und hi Uniform Fire Code Appendix I1-E Section3.2.6 for'a niOllitori~g 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 10.0 of the HMMP describes the facility's policy for monitoring secondary containment areas. Monthly inspections of hazardous materials and hazardous waste will use inspection.". forms attached to the HMMP. ' . "" . .1 7) The following requirements for inspection and record keeping procedures for mon'thly in-house inspection and maintenance of containment and emergency equipment for all amounts of hazardous or other materials that pose a risk to groundwater shall be met . ~n!ess 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' . .... . Date Received: Planner: AL S:\Amy Chinitz\l3usincsscs_DWP apps\Willamette VaHey Cancer Centcr\2005-05-13_ WVCC app response.doc' . d/~/)J)O'f I ' 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 ofthe inspector and the countersignature of the designated safety manager for the facility. Findings: Sections 10.0 and 11.0 of the HMMP describe the facility's policy for inspection and record keeping procedures. Monthly inspections of hazardous materials and hazardous waste will use inspection forms attached to the HMMP. The HMMP follows the standard procedure for notification 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 well(s), SDC 3.3-240 CONDITIONS 1) Section 8.2 of the HMMP states that "The sanitary sewage system operator may restrict the disposal of some pharmaceuticals to the sanitary sewer." The applicant should clarify this policy with the City of Springfield and provide specifics in the HMMP regarding guidelines for disposal of pharmaceuticals to the sanitary system. 2) 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 materials 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, ~D~ Amy Chinitz Water Quality Protection Coordinator '. Date ~eceived: f~,,).9<>9 Planner: AL S:\Amy Chinitz\Businesses_DWP apps\Wil1amette Valley Cancer Cenler\2005-05-13_ WVCC app response.doc