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Home My WebLink AboutComments SUB 11/3/2008 "~.. .. SPRINGFIELD UTILITY BOARD WATER SERVICE Cn-JTER 202 South 18th Street Springfjeld, OR 97477-5240 Tel 541.726.2396 Fax 541.747.7348 www.subutil.com November 3, 2008 Mark Metzger Development Services City of Springfield 225 Fifth Street Springfield, OR 97477 SUBJECT: JERRY'S HOME IMPROVEMENT, DWP OVERLAY DISTRICT APPLICATION DRC2008-00047 Mark, I have reviewed all documents submitted for the Jerry's Home Improvement 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 Maia 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 ofthe 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. This review applies to the HMMP submitte'd to the SUB Water Quality Protection Coordinator via e~mail by Scott Stolarczyk of Robertson Sherwood Architects on October 29, 2008. S:\Amy Chinitz\Busincsscs_DWP apps\lerry's\DWP app_W-08\lerry's app response_11-3-08.doc Date Received:~1 UJ7><{ 'planner: MM .ray.t 1_ 'I ~. , . 6) Description of the 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 allowed only upon compliance with containment and safety standards set by the most recent Fire Code adopted by the City. Findings: The HMMP and HMMP attachments submitted with the application adequately address 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, final DWP approval will be contingent on successful completion of that inspection, 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) Findings: Section JIl(A)(3) of the applicant's HMMP adequately addresses the secondary containment requirement. In the expansion to the main Jerry's building, all hazardous materials will be stored in areas with a sealed, recessed floor capable of containing a 20-minute discharge of fire protection water, Joints in the concrete will have a chemical resistant sealer applied into them. There will be no drains in these areas, In the warehouse space adjacent to Wilco, all hazardous materials will be stored in areas with a sealed floor. Since this surface will not be sloped, the walls will be sealed to a height of 8 inches off the ground, and spill kits will be readily available and equipped with appropriate items (e.g., boom socks) to ensure that no liquids or chemicals migrate to the outside environment during a spill event or fire sprinkler event. Hazardous materials in the garden center will be stored in areas with a sealed floor and no drains and enclosed by a sealed curb capable of containing a 20-minute discharge of fire protection water, The HMMP, HMMP attachments, memo from Scott Stolarczyk to Amy Chinitz dated October 24, 2008, and the updated DWP narrative dated October 24, 2008, provide specifications and chemical resistance data for the floor sealant and treatment products to be used. Detailed maintenance procedures for the flooring in the warehouse space adjacent to Wilco will be attached to the fin.al versiQ!1 oflerry's HMMP. ," ' ';' S:\Amy Ch}nitz\Businesses_DWP apps\Jerry's\DWP app_l0-08\lerry's app response_11-3-08.doc Q~. ~ ;t'J-.. 3) All new use of DNAPLs are prohibited. Findings: The applicant submitted a letter dated October 22, 2008, from Laura j. DeBell of Response Fire Protection addressed to Lauretta Davies of jerry's Home Improvement stating, "As you requested, I have reviewed your Hazardous Materials Inventory database in comparison to the Springfield Utility Board's restrictions regarding DNAPLs. I found that none of the DNAPLs on the ~egulated list are in jerry's Home Improvement's inventory, either as pure chemicals or as ingredients within other products. I reviewed the full list and found no other chEimicals that meet the DNAPL criteria," The Springfield Utility Board's DNAPL review of the applicant's HMIS is still pending. Section II(B) of the HMMP outlines the facility's policy for ensuring that no new DNAPL chemicals will be brought onlhe premises. The'Purchasing Department will be responsible forreviewing the MSDSs for all new hazardous materials proposed to be stored atthe McKenzie Field store to ensure the product does,not contain any DNAPLs. Purchasing Department Team Members will directany' questions regarding DNAPLs to the Springfield Utility Board (SUB) Water Quality Protection Coordinator (744-3745), Additionally, any new Purchasing Department Team Members responsible for screening materials for DNAPLs will contact the SUB Water Quality Protection Coordinator for an orientation. Conditions: Chemicals used/stored on-site must be consistent with those listed on the HMIS,submitted on july 16, 2008. . On an annual basis SUB must be provided with a list of all products added to the:HMIS since the last submittal. The applicant must maintain a current list of all DNAPL products that have been reviewed and/or eliminated from the HMIS. A log of these products should be kept so they are not re-introduced to the inventory. The log should include the product name, manufacturer,and DNAPL 'cof!1ponents. Anyproduct that'is determined by SUB to contain DNAPLs must be permanently removed from the HMIS and from the facility. 4) Any change inthe type,ofuse oran 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 types offacilities 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; S:\Amy Chi,nitz\Busincsscs_DWP apps\Jcrry's\DWP app_IO-08\lcrry's app responsc_t1-3-08:doc ~,o "'. ..' -. e. Land uses and new facilities that will use, store, treat, handle, and/or produce DNAPLs. Findings: The applicant has not proposed any of the above prohibited activities. 6) Requirements 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 JIl(A) of the HMMP describes the facility's policy for monitoring secondary containment areas. 7) Requirements found in Uniform Fire Code Appendix II-ESection 3.2.7 for inspection and record keeping 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. Findings: Section V of the HMMP describes the facility's policy for monthly inspection and record keeping procedures, The inspection check list is attached to the HMMP. 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). SDC 3.3-240 CONDITIONS 1) Signage describing the policy to shut off the sump pumps during loading and unloading of hazardous materials and in the event of a spijl should be placed at both loading docks, 2) Wellhead protection signs that follow SUB's sign standard should be placed permanently at both loading docks, the entrance to the new drive-thru sales area, and at trash enclosures. 3) The applicant may contact Amy Chinitz at 744-3745 ifs/he would like to schedule a brief drinking water protection presentation for employees, 4) 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 contactme at 744-3745 if you have any questions. Sincerely, ~it~ Water Quality Protection Coordinator S:\Amy ChinitZ\Busincsses_DWP apps\lerry's\DWP app_IO-08\Jerry's app responsc_11-3-08.doc ~ Q~' V