HomeMy WebLinkAboutComments SUB 9/17/2008
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From: CHINITZ Amy C. [AmyC@subutil.com]
Sent: Wednesday, September 17, 2008 3 :23 PM
To: CHINITZ Amy C.; babyfacetowing@yaboo.com
Cc: METZGER Mark .
Subject: Babyface DWP application comments
Attachments: HMMP 082207.pdf
Roger,
I just finished looking through the Drinking Water Protection Overlay District application you
submitted. Your narrative included most ofthe relevant information, and you did a great job describing
how you will.contain fluids from the vehicles; but the application was missing the hazardous materials
management plan (like the exampie I had given you from the Holiday Inn). The hazardous materials
management plan is not just for the purposes of this application. 'It is supposed to be the reference
document you keep on site for how you manage haz mats, prevent and contain spills, monitor and
inspect, and train employees. I have attached another example that you may find useful. You can copy
a great deal from this example and then add your own information as well. Much of the information
from your narrative can simply be incorporated into your HMMP.. Please'take a look at my comments
below, and then J[j]d be happy to walk you through the missing pieces.
The HMMP will need to describe your procedure for inspecting all the locations that have haz
mats (tne vehicles and the two drums) to keep an eye out for leaks, drips, defects, etc. The
HMMP should include an inspection sheet, and the inspection sheets should be logged on
site. Both of the HMMP examples I sent you include inspection sheets. Since you donl1lt have a
lot of storage locations, yours can be relatively simple. Please note that the inspection sheet
should include the floor as qne of the areas to be inspected.
You mentioned that all employees are trained in haz mat cleanup. The HMMP should list the
employee training topics and training schedule. See the attached HMMP for an
example. Training topics should include awareness ofthe drinking water protection area (I am
available as a resource to help with that, either by visiting with the staff or providing talking
points for you to share with them).
.. Who is responsible for placing the pans under the vehicles? PI~ase specify this in the HMMP
(this is important since the on.site employee is not always there). It would be helpful if you
placed a sign inside that reminded employees to place the pans under the vehicles.
As we discussed during the site visit, you will need to place on Springfield wellhead protection
sign outside the building.
We still havenl1lt received from Nick Cheney the confirmation from DEQ that the injection well
meets current Underground Injection Control (Ule) regulations. We need this confirmation to
approve the DWP permit.
Asyou stated, the cracks and joints in the concrete floor must be sealed. Nick Cheney has
indicated that the floor was already sealed. In order for the previous sealant application to
satisfy this requirement, he will need to provide information as tothe product used, the
productl1ls chemical resistance, the date of application, and any maintenance that has
occurred. We will then need to inspect the floor again to verify its condition. If we determine
that the floor needs to be sealed again, please provide u's specs for the chosen product and
application method before performing the application.
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Date Received, .--". ~
Planner: MM -
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. The HMMP should include a procedure for maintaining and repairing as necessary the floor
sealant. If you opt to work with Ron Watts, he will be able to provide you with this information.
Amy E. Chinitz."M.C.R.P, M.S.
Water Quality Protection Coordinator
Springfield,Utility Board
202 South 18th Street
Springfield. OR 97477
Phol1e: 541.744.3745
F;ax: 541.747.7348
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Date eC8l. ., ,., ---. ',---.
Planner: MM