HomeMy WebLinkAboutComments SUB 12/28/2007
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SPRINGFIELD UTILITY BOARD
\V,\TER S ER VI CE CENTE R 202 South 18th Street Springfield, OR 97477-5240 Tel 541.726.2396 Fax 541.747.7348 www.subutil.com
December 28, 2007
Molly Markarian
Development Services
City of Springfield
225 Fifth Street
Springfield, OR 97477
SUBJECT:
PEACE HEALTH RIVERBEND MEDICAL PAVILION
OVERLAY DISTRICT APPLICATION
DRC2007 -00072
Molly,
I have reviewed all documents provided for Peace Health Riverbend Medical Pavilion in light of the
items required for a City of Springfield DWP Overlay District Application (hereafter DWP
application) as outlined in Section 3.3-200 of the Springfield Development Code (SDC). The
property lies within the 1-5 year Time ofTravel 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, dearly 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: /J.-/)'f / J007
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Planner: AL
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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.
As per an e-mail from Gilbert Gordon dated December 10, 2007: "Springfield Fire Marshals
office has reviewed the DWP application for the RMP and NSC buildings. The submittals appear
to meet fire code requirements for the required HMMP and HMlS requirements. Based on these
submittals, Springfield Fire and Life Safety has no further comment at this time."
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 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 5.1 of the applicant's HMMP adequately addresses the secondary containment
requirement. However, the DWP application narrative provides information that conflicts with
the HMMP. Section 3(d) of the narrative states that "Although beyond the requirements in the
UFC and Springfield Code, Peace Health agrees to ensure the storage of corrosive compounds
(as defined by the UFC), in quantities less than the thresholds included in the UFC, are
maintained in locations that have compatible secondary containment." SDC Section 3.3-200
requires that all hazardous materials that pose a risk to groundwater be stored in areas with
approved secondary containment. Therefore, storing corrosive compounds in secondary
containment is not beyond the requirements of the Springfield Development Code, as claimed
by the applicant.
Date, Received: IJ./lt/J>o7_
Planner: AL
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Annex B of the HMMP identifies sixteen hazardous material storage areas: laboratory
processing, materials/supplies, pharmacy, housekeeping (7), medications (5), and endoscope
processing.
Medications and pharmaceuticals are not included in the HMIS. The DWP application narrative
seeks DWP exemption for "medicines."
Conditions:
The facility must follow the secondary containment policy outlined in Section 5.1 of the HMMP
submitted with the application and dated August 2007.
All sixteen hazardous material storage areas must provide secondary containment.
Because liquid pharmaceuticals and solid pharmaceuticals when dissolved in water (as in the
case of a sprinkler system release) have the potential to contaminate groundwater, the
applicant must provide more information about the quantity and types of medications and
pharmaceuticals that will be stored on site before any exemptions can be granted. Plans should
proceed to store medicines and pharmaceuticals in secondary containment.
3) All new use of DNAPLs are prohibited.
Findings:
The HMIS lists products to be used/stored on-site and landscaping products stored off-site for
use on-site. None of the products listed were found to contain DNAPLs.
Annex C of the HMMP outlines a Hazardous Material Review Procedure designed to evaluate
new chemicals for DNAPLs before they are purchased.
Conditions:
Chemicals used/stored on-site must be consistent with those listed on the HMIS.
Throughout the course of operations, any new chemicals proposed for use/storage need to be
evaluated for DNAPLs. In all cases of considering purchase of new hazardous materials, the
applicant should follow the Hazardous Material Review Procedure outlined in Annex C of the
HMMP submitted with the application and dated August 2007.
4) Any change in the type of use or an 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;
DatE" Received:
Planner: AL
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d. Fill materials containing hazardous materials;
e. Land uses and new facilities that will use, store, treat, handle, and/or produce DNAPLs.
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 10.0 of the HMMP describes the facility's policy for monitoring secondary containment
areas.
Conditions:
The facility must follow the inspection policy outlined in Section 10.0 of the HMMP submitted
with the application and dated August 2007.
7) Requirements found in Uniform Fire Code Appendix I1-E Section 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:
Sections 10.0 and 11.0 of the HMMP describe the facility's policy for inspection and record
keeping procedures.
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).
Conditions:
The facility must follow the inspection and record keeping policies outlined in Sections 10.0
and 11.0 of the HMMP submitted with the application and dated August 2007.
SDC 3.3-240 CONDITIONS
1) Materials used for landscape maintenance purposes should be used only according to
manufacturer's specifications.
2) 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.
3) Wellhead protection signage that uses the sign standard provided by SUB should be placed in
conspicuous locations (parking lot, outside of structure, building entrance, trash enclosure
area, truck entrance or loading areas if applicable) to alert staff and visitors to notify 911 in the
event of an unauthorized release of hazardous materials (please contact Amy Chinitz at 744-
3745 to purchase signs directly from SUB). n/ll /
r;::>t,. 1',"eceived:~E;.Jo'7-
PIGldiler: AL
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4) Section 9.0 of the HMMP states that "Facility personnel who handle hazardous materials and
hazardous waste may need basic training and direction...." All facility personnel who come into
contact with hazardous materials should receive at least annual training regarding the sensitive
area the clinic occupies and special precautions needed to protect the drinking water. This
training should include familiarization with the HMMP, the secondary containment
requirement, and the need to call 911 in the event of a major spill. Section 9.0 of the HMMP
should be revised to reflect this requirement. The applicant may contact Amy Chinitz at 744-
3745 if he/she would like to schedule a brief drinking water protection presentation for
employees.
Please feel free to contact me at 744-3745 if you have any questions.
Sincerely,
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Water Quality Protection Coordinator
[)3ti?l Received: J) /Jr 1'l..0"1_
Planner: AL ~.
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