HomeMy WebLinkAboutComments SUB 2/25/2010
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SPRINGFIELD UTILITY BOARD
WATER SERVICE CENTER 202 South 18th Street Springfield. OR 97477-5240 Tel 541.726.2396 Fax 541.747.7348 www.subutil.com
February 25, 2010
Mark Metzger
Development Services
City of Springfield
225 Fifth Street
Springfield, OR 97477
SUBJECT:
FRESENlUS MEDICAL CARE - D,S. of SPRINGFIELD
DRINKING WATER PROTECTION OVERLAY DISTRICT APPLICATION
Mark,
I have reviewed all documents submitted for the Fresenius Medical Care 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 5 - 10
year and 10 -20 year Time ofT ravel Zone to the Q Street wellhead and is governed by the
standards of the 5 - 10 year TOTZ (SDC 3.3-220(C)(3)).
SDC 3.3-225 (D): REVIEW
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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.
COMPLETE.
4) Description o'fthe 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.
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6) Description of the procedures for inspection and maintenance of containment devices
and emergency equipment.
COMPLETE. See Section (5) 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 (C): 5-10 YEAR TOTZ STANDARDS FOR APPROVAL
1) The storage, handling, treatment, use, 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 is allowed upon compliance with
containment and safety standards specified by the most recent Fire Code adopted by the
City.
Findings:
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The HMMP submitted with the application addresses product and container labeling, provision
of spill kits, spill prevention, and emergency response procedures.
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Conditions:
If the Springfield Fire Marshall's office requires a physical inspection, DWP approval will be
contingent on successful completion of that inspection.
2) 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 III oftre 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.
Section III of the HMMP identifies ten hazardous material storage area locations.
Conditions:
All stored pharmaceuticals shall be kept in secondary containment.
3) All new use of DNAPLs are prohibited.
Findings:
The HMlS lists products to be used and stored on-site. None of the products listed were found
to contain DNAPLs.
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Section II of the HMMP states that products containing DNAPLs are prohibited and that any
new products p'roposed for use or storage on site shall be evaluated for DNAPLs by the
Springfield Utility Board Water Quality Protection Coordinator,
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 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 other 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.The following
certain types'offacilities or changes in chemical use and/or storage of hazardous or
other materhlls that pose a risk to groundwater are prohibited:
Findings:
Section V 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. '
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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 CONpITIONS
1) Section I(B) and Section VI of the HMMP shall indicated that a drain mat (rather than an
"absorbent spill mat") will be kept on site to cover the stormwater catch basin in case of a spill.
2) The final HMM"P shall be signed by the owner/operator or designated representative.
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 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,
~ni~
Water Quality Protection Coordinator
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