U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
BP Terminal Indianapolis - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
Subject: POLREP #25
Progress PolRep
BP Terminal Indianapolis

Indianapolis, IN
Latitude: 39.8027163 Longitude: -86.2160273

To:
From: Shelly Lam, On-Scene Coordinator
Date: 9/16/2013
Reporting Period: August 16 - September 15, 2013

1. Introduction
  1.1 Background
   
Site Number: Z5K6    Contract Number:  
D.O. Number:      Action Memo Date:  
Response Authority: OPA    Response Type: PRP Oversight
Response Lead: PRP    Incident Category: Removal Action
NPL Status: Non NPL    Operable Unit:
Mobilization Date:      Start Date: 11/14/2011
Demob Date:      Completion Date:  
CERCLIS ID:    RCRIS ID:
ERNS No.:    State Notification:
FPN#: E11504    Reimbursable Account #:

1.1.1 Incident Category
Manufacturing/processing/maintenance - oil and gas storage

1.1.2 Site Description
The BP Indianapolis Terminal (the site) began operating as a petroleum storage and distribution facility since 1941.  The site consists of an administrative building, service garage, petroleum distribution rack, miscellaneous warehouse and pumping station sheds, oil/water separator, underground storage tanks (UST) and aboveground storage tanks (AST), which contain gasoline, diesel, ethanol, furnace oil, and heating oil. AST capacity ranges from 672,000 to 3,360,000 gallons, with a total capacity exceeding 18,000,000 gallons.

1.1.2.1 Location
The site is a 41-acre bulk terminal located at 2500 North Tibbs Avenue in Indianapolis, Marion County, Indiana, 46222.  Site coordinates are 39.8027163 degrees north latitude and 86.2160273 degrees west longitude.  The site is bordered by commercial property to the north; shopping plaza to the northeast; Ferguson Industrial Plastics Division and a fire station to the east; undeveloped property to the south; and Little Eagle Creek to the west.

1.1.2.2 Description of Threat
Environmental investigations conducted by BP and its consultants documented that there are petroleum-related groundwater impacts from benzene, toluene, ethylbenzene, xylenes (BTEX), methyl tertiary butyl ether (MTBE), naphthalene, ethanol, and polynuclear aromatic hydrocarbons (PAH) including benzo(a)anthracene, benzo(a)pyrene, benzo(k)fluoranthene, chrysene, dibenz(a,h)anthracene, and indeno(1,2,3-cd)pyrene beneath the site.  Light Non-Aqueous Phase Liquid (LNAPL) and dissolved-phase contamination have been found in a shallow aquifer beneath the Site and at seeps along Little Eagle Creek.  

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
Refer to previous Pollution Reports (PolRep).
2. Current Activities
  2.1 Operations Section
    2.1.1 Narrative
The site was previously in the Voluntary Remediation Program (VRP) of the Indiana Department of Environmental Management (IDEM).  IDEM referred the site to the U.S. Environmental Protection Agency (EPA) on December 13, 2010.  On November 14, 2011, EPA executed an Administrative Order by Consent (AOC) under Section 311 of the Clean Water Act.  The AOC requires BP to implement removal measures to prevent migration of petroleum hydrocarbon impacted groundwater into Little Eagle Creek.

2.1.2 Response Actions to Date
BP conducted the following activities during the reporting period: 
  • Conducted semi-monthly operation and maintenance (O&M) on the LNAPL recovery system installed at DHW-110 on August 26 and September 13, 2013;
  • Conducted Little Eagle Creek benthic community assessment and toxicity testing from August 19 - 21, 2013;

  • Conducted Little Eagle Creek surface water sampling on August 23, 2013; and

  • Submitted the Second Quarter 2013 Groundwater Monitoring Report on August 30, 2013.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
EPA executed Docket No. V-W-11 C-984, an AOC with BP on November 14, 2011.

2.1.4 Progress Metrics
Below is a schedule of items included in the AOC.  BP requested a deadline extension for submittal of the Investigation Report.   

Milestone Date Due Date Done
Effective Date 11/14/2011 11/14/2011
LNAPL Recovery, Quarterly Creek & MW Sampling 11/14/2011 11/14/2011
Contractor Notification 11/21/2011 11/21/2011
Project Coordinator Notification 11/21/2011 11/21/2011
HASP Submittal 12/6/2011 12/6/2011
QAPP Submittal 12/6/2011 12/6/2011
HASP/QAPP Approval   1/5/2012
HASP/QAPP Revisions 1/13/2012 1/13/2012
LNAPL Recovery, Creek Sampling Locations Notification, Quarterly MW Sampling 1/27/2012 1/27/2012
Creek and Groundwater Sampling Locations Revisions 2/17/2012 2/21/2012
Creek Sampling Location Approval   2/21/2012
Monthly Creek Sampling 3/6/2012 3/6/2012
On-Site Construction 12/14/2011 8/30/2011
Construction Complete 3/19/2012 3/19/2012
Investigation Work Plan 2/12/2012 2/12/2012
Revised Work Plan 4/13/2012 4/13/2012
Investigation Complete    
  - Supplemental soil characterization   6/18/2012
  - Supplemental groundwater characterization   6/22/2012
  - Supplemental surface water characterization (normal flow)   10/8/2012
  - Supplemental surface water characterization (low flow)   6/27/2012
  - Supplemental sediment characterization   6/27/2012
  - Natural Resources Assessment   9/19/2013
  - Sediment toxicity testing and analysis (benthic testing)   9/19/2013
  - Aquifer testing   10/21/2012
Investigation Report 1/31/2013 1/31/2013
Investigation Report Approval    
Removal Work Plan    
Removal Work Plan Approval    
Removal    
Final Report, 60 days after removal is complete    


  2.2 Planning Section
    2.2.1 Anticipated Activities
The following sections discuss planned response activities and next steps.

2.2.1.1 Planned Response Activities
During the next reporting period, BP will:
  • Continue to provide oversight and documentation support to EPA's On-Scene Coordinator (OSC);
  • Perform third quarter groundwater sampling from September 16 - 20, 2013;
  • Perform Little Eagle Creek monthly surface water sampling; and
  • Continue semi-monthly LNAPL recovery and system operation & maintenance O&M.

2.2.1.2 Next Steps
BP will continue addressing items in the Work Plan.

2.2.2 Issues
During the reporting period, the pump and treat system was operational for 92% of the time. The unscheduled down time occurred on August 31, 2013 when rain water accummulated in the secondary containment.  The containment was pumped out and the system was returned to service on September 3, 2013.

On August 26, 2013, the air compressor associated with the DHW-110 LNAPL recovery unit was removed from service for repair.  LNAPL was manually recovered from DHW-110 and an absorbent boom was placed in the well.  During the September 13, 2013 LNAPL recovery event, LNAPL was removed via bailer from DHW-110 and an absorbent boom was placed in the well.
  2.3 Logistics Section
    Not applicable (NA)
  2.4 Finance Section
    No information available at this time.
  2.5 Other Command Staff
    2.5.1 Safety Officer
EPA approved BP's Health and Safety Plan (HASP).  BP is conducting all environmental work at the site under the HASP.

2.6 Liaison Officer
NA

2.7 Information Officer
NA

2.7.1 Public Information Officer
NA

2.7.2 Community Involvement Coordinator
NA
3. Participating Entities
  3.1 Unified Command
NA

3.2 Cooperating Agencies
IDEM
Marion County Public Health Department
4. Personnel On Site
  A Superfund Technical Assessment and Response Team (START) contractor was on-site overseeing the benthic community assessment.
5. Definition of Terms
 
AOC Administrative Order by Consent
AST Aboveground Storage Tank
BTEX Benzene, toluene, ethylbenzene, xylenes
EPA Environmental Protection Agency
FPN Federal Project Number
HASP Health and Safety Plan
IDEM Indiana Department of Environmental Management
LNAPL Light Non-Aqueous Phase Liquid
MTBE Methyl teriary butyl ether
NA Not Applicable
O&M Operation and Maintenance
OSC On-Scene Coordinator
PAH Polynuclear aromatic hydrocarbons
PolRep Pollution Report
PRP Potentially Responsible Party
START Superfund Technical Assessment and Response Team
UST Underground Storage Tank
VRP Voluntary Remediation Program


6. Additional sources of information
  6.1 Internet location of additional information/report
Additional information can be found at www.epaosc.org/bpterminalindy.

6.2 Reporting Schedule
The OSC will submit the next PolRep on or about October 15, 2013.
7. Situational Reference Materials
  NA