U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
BP Terminal Indianapolis - Removal Polrep
Initial Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
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Subject:
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POLREP #1
Initial PolRep
BP Terminal Indianapolis
Indianapolis, IN
Latitude: 39.8027163 Longitude: -86.2160273
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To:
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From:
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Shelly Lam, On-Scene Coordinator
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Date:
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11/22/2011
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Reporting Period:
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November 14-22, 2011
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1. Introduction
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1.1 Background
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Site Number: |
Z5K6 |
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Contract Number: |
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D.O. Number: |
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Action Memo Date: |
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Response Authority: |
OPA |
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Response Type: |
PRP Oversight |
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Response Lead: |
PRP |
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Incident Category: |
Removal Action |
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NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
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Start Date: |
11/14/2011 |
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Demob Date: |
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Completion Date: |
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CERCLIS ID: |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
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FPN#: |
E11504 |
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Reimbursable Account #: |
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1.1.1 Incident Category
Manufacturing/processing/maintenance - oil and gas refining
1.1.2 Site Description
The BP Indianapolis Terminal (the Site) has operated 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 latitude and 86.2160273 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
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
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) has been found in a shallow aquifer beneath the Site and at seeps along Little Eagle Creek. This LNAPL was detected in on-Site monitoring wells at a maximum thickness of 5.83 feet in monitoring well DHW-110 in June 2008.
Recovery efforts to date have included using absorbent booms and pads in monitoring wells and Little Eagle Creek, manual bailing of monitoring wells, operation of a groundwater pump and treat system as a biosparge system, phytoremediation, and operation of an automated passive skimmer. Between 2006 and February 2010, 190.36 gallons of LNAPL were recovered.
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.
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
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
To date, BP has notified EPA of its designated contractor and project coordinator. Additionally, as per Section 31 of the AOC, BP has continued removal actions previously approved by IDEM including LNAPL recovery, quarterly surface monitoring in Little Eagle Creek, and quarterly sampling of groundwater from monitoring wells. In addition, BP has initiated construction of pump-and-treat system as a interim removal action, in accordance with Section 31(d) of the AOC.
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:
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Date Due |
Date Done |
| Effective Date (ED) |
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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 |
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| QAPP Submittal |
12/6/2011 |
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| On-Site Construction |
12/14/2011 |
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| Construction Complete |
2/12/2012 |
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| Investigation Work Plan |
2/12/2012 |
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2.2 Planning Section
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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 submit a Health and Safety Plan (HASP) and Quality Assurance Project Plan (QAPP). BP will continue LNAPL recovery and quarterly groundwater monitoring, and initiate monthly sampling of Little Eagle Creek
2.2.1.2 Next Steps
BP will continue construction of the interim pump-and-treat system and submit a work plan for additional investigation.
2.2.2 Issues
None
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2.3 Logistics Section
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Not applicable (NA)
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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2.5.1 Safety Officer
BP is preparing a HASP to submit to EPA for approval.
2.6 Liaison Officer
NA
2.7 Information Officer
NA
2.7.1 Public Information Officer
2.7.2 Community Involvement Coordinator
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3. Participating Entities
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3.1 Unified Command
NA
3.2 Cooperating Agencies
IDEM
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4. Personnel On Site
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NA
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5. Definition of Terms
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| AOC |
Administrative Order by Consent |
| AST |
Aboveground Storage Tank |
| BTEX |
Benzene, toluene, ehtylbenzene, 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 tertiary butyl ether |
| NA |
Not Applicable |
| OSC |
On-Scene Coordinator |
| PAH |
Polynuclear aromatic hydrocarbons |
| PRP |
Potentially Responsible Party |
| QAPP |
Quality Assurance Project Plan |
| UST |
Underground Storage Tank |
| VRP |
Voluntary Remediation Program |
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6. Additional sources of information
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6.1 Internet location of additional information/report
Additional information can be found at www.epaosc.org/bpterminalindy.
6.2 Reporting Schedule
The next PolRep will be submitted in December 2011.
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7. Situational Reference Materials
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NA
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