U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
BP Terminal Indianapolis - Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
|
|
Subject:
|
POLREP #29
Progress PolRep
BP Terminal Indianapolis
Indianapolis, IN
Latitude: 39.8027163 Longitude: -86.2160273
|
|
To:
|
|
|
From:
|
Shelly Lam, On-Scene Coordinator
|
|
Date:
|
1/21/2014
|
|
Reporting Period:
|
December 16, 2013 - January 15, 2014
|
|
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 January 13, 2014; and
- Submitted the revised Investigation Report.
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 (ED) |
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 (HQA) |
|
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 (CS) |
|
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 (IC) |
|
|
| - 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 |
|
8/19/2013 |
| - Sediment toxicity testing and analysis (benthic testing) |
|
8/19/2013 |
| - Aquifer testing |
|
10/20/2012 |
| Investigation Report |
1/28/2013 |
1/28/2013 |
| Investigation Report Approval (IRA) |
|
1/21/2014 |
| Removal Work Plan |
3/22/2014 |
|
| Removal Work Plan Approval (RWA) |
|
|
| 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 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 submit a removal work plan by March 22, 2014.
2.2 Issues
Little Eagle Creek could not be sampled due to cold temperatures and ice.
During the reporting period, the pump and treat system was operational 53% of the time. The following unscheduled down times occurred:
-
December 15, 2013: high pressure on the transfer pump due to loading of the particulate bag filters caused the system to be down for one day;
-
December 21, 2013: rainwater accumulated in the secondary containment. The secondary containment was pumped out and the system returned to service on December 23, 2013;
-
December 27, 2013: during a system inspection, field staff noticed a small drip originating from the intake manifold. The manifold was fixed and the system returned to service on December 30, 2013;
-
January 3, 2014: lines inside the trailer froze causing partial damage to the plumbing of the system. No release occurred due to the system being systematically shut off during the forecasted extreme weather. Parts have been ordered to repair damaged plumbing and will be installed beginning on January 15, 2014.
|
|
|
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
|
|
|
EPA's Superfund Technical Assessment and Response Team (START) contractor conducted oversight of groundwater sampling during the reporting period.
|
|
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 January 15, 2014.
|
|
7. Situational Reference Materials
|
|
|
NA
|
|
|
