U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
BP Terminal Indianapolis - Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
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Subject:
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POLREP #53
Progress 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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Paul Atkociunas
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Date:
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2/16/2016
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Reporting Period:
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January 15 to February 14, 2016
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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 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 (PolReps).
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2. Current Activities
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2.1 Operations Section
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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
Please refer to previous Polreps for actions prior to this reporting period. During the reporting period, Kinder Morgan Liquids Terminals LLC / BP conducted the following actions:
- Conducted routine maintenance on the groundwater extraction and treatment system.
- Conducted the monthly light non-aqueous phase liquid (LNAPL) recovery on January 15, 2016.
- Monthly Little Eagle Creek surface water sampling was not conducted in January due to frozen conditions. Three separate attempts were made to sample the creek on January 22, 25, and 29, 2016, but were unsuccessful.
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. On or about February 1, 2016, BP Products North America sold the terminal to Kinder Morgan. Kinder Morgan Liquids Terminals LLC (KMLT) currently operates the facility. BP Products North America Inc. is the owner of the site. Paragraph 6 of the AOC states the Order applies to persons who succeed to a controlling interest in BP. The AOC also states that any change in ownership or corporate status of Respondent, including but not limited to a transfer of assets or real or personal property relating to the site, will not alter BP's responsibilities under the Order.
2.1.4 Progress Metrics
On September 8, 2014, BP submitted a data package for the design of a Modified GWET system in accordance with the AOC. EPA provided comments and BP submitted a Revised Modified GWET system data package. On October 27, 2014, EPA approved the design in the Modified GWET Data Package, which is incorporated and fully enforceable under the AOC.
| 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) |
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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) |
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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) |
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| - Supplemental soil characterization |
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6/18/2012 |
| - Supplemental groundwater characterization |
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6/22/2012 |
| - Supplemental surface water characterization (normal flow) |
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10/8/2012 |
| - Supplemental surface water characterization (low flow) |
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6/27/2012 |
| - Supplemental sediment characterization |
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6/27/2012 |
| - Natural Resources Assessment |
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8/19/2013 |
| - Sediment toxicity testing and analysis (benthic testing) |
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8/19/2013 |
| - Aquifer testing |
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10/20/2012 |
| Investigation Report |
1/28/2013 |
1/28/2013 |
| Investigation Report Approval (IRA) |
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1/21/2014 |
| Removal Work Plan |
3/24/2014 |
3/24/2014 |
| Removal Work Plan Approval (RWA) |
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6/9/2014 |
| Removal |
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3/30/2015 |
| Final Report |
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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, KMLT / BP will:
- Continue to provide oversight and documentation support to the OSC;
- Perform the Little Eagle Creek monthly surface water sampling event, weather and stream levels permitting;
- Provide EPA a Capture Zone Analysis Report; and
- Continue monthly LNAPL recovery and operation and maintenance (O&M) of the GWET system.
2.2.1.2 Next Steps
EPA will continue to conduct oversight of the removal action and monitor progress / compliance with the AOC. EPA will review the Capture Zone Analysis Report.
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
KMLT / BP is conducting work associated with the AOC at the site under an approved Health and Safety Plan (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
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3. Participating Entities
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3.1 Unified Command
NA
3.2 Cooperating Agencies
IDEM
Marion County Public Health Department
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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, ethylbenzene, xylenes |
| EPA |
Environmental Protection Agency |
| FPN |
Federal Project Number
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GWET
HASP |
Groundwater Extraction and Treatment System
Health and Safety Plan |
| IDEM |
Indiana Department of Environmental Management |
| LEL |
Lower Explosive Limit |
| 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 |
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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 OSC will submit the next PolRep on or about March 16, 2016.
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7. Situational Reference Materials
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NA
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