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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) 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
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.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
BP submitted their Investigation Report on January 31, 2013. The report was intended to detail site conditions and fill identified data gaps. EPA concluded the following after reviewing the report, and asked that BP address deficiencies noted in the Comments letter, dated March 25, 2013, which is posted to www.epaosc.org/bpindyterminal.
1. There are high levels of benzene in groundwater monitoring wells directly adjacent to Little Eagle Creek. Data from June 2012 indicated that benzene was as high as 2,800 micrograms per liter (ug/L) in DHW-96 and 1,170 ug/L in OW-32. Both wells are located within feet of the banks of the creek.
2. LNAPL has been detected in measurable thickness at two different locations at the facility. The LNAPL plume associated with Tank 6 has been observed in DHW-84, less than 150 feet from the creek.
3. The current remediation system consists of a pump and treat system, interceptor trench, and extraction wells. The aquifer testing data presented in the report shows that several wells adjacent to the creek with high concentrations of benzene are outside the capture zone of the remediation system and/or the remediation system is not effectively preventing contaminant migration.
4. Benzene was detected in sediment samples, with one sediment sample above the Region 5 Ecological Screening Level at 143 micrograms per kilogram (ug/kg) and lower concentrations detected downstream.
5. Benzene has been detected in the surface water of Little Eagle Creek.
6. Benzene appears to be migrating from the facility into the sediments and surface water of Little Eagle Creek.
During a call with BP and their consultant on April 3, 2013, EPA also asked BP to address an area in the southwestern part of the property where groundwater mounding has been occasionally observed. Mounding could indicate that groundwater flow in that area is radial. As such, the full extent of contamination in groundwater and Little Eagle Creek may not be defined.
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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
BP conducted the following activities during the reporting period:
- Continued pump and treat system operation;
- Completed monthly system sample collection;
- Conducted semi-monthly O&M on the LNAPL recovery system installed at DHW-110;
- Conducted semi-monthly manual LNAPL recovery and related breathing zone monitoring;
- Completed carbon exchange on all six carbon vessels on April 12, 2013;
- Completed monthly Little Eagle Creek sampling on April 9, 2013; and
- Submitted the January 2013 Little Eagle Creek Sampling 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) |
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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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| - Sediment toxicity testing and analysis (benthic testing) |
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| - Aquifer testing |
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10/21/2012 |
| Investigation Report |
1/31/2013 |
1/31/2013 |
| Investigation Report Approval (IRA) |
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| Removal Work Plan |
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| Removal Work Plan Approval (RWA) |
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| Removal |
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| Final Report, 60 days after removal is complete |
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