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BP Terminal Indianapolis

All POL/SITREP's for this site BP Terminal Indianapolis
Indianapolis, IN - EPA Region V
POLREP #26
Progress PolRep 		Printer Friendly  |   PDF
 
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 #26
Progress PolRep
BP Terminal Indianapolis

Indianapolis, IN
Latitude: 39.8027163 Longitude: -86.2160273

To:
From: Shelly Lam, On-Scene Coordinator
Date: 10/21/2013
Reporting Period: September 16 - October 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 September 29 and October 11, 2013;

  • Conducted Little Eagle Creek surface water sampling on September 25, 2013; and

  • Submitted the August 2013 Little Eagle Creek Sampling Report on October 9, 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   9/19/2013
  - 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 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
    EPA will provide BP additional comments on their Investigation Report.  BP will resubmit their investigation report based on EPA's comments.  After final approval of the investigation report, BP will submit a removal work plan.

    2.2 Issues
    During the reporting period, the pump and treat system was operational 93% of the time. The only unscheduled down time occurred on October 5, 2013 when rain water filled the secondary containment, causing an automatic shutdown of the system. The secondary containment was pumped out and the system returned to service on October 7, 2013.
      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 and its contractors were not on-site 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 November 15, 2013.
    7. Situational Reference Materials
      NA