HomeMy WebLinkAboutRemonstrance Packet - Indianapolis Water Department of Waterworks, City of Indianapolis "DOW
Legacy PUD (Turkey Hill Minit Market)
Docket No.: 10110012 DP /ADLS
June 15, 2011
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Based upon the foregoing, DOW believes that approval and subsequent operation of a
fueling station at this location poses an unreasonable risk of groundwater contamination,
recommends against approval, and respectfully requests that the Plan Commission deny the
Development Plan associated with Docket No. 10110012 DP /ADLS. Thank you.
71/1 61 -4 6A1 fL r1
Sincerely,
7
Matthew Klein, Executive Director
Department of Waterworks
City of Indianapolis
Attachment: Keramida Report dated June 14, 2011
Legacy PUD (Corner Use Block Permitted Use Table)
401 North College Avenue
Indianapolis, Indiana 46202
(317) 685 -6600 Fax (317) 685 -6610
Global EHS Sustainability Services 1- 800 -508 -8034
keramida @keramida.com www.keramida.com
June 14, 2011
Mr. Andy Bowman
Bingham McHale
10 West Market Street
Suite 2700
Indianapolis, IN 46204
Re: Turkey Hill Minit Markets Gas Station Store #604 at Legacy Corner
7729 East 146 Street River Road
Carmel, Indiana
KERAMIDA Project No. 14271
Dear Mr. Bowman:
Pursuant to your recent request, KERAMIDA Inc. (KERAMIDA) has reviewed the publically
available information regarding the potential construction of anew retail gasoline station on the
southwest corner of East 146 Street and River Road in Carmel, Indiana. More specifically, the
proposed station is identified as Turkey Hill Minit Markets Gas Station Store #604 at Legacy
Corner, 7729 East 146 Street, Carmel, Indiana, 46033 (Site). In addition to the publically
available information regarding the proposed Site, KERAMIDA reviewed documents pertaining
to the location of public supply wells in the vicinity of the Site. The proposed development of the
Site includes construction of a retail gasoline station/convenience store equipped with
underground storage tanks (UST), dispensers and associated subsurface piping. The proposed
development also includes construction of a car wash, paved areas, landscaping, subsurface
utilities and associated stormwater controls.
BACKGROUND
Potential Contaminant Sources Potential sources of contaminants resulting from the
operations of the proposed gas station consist of the following primary areas of concern:
Underground Storage Tanks (USTs) and associated piping.
Surface releases associated with:
o Fuel dispensing operations including spills, overfills and incidental drips and
spills over an extended period of time.
o Filling operation during bulk fuel deliveries including tanker failure, spills,
overfills and incidental drips and spills over an extended period of time.
Releases of contaminated water from car wash operations to surface water and
groundwater.
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Turkey Hill Minit Markets
Gas Station Store #604 at Legacy Corner
Page 2
Wellhead Protection Areas Based upon the available information, the Site is located within the
sand and gravel outwash unit of the White River Valley of Central Indiana. This sand and gravel
outwash aquifer is the principal supply of drinking water to thousands of people in the nearby
metropolitan areas (Carmel, Fishers, Indianapolis, Noblesville and Westfield), as evidenced by
the numerous public water supply wells located within this unit in an area generally described as
extending south from SR32 to 96 Street and east from Keystone Avenue to Allisonville Road.
The area with the greatest continuous thicknesses of the aquifer is located between 126th and
146 street parallel to, and west of the White River. The sand and gravel outwash unit consists
of well sorted, coarse grained material. Overlying the outwash deposits in most areas is a thin
(3 -5' thick) layer of organics and topsoil. Of particular significance is the fact that the Site is
located within the one -year time of travel boundary of the wellhead protection zone for both the
City of Carmel and Indianapolis Department of Water Works wellheads. In addition, the Site is
located in close proximity to the wellhead protection zone for the City of Westfield, and is
located within the buffer zones for three additional public water supply wells.
Development of a "greenfield" (historically undeveloped) property for a retail gasoline service
station or other similar facility is generally inconsistent with allowable property use(s) within a
designated wellhead protection area and in fact, is prohibited by many municipal wellhead
protection plans, including those of nearby communities (e.g., Indianapolis /Marion County,
Westfield). The following local agencies have submitted letters to the City of Carmel Plan
Commission expressing concern regarding the proposed service station at the site:
Hamilton County Emergency Management Agency
Hamilton County Surveyor's Office
City of Indianapolis Department of Waterworks
City of Westfield
City of Noblesville
Town of Fishers
POTENTIAL AREAS OF CONCERN RELATING TO A
GASOLINE SERVICE STATION AT THE SITE
As summarized previously, there are a number of areas of concern relating to operation of a
gasoline service station at the Site. These issues are discussed in detail below:
Operation of a UST system while federal and state regulations promulgated since 1986
have significantly reduced the potential for releases from UST systems, the occurrence of
releases has not been completely eliminated. According to the U.S. Environmental
Protection Agency (USEPA), there were more than 6,300 confirmed releases of
petroleum hydrocarbons from UST systems nationwide in fiscal year 2010, which works
out to a little more than 17 per day. Even minor releases (on the order of three gallons,
according to the Indiana Department of Environmental Management [IDEM] and other
regulatory agencies) of gasoline have the potential to adversely impact potable wells,
including municipal wells. This is due primarily to the fact that gasoline contains
benzene, a known human carcinogen with a federal drinking water standard of just 5
Turkey Hill Minit Markets
Gas Station Store #604 at Legacy Corner
Page 3
parts per billion (ppb). Gasoline contains up to 2% benzene by volume, so a gallon of
gasoline may contain up to 20,000,000 ppb of benzene. Benzene is also more highly
soluble than other gasoline constituents and thus can more readily impact a larger portion
of an aquifer.
Although the proposed UST system will reportedly include double walled tanks and
piping with interstitial monitoring, this does not completely eliminate the potential for
releases. According to the IDEM (329 IAC 9- 7- 4[8]), interstitial monitoring systems for
USTs are only required to detect a release of up to 0.2 gallons per hour or a release of 150
gallons within a month. In addition, these systems are only required to have a probability
of detection of 0.95, meaning they must detect releases meeting the above criteria in 95
out of 100 cases. Interstitial monitoring systems for UST system piping (also known as
automatic leak detectors) must be able to detect a 0.1 gallon per hour release.
Consequently, for example, a release of just under 0.1 gallons per, hour (approximately 2
gallons per day) would go undetected by an interstitial monitoring system. Interstitial
monitoring systems also do not detect vapor releases, which are a very common source of
groundwater impacts at service stations.
Surface releases another concern with respect to USTs and groundwater contamination
are vapor releases and small spills of fuel that routinely occur when fuel is dispensed to
vehicles. Vapor releases are not detectable by conventional leak detection systems but
can result in groundwater impacts as vapors adsorb to soils and gradually desorb into
underlying groundwater as a result of seasonal water table fluctuations and /or infiltration
of surface water. Spills, overfills, and drips over an extended period of time in the same
general area (fuel dispensers) can also eventually impact shallow groundwater by seeping
through joints, cracks, or other defects in the pavement. Similarly, minor spills and drips
during bulk fuel deliveries from tanker trucks can also result in groundwater impacts over
an extended time period. According to the Analysis of U.S Oil Spillage (API Publication
356, August.2009), spills from tanker trucks increased 76% during the period from 1998-
2007, compared to the previous decade.
In addition, surface water flowing across the site can also pick up hydrocarbons when
passing through the fueling areas. While stormwater separator systems may be able to
capture free -phase product if properly designed, they do not typically address dissolved
phase impacted water that may result from sheet flow, and this water can then impact
shallow groundwater and /or surface water (such as the nearby White River in the case of
the Site).
Although uncommon, the potential for larger surface spills is also present at any active
gasoline service station. The API report referenced above indicated an average annual
spillage of 814 barrels (approximately 35,000 gallons) of oil at service stations and truck
stops from 1998 -2007, a decrease from the previous decade but a significant number
nevertheless. A catastrophic failure of a tanker truck, while a remote possibility could
occur, or more commonly an automobile could drive off with a fueling hose still attached
to the gas tank, resulting in a surface spill. Finally, a collision involving an automobile
and a fuel dispenser could result in a surface spill._ All of these possibilities would
adversely affect the groundwater below the Site if the spilled material penetrated the
pavement and/or flowed off the pavement into an unpaved area.
Turkey Hill Minit Markets
Gas Station Store #604 at Legacy Corner
Page 4
Car wash operations the proposed service station at the Site includes a car wash, which
is another potential source for impacts to shallow groundwater. Oil, grease, anti- freeze,
and other such materials removed from the vehicles during the washing process can
impact shallow groundwater by migrating into the subsurface through joints or cracks in
the pavement. In addition, these materials can also impact surface water if the water
treatment system for the car wash leaks, fails, or is improperly designed and/or installed.
Flood plain issues although the Site is not currently located within the 100 -year
floodplain of the White River, it is in close proximity to and virtually surrounded by
floodplain areas (National Flood Insurance Program, Flood Insurance Rate Map,
Hamilton County, Indiana, Panel 235 of 290, Map Number 18057CO235F). Further
development in the area could potentially alter the surface flow characteristics, resulting
in complete or partial flooding of the Site during a major storm event or other period of
high water in the nearby White River (e.g., spring flooding).
In summary it is our opinion that this is not a good location for the construction of a service
station. Should you have any questions regarding this correspondence, please contact us at 685-
6600.
Sincerely,
KERAMIDA Inc.
k)
Douglas B. Zabonick, .E.
President