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HomeMy WebLinkAboutJohn Duffy, Utilities Dept. Letter 9-12-2013Carmel Utilities City of Carmel Utilities 760 Third Avenue S.W., Ste. 110 • Carmel, IN 46032 Phone. (317) 571 -2443 • Fax (3 M 571 -2265 vv vcarmel.in.gov September 12, 2013 Ricker Oil Company Weihe Engineers, Inc. Creek Run L.L.C. PO Box 150 10505 N. College Ave. Environmental Engineering 30 W. 11th Street Indianapolis, IN 46280 P.O.Box 114 Anderson, IN 46016 Attn: Jamie Shinneman Montpelier, IN 47359 Attn: Terry Matthews RE: Proposed Ricker Oil Retail Station —146th Street and River Road —Carmel, IN Attached are two documents. The first is Carmel Utilities initial comments on the proposed fuel station and the report by Zenon Geosciences, Inc... Please understand that these comments and requirements should be considered as our initial review and we reserve the right to require additional items upon your response to our questions and requirements. Our comments are based on the information provided in the Zenon report. The report, along with our comments, questions, and requirements represent what we believe need to be addressed in a satisfactory manner before Carmel utilities can sign off on the issuance of building permit for a fuel station at this location. We are ready and willing to meet with you in the very near future after you have had time for review. I do appreciate your patience waiting for our response to your submittal and look forward to future discussion. Sin"cceerrely, John D Director of Utilities C: Mike Hollibaugh, DOCS Director Mike McBride, Carmel City Engineer Carmel Utilities comments on the proposed fuel station at 146th and River Road. 1. The report submitted by Creek Run L.L.C. calls for triple walled underground storage tanks to be installed. While we appreciate the fact that a triple walled underground petroleum storage tank is above what State of Indiana and Federal regulations requires, it is our opinion that all petroleum storage tanks, piping, and ancillary below grade equipment should be placed in constructed vault or similarly protective structure. Having the underground tanks installed within a vault provides ready access for visual inspections, immediate removal of released product, and offers the best protection against releases that are not detected by monitoring systems. The Creek Run report discusses the installation of vapor monitoring wells to detect soil gas vapors such as a photoionization detector. Does this system offer automatic real —time monitoring? The installation of automatic monitoring inside the vault structure can and should be checked monthly and would provide current information as opposed to vapor monitoring on a semi - annual basis that the Creek Run report discusses. Please address how a triple walled tank offers superior protection to the ground water resources in the area over a single walled tank system that is constructed within a vault structure? Item 3.3 of the Creek Run submittal states that "any spills during refueling will overflow into the concrete vault of the UST ". Please explain in more detail what this concrete vault is and what it is intended for? 2. The paved area underneath the canopy calls for the dispensers to have sumps installed to contain leaks from fuel piping or a loose fitting. It is our opinion that the better overall method is to have this area drain to a sump or similarly protective structure. This will provide protection against excessive overflows and spillage and capture the majority of contaminants associated with the operation of a gas station. The pavement outside of the canopied area should be graded to drain away from the canopied area. 3. The release detection regulations theoretically allow a release of 70 gallons per month or more to continue without detection. Please quantify, and address the maximum monthly volume that will go undetected bythe TRUCHEK leak detection system. 4. Please provide a detailed release monitoring and detection plan. In so doing, please address how the proposed tank pit monitoring wells will address the potential of spilled fluids infiltrating the soil before reaching the tank pit monitoring well given the permeability of the native soils in the area. The plan should also take into account potentially significant groundwater fluctuations that may be seasonal or during time of low ground water recharge. 5. The Creek Run submittal calls for a lined detention pond located off— site of the subject property to the west. The intent of the pond is to provide storm water treatment and serve as a catchment basin in the event of a large release. We believe this to be a positive measure for containing spills and releases. There are concerns regarding ownership, on -going maintenance and in the event of a spill, clean up and remediation. With that in mind, please provide documentation showing who will own and maintain the pond. Who will have the responsibility of maintenance of the pond on an on -going basis? What arrangements are in place as to who will be responsible for clean up should a major release occur? In general, we want to know who owns it and who is responsible for it? Please provide appropriate legal documents addressing these questions. Please provide financial documentation demonstrating that the owner and operator of the gas station and the retention pond have financial resources to immediately address small and large spills and /or releases. The pond is designed to have a six inch clay liner. Please explain why clay is a better choice than a synthetic liner that is capable of complete prevention of percolation to the underlying soils? Valves must be placed both upstream and downstream of the pond /basis to allow positive flow control in the event of catastrophic releases. 6. All storm water components must protect against release of pollutants to the surface. Please reference comments submitted to the City Engineers office. 7. Please provide more detail on your release and contingency response plan. Specifically, an analysis of the rate of contaminant migration and travel —times to potential receptors. An emergency response plan needs to be submitted that demonstrates a response that is the most protective of the nearest receptor. 8. All materials, UST system components, storm water components, liners, etc. that are relied upon to protect the ground water aquifer must be compatible with today's fuel blends and with probable E85 and biodiesel. It will be the owner's responsibility to insure that all future fuels are compatible with the materials used in the fueling tanks, piping, and related components. The owner needs to be able to show how they will manage the risks of associated with the use of a UST system of BMP components that are no longer compatible with fuel blends as federal mandates change overtime. 9. Carmel Utilities wants to be notified of any spills in excess of 3 gallons for petroleum and .5 pounds of other hazardous materials. 10. Please submit a detailed ground water protection plan demonstrating a recognition and understanding of the hydro geological conditions that render the ground water vulnerable to contamination, the possible causes of spills and releases, including those that are present or sudden, small or large volume, to the surface, or subsurface. The plan should further detail spill prevention measures, the use of dispersants, maintenance schedules for the BMP's, and a snow removal plan showing snow storage areas. These comments are our "first review comments ", and as such we reserve the right to make additional comments and require additional items and procedures to be installed and implemented upon your review and answers to our questions. Thank You.