INITIAL ABATEMENT REPORT ALLIED AVIATION RONALD REAGAN WASHINGTON NATIONAL AIRPORT FUEL FARM FACILITY Pollution Complaint # 2016-3082 11 Air Cargo Road ARLINGTON, VA 22202 Prepared for: Mr. Randy Chapman, Case Manager Virginia Department of Environmental Quality Northern Regional Office 13901 Crown Court, Woodbridge, Virginia 22193 Prepared by: Amec Foster Wheeler Environment & Infrastructure, Inc. 14424 Albemarle Point Place, Suite 115 Chantilly, VA 20151 On Behalf of: Allied Aviation Fueling Company of National Airport, LLC. 11 Air Cargo Road, Ronald Reagan National Airport Washington, DC 20001-4986 December 4, 2015 Amec Foster Wheeler Project No. 376350017
December 4, 2015 Mr. Randy Chapman Environmental Remediation Manager Virginia Department of Environmental Quality 13901 Crown Court, Woodbridge, VA 22193 Subject: Report of Initial Abatement Measures Allied Aviation, Ronald Reagan Washington National Airport Fuel Farm Facility LUST Case#: 2016-3082 Dear Mr. Chapman, On behalf of Allied Aviation Fueling Company of National Airport, LLC. (Allied). Amec Foster Wheeler Environment & Infrastructure, Inc. (Amec Foster Wheeler) is pleased to present this report describing the Initial Abatement Activities conducted at the Ronald Reagan Airport Fuel Farm Facility (site) located at Thomas Avenue, Arlington, Virginia. This report has been prepared in response to your November 3, 2015 letter regarding the confirmed petroleum release from the site on October 30, 2015 (Pollution Complaint #2016-3082). If you have any questions regarding this report, please do not hesitate to contact Mr. Brian Sariano of Amec Foster Wheeler at 215-272-4222 or via email at Brian.Sariano@amecfw.com or Mr. Jim Buchanan of Allied Aviation at 703-417-9770 or Jim.Buchanan@AlliedAviation.com. Sincerely, Amec Foster Wheeler Environment & Infrastructure, Inc. Daniel Dunlap, P.G. Geologist Brian Sariano Associate - Environmental Scientist Cc: Mr. Jim Buchanan, Allied Aviation Mr. Al Voelkle, P.G., Allied Aviation Correspondence: Amec Foster Wheeler 14428 Albemarle Point Place, Suite 115 Chantilly, Virginia 20151 USA Tel +1 (703) 488 3700 Fax +1 (703) 488 3701 amecfw.com
TABLE OF CONTENTS EXECUTIVE SUMMARY... 1 1.0 INTRODUCTION... 2 2.0 STORAGE TANK INFORMATION... 2 3.0 RELEASE INFORMATION... 2 4.0 INITIAL ABATEMENT MEASURES TAKEN... 4 5.0 CORRECTIVE ACTION MEASURES... 6 TABLE 1 Surface Water Analytical Results FIGURES 1 Site Location Map 2 Monitoring Well and Site Feature Map APPENDICES APPENDIX A Virginia DEQ Correspondence APPENDIX B Certificates of Disposal and Emergency Response Contractor Field Reports APPENDIX C Amec Foster Wheeler Memo APPENDIX D Laboratory Analytical Report APPENDIX E DCA Fuel Release Recap of Fuel Accounting APPENDIX F Corrective Action Plan APPENDIX G Daily Outfall Inspection Logs
EXECUTIVE SUMMARY A release of approximately 13,620 gallons of Jet Fuel A occurred at the Ronald Reagan Washington National Airport Fuel Farm Facility operated by Allied Aviation Fueling Company of National Airport, LLC (Allied) on October 29, 2015. Initial assessments indicated that the fuel release had been limited to airport property. Upon further review some quantity of free product and rain water was likely discharged to a storm sewer line located adjacent to the Fuel Farm Facility which discharges to Four Mile Run, located approximately 700 feet to the south, through Outfall-18. Additional response, abatement, and remediation activities were carried out in the vicinity of Outfall-18, Four Mile Run, and the Potomac River. Allied s emergency response contractor, together with various airport, local, and federal authorities responded to the release. Approximately 11,899 gallons of fuel has been recovered through various mediums, which leaves approximately 1,721 gallons unaccounted for. The difference in fuel may be attributed to several factors including; temperature variations associated with the fuel delivery itself, approximate estimates of fuel recovered utilizing sorbent material, and evaporation. The area around Outfall- 18 has been monitored daily since the release, and the sorbent booms placed around the outfall are being changed and maintained on a regular basis. Allied has completed a Corrective Action Plan which details the various measures they have and will implement to prevent a similar release in the future. A Site Characterization Report will be prepared by Amec Foster Wheeler on behalf of Allied to assess site conditions and make recommendations on risk mitigation and remediation if required. 1
1.0 INTRODUCTION At the request of Allied Aviation Fueling Company of National Airport, LLC. (Allied), Amec Foster Wheeler Environment & Infrastructure, Inc. (Amec Foster Wheeler) has prepared this Initial Abatement Report in response to the Virginia Department of Environmental Quality (DEQ) for the Ronald Reagan Washington National Airport Fuel Farm Facility (Site) confirmed petroleum release, Pollution Complaint #2016-3082, which occurred on October 29, 2015. The DEQ correspondence is included in Appendix A. This Initial Abatement report includes relevant site background information, mitigation measures and details of free product recovery and site cleanup. The Ronald Reagan National Airport is currently operated by the Washington Metropolitan Airports Authority (MWAA). 2.0 STORAGE TANK INFORMATION The Ronald Reagan Washington National Airport Fuel Farm Facility currently operates four 60- foot diameter, 40-foot tall, 840,000 gallon Jet Fuel-A Aboveground Storage Tanks (ASTs) which are filled via a six-inch pipeline operated by Plantation Pipeline Company (Plantation). The four tanks were constructed in 1993 and are currently active and in use. The site is located on the southern portion of Airport near the intersection of West Post Office Road and Thomas Road and is approximately 700 feet north of Four Mile Run (see Figure 1). 3.0 RELEASE INFORMATION At approximately 0200 hours on Thursday October 29, 2015 it is believed a discharge valve on a pressurized filter vessel pipe at the Site was not fully closed and resulted in a loss of approximately 13,620 gallons 1 of fuel during filling operations. According to Allied personnel it was raining at the time of the release. Weatherunderground.com 2 reports that Arlington, Virginia received 0.22 inches of rain between 12:46am and 1:52am. According to the National Oceanographic and Atmospheric Administration (NOAA) the tidal Potomac at Indian Head, Maryland 3 which is located south of the Site on the Potomac River, low tide occurred in the vicinity of 0300 hours. The subsequent high tide water at approximately 1300 hours on October 30, 2015. The release estimates were obtained through comparison of the quantity of fuel sent through the pipeline by Plantation and the quantity of fuel that was received by Allied in their AST. When the discharge 1 Data is included in the DCA Fuel Release Recap of Fuel Accounting document included in Appendix E 2 http://www.wunderground.com/history/airport/kdca/2015/10/29/dailyhistory.html 3 tidesandcurrents.noaa.gov/noaatidepredictions/noaatidesfacade.jsp?stationid=8579381&bmon=10&bday=29&byear=2015&edate=&timelength=daily 2
was identified the flow of fuel was shut off and the discharge was believed to have been contained to airport property. The fuel farm resumed normal operations. At approximately 2115 hours on Thursday, October 29, 2015, airport personnel responded to reports of a fuel odor on the south side of the airport property. At 2225 hours, responding personnel identified a fuel sheen in the water near Outfall-18 which discharges into Four Mile Run. The outfall is located adjacent to the location of the initial odor reports. Airport Operations, Airport Engineering and Maintenance, and Airport Fire and Rescue, in coordination with the District of Columbia Harbor Patrol, placed booms in the river to contained the observed spill. At 0700 hours on Friday October 30, 2015 the Transportation Security Administration Integration Facility (TSIF) building, located due west of the site, reported a fuel odor inside the building. The Airport Fire and Rescue responded as a precautionary measure. The TSIF building was evacuated and remained closed through Monday November 2, 2015. Figure 2 details the location of relevant site features. Based on the observations of fuel and petroleum odor located at locations outside the Fuel Farm Facility at the TSIF building and Outfall-18 following the 0200 hours release on October 29, 2015, it is likely that a portion of the released product was flushed into Four Mile Run. An Oil Water Separator (OWS) located at the Fuel Farm Facility is utilized to remove petroleum products from water discharged to the storm sewer system. It is likely that a portion of this OWS system failed and allowed some quantity of fuel to be discharged to the storm sewer or fuel was able to bypass the OWS and reach the storm sewer which leads to Outfall-18. At the conclusion of the initial abatement activities, Allied prepared an estimate of the fuel lost during the release. According to the DCA Fuel Release Recap of Fuel Accounting document provided to Amec Foster Wheeler by Allied, the Fuel Farm Facility began receiving fuel from Plantation on October 28, 2014 at 0750 hours. At 0159 hours on October 29, 2015, the fuel receipt was completed. The fuel receipt included three batches totaling approximately 385,980 gallons. The Allied records indicate that the volume of fuel received after the Plantation delivery to be approximately 372,360 gallons, which is a difference of approximately 13,620 gallons. However, it must be noted that the volume of fuel sent versus the volume of fuel received often varies due to the temperature at which the fuel was sent by Plantation (in Newington, VA) and then subsequently received by Allied (in Virginia/DC). This variance may be statistically insignificant. 3
4.0 INITIAL ABATEMENT MEASURES TAKEN Initial abatement measures can be classified into two events, the initial response on October 29, 2015 and the additional response measures carried out from October 30 through October 31, 2015. During the initial response Allied Aviation personnel utilized vacuum trucks and sorbent materials to contain the majority of the release to the confines of the Fuel Farm Facility. The recovered fuel and water was containerized on site pending analysis for reclamation and/or disposal by a qualified contractor (See Appendix B). A portion of the recovered fuel has already been removed for the site for disposal. The additional response measures included the deployment of Allied s emergency response contractor, Miller Environmental on October 30, 2015. The additional response measures were directed primarily at preventing free product from reaching Four Mile Run and the Potomac River from Outfall-18. Miller Environmental and the other responding authorities placed booms around the outfall to prevent the observed petroleum sheen from migrating. Additional sorbent materials were deployed along with the use of a vacuum truck to recover product floating in the area outside Outfall-18. These activities were performed between October 30 and November 2, 2015. Allied Aviation records indicate that NOAA and the U.S. Fish and Wildlife Service believe that the environmental impact to Four Mile Run and the Potomac River will be limited 4. According to Allied Aviation personnel the tidal fluctuations in the Potomac River are capable of flooding portions of the storm sewer line which discharges to Outfall-18. It is likely that the high tide kept the petroleum products from flowing from the storm sewer line located behind the Fuel Farm Facility through Outfall-18 and into Four Mile Run. This allowed the response contractor to recover the bulk of the fuel that entered the storm sewer. The containment booms have remained in place at Outfall-18 and are changed on a regular basis by Allied Aviation personnel. As of the writing of this report, the containment boom and pads have been changed 4 times. The booms outside Outfall- 18 are scheduled to be reconfigured on December 3, 2014. The inner booms located adjacent to the outfall and the third boom located furthest from the outfall will be removed. A hard boom was installed on December 1, 2015 and will remain in place. A 160 foot by five inch sorbent boom has installed between the hard boom and the outfall and will remain in place (See Figure 2). 4 NOAA and US Fish and Wildlife assessments information was included in the Metropolitan Washington Airports Authority Emergency Operations Center (EOC) Situation Report #1 for October 31, 2015 at 0900 hours. 4
The additional response measures were considered to have been completed on October 31 with continued recovery and collection of residual fuel in the area surrounding Outfall-18 through November 2, 2015. Amec Foster Wheeler mobilized to the site on October 31, 2015 and collected surface water samples from Four Mile Run ( Four Mile Run A through E ) outside of the boomed area and an additional surface water sample from inside the boomed area (Outfall-18). The details of the sampling including the sampling locations and photo documentation are included in the Amec Foster Wheeler Memo to Mr. James Buchanan of Allied Aviation on November 3, 2015 which is included in Appendix C. The analytical laboratory sampling results from the October 31, 2015 surface water sampling documented low concentrations (between 0.0014 milligrams per liter (mg/l) in sample Four Mile-E and 0.021 mg/l in sample Four Mile-D) of total petroleum hydrocarbons (TPH) gasoline range organics (GRO) and low concentrations (0.36 micrograms per liter (ug/l) in sample Four Mile-D to 1.27 ug/l in Outfall-18 Boom) of Xylenes. Naphthalene (4.6 ug/l) and TPH-Diesel Range Organics (DRO) concentrations were also detected in the Outfall 18 Boom sample. The laboratory analytical results are summarized in Table 1. The laboratory analytical reports are included in Appendix D. According to the DCA Fuel Release Recap of Fuel Accounting document (Appendix E), the following quantities of product were recovered: Entity Approximate Volume (gallons) Method/Storage Location MWAA 1,419 20 bags of 8 inch boom 15 bags of 5 inch boom 6 boxes of sorbent pads Miller Environmental 1,479 40 bales of sweep (on-water sorbent pads) 27 bags of 5 inch boom 10 boxes of sorbent pads 2 bags of granular absorbent Crystal Clean (Allied) 4,075 Vacuum Truck Recovery Allied 4,627 Vacuum recovery into two Frac Tanks Allied 299 66 5 inch booms 7 bags of granular absorbent Total Volume: 11,899 Approximately 13,620 gallons of fuel released and approximately 11,899 gallons of fuel were recovered, for a difference of approximately 1,721 gallons. The difference in released and recovered fuel may be attributed to the following: Petroleum products are subject to changes in volume and density due to temperature and pressure. Currently the temperature of fuel leaving the Plantation facility is monitored, while the fuel volume received by Allied is not corrected for changes in temperature which 5
may account for a change in volume, however, this volume differential may not be statistically significant. The estimates of fuel recovered utilizing sorbent booms, pads, sweep and granular material are approximate and are based on the manufacturer s specifications which may not reflect actual field conditions. Jet fuel is a volatile liquid and some quantity of product was likely lost due to evaporation over the course of the initial abatement and remediation activities. The variable site conditions during the initial abatement and remediation make an approximation of the volume of fuel lost to evaporation difficult to quantify. A Site Characterization Report (SCR) will be prepared to address the possible quantities of fuel that entered the storm sewer system and were contained at Outfall-18. 5.0 CORRECTIVE ACTION MEASURES Amec Foster Wheeler reviewed a Corrective Action Plan prepared by Allied, dated November 30, 2015. A copy of the Corrective Action Plan is included in Appendix F. The Corrective Action Plan details the steps that are currently being implemented as well as the measures that have already been enacted to prevent a similar event from taking place in the future. These correct actions include: Installation of a storm drain plug in the OWS system to prevent any further discharge to the storm sewer system until a more complete engineering study can be completed to assess the OWS. The manual sump drain valve which was responsible for the release has been replaced with a spring loaded, normally closed valve. Each of the other manual sump drain valves have also been replaced with these same valves. Allied is also in the process of implementing revised and enhanced safety and emergency response training for the Fuel Farm Facility new hires as well as additional training for current employees. Additional emergency response resources are being placed on retainer to provide more flexibility during an incident. Allied personnel have been monitoring the outfall daily since the release. The observation logs compiled by Allied are included in Appendix G. 6
TABLES
OUTFALL 18 SURFACE WATER ANALYTICAL RESULTS Four Mile Run at Ronald Reagan National Airport October 31, 2015 SAMPLE ID Parameter Method Matrix Units FOUR MILE - A FOUR MILE - B FOUR MILE - C FOUR MILE - D FOUR MILE - E OUTFALL 18 BOOM BTEX Benzene EPA 8260 Water ug/l <0.25 <0.25 <0.25 <0.25 <0.25 <0.25 Toluene EPA 8260 Water ug/l <0.26 <0.26 <0.26 <0.26 <0.26 <0.26 Ethylbenzene EPA 8260 Water ug/l <0.30 <0.30 <0.30 <0.30 <0.30 <0.30 Xylene (Total) EPA 8260 Water ug/l <0.66 <0.66 <0.66 <0.66 <0.66 <0.66 m&p-xylene EPA 8260 Water ug/l <0.66 <0.66 <0.66 <0.66 <0.66 0.75 J o-xylene EPA 8260 Water ug/l <0.23 <0.23 0.38 J 0.36 J <0.23 0.52 J Petroleum Constituents TPH-GRO EPA 5030/8015 Modified Water mg/l 0.0051 J 0.0019 J 0.0093 J 0.021 J 0.014 J 0.016 J TPH-DRO EPA 8015 Modified Water mg/l <0.10 <0.10 <0.10 <0.10 <0.10 1.9 PAHs Acenaphthene EPA 8270 Water ug/l <1.7 <1.7 <1.7 <1.7 <1.7 <1.7 Acenaphthylene EPA 8270 Water ug/l <1.8 <1.8 <1.8 <1.8 <1.8 <1.8 Anthracene EPA 8270 Water ug/l <1.1 <1.1 <1.1 <1.1 <1.1 <1.1 Benzo(a)anthracene EPA 8270 Water ug/l <0.72 <0.72 <0.72 <0.72 <0.72 <0.72 Benzo(a)pyrene EPA 8270 Water ug/l <0.71 <0.71 <0.71 <0.71 <0.71 <0.71 Benzo(b)fluoranthene EPA 8270 Water ug/l <0.81 <0.81 <0.81 <0.81 <0.81 <0.81 Benzo(g,h,i)perylene EPA 8270 Water ug/l <0.97 <0.97 <0.97 <0.97 <0.97 <0.97 Benzo(k)fluoranthene EPA 8270 Water ug/l <0.87 <0.87 <0.87 <0.87 <0.87 <0.87 Chrysene EPA 8270 Water ug/l <0.65 <0.65 <0.65 <0.65 <0.65 <0.65 Dibenz(a,h)anthracene EPA 8270 Water ug/l <0.70 <0.70 <0.70 <0.70 <0.70 <0.70 Fluoranthene EPA 8270 Water ug/l <0.87 <0.87 <0.87 <0.87 <0.87 <0.87 Fluorene EPA 8270 Water ug/l <1.6 <1.6 <1.6 <1.6 <1.6 <1.6 Indeno(1,2,3-cd)pyrene EPA 8270 Water ug/l <1.8 <1.8 <1.8 <1.8 <1.8 <1.8 Naphthalene EPA 8270 Water ug/l <1.5 <1.5 <1.5 <1.5 <1.5 4.6 J Phenanthrene EPA 8270 Water ug/l <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 Pyrene EPA 8270 Water ug/l <0.53 <0.53 <0.53 <0.53 <0.53 <0.53 LEGEND ug/l mg/l TPH-GRO TPH-DRO Bold J micrograms per liter milligrams per liter Total Petroleum Hydrocarbons-Gasoline Range Organics Total Petroleum Hydrocarbons-Diesel Range Organics Analyte detection Analyte detected at concentration less than the Reporting Limit (RL) and greater than or equal to the Method Detection Limit (MDL). Concentrations within this range are estimated
FIGURES
Potomac River Site Location Ronald Reagan Washington National Airport Four Mile Run Outfall-18 Fuel Farm Facility Source: Google Earth N N.T.S. SITE LOCATION MAP FIGURE 1 PROJECT NAME: Initial Abatement Report Allied Aviation Ronald Reagan Airport Fuel Farm Facility PROJECT NO.: 376350017 DATE: November 3, 2015 Amec Foster Wheeler, 14424 Albemarle Point Place Suite 115, Chantilly, VA 20151
Location of Filter Vessel Pipe Fuel Farm Facility Tanks N 400 Feet Source: Google Earth Legend Monitoring Well Location Oil Water Separator Location Approximate Storm Sewer Location Monitoring Well and Site Feature Map FIGURE 2 PROJECT NAME: Initial Abatement Report Allied Aviation Ronald Reagan Airport Fuel Farm Facility PROJECT NO.: 376350017 DATE: November 3, 2015 Amec Foster Wheeler, 14424 Albemarle Point Place Suite 115, Chantilly, VA 20151