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Draft Recommendations and Scope of Work For Bulk Fuel Storage and Dispensing Facility And Underground Fuel Storage Tank Removal Prepared for Addison Airport Addison, Texas 1. Tasking:
The Town ofAddison requested Washington Infrastructure to perform a review, make recommendations and develop the scope ofwork for design ofa replacement Bulk Fuel Storage Facility. The
design and subsequent construction is to be accomplished in conjunction with the removal ofall existing Underground Fuel Storage Tanks, as specified in the to be developed and approved
Underground Fuel Stcrage Tank Removal Plan. 2. References: Addison Airport ALP (Barnard Dunkelberg & Co), dated May 1999, and Addison Airport 10 year CIP (Shimek, Jacobs & Finklea, LLP),
dated Feb 2000 Phase I Environmental Site Assessment Update (Camp Dresser & McKee), dated Feb 1,2001 Addison Airport Development Drawing (Washington Infrastructure), dated Oct 30, 2000.
3. Background: Although the Capital Improvement Program (CIP) for Addison Airport, does not specifically address an upgrade or replacement Bulk Fuel Storage and Dispensing fucility,
the current status and regulatcry requirements for the nnmerous underground fuel stcrage tanks on Airport property mandate action. The referenced Phase I Environmental Site Assessment
indicates a need to control bulk fuel stcrage and dispensing, including the installation ofenvironmental protection and spill prevention systems, along with the necessity ofbringing
the Airport intc compliance with the current Underground Storage Tanks (UST) requirements. A do nothing alternative is not discussed because ofthe mandated upgrades required for the
systems and because closing the airport is not considered a reasonable or viable option. 4. Discussion: Centralized Bulk Fuel Storage and Dispensing versus Decentralized The existing
decentralized bulk fuel stcrage and dispensing systems are convenient for the tenant operators on the Airport. However, as indicated in the Phase I Environmental Assessment, and subsequent
actions by the Airport's insurance carrier, environmental and spill prevention controls, along with operational and spill response accountability are not up to current requirements or
Standards. As the Airport property owner, the Town ofAddison is responsible for oversight and management ofenvironmental requirements and will face increased liability for poor management
practices. In comparing the convenience of decentralized bulk fuel stcrage and dispensing facilities versus a centralized system on the Airport, a centralized system allows for better
security and effective management and monitoring ofoperations as well as the installation ofstandardized storage systems with appropriate environmental and spill prevention controls.
In addition, a new centralized system ADS Draft: 04/11/01 1 
Draft could be constructed in a large berm/diked containment area that would prevent catastrophic tank leakage and fuel release. A centralized system also allows the installation ofspill
collections systems under the bulk fuel unload and dispensing stands, to safely collect inadvertent spills into an oil/water separator. Finally, the cost of retrofitting appropriate
environmental and spill prevention controls, plus the cost to either install double wall underground fuel storage tanks with leak detection, or the area and cost to berm/dike new single
wall above ground fuel storage tanks at each decentralized location, makes a centralized storage and dispensing facility a more cost effective alternative. Recommendation Number 1: The
Town ofAddison and the Airport mandate that all bulk fuel storage and dispensing systems on the Airport are to be constructed in a centralized location with the appropriate containment
and spill collection systems. 5. Proposed Location for a new Centralized Bulk Fuel Storage and Dispensing Facility: A proposed location for the "Future Fuel Farms" was identified on
the May 1999 Airport Layout Plan (ALP); however, the site is not currently owned by the Airport. In addition, questions of land use and zoning compatibility could be raised, since the
surrounding area and facilities are commerciaJ/business, not industrial and aircraft refuel truck access to the aircraft parking areas could be a problem. Some concems may also be raised
about large over the road tanker trucks accessing the site for bulk fuel delivery. Several alternative locations are possible; however, for existing property owned by the Airport, a
new proposed location was identified on the North side ofthe airport, from the intersection ofBent Tree Plaza, along Westgrove Road, adjacent to the Town Servicing Yard and Facilities.
Construction would be outside the existing east Runway Obstacle Free Area line, but inside the 20 foot Building Restriction Line, which will make height of facilities a factor for design.
The location location is compatible with the Town Servicing Yard activities and also provides an opportunity to install a Town use, gas/diesel vehicle dispensing pump, while providing
for bulk storage within the Airport site. The greatest disadvantage ofthe location is that construction heights will be limited and the site is in the proposed "Future Approach" Runway
Protection Zone. Construction ofthe Bulk Fuel Storage Facility on this site will preclude upgrading Runway 15, as listed on the May 1999 ALP, to a higher category precision instrument
approach. Recommendation Number 2: None yet Determine ifthe proposed site is viable for the system or if it violates FAA guidelines for the current ILS approach. 6. Airport Ownership
versus Supplier Ownership of Storage Tanks and Dispensing Equipment: The key factors to consider in determining ownership ofthe storage tanks and dispensing equipment include available
funds, risk management, desire and ability to maintain the system and stability ofthe users. Ifthe Town/Airport has sufficient funding available and desires to make the up-front investment
in a new storage and dispensing system, they can recover the investment by long term leasing ofstorage and dispensing to users. The advantages are construction ofstandardized storage
tanks and dispensing equipment, common operation and maintenance procedures, and if any user develops financial problems, the storage and ADS Draft: 04/11/01 2 
Draft equipment is owned by the Airport and will not he included in any bankruptcy proceedings. The disadvantages are that the Town!Airport must maintain the tanks and equipment either
by contract or with in house personnel, and the Airport keeps liability for the storage tanks and dispensing equipment, along with the site. Ifthe TenantIFBO/Supplier installs the bulk
storage and dispensing equipment, installed items should he specified and approved by the Airport for standardization oftank size, material and construction, along with commonality of
dispensing equipment. Iftank and dispensing equipment is provided and installed by the TenantIFBO, lease documents should provide for immediate acquisition by the Airport at the amortized
value ofthe equipment ifthe operator develops financial problems. Recommendation: 7. Single bulk fuel storage system versus multi-supplier system A single bulk fuel storage and dispensing
system is the most efficient from a cost and space utilization perspective; however, ifa single system is used to supply all users ofthe Airport, then the system should he owned by the
Airport. This will also require the Airport to competitively bid the total airfield fuel requirement on an annual or biennial basis and all users must purchase from this supply. The
advantages are generally a lower per gallon price and a stable price to the user over the life ofthe supply contract; however, with market fluctuation, if the cost per gallon declines
after the contract, the user will still pay the same. In short, the Airport is buying all fuels and the users buy fuels from the Airport and there is no competition after the Airport
contracts for the best price available at time ofcontract. Since there is no market competition after contract, ifthe price offuel goes up, it's a good deal and if it goes down, the
contract becomes a poor deal. Current FBO arrangements with branded fuel suppliers could be impacted by a single fuel storage operation. The decision to take the Airport into the aviation
fuel market market as a supplier should he carefully considered by Airport and Town management. 8. Bulk fuel storage system Options: • CO!llbined Use Storage Facility with Shared Off-LoadlDispensing
Facility TIlls option may be the best option in terms ofspace use and total cost. With a combined use . storage facility, one large fuel storage complex could he designed with secondary
containment designed for the largest storage tank in the complex. TIlls method allows maximum flexibility for future needs and provides for maximum storage capacity in the minimum area
used. The shared on-load/dispensing equipment also economizes on space use as well as cost, since only one storage and dispensing system is constructed. The storage tanks would use a
card or key system to track withdrawal from the system by each user. TIlls system would work with one supplier, competitively bid by the Airport, for all airport users. Some disadvantages
ofthis system is that all users share the facility, which could be an operational/maintenance maintenance problem, which will be an Airport responsibility, and there is increased liability
risk to the Airport. If a spill occurs, it also may be more difficult to track responsibility. • Combined Use Off-Load and Storage Facility with Individual Dispensing Facilities ADS
Draft: 04/11/01 3 
Draft This option varies from the above option in that there is one selected fuel supplier and bulk fuel storage source which is dispensed to individual TenantIFBO for convenience of
accounting and access to the stored bulk aviation fuel. • Individual Storage Facilities using a Combined Use Off-LoadJDispensing Facility This option varies from the first in that one
Off-LoadlDispensing Stand would use electronically controlled pumps to place off-loaded fuel into the correct bulk fuel storage tank and electronically controlled dispensing pump would
select fuel from the correct bulk fuel storage tank to fill aircraft fuel servicing trucks. Advantage is a little less space required for Combined Off-LoadlDispensing facility, but the
design ofthe electronically controlled pump/manifold system is critical and there will be some product remaining in the dispensing piping after delivery, which goes to the next user.
• Consolidated Individual Facilities for Eacb Aviati!)u Fuel Operators This concept is that each TenantIFBO/Supplier has an individual bulk fuel storage and dispensing system, either
leased from the Airport or owned, within the Airport Bulk Fuel Storage site. Ifequipment and storage tanks are built by the users/suppliers, they follow Airport mandated standards for
construction on the Airport owned site and the equipment and storage tanks are maintained by the user/supplier. Individual storage and dispensing equipment can be either Airport or TenantIFBO/Supplie
r installed and owned. The advantage is that each storage and dispensing system is operated by the user, for clear delineation ofaccounting and responsibility, plus consolidated individual
systems minimizes liability to the Airport. The greatest disadvantage is the individual system requires more area for construction. 9. Other Considerations: Industry standard filtering
systems with automatic shutdown and alarms should be installed on the Off-Load side ofthe Storage Tanks, to protect product in the tank. An oillwaterseparator should be installed and
connected to the bermed containment area, Off-Load and Dispensing pads to allow for immediate wash-down of any spilled product and a designated parking area fur any aircraft refueler
vehicle that develop a leak. Use ofa concrete low wall would allow a more compact containment berm area and would also allow lowering the storage tank area by two to three feet, ifPart
77 geometry is a problem, or for appearance. Installing a panel and frame roof system, that allows access to storage tanks, would minimize rainfall into the containment area. This would
also allow the containment area to be valve connected to a smaller oillwater separator so that any major spill in the containment area can be washed down and pumped out through the oillwater
separator. A panel and frame roof system would also enhance the facility appearance from outside the Airport property 10. Scope of work: After including all appropriate guidance, recommendations
and options, the scope of work will provide for comprehensive design services and the the production ofbid documents for the new Bulk Fuels Storage and Dispensing Facility at Addison
Airport. Service should include developing an Environmental Assessment (EA) or a Category Exclusion (CA TEX) document as required, acquisition process support, bid result review, and
optional construction management and inspection, and project close-outfas-built service, ifdesired by the Airport and Town. ADS Draft: 04111/01 4 
Draft CONCEPTUAL SCOPE OF WORK For Underground Fuel Storage Tank Removal 1. Discussion: The following narrative describes the typical activities and possible results that would be conducted
as part ofthe Underground Storage Tank (UST) removal and environmental remediation program at Addison Airport. The narrative is not in itself a detailed scope of work but is intended
to provide guidance to Airport and Town Management on Environmental Engineering requirements and to support efforts in obtaining qualified contractors and testing consultants to successfully
execute the Airport UST removal program. Environmental Engineering Consultant and Management functions are required at the Airport to oversee construction, evaluation, remedial actions
and monitoring ofpossible problem sites, and to assist with qualified contractor selection. In addition to a Comprehensive Site Assessment, The Environmental Engineer must be prepared
to rapidly accomplish specific tasks, such as contamination assessment for sites discovered during construction, in an effort to accomplish the UST removal as expeditiously and cost
effectively <is possible. 2. Background and Tasking: From best infonnation available and according to the referenced Phase I Environmental Site Assessment Update, there are 29 registered
Underground Storage Tanks (USTs) and one unregistered above ground storage tank located at the airport and that 15 USTs are currently inactive. The remaining 14 active USTs and one above
ground storage tank must remain in service until a new bulk fuel storage and dispensing facility has been constructed or suitable temporary alternatives are available. There is also
concem that additional unregistered above ground and underground fuel storage tanks may be on the Airport. It is assumed that the new construction site will be on the Airport and that
the Airport and Town will provide general or specific management and oversight ofthe new facility. In addition, the Airport and Town desire that the 15 inactive USTs be fully taken out
ofservice and have fmal actions accomplished, which would be defined as either pe!TI1anent abandonment in place or removal. Subsequent to the activation ofthe new bulk fuel storage and
dispensing facility at the Airport, the remaining 14 USTs will be taken out of service and pennanently abandoned or removed. For all USTs, removal is the preferred option, uuless utility
lines or structures would be at substantial risk from removal operations, or the associated cost of removal is excessive. Based on the available infonnation and conditions on site, the
most efficient and effective process for comprehensive all UST removal at Addison Airport will be to first investigate, categorize and develop a baseline, then develop a UST removal/compliance/mitiga
tion plan, based on the investigation. After plan approval, proceed with UST removal or pennanent abandonment by a licensed UST removal contractor and accomplish final remediation on
each site as required. 3. Environmental Baseline and Investigation: An investigation is required to determine site conditions at each UST and develop a Baseline for the Airport that
clearly indicates the environmental status ofthe Airport with new Airport Management and Operations. The Phase I Environmental Site Assessment Update indicates several incidences ofhydrocarbon
spills to the surface. Although existing USTs should have been at least tank tightness tested, these documented spills, potential undocumented spills and ADS Draft: 04/11101 5 t 
Draft associated underground piping leakage would not be detected using only a tank tightness test. A soil gas analysis should be accomplished on all USTs as soon as possible to determine
actual conditions, verify current operating USTs comply and allow a credible estimate ofthe planoed UST removal and mitigation requirements. Soil gas analysis is a sensitive, relatively
accurate, and relatively inexpensive method ofidentifying impacts to geologic media. For this reason, we recommend a soil gas analysis be conducted in the areas ofthe tanks and/or identified
spill areas. The soil gas analysis will be key information in developing the Airport Environmental Baseline and Investigation. The Environmental Consultsnt should also perform an extensive
document, construction plan and written inspection review ofall bulk fuel storage tanks and related piping on the Airport as part ofthe Investigation. Ifthe Investigation determines
that one or more ofthe current operational underground fuel storage tanks are leaking, leaking, lNRCC must be notified and the operator must inunediately take that tank out ofservice.
The Environmental Consultsnt should work with the operator to develop reasonable temporary fuel storage options until the new system can be constructed. In the event that soil gas analysis
indicates the probability ofimpacted geologic media, Texas Natural Resource Conservation Commission (lNRCC) regulations would require that a Comprehensive Site Assessment be conducted
to determine the extent and magnitude ofthe impacts. This would include soil borings, monitoring wells, analytical testing, a receptor survey, and a hnman health risk assessment, at
a minimum. The Environmental Consultsnt should conduct this work for the Airport and Town under the direction ofa lNRCCregistered Corrective Action Project Manager. 4. Development ofdetailed
UST RemovallCompliancelMitigation Plans and Specifications: In some cases, it may be more cost effective to abandon tanks in place because ofsafety issues. This is more likely to be
the case when utility lines and structures will be placed at risk because of excavation and removal activities. Otherwise, we recommend removal ofall tanks to mitigate future liabilities.
The Environmental Consultant will develop detailed plans and specifications to function as bid documents for tank abandonment and/or removal by qualified tank removal contractors. The
Environmental Consultsnt should also conduct an Applicable or Relevant and Appropriate Regulations Analysis to identify regulations or reasonably accepted practices that must be or reasonably
should be complied with for the tank abandonment/removal and remediation programs. This effort assists in identifying Federal, State, County, and Town laws, regulations, and ordinances
that are mandatory, including identification ofany wastewater discharge permits/approvals, air emissions permits/approvals, waste disposal permits/approvals, and construction permits.
It will also help to identify industry accepted practices, such as American Petroleum Institute and American National Standards Institute standards, that are not necessarily mandatory
by regulation but which constitute "best practices." 5. Tank abandonment or removal: In accordance with the Airport and Town's desire to permanently remove the tanks from service, the
Environmental Consultant should assist the Airport and Town with selection of a qualified contractor(s) to conduct tank abandonment or removal. Activities include but are not limited
to: site preparation (drain the lines and tanks, remove and dispose or re-use fuels, remove ancillary equipment), remove flanunable vapors, test tank atmosphere, fill tanks with inert
material or remove them, backfill pit with clean fill soil, dispose waste soils, dispose tanks. The Environmental Consultant should monitor and document the removal and mitigation activities
of the selected contractor(s) and to report progress and compliance with statutory requirements and ADS Draft: 04111/01 6 
Draft contractual obligations for tank abandonment andlor removal. A detailed, site-specific health and safety plan for tank abandonment/removal process and for all remediation activities
should be developed by the contractor and reviewed by the Environmental Consultant on behalf ofthe Airport and Town. Soils must be excavated from the tank pits to allow access to the
tanks for backfilling or removal. Excavated soils that are not impacted by hydrocarbons can be used for backfill; otherwise, clean soils must be brought from a borrow source for backfilling.
Soils unsuitable as backfill, either because ofpoor geotechnical properties or contamination, must be disposed properly. Contaminated soils will be tested to determine contaminant levels,
which will then define the type ofdisposal facility that is suitable. In some situations, contaminated soils may be subjected to a treatment process, such as bio-remediation or thermal
desorption, ifit appears cost effective or is necessary because ofFederal Land Disposal Disposal Restrictions. Waste fuels, i.e. fuels unsuitable for use in aircraft, must be disposed
properly. Tank sediments and emulsions, consisting ofcorrosion byproducts, water, soil particles, and other detritus, must also be disposed properly. Construction equipment wash waters,
contaminated personal protective equipment, sampling devices, and all other waste produced as part ofthe abandonment/removal activities must be properly characterized and disposed. For
either abandonment/removal or remediation activities, soil, water, and wastes must be analyzed for hydrocarbons in order to properly characterize and categorize them. Analytical test
methods will be those approved by the U.S. EPA and TNRCC. The Environmental Consultant should define the analytical program and conduct the testing with our National Environmental Laboratory
Accreditation Program approved lab. Once the Applicable or Relevant and Appropriate Regulations Analysis is completed, the Environmental Consultant should either assist the Airport and
Town with obtaining the permits, approvals, and required plans (such plans function as permits by rule) or will monitor the activities ofcontractors and consultants that are obtaining
the permits, approvals, and plans on behalfofthe Airport and Town. Such permits/approvals/plans typically include but are not limited to wastewater discharge permits to other municipal
sewer systems, air permits, waste disposal authorizations from permitted disposal facilities, one-time waste generator numbers and waste identification numbers, construction permits,
construction stormwater pollution prevention plans, and authorizations to access privatelyoperated areas. 6. Final Site Remediation and Close-out: Ifgeologic media are contaminated above
acceptable human-health-based levels, a Remedial Action Program (RAP) must be implemented according to TNRCC guidelines. The Environmental Consultant should design the RAP and assist
the Town with selection ofcontractors to implement the RAP. Remediation could involve over-excavation and disposal ofwaste soils, in situ or ex situ treatment ofsoils, groundwater treatment,
soil vapor extraction, installation of barriers, etc. Excavated soils that are not impacted by hydrocarbons can be used for backfill; otherwise, clean soils must be brought from a borrow
source for backfilling. Soils unsuitabLe as backfill, either because ofpoor geotechnical properties or contamination, J;l1ust be disposed properly. Contaminated soils will be tested
to determine contaminant levels, which will then define the type ofdisposal facility that is suitable. In some situations, contaminated soils may be subjected to a treatment process,
such as bio-remediation or thermal desorption, ifit appears cost effective or is necessary because ofFederal Land Disposal Restrictions. Waste fuels, i.e. fuels unsuitable for use in
aircraft, must be disposed properly. Tank sediments and emulsions, consisting ofcorrosion byproducts, water, soil particles, and other detritos, must also be disposed properly. Construction
equipment wash water, contaminated personal protective equipment, ADS Draft: 04/11/01 
Draft sampling devices, and all other waste produced as part ofthe abandonment/removal activities must be properly characterized and disposed. For either abandonment/removal or remediation
activities, soil, water, and waste must be analyzed for hydrocarbons in order to properly characterize and categorize them. Analytical test methods will be those approved by the U.S.
EPA and TNRCC. The Environmental Consultant should define the analytical program and conduct the testing with our National Environmental Laboratory Accreditation Program approved lab.
With assistance from the contractor(s), the Environmental Consultant will prepare the project closeout and as built drawings, which will be coordinated with TNRCC as required. ADS Draft
04/11/01 8