19SN0564M n70s
i�Pt JE�J SL4bC
YI live in
the community, Chesterfield and I am asking
g
the county to vote NO on the conditional use permit to install above ground
fuel storage units on the water shed at Clover Hill Technical Center,
19SN0564 based on insufficient cost justification for the project.
The county is basing justification for this project a $300,000 savings on a
gas cost spread sheet that does not provide even a list of valid
assumptions. The entire cost analysis is a 5 row summary of figures
without any explanation of methodology, assumptions, or even how
calculations were derived. The backup data is even worse. It is a series of
gas station sites showing how much gas is bought at the various gas
stations servicing school buses and compares retail price of gas to
projected costs for gas at the "new" fueling station. It appears from the
data that buses are rerouted to various county fueling sites with the
expectation they will fuel their tanks at these sites. Some of the buses
listed to go to the Hull Street Technical Center are 17 or 18 miles or more
from their current filling station. Since many drivers bring their buses home
or to a convert site to where they drive after work, this probably means the
drivers will have to return to their original location again, doubling the
mileage. The bus drivers, many of who go to other jobs, or have families to
go to, must spend an extra 30 minutes, and in some traffic conditions,
much more time, just getting to the new fuel site and back to their parking
spot. Wages were not included in the study so the extra time in traffic and
fueling was not calculated.
In addition, the calculations give the impression that the $300,000 savings
will come from the CTC center. This is not true. The spreadsheet shows
about 121 thousand gallons of diesel fuel being used at the Tech Center
out of 375,000 gallons being used in Chesterfield. T e um ary diagram
shows a projection of 493,455 gallons of diesel. o c ation of how
over 100,000 gallons were added to the Chesterfield figures or why no
discount for diesel fuel was not calculated.
According to this analysis, everything is free. No costs for equipment,
installation, site preparation, security, etc. There is no cost benefit
analysis, no return on investment study, no formal risk analysis study, no
security study, no evacuation plan study, etc.. Because the cost of the
actual station has not been identified, including extra security and safety
additions, best practices road construction for maintenance and emergency
services, etc. the county cannot justify any statement of cost savings.
I understand this analysis came from the department of education. Sadly
they should have asked one of our well trained and poorly paid teachers to
do it. I hope this is used as a case study in our classrooms to teach
student what not to do. This is irresponsible and sets a poor tone for our
children whose lives will be impacted by any environmental compromise of
this site. I don't know how the planning department approved this but we
must VOTE NO.
I request that this statement be put into the minutes of this meeting
Projected annual consumption by CCPS at CTC - Hull fuel site
Row Labels
Grand Total
County price
Retail price
Sum of Sum of Sum of Sum of Total
DIESEL GAL LPG GAL UNL GAL Gallons
493,455 1 18,447 1 3,566 515,470
$1.84
$1.39
$1.43
$1.80
$2.47
n/a
Difference 1 $0.63 1 n/a 1 $0.37
Cost avoidance 1 $ 310,877 1 n/a 1 $ 1,319 1 $ 312,196
Note: based on December 2018 average pricing
LOCALITY ADDRESS
DIESEL GAL
% of TOT LPG GAL
% of TOT LINL GAL
% of TOT Total Gallons
Total % of TOT
ALT SITE
CHESTERFIELD
10030 MIDLOTHIAN TNP RICHMOND, VA 232340000
1,198.95
0.17%
0.00%
0.00%
1,198.95
0.15%
W
10031 HULL STREET ROAD RICHMOND, VA 232360000
1,629.61
0.23%
0.00%
298.60
0.54%
1,928.21
0.24%
CTC
10135 HULL STREET RD MIDLOTHIAN, VA 231123301
6,334.29
0.90%
0.00%
21.95
0.04%
6,356.24
0.79%
CTC
10150 HULL STREET MIDLOTHIAN, VA 231120000
643.80
0.09%
0.00%
0.00%
643.80
0.08%
CTC
10220 MIDLOTHIAN TUR RICHMOND, VA 232350000
231.19
0.03%
0.00%
0.00%
231.19
0.03%
CTC
10800 IRON BRIDGE RD CHESTER, VA 238310000
7,321.55
1.04%
0.00%
16.34
0.03%
7,337.89
0.92%
CC
11021 IRONBRIDGE ROAD RICHMOND, VA 23831
4,082.62
0.58%
0.00%
255.43
0.46%
4,338.05
0.54%
CC
11021 MIDLOTHIAN TURNPIKE RICHMOND, VA 23235
2,299.97
0.33%
0.00%
206.47
0.38%
2,506.44
0.31%
CTC
1113 BROWNS WAY ROAD MIDLOTHIAN, VA 231140000
0.00%
0.00%
43.97
0.08%
43.97
0.01%
CTC
1120 COURT HOUSE RD RICHMOND, VA 232360000
0.00%
0.00%
16.77
0.03%
16.77
0.00%
CTC
11200 BUNDLE RD CHESTERFIELD, VA 238320000
6,778.89
0.96%
0.00%
0.00%
6,778.89
0.85%
CC
11200 HULL STREET RD MIDLOTHIAN, VA 231120000
1,288.97
0.18%
0.000%
0.00%
1,288.97
0.16%
CTC
11440 WEST HUGUENOT ROAD MIDLOTHIAN, VA 231131119
0.00%
0.00%
0.00%
0.00
0.00%
CTC
11461 ROBIOUS RD BON AIR, VA 232350000
8,111.87
1.15%
0.00%
9.53
0.02%
8,121.40
1.02%
CTC
11531 MIDLOTHIAN TURNPIK MIDLOTHIAN, VA 231130000
90.46
0.01%
0.00%
16.08
0.03%
106.54
0.01%
CTC
11600 MIDLOTHIAN TURNPIK MIDLOTHIAN, VA 231130000
11,161.95
1.58%
0.00%
210.30
0.38%
11,372.25
1.42%
CTC
11701 JEFFERSON DAVIS HIG CHESTER, VA 23831
939.42
0.13%
0.00%
37.35
0.07%
976.77
0.12%
CH
11800 IRON BRIDGE PLAZA CHESTER, VA 238311455
5,292.22
0.75%
0.00%
0.00%
5,292.22
0.66%
CH
11800 IVY MILL ROAD CHESTERFIELD, VA 238380000
4,042.99
0.57%
0.000%
17.45
0.03%
4,060.44
0.51%
M
12001 SOUTHSHORE POINT DR MIDLOTHIAN, VA 231122088
7,959.08
1.13%
0.00%
31.79
0.06%
7,990.87
1.00%
CTC
12301 DEERHILL RD. MIDLOTHIAN, VA 231120000
16,265.94
2.30% 9,223.26
100.00%
0.00%
25,489.20
3.20%
CTC
12411 HULL STREET ROAD MIDLOTHIAN, VA 231120000
524.32
0.07%
0.00%
22.28
0.04%
546.60
0.07%
CTC
12500 JEFFERSON DAVIS HW CHESTER, VA 238315317
24,624.33
3.49%
0.00%
0.00%
24,624.33
3.08%
CC
13200 KINGSTON ROAD CHESTER, VA 238360000
3,501.70
0.50%
0.00%
0.00%
3,501.70
0.44%
M
13400 MIDLOTHIAN TPKE MIDLOTHIAN, VA 231134212
11,568.05
1.64%
0.00%
0.00%
11,568.05
1.45%
CTC
13636 GENITO RD MIDLOTHIAN, VA 231124000
6,875.01
0.97%
0.00%
47.23
0.09%
6,922.24
0.87%
CTC
13721 HULL STREET MIDLOTHIAN, VA 231122001
29,322.57
4.15%
0.00%
102.71
0.19%
29,425.28
3.68%
CTC
13866 VILLAGE PLACE MIDLOTHIAN, VA 231140000
0.00%
0.00%
25.76
0.05%
25.76
0.00%
CTC
13931 HULL STREET ROAD MIDLOTHIAN, VA 231120000
0.00%
0.00%
6.60
0.01%
6.60
0.00%
CTC
14008 MIDLOTHIAN TPK MIDLOTHIAN, VA 231130000
0.00%
0.00%
88.74
0.16%
88.74
0.01%
CTC
14051 STEEPLE STONE DRIV MIDLOTHIAN, VA 231130000
8,891.41
1.26%
0.00%
0.00%
8,891.41
1.11%
CTC
14101 MIDLOTHIAN TURNPIKE MIDLOTHIAN, VA 231140000
12,293.25
1.74%
0.00%
0.00%
12,293.25
1.54%
CTC
14350 BEACH ROAD CHESTERFIELD, VA 238320000
0.00%
0.00%
22.30
0.04%
22.30
0.00%
CTC
14600 TIME SQUARE DRIVE MIDLOTHIAN, VA 231120000
1,695.04
0.24%
0.00%
32.59
0.06%
1,727.63
0.22%
CTC
14600 TIME SQUARE DRIVE MIDLOTHIAN, VA 231124565
729.85
0.10%
0.00%
0.00%
729.85
0.09%
CTC
14746 VILLAGE SQR PL MIDLOTHIAN, VA 231120000
22,135.88
3.13%
0.00%
39.46
0.07%
22,175.34
2.77%
CTC
150 PIKE VIEW DR. MIDLOTHIAN, VA 23112
1,210.77
0.17%
0.00%
146.96
0.27%
1,357.73
0.17%
CTC
15700 WOODS EDGE ROAD COLONIAL HEIGHT, VA 238340000
12.28 0.00%
0.00%
0.00%
12.28
0.00%
M
15840 JEFFERSON DAVIS HIG CHESTERFIELD, VA 23832
10,937.93 1.55%
0.00%
98.41 0.18%
11,036.34
1.38%
M
16717 HULL STREET RD MOSELEY, VA 231201424
17,114.07 2.42%
0.00°%
0.00%
17,114.07
2.14%
CTC
1740 E HUNDRED RD CHESTER, VA 238363329
1,927.49 0.27%
0.00%
6.92 0.01%
1,934.41
0.24%
CC
1900 W. HUNDRED ROAD CHESTER, VA 23831
434.59 0.06%
0.00%
0.00%
434.59
0.05%
CC
20 5 PROVIDENCE RD RICHMOND, VA 232360000
2,188.79 0.31%
0.00%
10.36 0.02%
2,199.15
0.27%
W
20100 HULL STREET RD MOSELEY, VA 231200000
13,568.52 1.92%
0.00%
0.00%
13,568.52
1.70%
CTC
2053 HUGUENOT ROAD RICHMOND, VA 232350000
21,143.16 2.99%
0.00%
195.73 0.36%
21,338.89
2.67%
CTC
2117 WILLIS RD RICHMOND, VA 232370000
279.02 0.04%
0.00%
0.00%
279.02
0.03%
CC
2126 RUFFIN MILL ROAD RICHMOND, VA 238340000
1,411.84 0.20%
0.00%
0.00%
1,411.84
0.18%
M
231 EAST HUNDRED ROAD CHESTER, VA 238360000
9,647.13 1.37%
0.00%
47.75 0.09%
9,694.88
1.21%
CC
2421 W HUNDRED RD CHESTER, VA 238312304
1,006.23 0.14%
0.00%
0.00%
1,006.23
0.13%
CC
2708 BUFORD ROAD RICHMOND, VA 232350000
0.00%
0.00%
34.23 0.06%
34.23
0.00%
W
2730 E HUNDRED RD CHESTER, VA 238366400
0.00%
0.00%
13.19 0.02%
13.19
0.00%
M
2910 TURNER ROAD RICHMOND, VA 282240000
0.00%
0.00%
12.61 0.02%
12.61
0.00%
W
3001 POLO PKWY MIDLOTHIAN, VA 231134833
1,963.24 0.28%
0.00%
28.00 0.05%
1,991.24
0.25%
CTC
3840 NORTH BAILEY BRIDGE MIDLOTHIAN, VA 231122912
5,971.17 0.85%
0.00%
51.43 0.09%
6,022.60
0.75%
CTC
3900 BAILEY BRIDGE RD MIDLOTHIAN, VA 231130000
30,036.34 4.25%
0.00%
117.60 0.21%
30,153.94
3.77%
CTC
3900 N BAILEY BRIDGE MIDLOTHIAN, VA 231120000
4,048.34 0.57%
0.00%
0.00%
4,048.34
0.51%
CTC
5400 JEFFERSON DAVIS HIGH RICHMOND, VA 232236008
531.53 0.08%
0.00%
0.00%
531.53
0.07%
W
5600 JEFFERSON DAVIS HWY RICHMOND, VA 23234
1,618.17 0.23%
0.00%
0.00%
1,618.17
0.20%
W
600 EAST HUNDRED ROAD RO CHESTER, VA 23831
164.93 0.02%
0.00.0
63.35 0.12%
228.28
0.03%
CC
6001 IRONBRIDGE ROAD RICHMOND, VA 23234
4,415.08 0.63%
0.00%
737.46 1.34%
5,152.54
0.64%
W
6100 BELMONT RD CHESTERFIELD, VA 238320000
18.55 0.00%
0.00%
0.00%
18.55
0.00%
W
6116 IRON BRIDGE RD RICHMOND, VA 232345226
35.98 0.01%
0.00%
0.00%
35.98
0.00%
W
6131 JEFFERSON DAVIS RICHMOND, VA 232340000
23.23 0.00%
0.00%
0.00%
23.23
0.00%
W
6437 IRONBRIDGE RD RICHMOND, VA 232345205
372.89 0.050%
0.00%
0.00%
372.89
0.09%
CC
6500 JEFFERSON DAVIS HIGH RICHMOND, VA 232370000
359.24 0.05%
0.00%
0.00%
359.24
0.04%
W
6501 IRONBRIDGE RD NORTH CHESTERFI, VA 232340000
1,875.19 0.27%
0.00%
0.00%
1,875.19
0.23%
CC
7039 HULL STREET (US 360) RICHMOND, VA 232242549
1,222.03 0.17%
0.00%
0.00%
1,222.03
0.15%
W
7040 HULL STREET RICHMOND, VA 232240000
88.34 0.01%
0.00%
0.00%
88.34
0.01%
W
7041 COMMONS PLAZA CHESTERFIELD, VA 238320000
75.85 0.01%
0.00%
0.00%
75.85
0.01%
CC
7100 HULL ST RD BON AIR, VA 232350000
2,427.17 0.34%
0.00%
0.00%
2,427.17
0.30%
W
7500 MIDLOTHIAN TURNPIKE RICHMOND, VA 23225
86.85 0.01%
0.00%
0.00%
86.85
0.01%
W
7933 JEFF DAVIS HWY RICHMOND, VA 232370000
59.92 0.01%
0.00%
0.00%
59.92
0.01%
W
8211 HULL STREET RICHMOND, VA 232350000
0.00%
0.00%
13.88 0.03%
13.88
0.00%
W
8701 IRONBRIDGE RD RICHMOND, VA 232370000
116.91 0.02%
0.00%
0.00%
116.91
0.02%
CC
8806 FOREST HILL AVE RICHMOND, VA 232350000
4,480.83 0.63%
0.00%
0.00%
4,480.83
0.56%
W
9200 MIDLOTHIAN TNPK MIDLOTHIAN, VA 231120000
7.74 0.00%
0.00%
0.009/q
7.74
0.00%
W
9300 HULL ST RD RICHMOND, VA 232360000
3,529.85 0.50%
0.00%
10.21 0.02%
3,540.06
0.44%
W
9430 IRON BRIDGE RD CHESTERFIELD, VA 238326601
0.00%
0.00%
16.34 0.03%
16.34
0.00%
CC
9500 NEWBYS BRIDGE ROAD CHESTERFIELD, VA 238320000
6,135.96 0.87%
0.00%
0.00%
6,135.96
0.77%
CC
9900 CHESTER RD CHESTER, VA 238310000
14,587.42 2.07%
0.00%
20.60 0.04%
14,608.02
1.83%
CC
1 295 & RT 10 CHESTER, VA 238310000
615.09 0.09%
0.00%
4.72 0.01%
619.81
0.08%
CC
RT 360 AND GENITO RD MIDLOTHIAN, VA 231130000
2906 CEDAR LN COLONIAL HEIGHT, VA 238340000
1,619.39 0.23%
891.86 0.13%
0.00%
0.00%
0.00%
0.00%
1,619.39
0.20%
0.11%
CTC
M
COL HGTS
891.86
3523 BOULEVARD COLONIAL HEIGHT, VA 238340000
12,084.14 1.71%
0.00%
0.00%
12,084.14
1.51%
M
604 BOULEVARD COLONIAL HGTS, VA 238343261
1,288.05 0.18%
0.00%
19.93 0.04%
1,307.98
0.16%
M
DINWIDDIE
25722 COX RD PETERSBURG, VA 238036514
7000 TIM PRICE WAY N CHESTERFLD, VA 232250000
11,294.61 1.60%
2,795.43 0.40%
0.00%
0.00%
0.00%
0.00%
11,294.61
2,795.43
1.41%
0.35%
M
CH
RICHMOND
7316 FOREST HILL AVENE RICHMOND, VA 232251526
116.84 0.02%
0.00%
0.00%
116.84
0.01%
W
CHESTERFIELD Total
375,204.23 95.44%
9,223.261100.00%
3,199.45 99.70%1
387;626.94
95.94%
COL HGTS Total
14,264.05 2.05%
0.00 0.00%
19.93 0.00o'
14,283.98
1.81%
RICHMOND Total
2,912.27, 0.41%
0.00 0.00%
0.00 .0.06%
2,912.27
6.37%
DINWIDDIE Total
.11,294.61 1.62%
0.00 0.000%
.0.00 0.00%
11,294.61
143%
GRAND TOTAL
403,675.16 97.0%
9,223.26 2.2%
3.219.38 0.8%
416.117.80
100.0%
My name is Marie Stella. I live in the beautiful Brandermill Community, Chesterfield and I am asking the
county to vote NO on the conditional use permit to install above ground fuel storage units on the water
shed at Clover Hill Technical Center, 19SNO564 based on insufficient safety and environmental analysis.
A safety analysis based primarily on a $15,000 high level report that is basically a check list of rules and
regulations, no detailed analysis of retention ponds size, spill flow, EPA, CWA and other regulations and
best practices for watershed use was used to justify this project. The analysis should be included in the
19SN0564 package and reviewed by the Board and is attached to this statement.
The EPA states that the risk to aboveground fueling systems are four (4) fold: accidental spills,
vandalism, terrorism, and natural disasters like tornados, earthquakes, etc. It also advises that spills of 45
gallons within .5 miles of water on watershed land usually cause instantaneous damage. This storm
water retention pond is .02 miles from the tanks and .3 miles the Swift Creek Reservoir. The county
minimizes these issue but studies and past events in the United States and in other countries support the
EPA. A study of 242 accidents of storage tanks incidents that appeared in the Journal of Loss Prevention
in the Process Industries, found that 74% of accidents occurred in petroleum refineries, oil terminals or
storage. Fire and explosion account for 85% of the accidents. There were 80 accidents (33%) caused by
lightning and 72 (30%) caused by human errors including poor operations and maintenance. Other
causes were equipment failure, sabotage, crack and rupture, leak and line rupture, static electricity, open
flames etc. �-Igtl
Although County briefing claims that there are no damages possible t ncrete structures. This is not
true. An advisory from Concrete Construction states lightning co only causes structural damage. Cold
bolts of lightning, following their way to the ground through co rete (which is a better conductor than air)
often provide enough force to fragment the concrete. In a ition, when a main bolt follows a lightning
protection system to the ground an opposite charge is ilt up in the reinforcing steel in the nearby
concrete. This side flash produces an explosive e t in the concrete, causing static discharge burn -
through or heating ignition of vapor in these tanks. he source of static may be the result of normal
operations such as filling or draining, or it may be econdary effect from a direct or nearby lightning strike.
Secondary effect arcing is also static discharge. This arcing is produced by the inrush of ambient ground
charge toward the point of a lightning strike. The inrushing charge can arc across gaps in its path, thus
providing both a static charge and a static discharge. A cold strike of lightning has explosive effect rather
than flammable and it is estimated, for us layman, that a large bolt of cold lightning can lift 44,000 ton
Ocean Liner six feet into the air. Indeed the reports to the Supervisors, under separate cover, document
case studies demonstrating this and other damages the immense human, financial and environmental
damage they cause. Three (3) minutes doesn't give us time to discuss air contamination, earthquake
impact (which we have experienced from the Luisa earthquake) and other possible dangers and the need
for evacuation policies,, protection of citizens who must remain in place, etc.,.in the case of a catastrophic
event
We have also referenced weld leaks, damage from liquids, toxic chemicals, bacteria growth that corrodes
metals and crack cement in links provided to the Supervisors under separate cover. All these issues
reinforce the risk of unintended design errors, technology weaknesses, human error or natural disasters,
which are too high to warrant installing these tanks so close to our water source and citizen population.
We must Vote NO to 19SN0564
I request that this statement be put into the minutes of this meeting
June 26, 2019
My name is Candace Graham and I live in Woodlake, in the Matoaca District. I am opposed to
zoning for installation of a fueling station behind the Tech Center on Hull St Rd.
The reason the county considered the fuel installation was to save money and to make bus
routes more efficient. I am not convinced that this installation would do either. Mr. Pace sent us
the review that the independent research company did which looks good, on the face of it.
asked about the inground pipes that transfer fuel from the tanks to the pumps. Our region is
infamous for our shrink -swell soil. In the 30 years since our house was built, our garage floor
has dropped over 2 inches on one side. What kind of impact would that "settling," or an
earthquake, have on inground pipes?
The cost avoidance estimate of $300,000 is based on the savings of bus drivers fueling at
county facilities and not using their Voyager Cards at Sheetz or WaWa. Mr Pace said that the
cost of installation would be recouped in 1 year. That is also based on estimates. We won't know
the actual cost of construction until it is designed.
Another issue is the traffic on Hull St Rd. Anyone who drives on Hull, traveling East from
neighborhoods West of the Tech Center (Woodlake, Hampton Park, Harpers Mill, for example)
has experienced bumper to bumper traffic. School is out and the traffic was still heavy at 1 pm
this afternoon. Unless buses can be mandated to fuel up on a specific day and time, we could
potentially have all 360 buses (60% of the 600) trying to get fuel at the same time on the same
day.
Imagine that buses have been assigned a specific day, and have been mandated to fuel up
either before their morning routes (6:30 - 7:30am) or before their afternoon routes (1 - 2pm).
That means that 36 buses would be trying to enter, get fuel, and exit at the traffic light by the
Tech Center in 1 hour. I don't believe it's logistically possible.
Why not mandate that the other 240 buses use the existing facilities at Walmsley and near the
county offices that they are closest to? That will yield a 40% savings of the estimated $300,000
cost avoidance, without any additional costs. The 360 buses in the western area can continue to
fuel up where it's most convenient for them. That would actually be more efficient.
We should really be converting to electric and looking for a station location further west in
Chesterfield, where we are continuing to develop. This would be clean, safe and efficient.
At the very least, this proposal should be deferred until we have actual figures, not estimates,
and until an environmental impact study and a traffic study have been completed, to answer all
questions.
Gas stations vent far more toxic fumes than previously
thought
October 4, 2018
Date:
Source:
Columbia University's Mailman School of Public Health
Summary.
A study examined the release of vapors from gas station vent pipes, finding emissions were
10 times higher than estimates used in setback regulations used to determine how close
schools, playgrounds, and parks can be situated to the facilities.
Share:
FULL STORY
A study led by environmental health scientists at Columbia University Mailman
School of Public Health examined the release of vapors from gas station vent
pipes, finding emissions were 10 times higher than estimates used in setback
regulations used to determine how close schools, playgrounds, and parks can
be situated to the facilities. Findings appear in the journal Science of the Total
Environment.
Gasoline vapors contain a number of toxic chemicals, notably benzene, a carcinogen.
The researchers attached gas flow -meters to venting pipes at two large gas stations in the Midwest
and Northwest and took measurements over a three-week period. They report average daily
evaporative losses of 7 and 3 gallons of liquid gasoline, respectively, or 1.4 pounds and 1.7 pounds
per 1,000 gallons dispensed at the pump. By comparison, the California Air Pollution Control Officers
Association (CAPCOA) used an estimate of 0.11 pounds per 1,000 gallons. Based on CAPCOA
emission estimates, the California Air Resources Board (CARB) determined their setback regulation
of 300 feet (91 meters) from large gas stations. Similar laws exist in many, but not all states and
localities. In urban areas like New York City, some gas stations are located directly adjacent to
apartment buildings.
The study also simulated how the fuel vapor was carried in the air to assess the potential for short -
and medium-term benzene exposures, comparing their measurements to three established
thresholds. The California Office of Environmental Health Hazard Assessment one-hour Reference
Exposure Level (REL) for benzene -- defined as a continuous hour of exposure to the chemical --
was exceeded at both gas stations at distances greater than 50 meters. At the Midwest gas station,
REL was exceeded on two different days at distances greater than 50 meters, and once as far as
160 meters. The Agency for Toxic Substances and Disease Registry's Minimal Risk Level (MRL) for
benzene exposure over a period between two weeks and a year was exceeded within 7 or 8 meters
of the two gas stations. A less stringent measure used for short-term exposures of first responders,
the American Industrial Hygiene Association's Emergency Response Planning Guidelines (ERPG),
was not exceeded.
"We found evidence that much more benzene is released by gas stations than previously thought. In
addition, even during a relatively short study period, we saw a number of instances in which people
could be exposed to the chemical at locations beyond the setback distance of 300 feet," said first
author Markus Hilpert, PhD, associate professor of Environmental Health Sciences at the Columbia
Mailman School. "Officials should reconsider their regulations based on these data with particular
attention to the possibility of short spikes in emissions resulting from regular operations or improper
procedures related to fuel deliveries and the use of pollution prevention technology."
In previous work, Hilpert and colleagues documented the release of gasoline as fuel is stored and
transferred between tanker trucks, storage tanks, and vehicle tanks, and how these spills can
contaminate the surrounding environment. Next, the researchers will explore additional short-term
measures of vapor spread to determine the bounds of safe setbacks.
Co-authors of the new study include Ana Maria Rule at Johns Hopkins, Bernat Adria -Mora formerly
at Columbia, and Tedmund Tiberi at ARID Technologies, Inc. In a competing interest statement, the
authors note that Tiberi directs a company that develops technologies for reducing fuel emissions
from gasoline -handling operations. The research is supported by a grant from the National Institutes
of Health (ES009089).
Story Source:
Materials provided by Columbia University's Mailman School of Public Health. (Vote: Content
may be edited for style and length.
Journal Reference:
Markus Hilpert, Ana Maria Rule, Bernat Adria -Mora, Tedmund Tiberi. Vent pipe emissions from
storage tanks at gas stations: Implications for setback distances. Science of The Total
Environment, 2019; 650: 2239 DOI: 10.1016/j.scitotenv.2018.09.303
From the Website for the magazine: Scientific American
https://www.scientificamerican.com/article/is-it-safe-to-live-near-gas-station/
Is It Safe to Live Near a
Gas Station?
The health concerns for you or your family with living by
the pump
Dear EarthTalk: I am looking at possibly buying a house that is very
close to a gasoline station. Is it safe to live so close to a gas station?
What concerns should I have? I have toddler and infant babies.
-- Ranjeeta, Houston, TX
Despite all the modern health and safety guidelines they must follow, gas
stations can still pose significant hazards to neighbors, especially children.
Some`of the perils include ground -level ozQne.gaused in part by gasoline
fumes, groundwater dw ater hazards from petroleum products leakin into the
ground, and exposure.hazards from other chemicals that might be used at the
station if it's also a repair shop.
Ozone pollution is caused by a mixture of volatile organic compounds, some of
which are found in gasoline vapors, and others, like carbon monoxide, that
come from car exhaust. Most gas pumps today must have government -
regulated vapor -recovery boots on their nozzles, which limit the release of gas
vapors while you're refueling your car. A similar system is used by the station
when a tanker arrives to refill the underground tanks. But if those boots aren't
working properly, the nearly odorless hydrocarbon fumes, which contain
harmful chemicals like benzene, can be released into the air.
ADVERTISEMENT
Hi her,ozonelevels can lead'to res P it
g
atory problems and asthma, while"
benzene is a known cancer-causing chemical, according_to_the National
Institutes of Health (NIH)." The quest to reduce ozone levels has led the state
of California to implement a more stringent vapor -recovery law, effective April
12 2009, which requires that all gasoline pumps have a new, more effective
vapor -recovery nozzle.
Underground gasoline storage tanks can also be a problem. The U.S.
Environmental Protection Agency (EPA) estimates that there are some
660,000 of them from coast-to-coast. Many a lawsuit has been filed against oil
firms in communities across the country by people whose soil and
groundwater were fouled by a gas station's leaking underground storage tank.
In the past, most tanks were made of uncoated steel, which will rust over time.
Also, pipes leading to the tanks can be accidentally ruptured.
When thousands of gallons of.gasoline enter the soil,`chemicals travel to
I roundwater, which the EPA says is the source of drinking water for -nearly
half the U S: If buying.{a home, consider rts potential loss m value if a nearby
underground storage tank were to leak; Gasoline additives such as methyl
tertiary -butyl ether (MTBE), which has been outlawed in some states, make
the water undrinkable—and that is only one of iso chemicals in gasoline.
Repeated high exposure to gasoline, whether in liquid or vapor form, can
cause lung, brain and kidney damage, according to the NIH's National Library
of Medicine.
Spilled or vaporized gasoline is not the only chemical hazard if the station is
also a repair shop. Mechanics use solvents, antifreeze and lead products, and
may work on vehicles that have asbestos in brakes or clutches. Auto
refinishers and paint shops use even more potentially harmful chemicals.
In today's car -centric world, we can't escape exposure completely, because
these chemicals are in our air just about everywhere. But by choosing where
we live, keeping an eye out for spills, and pressuring the oil companies to do
the right thing for the communities they occupy, we can minimize our
exposures.
CONTACTS: U.S. EPA, www.epa.gov; National Institutes of
Health, www.nih.gov.
MARSH & MCLENNAN
AGENCY
June 17, 2019
Reference: CFC.475.599T
Mr. Jeff T. Howard
Chesterfield County
General Services — Waste & Resource Recovery Division
6751 Mimms Loop
Chesterfield, Virginia 23832
Re: Evaluation of Proposed CTC Hull Fuel Site
Dear Mr. Howard:
MMA Environmental
P.O. Box 12748
Roanoke, VA 24028
+1 540 985 9540
Toll Free +1855 245 2004
Fax +1 540 985 9538
MMA -Environmental (MMA -E) was retained by Chesterfield County to perform an
objective third -party evaluation of the proposed CTC Hull Fuel Site with respect to
environmental risk and approaches to suitably mitigate risk. Risk mitigation was evaluated
as it relates to environmental regulatory requirements at the federal, state and local level
as well as implementation of Best Management Practices (BMPs) that will provide a highly
protective tank and refueling system.
MMA -E is a global, full service environmental and safety risk management company. Our
qualifications, and those of the Principal Investigator, are provided as attachments to this
letter.
We understand the proposed facility will be located; at- the -Chesterfield Career and
Technical Center at 13900 Hull Street Road in Midlothian, Virginia and will consist of 5,000
gallons in gasoline storage, 10,000 gallons in diesel storage and 1,000 gallons in propane
storage. The gasoline and diesel will be contained in double -walled concrete vault -style
aboveground storage tanks (ASTs) and will be piped via subgrade double -walled piping
with line -leak detectors to two adjacent dispensers for fueling County buses and other
Mr. Jeff T. Howard
Reference: Evaluation of Proposed CTC Hull Fuel Site
06/17/19
Page 2
vehicles. We visited the site with County representatives on Monday, June 10, 2019.
During this visit we walked the project area in addition to downgradient property
surrounding local surface water bodies and the associated Resource Protection Area
(RPA)'.
Based on our site visit, discussions with County representatives and an evaluation of the
County's Conceptual Design and associated federal, state and local regulations we have
identified the legally required actions necessary to comply with referenced regulations in
addition to a series of BMPs to protect the RPA. Many of the identified design elements
and proposed actions have already been incorporated into the County's Conceptual
Design but are included herein for the purpose of completeness.
Regulatory requirements are detailed in the attached Table and the more substantive
requirements include the following:
- A Spill Prevention, Control and Countermeasure (SPCC) Plan under the Clean
Water Act to ensure the site design and operational practices prevent releases of
petroleum from the tank systems as well as providing steps to respond to any such
releases from reaching Waters of the Commonwealth (including streams and
reservoirs);
Registration of the gasoline and diesel ASTs with the Virginia Department of
Environmental Quality;
A Stormwater Pollution Prevention Plan (SWPPP) under the County's Municipal
Separate Storm Sewer System (MS4) Permit under the National Pollutant
Discharge Elimination System to ensure proper measures are taken to protect the
County's stormwater system and receiving bodies of water; and
Initial and subsequent annual notifications to local and state emergency
responders to facilitate effective emergency response services under the
Emergency Planning and Community Right -To -Know Act.
Mr. Jeff T. Howard
Reference: Evaluation of Proposed CFC Hull Fuel Site
06/17/19
Page 3
To ensure compliance with the aforementioned requirements and to provide an additional
layer of protectiveness the following proposed conceptual containment design is
presented. It consists of multiple layers of protectiveness in the form of both passive and
active containment and incorporates previously identified design features (e.g., double -
walled tank design). The attached figure presents a graphical image of the proposed
design:
- Double -walled tank design — The County's Conceptual Design specified that
each petroleum AST will have integral secondary containment and be of a concrete
vault design. These ASTs will have an interstitial space alarm, a multiple -tier
overfill alarm system, covered primary and emergency vents and will be certified
(e.g., UL=listed, STI/API compliant, etc.)
- Concrete block secondary containment — This tertiary containment system
would surround the ASTs and provide storage capacity for 100% of the largest
AST plus. adequate freeboard for a 25 -year, 24-hour rain event. It would have a
locked shutoff valve on the drain system that leads to an oil water separator as
discussed below. As'this valve would remain in locked shutoff status, stormwater
will accumulate. During daily checks of the system any accumulated stormwater
would be discharged through the oil water separator only after the inspector
documents that there is no petroleum sheen or other indicator of contamination.
- Rollover bermed area adjacent to the ASTs — This containment would surround
the area that a refilling truck would park to fill the ASTs. It would be designed with
a low profile to enable vehicles to drive over and into the area and have a storage
capacity equal to a fuel truck pod (typically 1,500-3,000 gallons). It would drain
through an open valve to piping leading to the oil water separator, except during
AST filling operations, when it would be closed. As it would remain open during
normal operations, no stormwater would accumulate. This bermed area could be
placed on any side of the proposed AST location.
Rollover bermed area and/or trench drains surrounding the dispensers —
There are three acceptable approaches to consider for suitably protective
containment around the dispensers:
I
Mr. Jeff T.. Howard
Reference: Evaluation of Proposed CTC Hull Fuel Site
06/17/19
Page 4
o Trench Drains — The County's Conceptual Design includes a series of
trench drains surrounding the dispenser fueling area which would be
constructed to contain any releases and pipe them to the oil water
separator. A valve would remain open during normal operations but could
be closed in the event of a release.
o Rollover Berm — Rollover berms in the dispenser fueling area could be
designed identically to the AST refilling rollover bermed area. It would
operate as described for the trench drains.
o Trench Drains and Rollover Berm, - While not required, additional
protectiveness could be provided by implementing both trench drains and
a rollover berm.
Oil water separator — This added protective measure, which was incorporated
into the County's Conceptual Designwould receive flow from all containment areas
described above and have sufficient capacity to intercept a reasonable worst case
release event. It would discharge to the downslope area to the south. This
discharge point would be inspected as part of the facility's quarterly inspections
conducted under the SPCC Plan and the SWPPP.
- Other protective measures — Other measures to be in place would include:
o Designed into the County's Conceptual Design:
■ Spill response kits of suitable size and location to enable rapid
response to a release event;
■ Trained County employees present during AST filling operations;
■ Quarterly and annual inspections of the entire system as required
under the SPCC Plan and the SWPPP; and
■ Routine maintenance/cleanout/inspections of the oil water
separator to ensure proper operation.
o Additionally, daily inspections of the containment areas to ensure proper
stormwater flow.
Mr. Jeff T. Howard
Reference: Evaluation of Proposed CTC Hull Fuel Site
06/17/19
Page 5
It is our opinion that the approach outlined in this letter will not only be compliant with
relevant federal, state and local regulatory requirements but will be highly protective of
surrounding sensitive areas such as the RPA. The design approach and BMPs will
comprise a best -in -class refueling operation that goes beyond the legal minimum
requirements.
Please feel free to contact me at (540) 767-4153 if you have any questions or comments.
MMA -E appreciates the opportunity to be of service to you and the County.
Sincerely,
Scott Perkins, P.E.
Client Executive
Attachments
ATTACHMENTS
Table 3 - legal Requirements AnoIVSls
Subject
Issue
Stepsto Resolve
Regulatory Citation
Comments
There are no applicable air permitting requirements associated
Air
with this action.
No steps required
9 VAC 5-10-10 e[seq.
The facility's SIC code does not trigger coverage under the
No steps required
9 VAC 25-151-10 et seq
NA
VPDES Industrial General Stormwater Permit.
Stormwater
Being within Chesterfield County subjects the facility to the
1. Confirm applicability with the Chesterfield County
County -wide MS4 Permit. The facility would he considered a
Environmental Engineering Department;
High Priority Municipal Facility and thus require a Stormwater
2 If applicable, develop a SWPPP asa HPMF, train employees and
County MS4 Permit
Pollution Prevention Plan (SWPPP) and inclusion in the County's
implement.
annual reporting to VDEQ.
No relevant Screening Threshold Quantities are exceeded for
Diesel and gasoline have no thresholds and there are no
Chemical Facility Antl- errori5m
chemicals stored per the Department of Homeland Security
or that exceed thresholds, while
components of dieseld
Standards
(DHS) Chemical Facility Anti -Terrorism Standards (CFAT5)
No steps required
6 CFR 27
is 60, 00
the propane threshold is 60,000 lbs (higher than the 4,20016s
therefore no Chemical Security Assessment Tool (LSAT) Top
stored on site).
Screen Assessment is required.
The facility's NAILS code does not trigger Toxic Release
Inventory reporting for chemicals whose annual throughput
No steps required
40 CFR 372
exceeds relevant thresholds. No such thresholds are exceeded
Emergency Planning and
and thus no reporting is required.
Community Rightto KnowAd
(EPCRA)
Initial and annual Tier II reporting is required for hazardous
-
chemicals that are stored at any time in excess of relevant
1. Submit an initial notice to local and state emergency response
thresholds. The 10,000 pound threshold for both diesel and
authorities within 90 days of initiating operation..
40 CFR 370
gasoline is exceeded however it is not exceeded for propane
2. Submit annual reports by March 1 of each subsequent year.
(4,200 lbs). Initial and annual reporting is required.
Petroleum tanks in excess of 660 gallons require registration
Register the diesel and gasoline ASTs using VDEQ Form 7540 -AST.
9 VAC 25-91-100
with VDEQ
1. Generate an SPCC Plan with Best Management Practices to
mitigate potential adverse impacts to surrounding surface water.
Additional general Clean Water Act prohibitions against adverse
Petroleum Management
Since there is greater than 1,320 gallons of petroleum to be
stored on site, the facility will require a Spill Prevention, Control
2. Train employees on spill prevention and response actions.
3. Provide the requisite spill response equipment and associated
40 CFR 112
impacts to surface water exist, but these are adequately
addressed by the SPCC Program requirements, which are a part
and Countermeasures (SPCC) Plan.
infrastructure to ensure the adjacentsurface water, including
ofthe Clean Water Act.
Swift Creek Reservoir, is protected.
c
t�
t,:*_�-� apt ,�'•a. ,�'� i
LEGEND
Cement block secondary
containment around ASTs
Rollover bermed area for AST
filling operations
Rollover bermed area and/or
trench drains for dispenser
operations
I Piping from containment areas to oil
water separator
Project No.: CFC.475.599T FIGURE 1
Drawn By/Date: SEP 06/12/19 SITE MAP MARSH & MCLENNAN
Checked By/Date: SEP 06/13/19 CTC Hull Fuel Site Proposed Approach F AGENCY
Scale: None 13900 Hull Street Road
Midlothian, Virginia
,4MARSH & MCLENNAN
0. AGENCY
MMA Environmental RISK CONSULTING
ENVIRONMENTAL SERVICES
Over the past three decades the promulgation of international, national, regional and local
regulations, coupled with increasingly stringent business standards and litigation, has
broadened the spectrum of business sectors that now must recognize and properly
manage their HSE liabilities. The myriad of HSE risks which corporations must face go
beyond simple regulatory compliance. Corporate managers must now understand
liabilities ranging from past contamination of real estate to the potential infestation of
microorganisms; from the historical disposal practices of newly acquired companies to
biological and chemical terrorism. MMA Environmental provides its clients with the
experience and expertise to structure and manage your comprehensive HSE program or
provide technical support.
MMA Environmental is a global practice that provides its clients a cadre of expertise
capable of addressing a range of concerns including conducting mergers and acquisitions
due diligence assessments, internal compliance reporting, building bioterrorism
vulnerability assessments and the development and implementation of compliance
management systems. MMA -E's technical experts have extensive experience in
conducting Risk, site condition assessments and remedial action plan design,
development and implementation of environmental management systems and procedures,
documenting and quantifying the extent and nature of environmental impacts, developing
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Utilizing our vast knowledge of manufacturing processes, international permitting and
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assist our clients and their attorneys by conducting independent investigations that cover
the spectrum of quality control practices, safety reviews and compliance audits. Our
services can be utilized not only regarding coverage issues, but also in consideration of
current sustainability and environmental awareness initiatives (for example, evaluation of
alternate fuel use, or due -diligence regarding possible acquisitions). MMA -E combines
internationally consistent methodologies for each of our HSE services with its global
presence and knowledge of the business value of HSE program alternatives to create the
appropriate procedures and programs that will identify and manage your environmental,
safety and employee health concerns. Environmental consulting services include:
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that go beyond the technical environmental reviews commonly produced by traditional
consultants. We review environmental risks associated with business operations as well
as legacy liability and property exposures. Within a full -scope engagement, MMA -E
inspects the physical condition of the site's equipment; reviews maintenance, operation,
environmental records, insurance policies and contracts; and interviews key staff. A
limited vulnerability review for physical conditions that could lead to chemical releases is
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MMARSH & MCLENNAN
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Environmental Insurability Evaluation. Since the Environmental Risk Assessment
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an Assessment, correlating various areas of potentially available coverage to client
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and manage a team of professionals for any environmental task using specialty software.
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primary focus is on integrated environmental management, and is responsible for the
appointment and review of specialist studies, Impact Assessments, Stakeholder
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waste), waste classification and delisting, design of waste management Systems, -
including waste treatment and disposal option identification and feasibility analysis,
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Investigations. Occupational Health Risk Assessments especially in relation with
Hazardous Chemical Substances, Quality control in Occupational Health, based on.ISO
standards, and Third Party Auditing covering Occupational Health, Environment (both
micro and macro), as well as ISO 14000 and OHSAS 18000.
Emissions Inventories and Carbon Footprint Assessments. MMA -E air specialists can
determine of stack, fugitive and ambient emissions (including particulate matter and CO2
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and CO2 equivalents, both direct and indirect), and Life Cycle Assessments including
comparisons of alternative products and services by calculation of total environmental,
social and financial footprint using ISO 14040 methodologies.
Site Rehabilitation Planning: Including re -vegetation plans (plant lists and plant
specifications), surface storm water management, hydrogeological modeling and
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Compilation and verification of Sustainability Reports, Covering Environmental,
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Claims consulting services. MMA -E provides claims support services specific to
environmental coverage disputes, coverage interpretations, and cost recoveries.
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Scott E. Perkins, P.E.
Client Executive
Scott has worked with MMA -Environmental, Inc., formerly
Faulkner & Flynn, Inc. for almost 15 years in the field of
environmental regulatory compliance. He is a licensed
Professional Engineer with degrees in Environmental
Engineering from Duke University and the University of
Colorado. His expertise in both environmental regulatory
compliance issues and environmental program management
is based on a 24 -year career, working in such unique
locations as Antarctica, the Niger River Delta and all regions
within the U.S., including substantial work for the chemical
industry. He has provided expert witness testimony in
federal and state trials at both the civil and criminal levels. MMA -Environmental is an
environmental risk management consulting firm within the Marsh and McLennan
family of companies.
Liberty Trust Building • Second Floor • 101 S. Jefferson Street • Roanoke, Virginia 24011
Telephone (540) 767-4153 • Facsimile (540) 985-9538 • www.faulknerflynn.com • scott.perkins@faulknerflynn.com
GENERAL
SERVICES
CTC Hull Fueling Site
Board of Supervisors Meeting
June 26, 2019
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Setbacks
• Exceed all setback requirements
➢ Site within existing cleared area and inside property/fence line
➢ Fuel tanks at least 150' from nearest property line (25' required)
• Preservation of all existing vegetation
➢ Screens site from adjacent properties
➢ Condition provides for additional plantings if warranted by seasonal changes
Site Selection Goals
• Geographical goals
➢ Started w/ GIS map of all schools and gas pumps
➢ Need = northern portion of County
➢ Proximity to existing schools and bus routes
➢ Located on a main road
➢ Minimize dead -head miles and impact on vehicles
➢ Utilize available county -owned land, mixed use location preferred
CTC Hull is already a mixed use facility — conference/meeting, educational, new pickleball
courts, planned park-and-ride, stadium, sports fields, etc.
• Consultation with CCPS, consistent use with who we're trying to serve
• Maximize financial benefits (est. $300K savings annually)
• Law enforcement users stay in their response areas
• Low visibility from main road and adjoining properties
• Signalized intersection
Traffic
• Minima impact —Fuel site only open to county vehicles
• Average traffic on 360 in this area = 78K vehicles/day
• Anticipated utilization = 72 buses/day (-.046% increase to traffic count)
➢ -60% of 600 buses used in northern part of county
➢ ^20% of these buses may fuel at any given day = 72
➢
—50% of the 72 buses likely travelling on Hull St. already
• Vehicles will use signalized entrance at CTC - Harbor Pointe signalized entrance (4462' away) not impacted
8
Emergency Response
• Chesterfield Fire & EMS fully trained and equi ped to provide comprehensive
response in the event of emergency or hazardpous materials incident
➢Fire Station #7 located next door— approximately 1/10 mile from site
Tanks & Secondary Containment
• Minimizing spill potential at tanks & pumps
➢ 110% secondary containment to capture 100% of tank
contents
➢ Concrete encased and double -walled steel
➢ High-level filling alarm
➢ Containment for pumps via trench drain and oil/water
separator
➢ Automatic continuous leak sensing, audible/visual alarms for
sudden loss of fuel, leaks and overfills
➢ Fleet staff supervises fuel deliveries for safety compliance
➢ Auto -fill mechanism pump nozzle handle will be removed
➢ Breakaway hoses with quick -disconnects will be installed
10
Tanks & Safety
Potential lightning strike:
➢ Tanks, canopy and dispensers will be designed with
grounding to -dissipate electrical charge to the ground
• Facility not subject to special reporting
required by Chemical Facility Anti -Terrorism
Standards(CFATS)
• Compliant with stringent Underwriters
Laboratories Inc. (UL) standard UL -2085, the
nationally recognized safety standard for
Protected Aboveground Tanks for blast, fire,
and ballistic impact protection
• Vent design:
➢ All vents capped and closed during normal operations
➢ Vents only open if pressure equalization is needed,
then immediate closure
Karagozian & Associates Blast Effects Study: Concrete
VY T"'
1
500 lbs TNT 40' So IbsTNr10'
Environmental Safeguards
• Protection of Resource Protection Area (RPA)
➢ Design complies with all EPA and DEQ regulations
➢ Spill Prevention, Control, and Countermeasures (SPCC) Plan required
➢ DEQ regulated & monitored Storm Water Pollution Prevention Plan
➢ Tanks built inside spill containment area w/ protective bollards
➢ Sloped design to ensure drainage away from RPA
➢ Canopy, bollards, trench drain and oil/water separator on pump site
➢ Driver training for spill response (users & delivery drivers)
➢ Spill kits at fuel island
500lbsTNT10' Section through AST
u
12
Chesterfield County Above Ground Tank Approach
• Rooted in 1984 amendments to Resource Conservation and Recovery Act (RCRA) which instituted regulation of underground
storage tanks (tank standards, reporting requirements, corrective action, financial responsibility, compliance monitoring, etc.)
> Required EPA to develop program for the regulation of underground storage tanks "as may be necessary to protect human health and the environment"
> By 12/22/98, underground storage tanks had to comply with federal and state regulations, be taken out of service or removed
• In response, County engaged consultant to develop recommendations and implementation plan for UST's
After considering pros and cons of both approaches, County adopted AST's as a standard based on the following:
> Regulatory compliance burden for AST's equally as strict as UST's
> AST's just as safe as UST's
> More easily inspected visually - leaks more immediately detectable
> Easier access for preventative maintenance and repairs
> Required financial responsibility demonstration for UST's not applicable to AST's
> Lower ongoing maintenance costs
> Eliminates need for specialized confined space entry for inspection & maintenance
> Decreased construction cost
• County has operated a tank safety program for over 15 years for over 200 ASTs in 7 different departments w/ no history of
vandalism, fires, explosions or significant spills
13
Securit
>Tanks locked and secured with full
enclosure on all sides
> County -supplied key fob required to
activate pumps
> Lighting at sites
> Increased Police presence for
fueling
> Concrete -encased tanks
14
Visibilit
➢ View from fueling site showing visibility through RPA
Visibilit
• Minimize impact on neighboring properties
➢ Lighting at fuel site will meet existing County code requirements
➢ View from existing R zoned parcels showing visibility through RPA:
is
16
4011 Harbour Pointe Rd
View From 14011 Harbour Pointe Road
-" c
kt Ors !$r.
iii � 4 � T4 �.r`, g i d+Y. ,\\ ^ �17 y,.�'y�
CIA Eastbluff Rd
View From 13909 Eastbluff
Road
147,
Noise
Minimize impact on neighboring properties
Fuel delivery time condition pushed back to 7 AM
Decibel readings collected:
❖ Ambient noise level at 721' = 58db (conversation in restaurant or office)
❖ Ambient noise level at 1062' = 42db (—library, low limit of urban ambient sound)
❖ No change detected with bus operating at fuel site
3rd Party Review Findings
• MMA Environmental retained to perform objective 3rd party evaluation of proposed project
• Scope:
➢ Evaluate environmental risk.
➢ Review approaches to mitigate risk
➢ Review of federal, state & local environmental regulatory compliance .
➢Analyze strategies to provide a highly protective tank/refueling system
• Recommendation:
➢Add rollover berms to tank and pump areas to provide an additional level of protection
• Opinion:
➢Approach to project compliant with all relevant federal, state and local regulatory requirements
➢ Project highly protective of surrounding areas and RPA
➢ Design approach will comprise a "best -in -class" fueling operation that exceeds requirements
19
20
Speeks Road Site
• Site doesn't align with site selection process
and goals:
➢ Location 4 % miles east of CTC Hull — doesn't serve buses
in the area of need
➢ Property not County owned —Purchase cost at least
$750K (not budgeted)
➢ Doesn't help minimize dead -head miles
➢ Not a compatible use for the area
• Site too small — difficult for buses to navigate
and ingress/egress safely
• Potential environmental issues and cost
➢ Remediation and/or removal of UST's (not budgeted)
➢ Demolition of structure(not budgeted)
• Removes property from tax rolls, Zl
REQUEST
Conditional use planned development to permit an unmanned automobile self-service station in a
Residential (R-7) District.
Notes:
A. Conditions may be imposed or the property owner may proffer conditions.
B. Conditions and exhibits are located in Attachments 1- 3.
SUMMARY
A vehicle refueling site to service the Chesterfield County and Chesterfield County Public School
vehicles is planned. The proposed site would occupy approximately 0.3 acres northwest of the
parking area for the Chesterfield County Public Schools Career and Technical Center.
RECOMMENDATION
PLANNING
APPROVAL
COMMISSION
AYES: Freye, Jones and Stariha ABSTENTION: Jackson ABSENT: Sloan
g„ CHESTERFIELD COUNTY, VIRGINIA
• Provides appropriate co -location of public facilities in area convenient to
STAFF
CLOVER HILL DISTRICT
t°"
esVeO
�4g STAFF'S ANALYSIS
AND RECOMMENDATION
Request
Property
Board of Supervisors (BOS) Public Hearing:
JUNE 26, 2019
BOS Time Remaining:'F��A
365 DAYS
Applicant's Agent:
e
ALVA PACE (804-748-1399)
Planning Department Case Manager:
JANE PETERSON (804-748-1045)
49.3 Acres (Portion of)
—13900 Hull Street Road
REQUEST
Conditional use planned development to permit an unmanned automobile self-service station in a
Residential (R-7) District.
Notes:
A. Conditions may be imposed or the property owner may proffer conditions.
B. Conditions and exhibits are located in Attachments 1- 3.
SUMMARY
A vehicle refueling site to service the Chesterfield County and Chesterfield County Public School
vehicles is planned. The proposed site would occupy approximately 0.3 acres northwest of the
parking area for the Chesterfield County Public Schools Career and Technical Center.
RECOMMENDATION
PLANNING
APPROVAL
COMMISSION
AYES: Freye, Jones and Stariha ABSTENTION: Jackson ABSENT: Sloan
APPROVAL
• Provides appropriate co -location of public facilities in area convenient to
STAFF
users
• As conditioned, minimizes impacts on area development
Providing a FIRST CHOICE community through excellence in public service
2 19SN0564-2019JUN26-BOS-RPT-C
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Comprehensive Plan
Classification: COMMUNITY BUSINESS
The designation suggests the property is appropriate for commercial uses that serve community -wide
trade areas.
Subject Property
1,000 500 0 1,000
Feet
Surrounding Land Uses and Development
3 19SNO564-2019J U N26-BOS-RPT-C
PLANNING
Staff Contact: Jane Peterson (804-748-1045) petersonj@chesterfield.gov
Proposal
An unmanned automobile self-service station is proposed on the site of the Chesterfield County
Public Schools Career and Technical Center (CTC) Hull Street Campus. The proposed facility,
contained within approximately 0.3 acres, would be limited to servicing Chesterfield County and
Chesterfield County Public School vehicles. The applicant indicates this location will reduce the
mileage to existing facilities located on Walmsley Boulevard and the County Government Complex,
as well as the cost of using retail sites. An unmanned automobile self-service station is first
permitted in the Neighborhood Business (C-2) District, requiring a conditional use planned
development in a Residential District.
The facility would be located northwest of the CTC parking area, using the school's access to
Hull Street Road (Exhibit A). The proposal includes two 10,000 gallon above ground fuel tanks
and two 1,000 gallon above ground propane tanks and would be available, with limited hours
for fuel vendors servicing the tanks. Refueling for County vehicles would be available 24 hours
a day, 7 days a week. As conditioned, facility improvements would be located no closer than
110 feet from the western parcel boundary. A Resource Protection Area (RPA) is located just
west of the proposed facility and would serve as a buffer between the facility and the closest
adjacent properties to the west. Conditions would provide for supplementation of vegetation,
as needed, to minimize views of the facility from the north and west as determined through site
plan review.
Use and Comprehensive Plan:
The Public Facilities Plan recommends location of fleet maintenance facilities where convenient
to fleet users, and with at least one access to a collector or major arterial road. The Plan also
encourages joint -use agreements between school and county agencies for use of school
facilities and grounds.
The chart on the following page provides an overview of recommended conditions to mitigate the
impact of the use on area properties:
4 19SN0564-2019J U N26-BOS-RPT-C
General Overview
Requirements
Details
As shown on exhibits. Minimum distance of 110 feet (fuel islands)
Location & Setbacks
and 150 feet (above ground fuel tanks) from western property
boundary.
Condition 1
Limited to Chesterfield County and Chesterfield County Public School
Use of Facility
vehicles. Condition 2
Above ground fuel tanks enclosed by fencing to preclude trespassing.
Security Fencing
Condition 3
Fuel Vendor
Limited to Monday through Friday from 7:00 a.m. to 6:00 p.m.
Days/Hours
Condition 4
Supplemental
Additional plantings around facility perimeter provided, as needed, to
Vegetation
minimize views of facility from north and west
Condition 5
VIRGINIA DEPARTMENT OF TRANSPORTATION
Staff Contact: Jonathan Phillippe (804-674-2560) jonathan.phillippe@vdot.virginia.gov
To date, no comments have been received.
FIRE AND EMERGENCY MEDICAL SERVICES
Staff Contact: Anthony Batten (804-717-6167) battena@chesterfield.gov
When the property is developed, the number of hydrants, quantity of water needed for fire
protection, and access requirements will be evaluated during the plans review process.
The storage of gasoline or diesel fuel requires a minimum separation distance of 25 feet from
the lot line. Dispensing devices require a minimum separation distance of 10 feet from the lot
line. The proposed setbacks from the lot line are 110 feet for fuel islands and 150 feet for
storage tanks.
Nearby Fire and Emergency Medical Service (EMS) Facilities
Fire Station The Clover Hill Fire Station, Company Number 7
EMS Facility The Clover Hill Fire Station, Company Number 7
5 19SNO564-2019J U N26-BOS-RPT-C
SCHOOLS
Staff Contact: Atonja Allen (804-318-8740) atonja_allen@ccpsnet.net
Mission
The Career and Technical Center (CTC) at Hull Street Road is an instructional facility for students
from grades 8 to 12 and the location of CCPS Division of School Leadership and Support Services,
Division of Teaching and Learning, Department of Communication and Community Engagement,
Department of Constituent Services and Student Leadership, and the Chesterfield Education
Foundation. It is also a venue for special events and conferences on a routine basis.
Students, staff, visitors, and school buses utilize the parking area, which is accessed through a
single point of ingress and egress on Hull Street Road. School buses currently take up a large
portion of parking space near the proposed fueling station. The applicant indicates that turning
radiuses for school buses will be adequate through the development of engineering site plan
drawings and on-site testing.
ENVIRONMENTAL ENGINEERING
Staff Contact: Rebeccah Ward (804-748-1028) wardr@chesterfield.gov
Geography
The majority of the subject property generally drains west and then via tributaries to an existing
stormwater basin prior to entering the Swift Creek Reservoir. The remainder of the property
drains north through the Harbour Pointe subdivision and into the Reservoir. The entire
property is located within the Upper Swift Creek Watershed.
The proposed vehicle fueling station site is located adjacent to the existing track and football
field. The majority of the proposed fueling station site and associated access is covered with
gravel and is currently used for overflow parking and storage.
Environmental Features
A Resource Protection Area (RPA) Designation was completed by the applicant and reviewed and
confirmed by the Department of Environmental Engineering — Water Quality Section. A portion of
the existing gravel area adjacent to the proposed fueling station site and the associated access
drive on the southern side of the fueling station is within the limits of the existing RPA. The
redevelopment of the gravel storage area for the installation of the fueling station and
appurtenant features will require a Water Quality Impact Assessment (WQIA), which must be
submitted to and approved by the Department of Environmental Engineering. The fueling station
must be kept outside of the limits of the RPA. In addition, the net impervious area within the
limits of the RPA cannot increase with the proposed redevelopment. On-site mitigation measures,
such as additional plantings and/or supplementary water quality features (BMPs), may be required
through the WQIA process.
6 19SNO564-2019J U N26-BOS-RPT-C
Improvements which require new impervious area within the limits of the RPA or parking within
the limits of the RPA must be approved by the Board of Supervisors though the Chesapeake Bay
Preservation Area Ordinance's Formal Exception process.
Stormwater Management
The redevelopment of the subject property will be subject to the Part IIB technical criteria of
the Virginia Stormwater Management Program Regulations for water quality and quantity.
COUNTY TRANSPORTATION
Staff Contact: Steve Adams (804) 748-1037 adamsSt@chesterfield.gov
UTILITIES
Staff Contact: Jamie Bland (804-751-4439) blandj@chesterfield.gov
PARKS AND RECREATION
Staff Contact: Stuart Connock (804-751-4484) ConnockS@chesterfield.gov
This request will have limited impact on these facilities.
7 19SNO564-2019J U N26-BOS-RPT-C
CASE HISTORY
Applicant Submittals
10/4/18 Application submitted
10/4/18 Exhibits submitted
Community Meeting
12/10/18
Meeting cancelled due to inclement weather.
1/2/19
Issues Discussed:
4/16/19
• Site selection; existing county fueling facilities (convenient site; Walmsley
and County Government complex)
• Anticipated number of vehicles using site (approximately 150 buses and
other County vehicles)
• Additional traffic on Hull Street Road
• Hours for tank filling; size of storage tanks; automatic shut-off for pumps
(limited hours; 2 propane (1,000 gal) and 2 fuel (10,000 gal))
• Distance from school (CTC) (approximately 500 feet)
• Environmental Impacts (containment); proximity to RPA/wetlands
• Impact on area home sales
• Future uses for area behind school (pickleball court; park & ride)
3/26/19
No citizens attended
Planning Commission
1/15/19
Action - DEFERRED ON THE COMMISSION'S OWN MOTION TO APRIL 16, 2019,
WITH THE APPLICANT'S CONSENT
4/16/19
Citizen Comments:
Citizens from the Harbour Pointe community noted concerns with noise from
additional bus traffic using the facility; security of fuel storage tanks;
environmental impacts from possible tank leaks and proximity to the Reservoir;
and odors. Consideration of commercially -zoned area properties was suggested.
Commission Discussion:
In response to questions of the Commission, the applicant estimated 75 buses
fueling at the site per day, with half coming from outside the immediate area.
A cost savings would be recognized for reduced vehicle mileage to access a
fueling facility without relying on retail sites. County protocol supports use of
above ground fuel storage as environmentally safe with clearer visibility of
potential leaks. Spill containment would be addressed with a double walled
containment system, an oil/water separator, and spill kits. Conditions limit
hours for filling tanks; security fencing around the tanks would preclude
trespass; and views of the facility would be buffered by RPA, existing vegetation
and the school building.
19SNO564-2019J U N26-BOS-RPT-C
Planning Commission (Continued)
4/16/19
In response to questions of the Commission, staff reviewed RPA and vegetated
areas around the site, and design measures required by the county during the
plans review process to address spill containment.
The Commission discussed concerns for the use of above ground v. buried fuel
tanks relative to vandalism and spill containment; impacts on neighboring
residential uses relative to buffers and fuel tank filling hours, and consideration
of alternate locations for the facility. It was agreed that a deferral would allow
time to address these concerns.
Action - DEFERRED ON THE COMMISSION'S OWN MOTION TO MAY 21, 2019,
WITH THE APPLICANT'S CONSENT
5/21/19
Citizen Comments:
Several citizens spoke in opposition to this request, noting concerns relative to
safety of above -ground fuel tanks in proximity to residential and daycare uses;
environmental impacts from possible tank leaks in proximity to Reservoir;
watershed integrity and potential effects on drinking water supply; noise, fumes
and odor from additional bus traffic; shallow setbacks insufficient to screen
visibility of facility in winter; emergency response times/evacuations for events
at an unmanned facility; and preference for alternate location away from
residential areas.
In response to questions of the Commission, the applicant noted county
management of approximately 200 above -ground fuel tanks with no spill
history; and the absence of tanks in this area for fueling county vehicles.
In response to questions of the Commission, county environmental staff noted
no objections to the proposal.
Mrs. Freye noted the deferral permitted time to provide details to questions
raised at the April public hearing. She noted proper measures are in place to
protect drinking water; the facility will attract a small amount of new traffic to
the area; above -ground and underground fuel tanks are equally safe and
regulated; conditions offer supplemental vegetation in setbacks to minimize
visual impacts of facility; and morning tank filling hours have been adjusted one
hour later. She indicated that conditions have been responsive to minimizing
facility impacts.
Recommendation — APPROVAL SUBJECT TO THE CONDITIONS IN ATTACHMENT
1
Motion: Freye Second: Jones
AYES: Freye, Jones, and Stariha
ABSTENTION: Jackson
ABSENT: Sloan
The Board of Supervisors on Wednesday, June 26, 2019, beginning at 6:00 p.m., will consider
this request.
19SNO564-2019J U N26-BOS-RPT-C
ATTACHMENT 1
CONDITIONS
1. Facility Size, Location and Concept.
a. The vehicle fueling facility shall contain a maximum of 0.3 acres and shall be as
generally located on Exhibit A.
b. The location of fuel islands and above ground fuel tanks shall be as generally
shown on Exhibit B. The number of above ground fuel tanks shall be limited to
four (4). From the western boundary of the subject property, fuel islands shall
be located a minimum distance of 110 feet, and above ground fuel tanks located
a minimum distance of 150 feet. (P)
2. Limitations on Use. Use of the fueling facility shall be limited to Chesterfield County and
Chesterfield County Public School vehicles. (P)
3. Security Fencing. Above ground fuel tanks shall be enclosed by a security fence
designed to preclude trespassing. A detailed plan depicting this requirement shall be
submitted to the Planning Department for approval in conjunction with building permit
review. (P)
4. Fuel Vendor Days/Hours. Servicing/filling of fuel tanks shall be limited to Monday
through Friday from 7:00 a.m. to 6:00 p.m. except during emergencies. (P)
5. Supplemental Vegetation. Supplemental landscaping shall be provided around the
perimeter of the fueling facility, as needed, to minimize its view from adjacent
properties to the north and west. The Planning Department, at the time of site plan
review, shall approve the landscaping plan with respect to the exact numbers, spacing,
arrangement and species of plantings. (P)
10 19SNO564-2019J U N26-BOS-RPT-C
ATTACHMENT 2
9.:
11 19SN0564-2019J U N26—BOS—RPT—C
stem
perty %Por+�
Along
reek
ATTACHMENT 3
IN9.19M
12 19SN0564-2019JUN26-BOS-RPT-C