DERR-2024-004278

February 19, 2024

WORK PLAN: OIV-02

ABATEMENT DURING UST REPLACEMENT

K & C Trading Post (Sinclair)
161 East Main Street
Bluff, Utah
Facility ID #5000084, Release Site OIV

Submitted To: Mr. Vance Nielson
JVP, Inc.
P. O. Box 27
Bluff, Utah 84512

Copy To: Mr. Hong-Lei Tao
Department of Environmental Quality
Division of Environmental Response and Remediation
P.0. Box 144840
Salt Lake City, Utah 84114-4840

Dear Mr. Nielson and Mr. Tao:

K & C Trading Post (Sinclair) reported a release of petroleum from an underground storage tank (UST)
to the Division of Environmental Response and Remediation (DERR) based on a failed tank tightness
test. The release was initially detected by the automatic tank gauging (ATG) system and then confirmed
by tank testing. The failed premium gasoline tank was immediately emptied. The failed UST in question
is part of a 15,000 gallon two-compartment fiberglass tank. The other compartment contained regular
gasoline.

The K & C Trading Post Sinclair is the only operating gas station in the remote town of Bluff, Utah.
Given the necessity for a gas station in Bluff, a replacement tank was promptly purchased. The
replacement tank, scheduled for delivery on March 13th, 2024 is a double walled fiberglass tank of the
same size and configuration. The delivery date was expedited given the urgency of the situation.

Work Plan OIV -02
K & C Trading Post (Sinclair)
Facility ID# 5000084, Release Site OIV

Underwood Environmental Consulting, Inc.
2
The existing flex piping will also be replaced and under dispenser containment added. The existing
canopy will remain. It should be noted that cleanup excavation activities have the potential to
compromise the stability of the canopy. In such an event, stabilization measures would be implemented
by using excavation equipment to hold the canopy upright during cleanup activities. This work plan
does not include these costs as they are considered an emergency contingency.

This work plan and budget has been prepared for implementation of abatement activities to cleanup
gasoline impacted soil within and below the existing UST(s) and, if contacted, groundwater or perched
water within the excavation. The proposed work would be implemented immediately following the
planned UST removal on March 6th, 2024 and conclude prior to the scheduled replacement UST on
March 13th, 2024. The costs included in this work plan intentionally exclude work which would be part
of the UST removal and replacement, per Utah DERR PST Fund guidelines.

The proposed work includes over-excavation and disposal of hydrocarbon impacted soil from within
and below the existing UST basin, confirmation sampling, backfilling, and related tasks. Public
notification has been conducted and no comments were received. During this proposed (abatement)
cleanup and subsequent UST system installation, the town of Bluff will be without a gasoline fueling
station.

Release site OIV is Petroleum Storage Tank (PST) Fund eligible. PST Fund payment claims will
reference this work plan and the specific task(s) itemized below.

I. OBJECTIVE

The objective of the work plan is to implement cleanup of gasoline impacts contained within and below the
existing UST excavation. The existing UST is 29 years old and constructed of non-corrosive fiberglass
material. It is not known what caused the failure of the tank. Based on the tank tester’s approximations and
inventory records, it is estimated that between 300 and 500 gallons of gasoline were lost. The tank
dimensions are approximately 8 feet in diameter and 44 feet long. The replacement tank will be
approximately the same size and configuration but it will be a double walled fiberglass tank rather than
single walled. The existing UST appears to be buried to a depth of approximately 12 feet below grade.
Therefore, the gasoline release would have impacted 7-8 feet of soil before reaching the groundwater table.
Much of the fuel released may be adsorbed in the soils below and surrounding the tank. This proposed
abatement could potentially address a significant portion of the overall cleanup. However, it is also likely
that further remedial efforts will be necessary to remediate the entire release.

Given the nature of a recent gasoline release additional safety measures will be required. Air monitoring
with an explosimeter and vapor suppression using a spray product such a Micro-Blaze emergency spill
control liquid is highly recommended.

The tasks in this work plan include preparation of general contractor specifications, bid solicitation, and
implementation of an excavation project. The general contractor’s bid has been awarded to a local
excavator, Sonderegger Inc., located in Monticello, Utah. Three competitive bids are included in this work
plan. Costs are based on unit rates and payment will be made directly to the general contractor based on
actual quantities incurred.

Work Plan OIV -02
K & C Trading Post (Sinclair)
Facility ID# 5000084, Release Site OIV

Underwood Environmental Consulting, Inc.
3
Limitations to excavation extents include the existing canopy to the south and underground utilities adjacent
to highway 191 to the north. The estimate for gasoline impacted soil volume targeted for removal is 200
cubic yards (CY) or approximately 300 tons. Additionally, 100 cy of non-impacted soil is included if
necessary to access the targeted soil. Actual quantities may exceed these preliminary estimates depending
on the nature and distribution of the release. Additional costs are included in the GC bid specifications to
manage groundwater if encountered. However, a recent subsurface investigation completed on February
19th, 2024 indicate the depth to groundwater to be 19 feet. Preliminary field data suggests the water table
is relatively flat with a slight gradient to the west and south (west towards Cottonwood Wash and south
towards the San Juan River). Given the limitations to excavation extent, as explained above, it may not be
feasible to reach a depth below the groundwater table. Therefore, it is likely that groundwater management
will not be necessary thus reducing the overall cost of the project. The San Juan County Landfill has
indicated that they will accept contaminated soil as long as it is non-hazardous. The landfill is located south
of Blanding, Utah which would be the closest disposal location. Other disposal facilities do exist but are at
a further distance from the project site.

A detailed cost estimate for the proposed work, prepared according to the format specified in UAC R311-
207-5, is attached. PST fund payment claims would reference the approved work plan and portions of work
completed. Payments, based on job completion, would be made directly to UEC, the facility owner and to
the general contractor (Sonderegger Inc).

II. TASKS

Task 1. Work Plan and Budget Development

• Project management, technical review
• Preliminary excavation plan, inquiries with disposal facilities
• Preparation of General Contractor (GC) bid specifications
• Bidding process and correspondence with excavation contractors
• Work plan preparation
• Budget preparation

Task 2. Soil Excavation and Disposal, Backfill, Resurfacing, Groundwater Management,
and Confirmation Sampling

• Field planning and coordination
• Excavation oversight, field screening, manifests
• Confirmation sampling, chain-of-custody, lab delivery
• Backfill oversight and documentation
• Site safety measures (Micro-Blaze, air monitoring, etc.)
• Groundwater management and treatment (frac tank) if necessary
• Asphalt/Concrete resurfacing if excavation is extended laterally
• Management oversight and review
• PST Claim preparation
• Other direct costs

Task 3. Reporting

• Data evaluation, data tables
• Site map(s) preparation
• Report preparation
• PST Claim preparation
• Office management
• Technical review

III. OPINION OF PROBABLE COSTS

An opinion of probable cost for the tasks proposed in this work plan is $176,502.44. A detailed budget
by task is attached. All activities are to be invoiced on a time, materials, and expense basis. No out of
scope work will be performed without your pre-approval.

We appreciate the opportunity to assist you on this project. Please feel free to contact me at (801) 831-
6966 should you have any questions or concerns.

Sincerely,
Underwood Environmental Consulting, Inc.

L. Earl Underwood, P.G.
Sr. Geologist
UST Consultant, CC-0018

K C Trading Post (Sinclair)
Abatement During Tank Removal/Replacement
Work Plan OIV-02, Facility ID 5000084
Task 1 - Project Management, Work Plan and Budget Development
LABOR
Hours Title Code Description Rate Total
2 Senior Proj Manager 101 Sr. Management and Review 152.00$ 304.00$
4 Professional Eng/Geol 102 Preliminary Excavation Plan 147.00$ 588.00$
8 Project Manager 103
Bid Specs, Bid Process,
Correspondence/Meetings with Excavation
Contractors 118.00$ 944.00$
4 Project Manager 103
Correspondence w/ Disposal Facility Rep.,
DERR and Property Owner 118.00$ 472.00$
9 Project Manager 103 Work Plan Prep 118.00$ 1,062.00$
2 PST Specialist 108 PSTF Accounting 78.00$ 156.00$
2 Admin Assistant 109 Clerical, Publishing/Mailing 62.00$ 124.00$
Subtotal 3,650.00$
SUBCONTRACTORS
Item Quantity Unit Rate Total
None Anticipated Subtotal -$
OTHER DIRECT COSTS
Item Quantity Unit Rate Total
Mileage 0 Mile 0.67$ -$
Subtotal -$
Task Total 3,650.00$
Page 1 of 3
K C Trading Post (Sinclair)
Abatement During Tank Removal/Replacement
Work Plan OIV-02, Facility ID 5000084
Task 2 - Soil Excavation and Disposal, Backfill, Resurfacing, Groundwater Management, and Confirmation Sampling
LABOR
Hours Title Code Description Rate Total
6 Senior Proj Manager 101
Oversight of project budget and field work
schedule, Review PSTF Voucher packages,
Data Review, Client, DERR and GC
Interface.152.00$ 912.00$
8 Project Manager 103
Coordination, Scheduling and Planning with
Disposal Facilities, Excavation Contractor
and Client 118.00$ 944.00$
8 Field Scientist 104 Prefield: Order Equipment and Supplies 101.00$ 808.00$
14 Project Manager 103 Travel; Round Trip (680 miles)118.00$ 1,652.00$
60 Project Manager 103
On-Site Project Supervision; Oversee
Abatement Activities; Field Screening during
excavation,Confirmation Sampling, Assume
6 days on-site between time of tank removal
and new tank installation.
118.00$ 7,080.00$
14 Field Scientist 104 Travel; Round Trip (680 miles)101.00$ 1,414.00$
52 Field Scientist 104
Excavation Safety: Air Monitoring with
Explosimeter and PID, Application of vapor
suppresent (Micro-Blaze), Track Soil
Manifests, Load Counts and Volume
Estimates; Assist Project Manager,
Sample Delivery; Assume 5 days on site.
101.00$ 5,252.00$
8 PST Specialist 108 PSTF Accounting, Invoice Verification 78.00$ 624.00$
8 Admin Assist 109 Clerical 62.00$ 496.00$
Subtotal 19,182.00$
SUBCONTRACTORS
Item Quantity Unit Rate Total
Excavation Contractor (per bid)1
Per Bid Sheet Total: Dig and Haul Backfill
and Resurface (does not include optional
vacuum truck / free product disposal)
141,179.00$ 141,179.00$
Lab Soil Analysis 10 8260B, 8015C (MBTEXN, GRO, DRO)85.00$ 850.00$
Lab Water Analysis 2 8260B, 8015C (MBTEXN, GRO, DRO)85.00$ 170.00$
Subtotal 142,199.00$
OTHER DIRECT COSTS
Item Quantity Unit Rate Total
PID 6 Day 95.00$ 570.00$
Micro-Blaze (5 gal)1 Estimate with shipping costs 300.00$ 300.00$
Spray Applicator (Micro-Blaze)1 Estimate 150.00$ 150.00$
Explosimeter Rental 1 Estimate 1 week with shipping 500.00$ 500.00$
Disposable Sampling Supplies 6 Day 25.00$ 150.00$
Per Diem 14 Day 45.00$ 630.00$
Lodging 14
Nights (6 nights for P104 and 8 nights for
P103)145.00$ 2,030.00$
Mileage 1432
680 miles per round trip, 2 round trips (one
for P103, one for P104) plus lab delivery (72
miles)0.670$ 959.44$
Subtotal 5,289.44$
Task Total 166,670.44$
Page 2 of 3
K C Trading Post (Sinclair)
Abatement During Tank Removal/Replacement
Work Plan OIV-02, Facility ID 5000084
Task 3 - Reporting
LABOR
Hours Title Code Description Rate Total
4 Senior Proj Eng/Geol 101
Final Document Review, PSTF Claim
Review, Client and DERR Correspondence 152.00$ 608.00$
2 Prof Eng/Geol 102
Review Maps, Tables and Documents for
Professional Accuracy 147.00$ 294.00$
40 Project Manager 103 Report Preparation 118.00$ 4,720.00$
4 PST Specialist 108 PSTF Claim Prep 78.00$ 312.00$
4 Admin Assist 109 Clerical 62.00$ 248.00$
Subtotal 6,182.00$
SUBCONTRACTORS
Item Quantity Unit Rate Total
None Anticipated -$ -$
Subtotal -$
OTHER DIRECT COSTS
Item Quantity Unit Rate Total
None Anticipated -$ -$
Subtotal -$
Task Total 6,182.00$
GRAND TOTAL 176,502.44$
Page 3 of 3
UST System
Site Aerial Map for Work Plan OIV-02
K & C Trading Post
161 East Main Street
Bluff, Utah
Facility ID 5000084
Release OIVN
PUBLIC NOTICE

Petroleum Underground Storage Tank Cleanup Project
K and C Trading Post (Sinclair), 161 Main St., Bluff, Utah
Facility ID# 5000084, Release Site OIV

The K and C Trading Post (Sinclair), under direction of the Utah Department of Environmental Quality, Division
of Environmental Response and Remediation, is planning to remediate petroleum-contaminated soil and/or
groundwater, if encountered, during the planned replacement of the underground fuel system. The environmental
consultant for the project is Underwood Environmental Consulting, Inc. (UEC). Contact: Earl Underwood, PG
at [phone].

Underground Storage Tank (UST) Replacement and Cleanup Measures

The underground storage tank and fuel system at the Sinclair gas station will be removed in mid to late March
2024. During and immediately after the tank removal petroleum impacted soils and groundwater, if encountered,
shall be excavated or extracted. Those impacted materials will be hauled to an approved disposal facility and/or
properly treated as appropriate. Following these cleanup measures a new UST will be installed in the same
excavation.

Schedule

The UST removal and soil cleanup project is tentatively scheduled to begin in March 2024. It is anticipated that
cleanup activities will take less that one week. Immediately following the cleanup activities, a new UST fueling
system will be installed. The fuel system installation is anticipated to take approximately two weeks.

For More Information

For additional information or to provide comment(s), please contact:

Mr. Hong-Lei Tao, Project Manager [phone]
Email: [e-mail]
Department of Environmental Quality
Division of Environmental Response and Remediation
P.O. Box 144840, SLC, UT 84114-4840