DERR-2024-006418

Hong-lei Tao <[e-mail]>
CAP Discussion for Western Petroleum/Naples Bulk Plant, 9000171, KMX
1 message
Hong-lei Tao <[e-mail]>Thu, Mar 28, 2024 at 1:51 PM
To: Earl <[e-mail]>
Cc: Michael Pecorelli <[e-mail]>, Avery Holyoak <[e-mail]>
Hi Earl,
Thanks for preparing and submitting the CAP for the Western Petroleum/Naples Bulk Plant. I have discussed this with Mike
and Avery, and we have some questions that need further clarification, which are listed below:
1. We like the approach for excavating contaminated soils in the area of tank basin/AST tank farm, and we think it
would also be a good idea to apply oxidation chemicals and/or biodegradation products at the bottom of the
excavation pit to address the residual contamination (I will call you to discuss regarding these chemicals/agents).
2. Could you give us an estimation for the quantity of the soils that need to be excavated? A rough estimate for the
excavation costs would be very helpful as well.
3. It is a feasible approach to use Calclean to abate the free products east of the tank basin. Please clarify if
Calclean could bring the extracted free product/GW with them and take them away from the site. In addition, please
clarify if additional extraction wells are needed for GW extraction.
4. Pumping GW out to Frac tanks from the excavation bottom, and re-inject back to the pit sounds like a feasible
approach as well. Please evaluate and clarify if there are alternative ways for disposal of impacted GW in the area
(i.e., landfills, wastewater treatment facilities, etc.).
5. Upon reviewing the historical soil boring logs, it appears that the on-site soils are mainly sand/gravel/cobble, so
SVE and Air Sparging may still be feasible approaches. Please add a paragraph in your CAP for evaluating the
feasibility and cost effectiveness of this approach. I know there is a clay/clay silt layer above 7 feet bgs at the site,
but I don’t know if it is continuous. It would be beneficial to prepare a cross section for the areas that need to be
remediated.
Please update your CAP and add the above-referenced supplement information. If you have any questions and/or concerns
on this matter, feel free to contact us. Thanks.
Hong-Lei Tao, M.S. | PST Fund Project Manager
385.391.8138 (office) | 801.536.3598 (fax)
4/25/24, 11:47 AM State of Utah Mail - CAP Discussion for Western Petroleum/Naples Bulk Plant, 9000171, KMX
https://mail.google.com/mail/u/0/?ik=a09aa4868b&view=pt&search=all&permthid=thread-a:r8474262878382846883%7Cmsg-a:r-3834849103662824140&simpl=msg-a:r-3834849103662824140&mb=1 1/2
195 North 1950 West, Salt Lake City, UT 84116
4/25/24, 11:47 AM State of Utah Mail - CAP Discussion for Western Petroleum/Naples Bulk Plant, 9000171, KMX
https://mail.google.com/mail/u/0/?ik=a09aa4868b&view=pt&search=all&permthid=thread-a:r8474262878382846883%7Cmsg-a:r-3834849103662824140&simpl=msg-a:r-3834849103662824140&mb=1 2/2