DERR-2025-004153

Tetra Tech
4750 West 2100 South, Suite 400 – Salt Lake City, Utah 84120
Tel [phone] tetratech.com
_7884746.1
May 13, 2025
Brent H. Everett
Director
Utah Division of Environmental Response and Remediation
195 North 1950 West
Salt Lake City, Utah 84114-4840

Via email: Brent Everett, Morgan Atkinson, Liberty Coe
Subject: Response to DERR Letters dated April 28 and 29, 2025 regarding the Former ABF
Freight Site at 55 South Redwood Road, Salt Lake City, Utah (Site)
Dear Mr. Everett,
Tetra Tech, Inc. (Tetra Tech) is submitting this letter on behalf of CTP DEV, LLC (CTP DEV), a Larry
H. Miller Real Estate company, in response to two letters issued by the Utah Division of Environmental
Response and Remediation (DERR):
1. April 28, 2025, Free Product Abatement and Groundwater Requirements, Former ABF Freight
System, Inc., 55 South Redwood Road, Salt Lake City, Facility ID 4001342, Release FFQ
2. April 29, 2025, Request for Information Regarding PST Fund Eligibility at the Former ABF
freight Site, ABF Freight, 55 South Redwood Road, Salt Lake City, Facility ID 4001342
After receipt of these letters, Tetra Tech’s Project Manager, David Wilson spoke with DERR’s
Underground Storage Tank Program Manager Morgan Atkinson and Project Manager Liberty Coe about
the letters, and we agreed that CTP DEV and Tetra Tech would reply with actions to be taken in
response to the letters. CTP DEV plans to undertake the following actions (with Tetra Tech support) in
cooperation with the DERR:
1. Perform product-thickness and depth-to-groundwater monitoring to assess potential changes in
Site conditions following the termination of power and product recovery at the trench
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containment system and remove LNAPL, if present, from wells along the fence line in
accordance with the first letter requesting free product abatement by May 28, 2025.
2.Provide a summary of the observations from Item 1 above by June 27, 2025.
3.Collaborate with the DERR to support expeditious review and approval of the previously
submitted Corrective Action Plan (CAP) for the Site; this includes DERR’s completion of a 15-
day public comment period. CTP DEV intends to implement the CAP as soon as DERR grants
approval and the selected remediation contractor (Spackman Enterprises) can mobilize to
perform this work. The work will begin with excavation along the north property line to capture
free product in this area and enhance LNAPL abatement at the fence line, if present, and provide
a permanent solution for the Site.
4.Present preliminary evidence of releases from the ABF Freight underground storage tanks 4, 5, 6
and 7 (ABF Tanks) prior to advancing a formal GRAMA request as described in the second
letter; please see Attachment 1 that presents current evidence to be discussed in a virtual
meeting with DERR concerning a second release from the ABF Tanks insured by the Petroleum
Storage Tank Fund (PSTF). Tetra Tech will propose a date for the meeting via separate
correspondence.
5.Issue a GRAMA request to DERR depending on the outcome of the meeting described in Item 4,
if further evidence gathering is required after the meeting. CTP DEV and Tetra Tech understand
from the second letter that evidence of a new release must be submitted to the DERR by June 28,
2025, if additional evidence is required beyond the contents of Attachment 1.
We thank you for your consideration and efforts to complete the public comment process and expedite
agency approval of the CAP. Please contact CTP DEV or Tetra Tech with questions regarding this
correspondence.
Sincerely,
David S. Wilson, PE, PG
Principal Engineer
3 TETRA TECH
_7884746.1
Copy: Michael Pecorelli, DERR
Chris Howell, DERR
Carl Duke, CTP DEV
Matt Blocker, CTP DEV
Ron Lund, Environmental Health Director, Salt Lake County Health Department
Eric Peterson, Environmental Health Deputy, Salt Lake County Health Department
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ATTACHMENT 1
SUPPLEMENTAL EVIDENCE OF RELEASES FROM TANKS 4, 5, 6 AND 7
AT FORMER ABF FREIGHT SITE
SUMMARY
The evidence provided herein demonstrates continuous,
unreported, releasesat the former ABF Freight underground
storage tanks (USTs) 4, 5, 6, and 7 system (ABF Tanks) from two
locations during the period of PSTF coverage (1992 to 2024):
1. Spills during filling operations at the ABF Tanks where
damaged spill buckets and piping were observed during
operation by DERR and UST removal by Spackman, and fresh
diesel constituents T, E, and X were detected in groundwater
2. Releases from the Fuel Building oil water separator (OWS)
showing B, E, and X in soils in 2020 on the floor of Excavation
D north of the OWS
Tetra Tech can provide calculated estimates of diesel fuel
quantities released at each location based on the operational
history of the USTs and OWS during the 32 years of PSTF
coverage
OWS
6 ft
USTs 4 ft
Map of product thickness in
1989 from Release FFQ
provided by Utah DERR
Product thickness at the
Fuel Building OWS ~ 6 feet
Product thickness at ABF Tanks
~ 4 feet
North and south of these
source areas, product
thickness diminishes rapidly
suggesting historical releases
from the Fuel Building OWS
and from ABF Tanks
Recent Monitoring (2023 and 2024) of Existing Diesel Plume
December 2023 September 2024
2023
groundwater
sampling results;
there were no
detections of
BTEX
2024 Groundwater analytical data show one low detection of
Benzene outside of plume area (MW-7) and no other detections of BETXN
During removal of ABF Tanks, Spackman and Tetra Tech
observed evidence of new release in areas of spill buckets and
UST piping
Tank 5 had staining on pump, piping and tank
Diesel from UST closure excavation, color is amber
and typical of fresh diesel per Spackman
ABF Tanks Closure Groundwater Results
Toluene, ethylbenzene, total xylenes detected in groundwater sample from
UST basin (yellow highlights)
These results are evidence of recent releases from ABF Tanks with light diesel
constituents present in the UST basin groundwater while prior groundwater well
data showed no BTEXN in 2023 and 2024
Map showing soil
Excavation D north of
Fuel Building and
Connected OWS
This excavation,
outlined in blue
was performed in 2020
north of the
OWS when ABF Tanks
were covered by the
PSTF
OWS
Fuel Building OWS Separator
Fuel Building OWS Removed December 2024
Diesel in OWS excavation at time of removal, color is black,
which Spackman stated indicates it is old diesel
Analytical results from highlighted floor samples
show benzene above ISLs and other light diesel
constituents: ethyl-benzene, naphthalene and
xylene, demonstrating the release of fresh diesel
from the Fuel Building and/or connected OWS
Fresh Diesel from Maverik Sample OWS-FB-NAPL
from vicinity of OWS
New Diesel and OWS Diesel
Fresh diesel sample compared to diesel from area of OWS
Sample OWS-FB-NAPL collected from the open excavation of the OWS
during demolition work in December 2024, detected polycyclic aromatic
hydrocarbons (PAHs), which typically come from waste oil. These
compounds were not detected in the fresh diesel sample.
2-Methylnaphthalene 3,320 mg/kg
Phenanthrene 1,970 mg/kg
This demonstrates that the OWS leaked waste oil (and diesel), and in
combination with the 2020 excavation results showing B, E, X that the
releases were recent and during PSTF coverage that began in 1992.
Additionally, according to Shane Adolf (former owner of Sump and Trap
Cleaning [STC]), STC began servicing the OWS in 2015. STC collected 4,000
to 4,500 gallons from the OWS every 6 months, of which 5-15% of that was
recoverable diesel fuel. STC servicedABF until they ceased operations in
2023.
Supplemental demonstration of unreported OWS leakage