DERR-2025-004327

Responses to DERR Technical Comments on Corrective Action Plan
for ABF Freight, Facility 4001342, Release FFQ
Page 1 of 3
AGENCY COMMENTS AND CTP DEV, LLC RESPONSES
Comments from Division of Environmental Response and Remediation (DERR, May 22, 2025)
No. Referenced
Section DERR Comments/Questions CTP DEV Responses
General Comments
1 Not Applicable
(n/a) for the
General
Comments
DERR General Comment #1 – This Corrective Action Plan (CAP) is intended to
outline the proposed cleanup remedy and not determine Environmental Assurance
Program Fund (formerly known as the PST Fund) eligibility or financial
responsibilities. To facilitate a timely review of the CAP, please remove any
reference to potential funding through the Environmental Assurance Program Fund.
The CAP has been revised to remove prior references to the Environmental Assurance Program
Fund (formerly PST Fund) and references to Release OLX have been reduced and limited to
historical acknowledgement that an independent assessment of evidence and potential coverage
for part of the facility is under review by CTP DEV, LLC (CTP DEV) and the DERR; however,
whether coverage applies to the facility or not does not affect the planned corrective action
presented in the CAP.
2 n/a DERR General Comment #2 – The CAP needs to address the known off-site
groundwater contamination and define the full extent of the groundwater plume.
Please include a section to define off-site monitoring and explain how off-site
groundwater contamination will be addressed.
Section 8.2 of the CAP describes the planned closure monitoring program following source
material removal from within the Site. The list of off-site wells to be monitored has been revised
to include Well W-26 per Specific Comment No. 8. Monitoring will be performed quarterly for the
first year and semi-annually thereafter per the CAP. CTP DEV has added language to this
section of the CAP to allow installation of additional off-site wells to further characterize
downgradient conditions if existing off-site wells show concentrations above the cleanup
standards in Section 2.1 of the CAP beginning in the second year of monitoring.
3 n/a DERR General Comment #3 – All landfill waste encountered during corrective
action activities must be visually inspected by a Utah Certified Asbestos Inspector
prior to being transported off-site. Any suspected Asbestos Containing Material
(ACM) must be segregated, sampled, and managed in accordance with Utah
Division of Air Quality Asbestos Program rules. Suspected ACM is not limited
exclusively to Transite Siding and Piping.
Section 7.1 of the CAP has been revised to include the DERR’s request that a Utah Certified
Asbestos Inspector visually inspect the excavated materials to assess whether ACM may be
present, and that such materials will be managed in accordance with Utah Division of Air Quality
Asbestos Program rules. This section already provides contingency measures to stop work in
areas where ACM is identified and procedures for removal by a Utah-certified asbestos
contractor.
4 n/a DERR General Comment #4 – Cyanide and Mercury have been identified as
chemicals of concern at the South Temple Landfill. At times, concentrations of
Cyanide have been identified at levels that are considered dangerous to worker
health. Cyanide is identifiable by blue/green stained soil. Your Waste Management
Plan should address this site concern.
Section 7.2 has been revised to include the DERR’s notice regarding the potential presence, risk
and appearance of cyanide in soils associated with the historical South Temple Landfill. This
section already provides contingency measures to stop work in areas where non-petroleum
impacts are identified and procedures for characterization, on-site management, transportation
and disposal.
5 n/a DERR General Comment #5 – The use of ISLs does not address vapor intrusion.
Since there are no buildings over the known plume area, this is not a current issue,
but the future plans for the property development need a vapor intrusion
assessment.
CTP DEV understands this recommendation from the DERR and depending on the results of
post-remediation sampling of soils around the site perimeter and/or groundwater results, vapor
intrusion risks will be considered. However, CTP DEV notes that during 2023 and 2024
groundwater monitoring events, volatile organic compounds (VOCs) were not detected. No
revision has been made to the CAP in response to this DERR comment.

Specific Comments
1 Section 2.2
Page 6
DERR Specific Comment #1 – The CAP states, “the [South Temple] landfill was
given no further action status based on investigative activities and contaminant
levels that were at or below U.S. Environmental Protection Agency (EPA) Regional
Screening Levels (RSLs).” This definition does not reflect the status of the site
accurately. The South Temple Landfill site (EPA ID UT0001767318) includes the
Section 2.2 has been revised to include the DERR’s clarifying language regarding the status of
the former South Temple Landfill site according to DERR’s review of EPA’s records for the
CERCLIS site.
Responses to DERR Technical Comments on Corrective Action Plan
for ABF Freight, Facility 4001342, Release FFQ
Page 2 of 3
AGENCY COMMENTS AND CTP DEV, LLC RESPONSES
Comments from Division of Environmental Response and Remediation (DERR, May 22, 2025)
No. Referenced
Section DERR Comments/Questions CTP DEV Responses
entirety of the subject project and was designated No Further Remedial Action
Planned (NFRAP) by the EPA in 2000 based on the former industrial use of the
property. The site was never archived and could be reopened in the future by the
EPA if a change of land use occurs that threatens human health and the
environment. Please revise the text to address this comment.
2 Section 2.2
Page 6
DERR Specific Comment #2 – The Power District VCP (also situated on the South
Temple Landfill established an action/cleanup level of 14 mg/kg for arsenic in soil.
Please adopt this number or propose additional sampling to establish site-specific
background arsenic concentrations and cleanup levels in your materials
management plan.
Section 2.2 (top of page 7) has been revised to incorporate the DERR language identifying 14
mg/kg arsenic as the established action/cleanup level for the Power District VCP and applicable
background level for the ABF Freight Site; plus, recognition that the arsenic results from Tetra
Tech’s 2023 Phase II ESA were all below this action/cleanup level.
3 Page 4.1
Page 12
DERR Specific Comment #3 – Backfilling should only take place after confirmation
sampling is completed and data has been evaluated for site-specific needs. Please
be aware that backfilling excavations prior to meeting cleanup goals may delay the
release reaching regulatory closure.
Section 4.1 has been revised to include as a final bullet the following language per the DERR’s
comment: “Backfill the excavation upon achievement of the cleanup standards or as required to
support CTP DEV development of the property while continuing to monitor groundwater following
completion of the corrective actions described herein. Backfilling will occur only after soil
confirmation sampling is completed and data has been evaluated for site-specific needs .”
4 Section 4.2
Page 14
DERR Specific Comment #4 – The CAP states, “Excavated soils will be
segregated into clean overburden soil for temporary stockpiling on Site and reuse as
excavation backfill upon completion of remediation.” Please note that DERR will not
permit any soil exceeding ISLs or other regulatory limits for other chemicals of
concern to be used as backfill. Any soil excavated from the site containing landfill
materials (metal, glass, brick, concrete, plastic, etc.) may not be used as backfill.
Section 4.2 (paragraph 7) has been revised to include the following language per the DERR’s
comment: “The DERR has directed, and CTP DEV agrees that no soil exceeding ISLs or other
regulatory limits for other chemicals of concern may be used as backfill at the Site. Soil
containing trash characteristic of municipal solid waste will not be used as backfill; however,
generally inert materials such as construction and demolition debris (e.g., concrete, brick, wood,
limited metals, etc.) mixed with soil may be used as backfill provided it meets the criteria above in
terms of ISLs and other regulatory limits as applicable. The use of inert waste used as road
building material and fill material are excluded from the C&D landfill requirements (R315-305-
1(c)(2) and includes the existing site fill unless it exhibits the chemical characteristics described
above.”

CTP DEV respectfully disagrees with the DERR’s comment regarding reuse of backfill containing
C&D material, as noted above. The reuse of such materials as fill material is common practice in
Utah and should be allowed as clarified above and consistent with Utah regulations.
5 Section 4.3
Page 15
DERR Specific Comment #5 – Confirmation soil samples must be collected from
the floor and sidewalls of the excavation. Please propose sidewall sampling at a
minimum of every 50 feet and floor sampling at a rate of one sample per excavation
cut (as seen on Figure C-102). The DERR recommends removing all petroleum
impacted soil, which may not be limited to the proposed 11-foot excavation depth.
Section 4.3 has been revised as follows to incorporate DERR’s request for additional
confirmation soil samples: “Samples will be collected every 100 linear feet to document residual
petroleum concentrations that remain following soil excavation. Excavation floor samples will be
collected approximately every 100 linear feet as well to document residual concentrations (if any)
that remain following soil excavation. The floor samples will be collected using the excavator
bucket because these materials will be recovered from below the groundwater surface. Sidewall
samples will be collected every 100 linear feet to document residual petroleum concentrations
that remain following soil excavation at a depth within the vadose zone or approximately 1 foot
above the current depth to groundwater (i.e., approximately 6-7 feet bgs). The 100-foot spacing
for side-wall samples is recommended instead of 50-foot spacings because of the scale of this
Responses to DERR Technical Comments on Corrective Action Plan
for ABF Freight, Facility 4001342, Release FFQ
Page 3 of 3

AGENCY COMMENTS AND CTP DEV, LLC RESPONSES
Comments from Division of Environmental Response and Remediation (DERR, May 22, 2025)
No. Referenced
Section DERR Comments/Questions CTP DEV Responses
excavation. The Engineer will collect samples from areas of visible sidewall staining and/or
elevated PID readings for analysis of potential high-concentration soils.”

CTP DEV has added floor samples at DERR’s request even though these samples will come
from below the water table; efforts will be made to collect these samples so that they are not
compromised by potential constituents in the groundwater. The spacing of samples is proposed
at 100-feet around the excavation sidewalls and across the excavation floor for consistency of
spacing. A horizontal spacing is recommended rather than one sample per excavation cut
because the configuration of the aggregate berms may be altered from the drawings based on
Contractor input and value engineering. The number of confirmation samples to be collected
based on this spacing is estimated to be about 10 excavation floor samples and 12 sidewall
samples.
6 Section 5.0
Page 16
DERR Specific Comment #6 – Please include the following permitting requirements
in the text: Fugitive Dust and VOC Emissions Permits.
Section 5.1 has been revised to indicated that receipt of Fugitive Dust and VOC Emission
Permits will be required prior to the start of excavations, as applicable.
7 Section 8.2
Page 20
DERR Specific Comment #7 – The Off-Site Wells to be monitored in the post
corrective action groundwater monitoring do not include W-26. Please included W-
26 in the proposed sampling.
Section 8.2 has been revised to included Well W-26 within the list of off-site wells to be monitored
as described under CTP DEV’s response to General Comment No. 2.