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HomeMy WebLinkAbout24046_MIllerCoors Brewery Decision Memorandum_202112081 MillerCoors Brewery/24046-20-079/20230723 DECISION MEMORANDUM DATE: July 23, 2023 FROM: Bill Schmithorst TO: BF Assessment File RE: MillerCoors 853 Meadow Road Eden, Rockingham County BF # 24046-20-079 Based on the following information, it has been determined that the above referenced Brownfields Property, whose intended use is for no uses other than industrial, office, parking, and warehousing, and with prior written DEQ approval, other commercial uses, can be made suitable for such uses. Introduction: The Brownfields Property is an industrial facility totaling approximately 1358.979 acres, most recently occupied by MillerCoors for brewery operations. However, the Brownfields Property has been vacant since March 2017. The Brownfields Property is composed of three parcels Parcel ID Numbers: 7091-00-11-0943-00 [approximately 1,300-acres], 7091-00-41-9281-00, and 7080-07-69-9891-00) bounded by East Meadow Road, residential and light industrial use to the south, residential and undeveloped land to the east and north, and a mix of commercial and light industrial facilities to the west. The Prospective Developer is Nestle Purina Petcare Company. The Brownfields Property is developed with an approximate 1,151,440 square foot manufacturing building and 12 surrounding buildings that supported former brewing facility operations. Areas of the Brownfields Property that are not developed with buildings or infrastructure, including the majority of the northern half of the property, are either grass covered fields or are wooded and undeveloped. There are seven surface water bodies on the Brownfields Property, including four unnamed intermittent tributary creeks which drain into Lake Miller, an additional unnamed intermittent tributary east of the main building, and Dry Creek, which runs along the southern perimeter of the Brownfields Property. Lake Miller was a manmade lake contained by an earthen dam, which was breached under a North Carolina-issued dam removal permit in 2017, reducing its typical wet surface area from 16 acres to approximately 1 acre. Lake Miller and the remaining tributary creeks drain into Dry Creek at a point approximately 6,300 feet north-northeast of the Brownfields Property. Based on topography, it appears that overland run-off from the Brownfields Property would ultimately drain to the east-northeast toward the intermittent tributary stream. 2 MillerCoors Brewery/24046-20-079/20230723 The manufacturing building is located in the southwest portion of the property. An employee parking lot is located on the southeast side the plant. Several railroad spurs enter the Brownfields Property from the southwest corner, which supplied raw materials to the south side of the plant and formerly provided coal to a staging yard on the southwest side of the plant. The area used for coal storage is asphalt paved. Two 1,000,000-gallon water ASTs and one 1,000,000-gallon fuel oil AST are located near the southwest corner of the plant building. An approximate 105,217-square foot warehouse building is located west of the plant and an approximate 50,000 square foot warehouse building is located northwest of the plant. An asphalt parking lot for tractor trailers is located at the western property boundary. The wastewater treatment plant is located north of the plant building. It includes a 28,951 square-foot process building and two smaller supporting buildings. There are eight aeration basins located on the north side of the main treatment building and four secondary clarifiers located east of the treatment building. Two 5-acre polishing lagoons are located farther east of the treatment plant. In total the wastewater treatment infrastructure encompasses approximately 20 acres. Redevelopment Plans: The PD is modifying the existing facility for the production of animal feeds. Redevelopment plans conform with the proposed uses. Site History: Prior to 1978, the property was undeveloped with the exception of use for agricultural purposes. MillerCoors (and its’ corporate predecessors) occupied the Brownfields Property for the production of multiple varieties of beer between 1978 until manufacturing and packaging operations were discontinued on September 1, 2016 and the plant was fully closed in March 2017. Primary chemicals used on-Site included caustics (vessel cleaning), acids, water treatment chemicals (sodium hydroxide, and anti-microbial and corrosion/scale inhibitors), anhydrous ammonia (for vessel cooling) and compressed gases (equipment maintenance/beer tap operation). Primary raw materials used on-Site included malts (raw grains), hops, yeast, silica powder (beer stabilizer), minor amounts of brew salts, and carbon dioxide gas. Yeast was grown at the facility within several automated yeast propagation vessels located in the yeast propagation room. The remaining raw materials were received at the facility via truck and rail car. Final products were shipped offsite via truck. Spent grain and yeast were sold for off-Site recycling (i.e. re-sale). Ancillary operations performed at the former brewery included high-purity water treatment of influent process water (via a carbon filtration system), treatment of brewery wastewater at the wastewater treatment building, shipping and receiving, sales, administrative activities, and facility maintenance. Operations at the facility were reportedly generally consistent throughout the operational period of the brewery, with the following notable exceptions: 3 MillerCoors Brewery/24046-20-079/20230723 • MillerCoors formerly operated two coal-fired boilers from 1978 until 2014. The coal was offloaded from railcars in the southwest portion of the Brownfields Property and conveyed via an overhead covered conveyor to the boilers located at the southwest corner of the manufacturing building. These coal-fired boilers were replaced with one biomass boiler and two natural gas fired boilers in a building located southwest of the manufacturing building. • Two aeration basins in the wastewater treatment system were taken out of service because of leaks, and one of the basins was used as a digester. • MillerCoors converted the facility's two wastewater treatment plant tertiary polishing lagoons into two non-wastewater ponds in 2016 and 2017. The method of closure was performed in conformance with an approved Lagoon Closure Plan submitted to the North Carolina Department of Environmental Quality (DEQ) - Division of Water Quality (DWQ) on July 1, 2016. Approximately 1,960,200 cubic feet of bottom-lining sludge material was disposed of as an agricultural soil amendment in accordance with the current active permit conditions set forth by DEQ - DWQ Permit No. WQ0001347. • Several processes were removed, including the use of ammonia, sulfuric acid, ceramic filters, and a keg polish filter. • A No. 2 fuel oil fired boiler was formerly used at the wastewater treatment system. The boiler was removed from service in July 2014 and the 10,000-gallon No. 2 fuel oil AST associated with it was subsequently emptied. There is no record of historical use of chlorinated solvents on-site. Environmental Assessments and Area of Concern (AOC) Descriptions Phase I environmental assessment activities conducted for property due diligence purposes identified nine areas of concern: Bulk Fuel Storage Area; Coal Staging Area; Palletizers; WWTP Aeration/Settling Basins; WWTP Lagoons; Utilities Area; Lake Miller; Site Drainage Areas; Historical Soil/Debris Piles. The areas of concern are discussed below. AOC-1 Bulk Fuel Storage Area (No. 6 Fuel Oil Tank) One No. 6 fuel oil tank was located to the west of the main facility brewhouse, situated within an earthen dike and clay cap. The tank was believed to have been intermittently used to store No. 6 fuel oil since the late 1970s. In July 2016, a passive soil gas survey was conducted using 26 passive soil gas samplers surrounding the unused tank. Soil gas survey results for the area surrounding the No. 6 Fuel Oil Tank indicated that benzene, toluene, ethylbenzene, and xylene compounds (BTEX) and/or petroleum hydrocarbon constituents were present in ten of the samples, with the highest concentrations found on the eastern side of the tank. In July 2020, 10 soil borings were advanced in this area. Twenty-two soil samples were submitted for diesel range organics/gasoline range organics (DRO/GRO) analysis, with 11 of these samples also analyzed for BTEX and polyaromatic hydrocarbons (PAHs). Of these samples, only low levels of GRO (up to 5.9 mg/kg) and DRO (up to 15 mg/kg), and toluene (0.0263 mg/kg) were detected. All of these were below screening criteria and applicable action levels. 4 MillerCoors Brewery/24046-20-079/20230723 Two shallow grab groundwater samples were also collected, and a bedrock well was installed to a depth of 41 feet and sampled. Groundwater samples were analyzed for volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs). Laboratory results indicated that no constituents were detected above DEQ Preliminary Soil Remediation Guidelines (PSRGs) or DEQ Underground Storage Tank Section total petroleum hydrocarbon (TPH) screening levels. The only compound detected in groundwater above the 15A NCAC 02L .0202 Groundwater Quality Standards (2L Standards) was pentachlorophenol. Pentachlorophenol was detected in one shallow groundwater sample, it was a widely used biocide and wood preservative, such as for utility poles and railroad ties. Its use has been restricted to certified applicators since 1984. The sample was collected near the railroad spur and multiple utility poles. AOC-2 - Coal Staging Area The Coal Staging Area was used to store raw coal and was loaded into the area from the railroad spur. The concrete paved staging area was sloped to the south. There was no overhead cover or side walls. Fines that washed from this area washed into a drainage swale, and later, a lagoon and a fines filtration basin was added. Three soil borings were advanced in this area. Eight soil samples were submitted for PAH and Priority Pollutant Metals analysis. Laboratory results indicated that the only constituents detected in soil above Industrial/Commercial PSRGs were arsenic as high as 81.5 mg/kg and thallium up to 5.0 mg/kgin shallow soil (SB-20) located in a grassy area south of the concrete paved coal storage area. Soil samples were collected at the following depths with associated arsenic & thallium concentrations: 0-2 ft. bgs (81.5; 5.0 mg/kg), 3-5 ft. (9.3; 1.3 mg/kg), and 6-7 ft. (<3.5; <23.5 mg/kg). Shallow soils with elevated arsenic and thallium concentrations were reportedly over-excavated in September 2020 and approximately 60 tons of soil was transported offsite for disposal at A-1 Rock C&D Landfill in Greensboro. However, no report or disposal documentation was provided to DEQ Brownfields. Therefore, the data has been evaluated as though it remains on-site. Arsenic was detected above the Industrial/Commercial PSRG at concentrations ranging from 3.5 mg/kg-11.0 mg/kg in other samples from AOC - 2. Thallium was also detected slightly above its Industrial/Commercial PSRG in two other samples (up to 2.6 mg/kg) within AOC-2. One shallow groundwater sample was collected, and a bedrock well was installed to a depth of 90 feet and sampled. Groundwater samples were analyzed for VOCs, SVOCs, and Priority Pollutant Metals. Arsenic, chromium, iron,lead, and manganese were detected above 2L Standards in the shallow groundwater sample (AOC-2-GWP-20). The environmental report indicated that the groundwater samples collected from the temporary direct-push locations were very turbid, which could cause artificially high metals concentrations. Iron, manganese, and selenium were detected above 2L Standards in BW-5 (AOC-2). 5 MillerCoors Brewery/24046-20-079/20230723 AOC 3 - Palletizer Investigation The MillerCoors facility historically contained 14 palletizers located inside and along a central wall of the main facility warehouse. The palletizers were used to operate beverage bottling and canning conveyers and were reportedly decommissioned and removed of all accompanying hydraulic oil in response to facility shut down. All palletizers were removed in 2016 and 2017. Historical regulatory and assessment reports indicated four prior incidents within the palletizer area (DEQ UST Incident Numbers 19469, 87676, 95029, 95089, and 95123). These incidents pertained to minor hydraulic oil soil contamination identified during palletizer replacement and remained limited to the area around the in-ground hydraulic shafts/lifts. DEQ issued a no further action decision in October 2016 (DEQ UST Incident No. 95123). Based on the history of reported releases in the palletizer area, a subsurface investigation was completed by MillerCoors as part of the facility closure in July 2020. Seven soil borings were advanced in this area, typically within one to two feet east of the 12- inch diameter sub-floor cavities which contained the hydraulic lift equipment. Seventeen soil samples were submitted for PAH and TPH oil range organics (ORO) analysis. Based on the sample results, one of the samples (SB-57) was also analyzed for extractable petroleum hydrocarbons (EPH), consistent with DEQ guidance for hydraulic oil releases and with previous palletizer area investigations. TPH ORO was detected in one soil sample (SB-57) at a concentration of 628 mg/kg (action level of 100 mg/kg), at a depth of 8 to 10 feet bgs. EPH concentrations ranged from not detected to 398 mg/kg and were below their respective DEQ residential MSCCs. Shallow groundwater was not encountered in this AOC. A bedrock well (BW-6) was installed to a depth of 35 feet and sampled for VOCs and SVOCs. Laboratory results indicated that no VOCs or SVOCs were detected. AOC-4 - WWTP Aeration and Settling Basins This area encompasses approximately 10 acres. Spills of hazardous materials within the manufacturing facility could have ultimately made their way through the manufacturing facility drains to the wastewater treatment plant. In addition, two of the aerators were reportedly taken out of service due to leaks. Twelve soil borings were advanced, adjacent to the acid/caustic tanks. Twenty-three soil samples were submitted for metals analysis, with 16 of these samples also analyzed for BTEX and PAHs. Four samples were submitted for GRO/DRO analysis, and four samples were submitted for pH analysis. A bedrock well was installed to a depth of 36 6 MillerCoors Brewery/24046-20-079/20230723 feet and sampled for VOCs, SVOCs, and priority pollutant metals. Four shallow grab groundwater samples were proposed for this area, but no shallow groundwater was present. No organic compounds, including DRO/GRO, were detected from any of the soil samples collected from this AOC. Arsenic was detected above the Industrial/Commercial PSRG concentration up to 17 .5 mg/kg and higher than background concentrations. Thallium was also detected at concentrations up to 3.0 mg/kg, slightly above its Industrial/Commercial PSRG. Shallow groundwater was not encountered in this AOC. A bedrock well (BW-3) sampled for VOCs and SVOCs. Laboratory results indicated that no VOCs or SVOCs were detected. Various metals were detected, but only arsenic, iron and manganese were detected above the applicable 2L Standards. AOC-5 - WWTP Lagoons This area encompasses approximately 10 acres and is comprised of two 5-acre clay lined lagoons. In July 2020, six soil borings were advanced around the perimeter of the lagoons. Eighteen soil samples were submitted for metals analysis, with nine of these samples also analyzed for BTEX and PAHs. Two shallow grab groundwater samples were also collected and analyzed for VOCs, SVOCs, and metals. No organic compounds were detected from any of the soil samples collected from this AOC. Arsenic was detected in soil above the Industrial/Commercial PSRG. Arsenic was detected above the Industrial/Commercial PSRG at concentrations of up to 13.3 mg/kg and higher than background arsenic concentrations. Thallium was also detected up to 3.0 mg/kg slightly above its Industrial/Commercial PSRG. No VOCs or SVOCs were detected in the two shallow groundwater samples collected from this AOC. Chromium, iron, lead, and manganese were detected above their respective 2L Standards in one of the two shallow groundwater samples. It was reported that the sample collected from the temporary well location GWP-39 was very turbid, which could be a contributing factor to the elevated metals concentrations in this sample. AOC-6 - Utilities Area The utilities area provided power to a large portion of the facility. Petroleum, used oil and other hazardous materials were stored here. Spent coal ash was loaded onto trucks for offsite disposal. There were also numerous pumps and engines within the building. Eight soil borings were advanced in this area in July 2020. Seventeen soil samples were submitted for GRO/DRO analysis, with eight of these samples also analyzed for VOCs, PAHs and Priority Pollutant Metals. A bedrock well was installed to a depth of 45 feet 7 MillerCoors Brewery/24046-20-079/20230723 and sampled for VOCs, SVOCs, and metals. Four shallow grab groundwater samples were proposed for this area, but no shallow groundwater was present. Laboratory results indicated that no VOCs or SVOCs were detected in soil above screening levels. Arsenic was detected above Commercial/Industrial PSRGs at concentrations of up to 8.2 mg/kg. These concentrations are generally consistent with background concentrations at the property. No VOCs or SVOCs were detected in the bedrock groundwater sample; however, iron and manganese were detected above 2L Standards. AOC-7 - Lake Miller This area received drainage from many areas of the property. Five soil samples were collected from the former lake bed and submitted for analysis of VOCs, SVOCs, metals, herbicides, and pesticides. One shallow grab groundwater sample was collected and analyzed for VOCs, SVOCs, and metals. No VOC, SVOC, pesticide or herbicide compounds were detected in any of the soil samples collected from Lake Miller above Industrial/Commercial PSRGs. Arsenic was detected above the Commercial/Industrial PSRG at concentrations up to 7.9 mg/kg. These concentrations are generally consistent with background concentrations at the property. No VOCS or SVOCs were detected in the shallow groundwater sample. Iron and manganese were detected above the respective 2L Standards in the shallow groundwater sample. No other metals were detected above the 2L Standards. AOC-8 - Site Drainage Areas There is a network of open channel drainage swales on the property. On the northern portion of the Brownfields Property, these channels fed the WWTP features and/or Lake Miller. On the southern portion of the Brownfields Property, they flow to an unnamed retention pond. This pond and associated swales also receive runoff from the adjacent road. The contractor laydown yard northwest of the main building and an area receiving runoff from an adjacent trucking depot west of the facility are also included in this AOC. Fifteen soil samples were collected in this area and submitted for analysis of VOCs, PAHs, and Priority Pollutant Metals, and six samples were submitted for herbicide analysis, and nine samples were submitted for pesticides. A bedrock well was installed near the southeastern drainage pond and sampled for VOCs, SVOCs, and priority pollutant metals. Two shallow grab groundwater samples were proposed for this area, but no shallow groundwater was present. No SVOCs were detected above Industrial/Commercial PSRGs. The VOC compound p- isopropyltoluene was detected for which there is no established standard. No other organic compounds, including herbicides and pesticides, were detected in the soil samples. 8 MillerCoors Brewery/24046-20-079/20230723 Arsenic was detected above the Commercial/Industrial PSRG at concentrations up to 22.2 mg/kg. Cobalt was detected above the Commercial/Industrial PSRG (70 mg/kg) in one soil sample (SB-52), at a low-lying area receiving runoff from an adjacent trucking terminal) at a concentration of 70.3 mg/kg. Thallium was also detected slightly above its Industrial/Commercial PSRG in three of the samples at concentrations up to 4.0 mg/kg. No VOCs or SVOCs were detected in the bedrock groundwater sample. Iron and manganese were detected above the respective 2L Standards in the bedrock groundwater sample. AOC-9- Historical Soil/Debris Piles Nine soil/debris piles were identified along the perimeter of the woods north of the developed portions of the Brownfields Property. These were reported to have been construction related piles, including excavated soils stockpiled for possible future use; however, miscellaneous debris, including plastic, concrete, and tires were observed in some of the piles. The soil/debris piles were reportedly removed and disposed of offsite; however, documentation of disposal was not reported or provided to DEQ Brownfields Four soil samples were obtained from these piles. All four soil samples were analyzed for VOCs, PAHs, and metals. Two of the samples were also analyzed for herbicides and pesticides. No organic compounds were detected above Commercial/Industrial PSRGs. Arsenic (in two of the four samples) and thallium in one of the four samples were detected above the Commercial/Industrial PSRG. A groundwater sample was not collected in association with the soil piles. Potential Receptors: Potential receptors considered include construction workers, site workers, and trespassers. A brownfields receptor survey was completed. Contaminated Media: DEQ has evaluated data collected from the following media at the subject property: soil, groundwater, and soil gas. DEQ relies on the following data to base its conclusions regarding the subject property and its suitability for its intended reuse. Those areas of concern with sample laboratory results exceeding screening levels are summarized below. Compounds detected above screening levels are listed in Exhibit 2 of the Brownfields Agreement. Soil Soil impacts are discussed by AOC in the above sections. 9 MillerCoors Brewery/24046-20-079/20230723 Background Soil Sampling On July 21, 2021, five background soil samples were collected from depths of 0-2 feet bgs in areas generally representative of locations that are undeveloped and submitted to a laboratory for the analysis of RCRA metals, hexavalent chromium, cobalt, and thallium. Laboratory results indicated that arsenic was the only metal detected above Industrial/Commercial PSRGs, ranging in concentration from 1.2 to 4.5 mg/kg. Groundwater Pentachlorophenol was detected in the shallow groundwater sample from temporary monitoring well SB-10 located in the Bulk Fuel Storage Area, exceeding 2L Standards at a concentration of 24.4 micrograms per liter (µg/L). This detection is the reason for the Inactive Hazardous Site listing NONCD0003123. Laboratory results indicated that chromium and lead were detected above 2L Standards in groundwater samples collected from temporary monitoring wells AOC-2-GWP-20 and AOC-5-GWP-39. In addition, iron and manganese were detected above 2L Standards in groundwater samples collected from several monitoring wells located around the Brownfields Property. The assessment report indicated that turbidity was elevated in the groundwater samples. Groundwater data evaluated through the DEQ Risk Calculator (excerpted below) indicates an exceedance of risk for both residential and non-residential use. Groundwater will be restricted. Surface Water Surface water was not sampled. Most of Lake Miller had been drained and soil samples were collected from the former lake bed. Soil Gas and Sub-Slab Vapor Passive soil gas samples were collected around the bulk fuel storage tank for screening purposes to identify soil sampling locations. Based on the lack of VOCs detected around the remainder of the areas of concern and the cumulative site-wide groundwater data evaluated using the risk calculator, no additional sub-slab samples for evaluation of vapor intrusion were warranted. Indoor Air No indoor air samples were collected. Risk Calculations Risk calculations were performed using the June 2021 DEQ Risk Calculator https://deq.nc.gov/permits-rules/risk-based-remediation/risk-evaluation-resources. The risks from soil were evaluated by using the data from soil and groundwater samples exhibiting the highest concentrations of constituents at specified areas of concern. 10 MillerCoors Brewery/24046-20-079/20230723 Risk for Individual Pathways Output Form 1A Version Date: June 2021 Basis: May 2021 EPA RSL Table Site ID: 24046-20-079 Exposure Unit ID: Site Wide Groundwater (Max) Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded? Soil NC NC NC Groundwater Use*8.9E-04 1.8E+01 YES Soil NC NC NC Groundwater Use*3.6E-04 2.9E+00 YES Construction Worker Soil NC NC NC Soil NC NC NC Surface Water*NC NC NC DIRECT CONTACT SOIL AND WATER CALCULATORS Resident Non-Residential Worker Recreator/Trespasser Risk for Individual Pathways Output Form 1A Version Date: June 2021 Basis: May 2021 EPA RSL Table Site ID: 24046-20-079 Exposure Unit ID: Bulk Fuel Oil Storage - AOC -1 Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded? Soil NC NC NC Groundwater Use*NC NC NC Soil 0.0E+00 5.4E-04 NO Groundwater Use*3.0E-04 4.2E-01 YES Construction Worker Soil 0.0E+00 1.4E-03 NO Soil 0.0E+00 2.4E-03 NO Surface Water*NC NC NC DIRECT CONTACT SOIL AND WATER CALCULATORS Resident Non-Residential Worker Recreator/Trespasser Risk for Individual Pathways Output Form 1A Version Date: June 2021 Basis: May 2021 EPA RSL Table Site ID: 24046-20-079 Exposure Unit ID: AOC 2 - Coal Storage Area Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded? Soil NC NC NC Groundwater Use*NC NC NC Soil 2.7E-05 9.2E-01 NO Groundwater Use*5.4E-05 5.5E+00 YES Construction Worker Soil 5.5E-06 9.2E+00 YES Soil 6.7E-05 7.4E+00 YES Surface Water*NC NC NC DIRECT CONTACT SOIL AND WATER CALCULATORS Resident Non-Residential Worker Recreator/Trespasser 11 MillerCoors Brewery/24046-20-079/20230723 Risk for Individual Pathways Output Form 1A Version Date: June 2021 Basis: May 2021 EPA RSL Table Site ID: MillerCoors Exposure Unit ID: AOC 3 Palletizers SB-57 Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded? Soil NC NC NC Groundwater Use*NC NC NC Soil 0.0E+00 1.0E-01 NO Groundwater Use*NC NC NC Construction Worker Soil 0.0E+00 0.0E+00 NO Soil 0.0E+00 1.1E-01 NO Surface Water*NC NC NC DIRECT CONTACT SOIL AND WATER CALCULATORS Resident Non-Residential Worker Recreator/Trespasser Risk for Individual Pathways Output Form 1A Version Date: June 2021 Basis: May 2021 EPA RSL Table Site ID: 24046-20-079 Exposure Unit ID: AOC-4 WWTP Area Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded? Soil NC NC NC Groundwater Use*NC NC NC Soil 5.8E-06 7.0E-01 NO Groundwater Use*5.1E-05 4.3E+00 YES Construction Worker Soil 2.5E-06 1.4E+01 YES Soil 1.4E-05 5.8E+00 YES Surface Water*NC NC NC DIRECT CONTACT SOIL AND WATER CALCULATORS Resident Non-Residential Worker Recreator/Trespasser Risk for Individual Pathways Output Form 1A Version Date: June 2021 Basis: May 2021 EPA RSL Table Site ID: 24046-20-079 Exposure Unit ID: WWTP Lagoons AOC 5 Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded? Soil NC NC NC Groundwater Use*NC NC NC Soil 4.4E-06 6.2E-01 NO Groundwater Use*NC NC NC Construction Worker Soil 1.8E-06 1.1E+01 YES Soil 1.1E-05 5.1E+00 YES Surface Water*NC NC NC DIRECT CONTACT SOIL AND WATER CALCULATORS Resident Non-Residential Worker Recreator/Trespasser 12 MillerCoors Brewery/24046-20-079/20230723 Risk for Individual Pathways Output Form 1A Version Date: June 2021 Basis: May 2021 EPA RSL Table Site ID: 24046-20-079 Exposure Unit ID: Utilities Area Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded? Soil NC NC NC Groundwater Use*NC NC NC Soil 2.7E-06 3.0E-01 NO Groundwater Use*NC NC NC Construction Worker Soil 1.5E-06 8.8E+00 YES Soil 6.7E-06 2.4E+00 YES Surface Water*NC NC NC DIRECT CONTACT SOIL AND WATER CALCULATORS Resident Non-Residential Worker Recreator/Trespasser Risk for Individual Pathways Output Form 1A Version Date: June 2021 Basis: May 2021 EPA RSL Table Site ID: 24046-20-079 Exposure Unit ID: AOC 7 Lake Miller Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded? Soil NC NC NC Groundwater Use*NC NC NC Soil 2.6E-06 4.0E-01 NO Groundwater Use*NC NC NC Construction Worker Soil 1.1E-06 1.1E+01 YES Soil 6.5E-06 3.2E+00 YES Surface Water*NC NC NC DIRECT CONTACT SOIL AND WATER CALCULATORS Resident Non-Residential Worker Recreator/Trespasser Risk for Individual Pathways Output Form 1A Version Date: June 2021 Basis: May 2021 EPA RSL Table Site ID: 24046-20-079 Exposure Unit ID: AOC 8 - Drainage Channels Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded? Soil NC NC NC Groundwater Use*NC NC NC Soil 7.5E-06 8.5E-01 NO Groundwater Use*NC NC NC Construction Worker Soil 3.3E-06 1.6E+01 YES Soil 1.9E-05 6.9E+00 YES Surface Water*NC NC NC DIRECT CONTACT SOIL AND WATER CALCULATORS Resident Non-Residential Worker Recreator/Trespasser 13 MillerCoors Brewery/24046-20-079/20230723 Risk for Individual Pathways Output Form 1A Version Date: June 2021 Basis: May 2021 EPA RSL Table Site ID: 24046-20-079 Exposure Unit ID: AOC-9 Soil & Debrie Piles Receptor Pathway Carcinogenic Risk Hazard Index Risk exceeded? Soil NC NC NC Groundwater Use*NC NC NC Soil 1.1E-05 1.0E+00 YES Groundwater Use*NC NC NC Construction Worker Soil 3.5E-06 2.7E+01 YES Soil 2.0E-05 7.6E+00 YES Surface Water*NC NC NC DIRECT CONTACT SOIL AND WATER CALCULATORS Resident Non-Residential Worker Recreator/Trespasser NC-Pathway not calculated The risk calculations indicate the following based on available data, including the following media: groundwater and soil. Risk calculator results indicate that a Hazard Index of 1.0 was exceeded for construction workers and trespassers over the developed areas of the Brownfields Property. The elevated risk calculator results were driven by metals concentrations in soil. In addition, risk calculator results indicate that groundwater exceeds a Hazard Index of 1.0 for groundwater use in areas where metals were analyzed, and at the Bulk Fuel Storage Area where pentachlorophenol was detected above 2L Standards. Groundwater to Indoor Air risk calculations did not exceed applicable screening levels. Due to the concentrations of metals in soil that exceed a hazard index of 1, development activities involving soil excavation and grading will be conducted under an Environmental Management Plan. In addition, the Prospective Developer should manage construction involving soil movement under a site specific health and safety plan for construction workers. A land use restriction will be placed on groundwater prohibiting use. Required Land Use Restrictions: The standard land use restrictions including land use, Environmental Management Plan and reporting requirements, prohibition on groundwater use, soil restrictions, access, notification, and prohibition on the use of known contaminants, and the annual land use update obligation are required for this Brownfields Agreement. Based on the site-specific data provided to the Brownfield program, the site reuse is suitable for the site as long as the agreed upon land use restrictions in the BFA are abided by. PROPERTY MANAGEMENT ISSUES -No soil vapor issues. -The Hazard Index for soil is elevated above 1.0 due to the presence of metals in soil. Although arsenic was the primary metal to be detected above Industrial/Commercial 14 MillerCoors Brewery/24046-20-079/20230723 PSRGs, the cumulative effects of other metals detected in soil, such as, aluminum, iron, manganese, and vanadium caused the HI to exceed 1.0. -The need for a groundwater land use restriction is primarily due to elevated concentrations of metals detected in groundwater, with the exception of the detection of pentachlorophenol at the Bulk Fuel Storage Area.