HomeMy WebLinkAbout23061_Caraustar Mills Decision Memo_20231101DECISION MEMORANDUM
DATE: November 1, 2023
FROM: Bill Schmithorst
TO: BF Assessment File
RE: Caraustar Mills
326, 401, 410, 411, 418, and 440 S. Gardner Ave.; 400, 404, 408, 412,
420, 428, 432, 500, and 528 S. Turner Ave.; 2425, 2426, 2429, and 2636
Chamberlain Ave.; 330 and 340 Savona Creek Drive; and 710, 720, 725,
809, and 815 Savona Mill Lane
Charlotte, Mecklenburg County
BF # 23061-19-060
Based on the following information, it has been determined that the above referenced
site, whose intended use is for no uses other than high density residential, industrial,
office, retail, restaurant, distillery, brewery or food production facility, recreation,
institutional, entertainment, hotel, open space, parking, and with DEQ’s prior written
approval, other commercial uses, can be made suitable for such uses.
Introduction:
The Brownfields Property consists of 9 contiguous tax parcels (Parcel ID Nos. 07111209,
07111412, 07111410, 07111418, 07111419, 07111417) totaling approximately 30 acres
located on both sides of South Turner Avenue and Chamberlain Avenue. Northern
portions of the property along Chamberlain Avenue are developed with an approximately
14,500 square foot (sq ft) industrial warehouse building (2426 Chamberlain Avenue), an
approximately 22,500 sq ft industrial warehouse building (2425 Chamberlain Avenue),
an approximately 9,500 sq ft light manufacturing building (410 S. Gardner Avenue), and
an approximately 31,000 sq ft industrial warehouse building and an approximately 4,500
sq ft office building (401 S. Gardner Avenue). The eastern portion of the property along
S. Turner Avenue is developed with an approximately 186,000 sq ft former mill building.
Remaining portions of the Brownfields Property consist of undeveloped vacant land
except for foundations of former mill buildings, paved access roads, and paved parking
areas.
The southwestern portion of the Brownfields Property (Tax Parcel 071-114-12), located
west of South Turner Avenue and south of Chamberlain Avenue, is developed with two
warehouses and an office building associated with the former Savona Mill, Caraustar
Industries and Old Dominion Box Company operations. The southeastern portion of the
Brownfields Property located along both sides of South Turner Avenue, consists of the
former Savona Mill facility and Blue Blaze Brewery located within a metal auxiliary
building, south of the main mill building.
An amendment to the Brownfields Property Application was submitted on September 1,
2021. The amendment included adding tax parcel 07111410 (former Wickoff Color
Corporation, 410 South Gardner) to the Brownfields Property and removing tax parcel
07110502 (532 State Street).
The Brownfields Property is bound to the south and southwest by Stewart Creek and
wooded land and to the south by State Street, residences and an automotive mechanics
shop. The adjoining properties to the north and east consist predominantly of residences
and a day care facility. The Sinclair and Valentine Co. DEQ Inactive Hazardous Sites
Branch site (NCD083678631) is located east of the Brownfields Property across South
Turner Avenue.
Redevelopment Plans:
The Prospective Developer is currently developing high density residential apartment
buildings on the Brownfields Property. The former Wickoff Color building and buildings
located on S. Gardner Ave. are proposed for commercial/industrial uses. The Prospective
Developer intends to restore the historic mill building for commercial uses.
Site History:
A property use summary by address and tax parcel number is provided in the Table 1.
Former Savona Textile Mill was located at the southern and south-central portions of the
Brownfields Property and operations included spinning, weaving, and dyeing from
approximately late 1910s to 1934, and was then used as a box manufacturing facility. The
existing mill building on parcel 07111417 is a historic structure and is currently vacant. A
brewery operates out of a metal building located south of the mill building. Parking for
the former mill building was located on parcels 071110501, 071110551, and 071110552.
In 1935, Old Dominion Box Company (ODBC) began manufacturing boxes and
paperboard products on the site. Operations were expanded in the mid-1950s, with
ODBC constructing a three-story paper warehouse at the northern end of the Savona Mill
building and adding several buildings to the north near the intersection of Chamberlain
Avenue and Gardner Avenue (Parcels 07111412, 07111209, and 07111403). According
to historical information, ODBC continued operations until the late-1980s or mid-1990s.
In the 1940s, Carolina Paperboard Corporation (CPC) constructed a paperboard
manufacturing facility to the northwest of the ODBC operation. The CPC facility
included a pulp mill, offices, finishing room, machine shop, settling basin, and other
ancillary structures. Operations included bleaching, finishing, pulp mill, petroleum
storage, wastewater treatment and clarifier/aeration ponds, boiler room, maintenance
shop, and warehouses.
The former Weyerhaeuser Company/Old Dominion Box Company/Carolina Paperboard
paper board manufacturing facility was located at the eastern portion of the Brownfields
Property from approximately the 1950s until 1988 (Parcels 07111412, 07111209, and
07111403). Operations included bleaching, finishing, pulp mill, petroleum storage,
wastewater treatment and clarifier/aeration ponds, boiler room, maintenance shop, and
warehouses. The property was developed as early as 1929 as a manufacturer of cotton
fabrics, and the majority of the property was developed with paperboard manufacturing
buildings by 1950 and later used as a recycled paperboard manufacturing facility. The
manufacturing buildings were removed by the prior owner, and the remaining buildings
were used for storage of finished paperboard products. The former on-site CPC
reportedly operated one 3,000-gallon underground gasoline storage tank (UST), one
2,000-gallon diesel UST, one 4,000-gallon diesel UST, one 10,000-gallon diesel UST,
and six 30,000-gallon fuel oil USTs which were installed between 1968 and 1982. The
tanks were reportedly removed from the ground in 1993. A UST closure report available
from the NCDEQ documented the removal of the six 30,000-gallon USTs and two
associated fuel oil ASTs in February 1993. The February 1993 closure report indicates
minor petroleum contamination was identified in soils during removal activities (UST
Incident #13895). A subsequent initial abatement report including delineation of soil
impacts using soil borings identified residual soil impacts limited to the area of the USTs.
A groundwater monitoring well installed at that time was not impacted by petroleum
constituents above laboratory detection limits. Regulatory files indicate the incident was
not closed by NCDEQ.
In 1980, CPC merged into Caraustar Industries, Inc. (Caraustar) and Atlantic Coast
Carton Company. The new entity continued paper manufacturing operations on the
property until approximately 2010. Limited recycling and storage operations continued
until 2016. Caraustar demolished most of the structures on the Brownfields Property to
the west of the Savona Mill building between 2000 and 2010. An auxiliary metal building
was constructed on the south side of the Savona mill building in 1996. The building has
been occupied by Blue Blaze Brewing since 2016.
The Brownfields Property was acquired by Caraustar Mill Group, Inc. (Caraustar
Industries, Inc.) in 1988, and most of the buildings in the central portion of the
Brownfields Property were razed while buildings in the northern portion of the property
are mostly vacant. One building in northern portion of the Brownfields Property operated
as a paper recycling facility until 2016.
The former Wikoff Color Corporation property is located at 410 South Gardner Ave.
The facility historically manufactured inks used for food packaging products from 1965
until 2015. Three underground storage tanks (USTs; Facility ID: 00-0-0000014618) were
reportedly operated at the property from 1966 to 1989 when they were removed from the
ground. The contents of the USTs reportedly were described as “other, hazardous.” In
addition, the former Wikoff facility was regulated as a former Resource Conservation and
Recovery Act (RCRA) small quantity generator of ignitable waste by the EPA (Facility
ID: NCD093339265).
Based upon review of available historical aerial photographs, the parcels located east of
South Turner Avenue were developed with ancillary structures and single-family
residences as early as the late 1930s. By the late 1940s, parking areas associated with
Savona Mill were developed on the property east of S. Turner Avenue. The eastern
parcels have primarily been utilized for trailer storage and parking areas since the 1980s.
One single family residence remains at 524 State Street.
Currently, the majority of the site is vacant, but tenants occupy buildings in the northern
(small woodworking and furniture shop) portion of the Brownfields Proeprty, and a small
brewery located at the southern end of the property.
Table 1. Brownfields Property Use Summary
Tax Parcel Associated Address(es) Former and Current Use
07111412 411 South Gardner Avenue,
443 South Gardner Avenue,
2425 Chamberlain Avenue
A warehouse, remnant
building slabs of the former
Savona Mill, Caraustar
Industries, and/or Old
Dominion Box Company, and
undeveloped wooded land
07111418 401 South Gardner Avenue Vacant warehouse and office
building associated with
former Caraustar Industries
07111410 410 South Gardner Avenue Leased building formerly
operated by Wikoff Color
07111209 326 South Gardner Avenue,
2426 Chamberlain Avenue
Warehouse containing trolley
storage and a small
woodworking shop
07111417 500 South Turner Avenue, 528
South Turner Avenue
Former Savona Mill building
(vacant),
Blue Blaze Brewing
07110551 525 Coxe Avenue Parking lot
07110552 N/A Vacant/undeveloped
07110501 536 State Street Parking lot
07110503 524 State Street Single-family residence
(vacant)
Environmental Assessments
Pre-Brownfields Site Assessment Activities
Six USTs were removed from the area formerly occupied by the paperboard
manufacturing facility in 1993. A limited site assessment was conducted at the
Brownfields Property in September 2005 for property due diligence purposes.
Assessment activities included collecting six soil samples and three groundwater
samples. Soil and groundwater samples were submitted to a laboratory for the analysis of
volatile organic compounds (VOCs) and volatile petroleum hydrocarbons (MADEP VPH
Method). No constituents were detected in soil, and chloroform was the only constituent
detected in groundwater at a concentration below NC 2L Groundwater Quality Standards.
An additional limited site investigation was conducted in February 2016 for property due
diligence purposes. Soil assessment activities included collecting 27 soil samples across
the property in areas where impacted soils were most likely to occur based on historical
use. Soil sample locations were selected to evaluate the following potential
environmental issues; the adjacent former Wikoff Color facility (Wikoff Color was not
proposed to be part of the Brownfields Property when the 2016 assessment was
conducted), former pulp mill clarifier, former pulp mill AST, former leaking underground
storage tanks (LUST), former boiler room, former aeration pond, former textile mill area
and suspected dyeing operation, former bleaching and finishing room, former machine
shop, former pulp manufacturing area, an on-site diesel AST, an old railroad spur, a
bleaching/dyeing room, and the areas surround the buildings located at 401 S. Gardner
Ave. Some borings were also intended to generally characterize other areas of the site for
future soil management purposes. Samples were analyzed for volatile organic compounds
(VOCs), semi-volatile organic compounds (SVOCs) and Resource Conservation and
Recovery Act (RCRA) metals. In addition, five shallow groundwater monitoring wells
were installed to evaluate potential impacts to groundwater from on-site and off-site
sources. The groundwater samples were submitted for laboratory analysis of VOCs and
SVOCs.
Laboratory results from February 2016 site investigation indicated that SVOCs were
detected above NC Residential Preliminary Soil Remediation Goals (PSRGs) screening
levels in two of the 27 soil samples collected. In addition, arsenic was detected in seven
soil samples above Residential PSRGs. Groundwater laboratory results indicated that
naphthalene was detected in one groundwater monitoring well located downgradient of
the former above ground storage tank area at a concentration above NC 2L Groundwater
Standards.
In March 2018, five sub-surface soil samples were collected, for property due diligence
purposes, from areas near the southwestern corner of the former paper storage building
(2425 Chamberlain Ave.) within the proposed route of a new storm water drainage pipe.
The soil samples were submitted to a laboratory for the analysis of VOCs, SVOCs and
RCRA metals. No VOCs were detected above Residential PSRGs; however, SVOCs
were detected in soil samples SB-3, SB-4, and SB-5 above Residential PSRGs. In
addition, arsenic was detected in each soil sample at concentrations above Residential
PSRGs.
Brownfields Site Assessment Activities
An environmental assessment was conducted in 2020 in accordance with a DEQ-
approved Brownfields work plan to fill in data gaps at the following site locations: the
existing Savona Mill building; the former Caraustar Warehouse building; the tax parcels
located east of South Turner Avenue; the wooded area located southwest of the
intersection of South Turner Avenue and Chamberlain Avenue; and within or near the
footprints of proposed residential development. Nine soil samples were collected for the
analysis of VOCs, SVOCs, and RCRA metals. Five groundwater samples were collected
from temporary groundwater monitoring wells and analyzed by a laboratory for VOCs,
SVOCs and RCRA metals. Monitoring well 2021-GW-01 was collected from the recently
added Wikoff parcel.
As part of assessment activities at the Wikoff parcel and in accordance with NCDEQ’s
email approval dated January 4, 2021, two additional shallow soil samples were also
collected in the loading dock areas of the property for the analysis of VOCs, SVOCs, and
RCRA metals. In addition, a ground penetrating radar (GPR) survey was conducted on
the Wikoff parcel on January 6, 2021, to investigate for evidence of former UST use.
Results of the GPR survey did not identify evidence of a UST or former UST basin.
Assessment activities conducted in 2020 also included sub-slab soil vapor sampling. Six
sub-slab soil vapor samples and four shallow exterior soil vapor samples were collected
for the analysis of VOCs. Laboratory results from two of the sub-slab samples (2020-SV-
03 and 2020-SV-12) were not used for risk evaluation purposes because the samples were
collected within an area of the building with an existing crawl space. In addition,
laboratory results from sample 2020-SV-04 were not used for risk evaluation purposes
due to quality control issues.
In 2021, based on changes to the locations of proposed multi-family structures at the
Brownfields Property, the results of the initial soil vapor testing within the Savona Mill
building, and the PD’s pending acquisition of the Wikoff parcel, four additional sub-slab
soil vapor samples (two within the Savona Mill building and two within the Wikoff Color
building) and seven shallow exterior soil vapor samples were collected at the Brownfields
Property.
The environmental consultant reported that methane was detected in the exterior soil
vapor samples during the 2020 sampling event. The PD contracted SCS Engineers to
conduct a subsurface methane assessment. Nine exterior soil gas probes were collected at
the Brownfields Property in July 2021 in areas where the environmental consultant had
reported methane. Results from the methane assessment indicated that methane was not
detected above DEQ Brownfields screening levels.
Additional brownfields assessment activities completed in April 2022, in accordance with
a DEQ-approved work plan, included collection of soil, sub-slab soil gas, and exterior
soil gas samples to further evaluate the potential for impacts associated with historical
site operations. As part of the additional assessment activities, soil borings were advanced
in the area northwest of the former Wikoff Color buildings to further delineate metals
impacts in shallow soil. In addition, soil and exterior soil gas samples were collected
adjacent to an offsite daycare facility located adjacent to the northern property boundary,
along Chamberlain Ave., to evaluate the potential for offsite impacts. To evaluate the
potential for structural vapor intrusion into previously unassessed buildings, sub-slab soil
gas samples were collected from within the 401 and 411 South Gardner Avenue
buildings.
Soil delineation samples collected from the Wikoff Color parcel indicated exceedances
for hexavalent chromium near the loading dock. The soil samples were also analyzed for
TCLP metals, and no exceedances were detected.
Exterior and Sub-Slab Soil Gas Sampling Results
Proposed Residential Buildings No. 1 through No. 7 and Proposed Parking Deck
The compounds benzene, 1,3-butadiene, carbon tetrachloride, chloroform, ethylbenzene,
naphthalene, and vinyl chloride were detected at concentrations above the DEQ DWM
Vapor Intrusion Residential SGSLs in soil gas samples collected within the footprint of
proposed residential Building No. 1 through No. 7 and within the footprint of the
proposed parking deck.
Proposed Residential Buildings No. 8 and No. 9
The compounds chloroform, 1,2-dichloroethane, ethylbenzene, and naphthalene were
detected at concentrations above the DEQ DWM Vapor Intrusion Residential SGSLs
collected within the footprint of proposed residential Building No. 8 and No. 9.
Savona Mill Building – Proposed Commercial Use
Low levels of several compounds were detected in sub-slab soil gas samples collected
within the Savona Mill building. No compounds were detected at concentrations above
the DEQ DMW Vapor Intrusion Non-Residential Vapor Intrusion Screening Levels
(VISLs).
Two indoor air samples were collected from within the northern portion of the mill
building. Results of indoor air sampling identified benzene and naphthalene at
concentrations above the DEQ DWM Indoor Air Screening Levels (IASLs) and slightly
above the Non-Residential VISLs. Low levels of chloroform, 1,4-dichlorobenzene, and
ethylbenzene were also detected at concentrations above the Residential IASLs but below
Non-Residential IASLs in the indoor air samples collected in the mill building.
An additional sub-slab sample was collected from the adjacent Blue Blaze Brewery
warehouse. No VOCs were detected above Non-Residential VISLs.
Former Wikoff Color Site Building – Proposed Commercial/Industrial Use
Sub-slab soil vapor laboratory results indicated that VOC concentrations did not exceed
non-residential VISLs.
401 and 411 South Gardner Avenue – Proposed Commercial/Industrial Use
Sub-slab soil vapor laboratory results indicated that VOC concentrations did not exceed
non-residential VISLs.
Chamberlain Avenue Northern Property Boundary
No VOCs were detected above Residential VISLs in exterior soil gas samples.
Potential Receptors:
A Brownfields Receptor Survey was completed in August 2020. Potential receptors are:
construction workers, on-site workers, and future residents. Stewart Creek is located
along the western boundary of the Brownfields Property.
Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property: soil,
groundwater, exterior soil gas, sub-slab soil gas, and indoor air. DEQ relies on the
following data to base its conclusions regarding the subject property and its suitability for
its intended reuse. Please see the Brownfield Agreement’s Exhibit 2 for specific sample
locations, dates, and contaminants of concern (COCs).
Soil
SVOCs: Several SVOCs including including benzo(a)pyrene, benzo(a)anthracene,
benzo(b)fluoranthene and benzo(g,h,i)perylene exceeded Residential PSRGs.
Metals: Arsenic, lead and hexavalent chromium exceeded Residential PSRGs.
Groundwater
Laboratory results indicated that naphthalene was detected above NC 2L Groundwater
Standards.
Surface Water
No surface water is located within the Brownfields property boundary.
Exterior Soil Gas
Several VOC compounds were detected above Residential VISLs, including, but not
limited to, benzene, 1,3-dichlorobenzene, and ethylbenzene. Trichlorethylene was also
detected below Residential VISLs in one exterior soil gas sample.
Sub-Slab Vapor
No compounds were detected above Non-Residential VISLs. TCE was detected in one
exterior soil gas sample below Residential VISLs.
Indoor Air
Benzene and naphthalene were detected in the mill building above Non-Residential
Indoor Air Screening Levels.
Risk Calculations
Risk calculations were performed using the January 2022 DEQ Risk Calculator
https://deq.nc.gov/permits-rules/risk-based-remediation/risk-evaluation-resources. For the
purposes of looking at the site spatially, the site was divided by proposed use: Residential
Buildings 1-9, the former mill building (commercial), Gardner Ave.
commercial/industrial buildings 401 and 410 S. Gardner Ave. commercial/industrial
parcels, former Wikoff Color property, and the Chamberlain Ave. northern property
boundary. Groundwater exposure risk was evaluated site-wide.
The risk calculations indicated the following based on available data, including the
following media: groundwater, soil, exterior soil gas, sub-slab soil gas, and indoor air.
Risk for Individual Pathways Output Form 1A
Version Date: July 2022
Basis: May 2022 EPA RSL Table
Site ID: 23061-19-060
Exposure Unit ID: New Buildings 1-9 Soil, SG, GW
Receptor Pathway
Carcinogenic
Risk Hazard Index Risk exceeded?
Soil 1.0E-04 1.2E+00 YES
Groundwater Use* 1.4E-04 2.8E+00 YES
Soil 1.1E-05 9.6E-02 NO
Groundwater Use* 3.8E-05 6.6E-01 NO
Construction Worker Soil 2.2E-06 1.0E+00 YES
Soil 5.7E-05 6.3E-01 NO
Surface Water* NC NC NC
Receptor Pathway
Carcinogenic
Risk Hazard Index Risk exceeded?
Groundwater to Indoor Air 3.7E-06 9.7E-02 NO
Soil Gas to Indoor Air 2.1E-05 7.2E-01 NO
Indoor Air NC NC NC
Groundwater to Indoor Air 8.4E-07 2.3E-02 NO
Soil Gas to Indoor Air 1.5E-06 5.7E-02 NO
Indoor Air NC NC NC
DIRECT CONTACT SOIL AND WATER CALCULATORS
Resident
Non-Residential Worker
Recreator/Trespasser
VAPOR INTRUSION CALCULATORS
Resident
Non-Residential Worker
Version Date: July 2022
Basis: May 2022 EPA RSL Table
Site ID: Wikoff Color
Exposure Unit ID:
Receptor Pathway
Carcinogenic
Risk Hazard Index Risk exceeded?
Soil 1.1E-04 5.2E-01 YES
Groundwater Use* 1.2E-02 9.7E+00 YES
Soil 6.0E-06 3.7E-02 NO
Groundwater Use* 1.2E-03 2.3E+00 YES
Construction Worker Soil 9.6E-06 4.0E-01 NO
Soil 6.4E-05 2.9E-01 NO
Surface Water* NC NC NC
Receptor Pathway
Carcinogenic
Risk Hazard Index Risk exceeded?
Groundwater to Indoor Air 0.0E+00 0.0E+00 NO
Soil Gas to Indoor Air 2.7E-07 1.9E-02 NO
Indoor Air NC NC NC
Groundwater to Indoor Air 0.0E+00 0.0E+00 NO
Soil Gas to Indoor Air 2.1E-08 1.5E-03 NO
Indoor Air NC NC NC
DIRECT CONTACT SOIL AND WATER CALCULATORS
Resident
Non-Residential Worker
Recreator/Trespasser
VAPOR INTRUSION CALCULATORS
Resident
Non-Residential Worker
Risk for Individual Pathways Output Form 1A
Version Date: July 2022
Basis: May 2022 EPA RSL Table
Site ID: 23061-19-060
Exposure Unit ID: Former Mill Bldg. Soil Gas and Indoor Air Worst Case
Receptor Pathway
Carcinogenic
Risk Hazard Index Risk exceeded?
Soil NC NC NC
Groundwater Use* NC NC NC
Soil NC NC NC
Groundwater Use* NC NC NC
Construction Worker Soil NC NC NC
Soil NC NC NC
Surface Water* NC NC NC
Receptor Pathway
Carcinogenic
Risk Hazard Index Risk exceeded?
Groundwater to Indoor Air NC NC NC
Soil Gas to Indoor Air 1.8E-05 2.8E+00 YES
Indoor Air 1.7E-05 6.5E-01 NO
Groundwater to Indoor Air NC NC NC
Soil Gas to Indoor Air 1.4E-06 2.2E-01 NO
Indoor Air 3.8E-06 1.5E-01 NO
DIRECT CONTACT SOIL AND WATER CALCULATORS
Resident
Non-Residential Worker
Recreator/Trespasser
VAPOR INTRUSION CALCULATORS
Resident
Non-Residential Worker
Risk for Individual Pathways Output Form 1A
Version Date: July 2022
Basis: May 2022 EPA RSL Table
Site ID:
Exposure Unit ID: S. Gardner Street Bldgs.
Receptor Pathway
Carcinogenic
Risk Hazard Index Risk exceeded?
Soil 0.0E+00 1.6E-02 NO
Groundwater Use* NC NC NC
Soil 0.0E+00 1.3E-03 NO
Groundwater Use* NC NC NC
Construction Worker Soil 0.0E+00 1.4E-02 NO
Soil 0.0E+00 8.4E-03 NO
Surface Water* NC NC NC
Receptor Pathway
Carcinogenic
Risk Hazard Index Risk exceeded?
Groundwater to Indoor Air NC NC NC
Soil Gas to Indoor Air 7.2E-06 3.9E-01 NO
Indoor Air NC NC NC
Groundwater to Indoor Air NC NC NC
Soil Gas to Indoor Air 5.4E-07 3.1E-02 NO
Indoor Air NC NC NC
VAPOR INTRUSION CALCULATORS
Resident
Non-Residential Worker
DIRECT CONTACT SOIL AND WATER CALCULATORS
Resident
Non-Residential Worker
Recreator/Trespasser
Risk for Individual Pathways Output Form 1A
Version Date: July 2022
Basis: May 2022 EPA RSL Table
Site ID: 23061-19-060
Exposure Unit ID: Chamberlain Ave. Property Boundary
Receptor Pathway
Carcinogenic
Risk Hazard Index Risk exceeded?
Soil 1.2E-05 2.3E-01 NO
Groundwater Use* NC NC NC
Soil 2.2E-06 1.7E-02 NO
Groundwater Use* NC NC NC
Construction Worker Soil 3.7E-07 1.8E-01 NO
Soil 6.4E-06 1.3E-01 NO
Surface Water* NC NC NC
Receptor Pathway Carcinogenic
Risk Hazard Index Risk exceeded?
Groundwater to Indoor Air NC NC NC
Soil Gas to Indoor Air 2.0E-06 1.8E-01 NO
Indoor Air NC NC NC
Groundwater to Indoor Air NC NC NC
Soil Gas to Indoor Air 1.4E-07 1.4E-02 NO
Indoor Air NC NC NC
VAPOR INTRUSION CALCULATORS
Resident
Non-Residential Worker
DIRECT CONTACT SOIL AND WATER CALCULATORS
Resident
Non-Residential Worker
Recreator/Trespasser
Red shading LICR> 1E-04 or HI> 1.
LICR = Lifetime Incremental Cancer Risk
HI = Hazard Index
A summary of Hazard Index (HI) risk threshold exceedances are provided by property
use area below:
Site-Wide Groundwater
Groundwater exceeded an HI of 1.0 for Residential Use but did not exceed Non-
Residential Use. In addition, groundwater to indoor air did not exceed an HI of 1.0.
Site-Wide Soil
Soil exceeded an HI of 1.0 for Residential and Construction receptors at multiple
locations across the Brownfields Property.
Proposed Residential Buildings 1-9
Soil exceeded an HI of 1.0 for Residential and Construction Worker receptors due to
elevated concentrations of petroleum compounds and metals. Exterior soil gas did not
exceed an HI of 1.0 for Residential receptors.
Wikoff Color
Soil exceeded an HI of 1.0 for Non-Residential and Construction Worker receptors due to
elevated concentrations of metals. Groundwater also exceeded an HI of 1.0 due to metals
concentrations. Sub-slab soil gas did not exceed an HI of 1.0 for Non-Residential
Workers.
401 and 411 S. Gardner Street Buildings
Sub-slab soil gas and soil sample data did not exceed an HI of 1.0.
Former Mill Building
Sub-slab soil gas and indoor air sample data did not exceed an HI of 1.0 for Non-
Residential receptors.
Chamberlain Ave. Property Boundary
Exterior soil gas and soil sample data did not exceed an HI of 1.0 for Residential
receptors. Soil did not exceed an HI of 1.0 for Residential receptors.
Residential and commercial development is planned for the Brownfields Property.
Residential use will be limited to new construction which will include passive vapor
mitigation. Sub-slab data indicate that vapor mitigation is not necessary at existing
buildings 401 and 410 S. Gardner Ave. buildings and the former Wickoff Color building.
The former mill building is being remodeled and pre-occupancy sub-slab and indoor air
sampling will be required to confirm that there are no vapor intrusion issues. Elevated
concentrations of petroleum-related compounds and metals detected in groundwater will
require a land use restriction prohibiting groundwater use. Municipal water is available at
the Brownfields Property and surrounding properties, further minimizing the potential
exposure risks.
A DEQ-approved Environmental Management Plan (EMP), approved by DEQ, was
prepared before the start of soil grading to prevent exposure to site workers and future
residents from unacceptable levels of contaminants, and to manage the safe handling and
disposal of potentially contaminated materials during construction. In addition, final
grade soil sampling of exposed areas, as approved by DEQ, will be required prior to
occupying the Brownfields Property to demonstrate that the property is safe for the
intended use.
Pre- and post-occupancy sub-slab vapor sampling will be required at the new residential
buildings.
Required Land Use Restrictions:
The standard land use restrictions including land use, Environmental Management Plan
and reporting requirements, prohibition on groundwater use, soil restrictions, final grade
sampling, vapor intrusion mitigation, access, notification, and prohibition on the use of
known contaminants, and the annual land use update obligation are required for this
Brownfields Agreement.
Project Management Unit
Environmental Management Plan required.
Final grade sampling of exposed areas required.
Pre-occupancy sub-slab vapor and indoor air sampling required at the former mill
building. Due to ongoing interior demolition activities in the mill building,
additional sub-slab soil vapor or indoor air samples could not be collected prior to
completion of the Brownfields Agreement.
Passive vapor mitigation systems are being installed in the new residential
buildings.
Residential buildings will require pre- and post-occupancy sub-slab sampling.
TCE was detected in one exterior soil gas sample near the proposed parking
structure at a concentration below DEQ Residential VISLs.
Additional vapor sampling requirements for the mill building will be evaluated
upon completion of pre-occupancy vapor sampling.