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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.