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Cameron Village Condominiums/24017-20-092/20231025
DECISION MEMORANDUM
DATE: 10/25/2023
FROM: Claire Sorrell
TO: BF Assessment File
RE: Cameron Village Condominiums
1801 Cameron Street
Raleigh, Wake County
Brownfields Project No. 24017-20-092
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 rental residential, retail,
recreation, restaurant, associated parking, and subject to prior DEQ written approval,
other commercial uses, can be made suitable for such uses.
Introduction:
The Prospective Developer (PD) is CUSA N.C. Holdings, L.P., with its principal office
located at 11 Greenway Plaza, Suite 2400, Houston, TX 77046. The manager of this
entity is William W. Sengelman of the same address. The Brownfields Property
comprises one parcel totaling approximately 4.65 acres located at 1801 Cameron Street,
Raleigh, NC (Wake County Tax Parcel ID No. 1704126630). On September 9, 2022, the
parcel which was referenced in the Brownfields Property Application (BPA)
(1704125771, 4.65 acres) was split into two separate parcels, one remaining as the
Brownfield Property (1704126630, 4.65 acres), and one being recombined with an off-
site parcel (1704124393, 0.02 acres).
The Brownfields Property is immediately adjacent to the Village District Shopping
Center (formerly Cameron Village Shopping Center) and Wake County Public Library
Oberlin Regional Library (formerly Cameron Village Branch) to the west, commercial
development to the north, and residential development to the south and to the east beyond
Bellwood Drive and an unnamed tributary to Pigeon House Branch east Bellwood Drive.
Redevelopment Plans:
The zoning for this location is RX-3, which is residential with limited retail and a three-story
height limit. The proposed reuse for the Brownfields Property included razing the existing
site buildings and constructing two new buildings for mixed-use purposes that include
residential multi-family housing structures of up to 400 units and approximately 10,000
square feet of amenity space and associated parking. Other potential uses include retail,
recreational use, and restaurant.
Subgrade features will be located in the southwestern corner of the Brownfields Property;
they include the lower level of the parking deck, fire rooms, and risers. There will be an
elevator in each of the two buildings.
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Vapor intrusion mitigation system (VIMS) design plans for this Brownfields Property
were approved by the Brownfields Redevelopment Section and a letter stating this was
provided to the PD on October 19, 2022. The VIMS is comprised of passive design
elements, which can be made active with the addition of fans. Vertical construction
commenced in February 2022 and the southern building is expected to be complete by
Fall 2024. The northern building is expected to be complete by Fall 2025. Pre-occupancy
sampling for the southern building is expected to occur in late 2024, ahead of September
2024 anticipated occupancy.
Soil was removed from the Brownfields Property in mid- to late 2022 under a DEQ-
approved Environmental Management Plan (EMP) and was taken to Triangle Area Earth
Corporation (TAE), in Zebulon, NC, and Soil Works Inc., in Selma, NC. Manifests are
provided in the Redevelopment Summary Report (Hart and Hickman, June 12, 2023).
Imported soil is needed, and as of July 2023, the PD is working on sourcing this soil.
Site History:
It was first developed in 1949 with 12 residential multi-tenant condominium buildings
and associated parking, sidewalks, and landscaping. Since that initial development, the
Brownfields Property has been used for residential and office space.
On February 7, 2020, the PD, CUSA NC Holdings, L.P., purchased the Brownfields
Property from Cameron Village Condominiums. The PD demolished the 1949 structures
in August/September of 2022. In September 2020, vapor intrusion assessment activities,
background soil sampling, and receptor survey activities were completed by Hart and
Hickman to support the Brownfields process. The PD submitted an Environmental
Management Plan (EMP), dated March 17, 2021, which was approved by the
Brownfields Redevelopment Section on April 20, 2021.
The Brownfields Property has been impacted from contaminant releases, including on-site,
heating oil underground storage tanks (USTs) and off-site drycleaner releases. Heating oil
was used to run the residential heating systems until they were converted to natural gas in
the 1970s. No USTs were identified during the ground penetrating radar (GPR) survey
that was performed at the Brownfields Property prior to the September 2020 assessment
activities discussed in the Brownfields Assessment Report (Hart and Hickman, LC,
November 5, 2020). However, as noted in the Redevelopment Summary Report (Hart and
Hickman, June 12, 2023), in September 2022, a UST was found containing liquids and
was removed from the Brownfields Property. Approximately 1,000 cubic yards of soil
were removed, stockpiled, tested, and disposed of offsite. The cut depth around the UST
was about 16 feet deep, and soil from the UST excavation was used as fill to bring the
grade to ground surface.
DSCA sites near the Brownfields Property
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There are two DSCA sites which are upgradient of the Brownfields Property, both of
which have received a No Further Action (NFA) determination. The Medlin-Davis
Cleaners site and the Newton’s Laundry and Cleaners.
Medlin-Davis Cleaners
Contaminants that originated off site include tetrachloroethylene (PCE) from the upgradient
Medlin-Davis Cleaners site, which was historically located at 2028 Cameron Street. The
Medlin-Davis Cleaners site has been investigated under the jurisdiction of the North Carolina
Department of Environmental Quality (DEQ) Dry-Cleaning Solvent Cleanup Act (DSCA)
Program (ID No. DC920013). PCE has been detected in the groundwater located in the
northern area of the Brownfields Property above its NC 2L Groundwater Quality Standard in
well MW-20; however, the Brownfields Property overlies the distal edge of the groundwater
plume.
Due to the PCE contamination in onsite groundwater, a Notice of Dry Cleaning Solvent
Remediation deed restriction was placed on the Brownfields Property under its previous
owner (Cameron Village Condominiums) and previous parcel identification number
(1704125771) on April 25, 2006. On May 5, 2016, a No Further Action (NFA)
determination was issued to the Medlin Davis Cleaners. This deed restriction prohibits
groundwater usage as part of the DC920013 Medlin-Davis Cleaners remedy. Such a deed
restriction is not in conflict with the land use restrictions that will be put in place for the
anticipated Brownfields Agreement for this Brownfields Property.
Newton’s Laundry and Cleaners
Newton’s Laundry and Cleaners, located at 2023 Cameron Street, Raleigh, NC, was
certified into the DEQ DSCA Program under identification number DC920012 in
December 2001. Assessment of the site indicates that contaminants are not expected to
impact the Brownfields Property. On January 3, 2012, a No Further Action (NFA)
determination was issued for the former Newton’s Laundry and Cleaners.
Based on the most recent data collected from hydrogeologically upgradient properties in
the 2000s and 2010s, (1900 Cameron Street, 2016 Cameron Street, and 616 South
Salisbury Street), the distal edge of the PCE plume in groundwater from the Medlin-
Davis Cleaners property (2016 Cameron Street) extended underneath at least the northern
portion of the Brownfields Property, and has been identified in the surface water located
just east of the Brownfields Property.
York Properties Facility
In November 1992, the predecessor of DEQ, the Department of Environmental and
Natural Resources (DENR) UST Section issued a Notice of Violation and a Notice of
Regulatory Requirements to an off-site property for the former York Properties Facility
(1900 Cameron Street), which is located topographically upgradient to cross gradient,
adjacent to the Brownfields Property, north of Cameron Street. The incident (UST
Incident #3409) involved the release of approximately 58 gallons of product from a UST
that was flushed into the unnamed tributary of Pigeon House Branch east of Bellwood
Drive. After this event, three USTs and an unknown volume of impacted soils were
removed and disposed of off the property. Groundwater impacts related to the release
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were addressed by extracting groundwater for treatment. The most recent records for
groundwater assessment activities related to this incident are from July 2006, and they
show detections of petroleum-related compounds above the NC 2L Groundwater
Standards, but below the Gross Contaminant Levels (GCLs). Surface water assessment
indicates that the unnamed tributary to Pigeon House Creek did not have petroleum-
related compounds at concentrations above the applicable 2B Standards for Class C
Waters. It does not appear that this release impacted the Brownfields Property.
Potential Receptors:
Potential receptors are construction workers, on-site workers, future residents, visitors,
animals, trespassers, and recreators. One known offsite receptor is the unnamed tributary
to Pigeon House Branch, which has had documented impact from the discharge of
groundwater impacted by the Medlin-Cleaners PCE release.
Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property: soil,
groundwater, and exterior soil gas samples. 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).
Risk Calculations:
Risk calculations were performed using the January 2023 DEQ Risk Calculator
https://deq.nc.gov/permits-rules/risk-based-remediation/risk-evaluation-resources. No
significant changes were made to the updated July 2023 risk calculator that affect the site
contaminants at this Brownfields Property, so the results from the January 2023 risk
calculator are considered still valid for this Brownfields Property. For the purposes of
looking at the site spatially, a site-wide assessment was conducted.
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Soil
Soil samples were collected at a depth of 0-2 feet below ground surface (ft bgs) from
locations SB-1 and SB-2 on the Brownfields Property. Additional soil samples were
collected at a depth of about 16 feet from TB-1 and TB-2. The acceptable cancer risk
range maximum of 1E-4 and the threshold noncancer hazard index of 1.0 are not
exceeded for soil, based on risk calculator output, for residential, non-residential worker,
construction worker, nor recreator/trespasser exposure scenarios. Per the cut map
provided in the EMP (approved April 20, 2021), the soil sampling locations represent soil
that remains at the site; SB-1 and SB-2 were abandoned and soil above the samples
remained in situ. TB-1 and TB-2 were backfilled with site soils to match the surrounding
grade.
Groundwater
Groundwater samples were collected from the northern area of the Brownfields Property
and assessed from monitoring well YK-MW-10, between March 2000 and March 2008,
before it was abandoned. Samples were collected from MW-10 (also identified as YK-
MW-10) and MW-20 on the Brownfields Property in two wells along the northern
property line for DSCA ID No. 92-0013. These onsite PCE concentrations are considered
to be from the off-site dry-cleaning sources, and the general PCE concentration trend is
decreasing. There is no ongoing monitoring of onsite wells required by another
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regulatory program. Contaminants, including trichloroethylene (TCE), were also detected
in groundwater that daylighted during excavation work in the southern portion of the
Brownfields Property.
Groundwater was found at depths between about 15.7 feet below ground surface (ft bgs)
in well YK-MW-10 during the March 15, 2000, sampling event to 20 ft bgs during the
June 2016 well abandonment of MW-20. Based on the groundwater flow direction for the
area developed for the DSCA investigation at the Medlin-Davis Cleaners site, the
groundwater flow on the Brownfields Property is assumed to be east-southeast towards
the tributary to Pigeon House Branch.
The threshold noncancer hazard index (HI) of 1.0 was exceeded for residential
groundwater direct contact (HI of 5.3) with the risk drivers being the concentrations of
TCE, mercury, and dibutyl phthalate, and the groundwater to indoor air vapor intrusion
pathway (HI of 2.7) for residential exposure, with the risk driver for this pathway being
TCE.
The threshold noncancer hazard index of 1.0 was exceeded for non-resident worker
groundwater direct contact (HI of 1.2) with the risk drivers being TCE and mercury;
however, the threshold noncancer hazard index of 1.0 was not exceeded for the
groundwater to indoor air vapor intrusion pathway for non-residential worker exposure
scenarios, based on the risk calculator output.
The acceptable cancer risk range maximum of 1E-4 was not exceeded for groundwater
nor the groundwater to indoor air vapor intrusion pathway for residential or non-
residential worker exposure scenarios, based on the risk calculator output.
Laboratory detection limits were higher than the residential groundwater Vapor Intrusion
Screening Levels (VISLs) for the following compounds: benzene,
bromodichloromethane, carbon tetrachloride, chloromethane, 1,2-dichloroethane (EDC),
ethylbenzene, naphthalene, 1,1,1,2-tetrachloroethane, 1,1,2,2-tetrachloroethane,
trichloroethylene, vinyl chloride.
PCE concentrations exceeding the NC 2L Groundwater Standard of 0.7 ug/L were found
on the Brownfields Property; as a result, limitations on direct contact with groundwater
are included in the Land Use Restrictions of the Brownfields Agreement, which are
consistent with the previous deed restriction placed on the property stemming from the
DSCA investigation.
Note: The most recent value of 9.4 micrograms per liter (ug/l) trichloroethylene (TCE) in
groundwater sampling data from monitoring well, MW-10, was collected on 4/10/2003,
as reported in the Annual Monitoring Report (SM&E, Inc., October 24, 2006). We
included this data point due to the lack of groundwater data south of MW-20 and due to
the detection of TCE in the southern area during excavation activities. The inclusion of
this one data point results in a residential direct exposure to groundwater pathway
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calculated Hazard Index (HI) greater than 1.0 (HI of 3.3 for TCE) and a groundwater to
indoor air residential vapor intrusion HI greater than 1.0 (HI for TCE is 1.8); the risk in
both pathways is being driven by TCE.
Surface Water
Surface water is not located on the Brownfields Property, but tributary to Pigeon House
Branch is located east of Bellwood Drive, which borders the Brownfields Property on the
east. Samples of surface water indicated that PCE was detected in those samples collected
in the northern portion of the stream.
Exterior Soil Gas
Exterior soil gas samples were collected at six sample locations at the Brownfields
Property. Based on the risk calculator output, the calculated vapor intrusion soil gas risk
ranges do not exceed either the acceptable carcinogenic risk range maximum of 1E-4 or
the threshold non-cancer hazard index of 1.0 for either the residential nor non-residential
worker exposure scenarios. However, exterior soil gas sample results can underpredict
the concentrations of volatile organic compounds (VOCs) in sub-slab vapor samples after
redevelopment. The contaminants that primarily drive the risk for exterior soil gas are:
chloroform, ethylbenzene, naphthalene, and PCE.
Trichloroethylene (TCE) was detected in exterior soil gas sample locations SG-1S, SG-
1D, SG-2, SG-3, and SG-4 during the September 10, 2020, sampling event, with the
highest concentration of TCE measured at 2.0 µg/m3 at sample location SG-1D. Although
the concentrations detected in exterior soil gas samples do not exceed the TCE
Residential VISL of 14 µg/m3, once the redevelopment is in place, TCE and other VOCs
could accumulate below the slabs of the new buildings due to the change in site
conditions. Additional considerations include that there is the potential for PCE
degradation into TCE, the proximity of the PCE plume to the Brownfields Property, and
the detection of contaminated groundwater in the southern area of the Brownfields
Property.
Based on the Draft DWM Minimum Mitigation and Sampling Requirements for Reuse
(February 2023), a vapor intrusion mitigation system (VIMS) is recommended since the
hazard index for soil gas to indoor air is 0.64, TCE is detected in site media, and the
redevelopment includes residential reuse. The PD has installed a VIMS in each of the two
buildings which are present on the Brownfields Property. In addition, pre- and post-
occupancy indoor air and sub-slab vapor sampling will be required for all new buildings
at the Brownfields Property.
Sub-Slab Vapor
Sub-slab vapor samples were not collected as part of the Brownfields Property
assessment prior to redevelopment. A vapor intrusion mitigation system (VIMS) plan was
submitted on June 24, 2022, revised on November 8, 2022, and approved on February 7,
2023. Sub-slab vapor samples are expected to be collected as part of pre- and post-
occupancy sampling efforts after the installation of the VIMS.
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Indoor Air
Indoor air samples were not collected as part of the Brownfields Property assessment
prior to redevelopment. A vapor intrusion mitigation system (VIMS) plan was submitted
on June 24, 2022, revised on November 8, 2022, and approved on February 7, 2023.
Indoor air sampling is expected to be conducted as part of pre- and post-occupancy
sampling efforts after the installation of the VIMS.
Land Use Restrictions:
Land use restrictions (LURs) will include the standard land use restrictions including
approved uses, land use definitions, requirement for an EMP, prohibitions on
groundwater use, final grade sampling, vapor intrusion, access, notification, known
contaminants, and land use restriction update LURs. As a result of DSCA-led closure
activities, a Notice of Dry-Cleaning Solvent Remediation (NDCSR) was filed on the deed
for the Brownfields property prohibiting groundwater use, which does not conflict with
the Brownfields LURs.
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 Branch Issues:
The Environmental Management Plan (EMP) dated March 17, 2021, was approved by the
Brownfields Redevelopment Section on April 20, 2021. Redevelopment activities are
anticipated to be concluded in late 2024. The EMP does not require final grade soil
sampling unless significant soil impacts are identified during grading or excavation
activities; however, the PD is sourcing fill for import and therefore final grade sampling
may be conducted for confirmation purposes.
The Vapor Intrusion Mitigation System Plan (VIMP) dated November 8, 2022, was
approved on February 7, 2023. Pre- and post-occupancy sub-slab vapor and indoor air
monitoring is expected in accordance with the finalized DEQ VI sampling guidance.
A VIMS Installation Completion Report which documents the VIMS installation
activities is anticipated in late 2024. Additionally, addendum reports which cover the
inspections after tenant upfit activities shall be submitted under separate cover to DEQ.
Additional reports shall be submitted after each post-construction sub-slab sampling
event.
On June 12, 2023, the Brownfields Redevelopment Section received the Redevelopment
Summary Report (Hart and Hickman, PC, June 12, 2023). Underground storage tank
removal and soil export are discussed in this report. Additionally, daylighted groundwater
grab samples and containerized groundwater samples were collected and analyzed.
Future redevelopment activities shall comply with the requirements of the approved
Environmental Management Plan and Approved Brownfields Agreement.