17046_WLewisSt_DM_20240219

DECISION MEMORANDUM
DATE: February 19, 2024
FROM: Sharon Eckard
TO: BF Assessment File
RE: West Lewis Street
109, 117-B 1, & 120 W. Lewis Street
Greensboro, Guilford County
BF Project No. 17046-13-041
Based on the following information, it has been determined that the above referenced site, whose
intended use is for retail, restaurant, beverage or food production facility, office, event space, and
subject to DEQ's prior written approval, other commercial uses, can be made suitable for such
uses.
Introduction:
The Prospective Developer (PD) is AZ Development, LLC, located at 3412 Old Onslow Road,
Greensboro, NC, 27407. Its manager is Andrew Zimmerman of the same address. The
Brownfields Property comprises three parcels totaling approximately 1.22 acres located at 109,
117-B1, & 120 W. Lewis Street, Greensboro, NC (Guilford County Tax Parcel ID Nos.
7864631801, 7864539880, and 7864640041, respectively). This parcel assemblage also formerly
was associated with the following addresses: 111, 115, and 117 W. Lewis Street. The property is
currently developed with buildings dating back to the early 1900s within an urban area of
Greensboro.
The parcel located at 120 W. Lewis Street is the subject of a former NC Brownfields Agreement
known as the Model Linen site (BFs Project No. 08007-04-041). The Model Linen Notice of
Brownfields Property was recorded at the Guilford County Register of Deeds on September 14,
2006 (Book 6599, Page 1539-1564); an erroneous associated brownfields survey plat was
recorded on July 19, 2006 in Plat Book 166, Page 1.
A Notice of No Further Action for the Model Linen site was issued on December 21, 2015 by the
DEQ UST Section as a Notice of Residual Petroleum (NORP) was filed for this property with
the Guilford County Register of Deeds on December 3, 2015 (Book: 7764, Page: 2682-2684).
The NORP contains the following land use restrictions:
Soil: The Site shall be used for industrial/commercial use only. Industrial/commercial
use means a use where exposure to soil contamination is limited in time and does not
involve exposure to children or other sensitive populations such as the elderly or sick.
The real property shall not be developed or utilized for residential purposes including but
not limited to: primary or secondary residences (permanent or temporary), schools,
daycare centers, nursing homes, playgrounds, parks, recreation areas and/or picnic
areas.
WLewis St/ 17046-13 -041 / 19F62024

Groundwater: Groundwater from the site is prohibited from use as a water supply.
Water supply wells of any kind shall not be installed or operated on the site.
This Agreement, once recorded, supersedes the Model Linen Brownfields documents that were
recorded at the Guilford County Register of Deeds on July 19, 2006 (Plat Book 166, Page 1), and
on September 14, 2006 (Book 6599, Page 1539-1564), and replaces those land use restrictions
with those provided below in paragraph 12. It is the intent of DEQ and the Prospective
Developer that the execution and recordation of this Agreement between DEQ and Prospective
Developer shall not in any way impact any other person's existing liability protection under the
Act and the previously entered Model Linen Agreement.
This Agreement, once recorded, will not supersede nor replace the land use restrictions of the
NORP referenced above as the land use restrictions set forth in this Agreement in paragraph 12
below are not in conflict with those set forth in the NORP recorded December 3, 2015 (Book:
7764, Page: 2682-2684) for the Model Linen site.
Redevelopment Plans:
The redevelopment plan includes the reuse of the existing historic buildings for the proposed
reuses.
Site History:
Historic operations at 109/111 W. Lewis Street date back to the late 1800s where evidence
indicates this location was occupied by a paint shop associated with the J.C. Lewis Wagon Shop,
later the J. Lewis and Sons Wagon and Carriage Works with wood working, painting and gas
engine shop, and storage uses. By 1919 the buildings were noted as a garage and auto repair
shop (west side) and the Pepsi Cola Bottling Works (east side). By 1950, the building were used
for furniture storage through at least 1971. Most recently, this location was used as HQ
Greensboro flex space before conversion to a distillery.
Historic operations at 109/111 W. Lewis Street date back to the late 1800s where evidence
indicates this location was occupied by a paint shop associated with the J.C. Lewis Wagon Shop,
later the J. Lewis and Sons Wagon and Carriage Works with wood working, painting and gas
engine shop, and storage uses. By 1919 the buildings were noted as a garage and auto repair
shop (west side) and the Pepsi Cola Bottling Works (east side). By 1950, the building were used
for furniture storage through at least 1971. Most recently, this location was used as HQ
Greensboro flex space before conversion to a distillery.
Historic operations information at 117 B 1 W. Lewis Street date back to residential use in the late
1800s, with lumber storage yard and planning mill, livery stable, storage, furniture repair and
storage into the 1920s. In 1925, this location was operated as Wet Wash Laundry. By 1946, the
Ideal Laundry and WC Buchanan (wine interest) were operating at this location. From 1950
through 1971 the Greensboro Laundry Company with suspected drycleaning operated at this
location. New Bessemer Cleaners was also noted at this location in 1966. The building was
vacant from 1986 through at least 2000. In 2008, an antique shop was located there; it was also
the former site of the Forge community makers shop and now a brewery.
2
WLewis St/ 17046-13 -041 / 19F62024

Historic operations at 120 W. Lewis Street were as a manufacturer of wood -burning stoves from
1910 through 1979 and as a linen cleaning service known as Model Linen from 1979 through
1999. This parcel was vacant until 2004 when it was redeveloped for use as a software
development company and now Boxcar Arcade. The Model Linen parcel is also associated with
these regulatory incident numbers: UST Incident No. 16349 (petroleum contamination from
removal of one or more heating oil USTs) and Incident No. 86606 (groundwater contamination);
Facility ID: NONCD0002088.
There are two former or current off -site drycleaning locations in the area that are under
investigation in the Dry Cleaning Solvent Act (DSCA) Program as well. These include Wades
Dry Cleaning (DSCA ID: DC410052) at 607 S. Elm Street, Greensboro and Odorless Cleaners
(DSCA ID:DC 410047) at 205 W. Lewis Street, Greensboro.
The PD, AZ Development, LLC purchased the parcel located at 117 B 1 W. Lewis Street on
October 30, 2013 (Guilford County Register of Deeds Book 7546, Page 1894) from individuals,
and the parcel located at 109/111 W. Lewis Street on October 30, 2014 (Guilford County
Register of Deeds Book 7647, Page 1242) from South End Partners, LLC.
An affiliated company of the PD, ZCD II, LLC, was a follow-on owner of the parcel at 120 W.
Lewis Street having purchased the parcel from Double G Properties, LLC on December 30, 2015
(Guilford County Register of Deeds Book 7772, Page 3086), which purchased the parcel on June
5, 2015 from the Roberts family, which was affiliated with QUB Studios (Guilford County
Register of Deeds Book 7708, Page 1344), the PD for the original Model Linen Brownfields
Agreement recorded in 2006. However, ZCD II, LLC sold this parcel to Boxcar GSO Holdings,
LLC in July 2021 (Guilford County Register of Deeds Book 8488, Page 0433).
Potential Receptors:
Potential receptors are: construction workers, on -site workers, occupants, visitors, and
trespassers.
Contaminated Media:
DEQ relies on the following data collected from the following media at the subject property to
base its conclusions regarding the subject property and its suitability for its intended reuse: soil,
groundwater, sub -slab vapor, crawl space air, and indoor air. Exterior soil gas samples were not
collected at this property. Please refer to the Exhibit 2 of the Brownfields Agreement for any
specific data that exceeded regulatory standards or applicable screening levels.
Risk Calculations
Risk calculations for vapor intrusion risk were performed using the July 2023 version of the
DEQ Risk Calculator https:Hdeq.nc. _ og_y/pennits-rules/risk-based-remediation/risk-evaluation-
resources. A recent update to the risk calculator was provided this month, February 2024;
however, none of the changes to the risk calculator are applicable to this site. Therefore, the July
2023 risk output is acceptable for the contaminants of concern at the Brownfields Property.
WLewis St/ 17046-13 -041 / 19F62024

Separate risk calculators for vapor intrusion risk were prepared for 109 W. Lewis St, 111 W.
Lewis St., 115 W. Lewis Street, 117 W. Lewis St, 117 B-1 W. Lewis Street, and 120 W. Lewis
Street. Output from these risk calculations is provided below:
109 W. Lewis Street - Crawl space & indoor air only:
Risk for Individual Pathways
Version Date: July 2023
Basis: May 2023 EPA RSL Table
Site ID: 17046-13-041
Exposure Unit ID: 109 W Lewis Street, CS & IA Only
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Hazard Index
Risk exceeded?
Resident
Soil
NC
NC
NC
Groundwater Use*
NC
NC
NC
Non -Residential Worker
Soil
NC
NC
NC
Groundwater Use*
NC
NC
NC
Construction Worker
Soil
NC
NC
NC
Recreator/Trespasser
Soil
NC
NC
NC
________
Surface Water*
NC
NC
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
Carcinogenic
Risk
Hazard Index
Risk exceeded?
Resident
Groundwater to Indoor Air
NC
NC
NC
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
1.6E-04
5.7E+00
YES
Non -Residential Worker
Groundwater to Indoor Air
NC
NC
NC
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
3.5E-05
1.4E+00
YES
Based on the crawl space and indoor air data collected in 2021 through 2023, the calculated
carcinogenic risk and non -cancer hazard index (HI) exceed acceptable regulatory risk thresholds
for residential exposure pathways at 109 W. Lewis Street. The threshold HI of 1.0 is exceeded
for the non-residential worker exposure pathway as well. The risk drivers are trichloroethylene
(TCE) in CS-2 (12/15/2021) and naphthalene in IA-5 (9/25/2023).
4
WLewis St/ 17046-13 -041 / 19Feb2024

However, if you only run the most recent indoor air results from 9/25/2023 and exclude the
crawl space data collected in 2021, the revised calculated risk in 109 W. Lewis St is decreased to
the following:
Risk for Individual Pathways 1L�
Version Date: July 2023
Basis: May 2023 EPA RSL Table
Site ID: 17046-13-041
ExposureUnit ID: 109 W. Lewis, IA only
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
Carciinogenic
Ri
Hazardlndex
Risk exceeded?
Resident
Soil
NC
NC
NC
Groundwater Use*
NC
NC
NC
Non -Residential Worker
Soil
NC
NC
NC
Groundwater Use*
NC
NC
NC
Construction Worker
Soil
NC
NC
NC
Recreator/Trespasser
Soil
NC
NC
NC
Surface Water*
NC
NC
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
Carciin kenic
Ri
Hazardlndex
Risk exceeded?
Resident
Groundwater to Indoor Air
NC
NC
NC
Soil Gas to Indoor Air
NC
_
NC
_
NC
Indoor Air
1.4E-04
3.7E+00
YES
Non -Residential Worker
Groundwater to Indoor Air
NC
NC
NC
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
3.2E-05
8.8E-01
NO
Looking only at recent IA data, the calculated HI for the non-residential exposure pathway is
0.88 with the risk driver being naphthalene. TCE and PCE are not present in these indoor air
samples. A HI of 0.88 falls within the vapor intrusion risk management framework to
recommend, but not require a vapor intrusion mitigation system (VIMS). However, given that
the HI is very close to 1, post -occupancy monitoring in this space is appropriate.
5
WLewis St/ 17046-13 -041 / 19F62024

111 W. Lewis Street — Crawl space & indoor air only:
Risk for Individual Pathways
Version Date: July 2023
Basis: May 2023 EPA RSL Table
7
Site ID: 17046-13-041
ExposureUnit ID: III W Lewis St, CS & IA 2021-2023
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
Carcinogenic
Risk
Hazardindex
Risk exceeded?
Resident
Soil
-------------------------------------------
Groundwater Use*
NC
---------
NC
NC
---
NC
NC W
NC
Non -Residential Worker
Soil
NC
NC
NC
___ _
Groundwater Use*
NC
NC
NC
Construction Worker
Soil
NC
NC
NC
Recreator/Trespasser
Soil
NC
NC
NC
_______
Surface Water*
NC
NC
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
Carcinogenic
Risk
Hazard Index
Risk exceeded?
Resident
Groundwater to Indoor Air
NC
NC
NC
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
8.3E-05
2.2E+00
YES
Non -Residential Worker
Groundwater to Indoor Air
NC
NC
NC
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
1.9E-05
5.3E-01
NO
Based on the crawl space and indoor air data collected in 2021 and 2023, respectively, the
calculated HI exceeds the acceptable regulatory risk threshold of 1.0 for residential exposure
pathways at 111 W. Lewis Street, but falls within the range where we would recommend a vapor
intrusion mitigation system (VIMS) for non-residential worker exposure pathways. The risk
driver is naphthalene in sample CS-5 (12/15/2021).
6
WLewis St/ 17046-13 -041 / 19Feb2024

However, if you only run the most recent indoor air results from 9/25/2023 and exclude the
crawl space data collected in 2021, the revised calculated risk in 111 W. Lewis St is decreased to
the following:
Risk for Individual Pathways
Version Date: July 2023
Basis: May 2023 EPA RSL Table
Site ID: 17046-13-041
ExposureUnit ID: III W. Lewis St, IA data only
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
Carcinogenic
Risk
Hazardindex
Risk exceeded?
Resident
Soil
-------------------------------------------
Groundwater Use*
NC
---------
NC
NC
---
NC
NC W
NC
Non -Residential Worker
Soil
NC
NC
NC
___ _
Groundwater Use*
NC
NC
NC
Construction Worker
Soil
NC
NC
NC
Recreator/Trespasser
Soil
NC
NC
NC
_______
Surface Water*
NC
NC
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
Carcinogenic
Risk
Hazard Index
Risk exceeded?
Resident
Groundwater to Indoor Air
NC
NC
NC
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
5.1E-06
1.2E-01
NO
Non -Residential Worker
Groundwater to Indoor Air
NC
NC
NC
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
1.2E-06
2.8E-02
NO
Using only the most recent indoor air data, the HI for the non-residential exposure pathway is
0.028, for which we do not require nor recommend a VIMS. While there is a low concentration
of tetrachloroethylene in the IA-4 sample (J value, 0.16 ug/m3), there is no TCE nor
naphthalene, the risk driver for the 2021 data, present in the 2023 indoor air sample.
7
WLewis St/ 17046-13 -041 / 19Feb2024

115 W. Lewis St — Sub -Slab Vapor only:
Risk for Individual Pathways
Version Date: July 2023
Basis: May 2023 EPA RSL Table
Site ID: 17046-13-041
ExposureUnit ID: 115 W Lewis St, SSV only
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
Carcinogenic
Risk
Hazardlndcx
Risk exceeded?
Resident
Soil
NC
NC
NC
_____
Groundwater Use*
NC
NC
NC
Non -Residential Worker
Soil
NC
NC
NC
Groundwater Use*
NC
NC
NC
Construction Worker
Soil
NC
NC
NC
Recreator/IYespasser
Soil
NC
NC
NC
__________ ____________
Surface Water*
_ _
NC
NC
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Hazard Index
Risk exceeded?
Resident
Groundwater to Indoor Air
NC
-----
1.1E-06
NC
NC
-------
Soil Gas to Indoor Air
--
5.7E-02
NO
Indoor Air
NC
NC
NC
Non -Residential Worker
Groundwater to Indoor Air
NC
NC
NC
Solt Gas to Indoor Air
8.0E-08
4.5E-03
NO
Indoor Air
NC
NC
NC
The risk output based on sub -slab vapor samples collected in 2021 in 115 W. Lewis Street does
not exceed either the acceptable regulatory carcinogenic risk range nor the threshold value of 1.0
for the noncancer HI for both residential and non-residential exposure pathways. The calculated
HI values are also below that for which we would require or recommend a VIMS, or indoor air
sampling.
8
WLewis St/ 17046-13 -041 / 19F62024

117 W. Lewis Street — Sub -slab vapor only (excludes the data collected at 117 13-1 West Lewis
St.)
Risk for Individual Pathways Lultlilln,
Version Date: July 2023
Basis: May 2023 EPA RSL Table
Site ID: 17046-13-041
ExposureUnit ID: 117 W Lewis St, SSV only
DIRECT CONTACT SOIL AND WATER CALCULATORS AL
Receptor
Pathway
Carcinogenic
Risk
Hazard Index
Risk exceeded?
Resident
Soil
NC
NC
NC
NC
_ _ _ _ _ _
Groundwater Use*
NC
NC
Non -Residential Worker
Soil
NC
NC
NC
Groundwater Use*
NC
NC
NC
Construction Worker
Soil
NC
NC
NC
Recreator/Trespasser
Soil
NC
NC
NC
Surface Water*
NC
NC
NC
ff-
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Hazardlndes
Risk exceeded?
Resident
Groundwater to Indoor Air
NC
NC
NC
Sod Gas to Indoor Air
1.1E-06
6.1E-01
NO
Indoor Air
NC
NC
NC
Non -Residential Worker
Groundwater to Indoor Air
NC
NC
NC
Solt Gas to Indoor Air
8.2E-08
4.8E-02
NO
Indoor Air
NC
NC
NC
The risk output based on sub -slab vapor samples collected in 2021 in 117 W. Lewis Street does
not exceed either the acceptable regulatory carcinogenic risk range nor the threshold value of 1.0
for the noncancer HI for both residential and non-residential exposure pathways. The calculated
HI values are also below that for which we would require or recommend a VIMS for non-
residential exposure pathways. Although TCE and perchloroethylene (PCE) are present in sub -
slab vapor samples, the main risk driver in this set of data for residential exposure pathways is
isopropanol, which is likely a laboratory artifact in the samples.
9
WLewis St/ 17046-13 -041 / 19F62024

However, risk calculator results on crawl space samples CS-12 and CS-13 collected in 117 B-1
W. Lewis St using the January 2022 risk calculator. are the following:
Risk for Individual Pathways 11 loll
Version Date: January 2022
Basis: November 2021 EPA RSL Table
Site ID: 17046-13-041
ExposureUnit ID: 117 B-1 W Lewis St., CS-12 & CS-13
DIRECT CONTACT SOIL AND WATER CALCULATORS AL
Receptor
Pathway
Carcinogenic
Risk
Hazard Index
Risk exceeded?
Resident
Soil
NC
NC
NC
NC
_ _ _ _ _ _
Groundwater Use*
NC
NC
Non -Residential Worker
Soil
NC
NC
NC
Groundwater Use*
NC
NC
NC
Construction Worker
Soil
NC
NC
NC
Recreator/Trespasser
Soil
NC
NC
NC
Surface Water*
NC
NC
NC
ff-
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Hazardlndes
Risk exceeded?
Resident
Groundwater to Indoor Air
NC
NC
NC
Sod Gas to Indoor Air
NC
NC
NC
Indoor Air
3.9E-05
9.2E+00
YES
Non -Residential Worker
Groundwater to Indoor Air
NC
NC
NC
Solt Gas to Indoor Air
NC
NC
NC
Indoor Air
9.0E-06
2.2E+00
YES
These results indicate an elevated HI for both residential and non-residential indoor air exposure
pathways over the acceptable regulatory environmental threshold of 1.0. These results led to the
requirement to mitigate the crawl space under 117 B-1 W. Lewis Street as part of the
Brownfields Agreement. The PD was to mitigate the space and re -sample. However, the crawl
space was resampled in September 2023 without mitigation being performed.
10
WLewis St/ 17046-13 -041 / 19F62024

These 2022 RC results were entered into the July 2023 risk calculator, but that did not change the
risk output.
Risk for Individual Pathways 1
Version Date: July 2023
Basis: May 2023 EPA RSL Table
Site ID: 17046-13-041
ExposureUnit ID: 117 B-1 W Lewis St, CS-12 & CS-13 only
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
Carciinogenic
Ri
Hazardlndex
Risk exceeded?
Resident
Soil
NC
NC
NC
Groundwater Use*
NC
NC
NC
Non -Residential Worker
Soil
NC
NC
NC
Groundwater Use*
NC
NC
NC
Construction Worker
Soil
NC
NC
NC
Recreator/Trespasser
Soil
NC
NC
NC
Surface Water*
NC
NC
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
Carciin kenic
Ri
Hazardlndex
Risk exceeded?
Resident
Groundwater to Indoor Air
NC
NC
NC
Soil Gas to Indoor Air
NC
_
NC
_
NC
Indoor Air
3.9E-05
9.2E+00
YES
Non -Residential Worker
Groundwater to Indoor Air
NC
NC
NC
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
9.0E-06
2.2E+00
YES
11
WLewis St/ 17046-13 -041 / 19Feb2024

The risk calculator results for crawl space sample, CS-13B collected on 9/25/2023, indicates the
following increase in HI over the risk calculator results based on the 2021 data (July 2022/July
2023 risk calculator):
Risk for Individual Pathways 1
Version Date: July 2023
Basis: May 2023 EPA RSL Table
Site ID: 17046-13-041
Exposure Unit ID: 117 B-1 CS-13B only
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
Carcinogenic
Ri
Hazard Index
Risk exceeded?
Resident
Soil
NC -----
NC
NC
NC
----- ---
Groundwater Use*
----
NC
NC
Non -Residential Worker
Soil
NC
NC
NC
NC
NC
Groundwater Use*
NC
Construction Worker
Soil
NC
NC
NC
Recreator/Trespasser
Soil
NC
NC
NC
----------------------------------
Surface Water*
NC
NC
W
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
Carciin kenic
Ri
Hazardlndex
Risk exceeded?
Resident
Groundwater to Indoor Air
NC
NC
NC
_
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
6.9E-05
1.4E+01
YES
Non -Residential Worker
Groundwater to Indoor Air
NC
NC
NC
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
1.2E-05
3.2E+00
YES
It should be noted that although it was requested that mitigation be performed in this area prior to
additional sampling, such mitigation was not performed prior to the September 2023 sampling
event. The increase in the calculated non-residential work indoor air HI to 3.2 from the prior 2.2
appears to be because of the presence of additional compounds that were not reported or detected
in 2021, and an increase in the concentration of PCE in the crawl space sample in 2023. The
main risk driver of both datasets is PCE, which was detected at the higher concentration of 560
µg/m3 in 2023 versus 381 µg/m3 in 2021. TCE was detected in this most recent crawl space
sample, but at a concentration of 0.59 µg/m3.
Due to this HI, mitigation of this space is required and is written into the Brownfields
Agreement. The area below this building is comprised of an earthen crawl space. The PD has
been apprised to retrofit this crawl space with a chemical barrier, or to increase ventilation, and
to sample this space and other spaces for indoor air, once the mitigation has been performed, to
evaluate if other vapor intrusion mitigation steps should be taken.
12
WLewis St/ 17046-13 -041 / 19F62024

120 W. Lewis St — Sub -slab vapor and indoor air samples 2021 — 2023:
Risk for Individual Pathways
Version Date: July 2023
Basis: May 2023 EPA RSL Table
Site ID: 17046-13-041
ExposureUnit ID: 120 W Lewis St, SSV & IA 2021-2023
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
Carcinogenic
Risk
Hazardlndex
Risk exceeded?
Resident
Soil
NC
NC
NC
_____
Groundwater Use*
NC
NC
NC
Non -Residential Worker
Soil
NC
NC
NC
Groundwater Use*
NC
NC
NC
Construction Worker
Soil
NC
NC
NC
Recreator/IYespasser
Soil
NC
NC
NC
__________ ____________
Surface Water*
_ _
NC
NC
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Hazardlndex
Risk exceeded?
Resident
Groundwater to Indoor Air
----- NC
3.1E-05
NC
NC
------
Soil Gas to Indoor Air
---
7.7E+00
YES
Indoor Air
2.6E-05
1.9E+00
YES
Non -Residential Worker
Groundwater to Indoor Air
NC
NC
NC
Solt Gas to Indoor Air
2.3E-06
6.1E-01
NO
Indoor Air
5.9E-06
4.6E-01
NO
While there are no exceedances of the acceptable regulatory carcinogenic risks for 120 W. Lewis
Street based on these sub -slab and indoor air samples, clearly the threshold noncancer HI of 1.0
is exceeded for both soil gas and indoor air under residential exposures. The calculated HIs of
0.61 and 0.46 for the non-residential worker exposure pathways are within a range for which we
recommend a VIMS; however, the risk driver here is PCE and not TCE. Therefore, a VIMS
retrofit is not recommended at this time.
Risk calculators for on -site soil, groundwater use, and groundwater to indoor air vapor intrusion
risk were created separately for 109-111 W. Lewis Street, and 117 B1 West Lewis Street, and
120 W. Lewis Street in 2021 using the July 2020 risk calculator; based on the land use
restrictions pertaining to soil and groundwater at the Brownfields Property, these risk calculators
were not updated, the major risk being the vapor intrusion pathways that are addressed through
the July 2023 risk calculator results above.
Risk calculator output results for the older July 2020 versions are as follows:
13
WLewis St/ 17046-13 -041 / 19F62024

109-111 W Lewis St parcel — groundwater, soil aas
Risk for Individual Pathways
Version Date: July 2020
Basis: May 2020 EPA RSL Table
Site ID: 17046-13-041
ExposureUnit ID: 109-111 W Lewis St parcel
DIRECT CONTACT SOIL AND WATER CALCULATORS IL
Receptor
Pathway
Carcinogenic
Risk
Hazard Index
Risk exceeded?
Resident
Soil
0.0E+00
3.8E-06
NO
-____
Groundwater Use*
4.2E-03
7.8E+01
YES
Non -Residential Worker
Soil
0.0E+00
3.4E-07
NO
Groundwater Use*
1.1E-03
1.9E+01
YES
Construction Worker
Soil
0.0E+00
9.2E-07
NO
Recreator/IYespasser
Soil
0.0E+00
1.8E-06
NO
__________ _________
Surface Water* _
NC
NC
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Hazardlndex
Risk exceeded?
Resident
Groundwater to Indoor Air
3.2E-04
-----
5.6E-06
5.7E+00
YES
-------
Soil Gas to Indoor Air
--
4.4E+00
YES
Indoor Air
NC
NC
NC
Non -Residential Worker
Groundwater to Indoor Air
7.3E-05
1.4E+00
YES
Soil Gas to Indoor Air
3.9E-07
3.5E-01
NO
Indoor Air
NC
NC
NC
14
WLewisSt/17046-13-041/19Feb2024

117 B 1 West Lewis St: Soil and Groundwater
Risk for Individual Pathways
Version Date: July 2020
Basis: May 2020 EPA RSL Table
Site ID: 17046-13-041
ExposureUnit ID: 117 B1 West Lewis St parcel
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
Carcinogenic
Risk
Hazardlndex
Risk exceeded?
Resident
Soil
1.6E-10
5.0E-05
NO
_____
Groundwater Use*
2.5E-05
7.5E-01
NO
Non -Residential Worker
Soil
3.6E- I I
9.8E-06
NO
Groundwater Use*
6.5E-06
1.8E-01
NO
Construction Worker
Soil
8.3E- 12
5.7E-05
NO
Recreator/IYespasser
Soil
1.5E-11
8.7E-06
NO
__________ ____________
Surface Water*
_
NC
NC
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Hazardlndex
Risk exceeded?
Resident
Groundwater to Indoor Air
2.5E-06
-----
NC
2.1E-01
NO
-------
Soil Gas to Indoor Air
--
NC
NC
Indoor Air
NC
NC
NC
Non -Residential Worker
Groundwater to Indoor Air
5.7E-07
5.0E-02
NO
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
NC
NC
NC
15
WLewisSt/17046-13-041/19Feb2024

120 W. Lewis Street: Soil and groundwater
Risk for Individual Pathways
Version Date: July 2020
Basis: May 2020 EPA RSL Table
Site ID: 08007-04-041
ExposureUnit ID: 120 W Lewis Street - GW MW-3 (2014)
DIRECT CONTACT SOIL AND WATER CALCULATORS IL
Receptor
Pathway
Carcinogenic
Risk
Hazard Index
Risk exceeded?
Resident
Soil
0.0E+00
0.0E+00
NO
-____
Groundwater Use*
2.8E-04
5.1E+00
YES
Non -Residential Worker
Soil
0.0E+00
0.0E+00
NO
Groundwater Use*
7.5E-05
1.2E+00
YES
Construction Worker
Soil
0.0E+00
0.0E+00
NO
Recreator/Trespasser
Soil
0.0E+00
0.0E+00
NO
__________ _________ _
Surface Water* _
NC
NC
NC
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
CarcinogenicRisk
Hazardlndex
Risk exceeded?
Resident
Groundwater to Indoor Air
2.9E-05
-----
0.0E+00
6.5E-01
NO
-------
Soil Gas to Indoor Air
--
0.0E+00
NO
Indoor Air
NC
NC
NC
Non -Residential Worker
Groundwater to Indoor Air
6.6E-06
1.6E-01
NO
Soil Gas to Indoor Air
0.0E+00
0.0E+00
NO
Indoor Air
NC
NC
NC
Residential use of the Brownfields Property is not currently contemplated and is prohibited in the
Brownfields Agreement. Vapor intrusion mitigation is required only in the crawl space under
117 B-1 West Lewis Street. Additional post -occupancy monitoring should occur in 109 and 120
W. Lewis Street.
Required Land Use Restrictions:
The standard land use restrictions as to land use, no physical redevelopment without an EMP,
reporting, prohibitions on groundwater use and residential use, schools, and dry cleaning with
chlorinated solvents, restrictions on soil disturbance, vapor intrusion provisions, known
contaminant uses, abandonment of groundwater monitoring wells, damages to wells, notices,
access, and land use restriction update provisions are included in this Brownfields Agreement.
In addition, the PD is required to mitigate the crawl space below 117 B-1 W. Lewis Street as the
HI exceeds 1.0 for the non-residential worker exposure pathway (3.2).
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.
Brownfields Prope , Management Issues
Evaluate whether additional vapor intrusion mitigation steps are required once retrofit of 117 B-1
W. Lewis Street and the indoor air data collection has been performed.
16
WLewis St/ 17046-13 -041 / 19F62024

Confirm no mitigation is required at 109 W. Lewis St. & 120 W. Lewis St with additional post -
occupancy sampling.
17
WLewis St/ 17046-13 -041 / 19F62024