17050_Surrett Drive_DM_20200603

DECISION MEMORANDUM
DATE: June 3, 2020
FROM: Tony Duque
TO: BF Assessment File
RE: Surrett Drive
1110 Surrett Drive
High Point, Guilford County, NC
Brownfields Project No. 17050-13-041
Based on the following information, it has been determined that the above referenced
site, whose intended use is for no uses other than industrial, warehousing, office, retail or,
with DEQ's prior written approval, other commercial uses, can be made suitable for such
uses.
Introduction:
The Brownfields Property comprises five parcels (Guilford County Parcel Numbers
0177670, 0177669, 0177668, 0177672 and 0177671) totaling 13.147 acres and located at
1110 Surrett Drive, 803 Davidson Avenue and 510-514, 516 and 518 Timber Street in the
northern part of High Point, Guilford County, NC. The Brownfields Property is located in
a commercial and industrial part of High Point. It is bordered on the north by
undeveloped wooded land with Timber Street and a commercial furniture sales facility
beyond; to the east by Surrett Drive with furniture warehousing beyond; and to the west
by wooded land with commercial businesses beyond.
The Brownfields Property was first developed at least as early as the late 1930s for
agricultural uses and was known as Sullivan Farm. Two residences and farming
structures were razed in 1958. Custom Processing and Manufacturing (CP&M) acquired
the Brownfields Property and constructed the first commercial building thereon in 1962.
The building features slab -on -grade concrete foundation, metal framing, concrete and
brick exterior walls and a flat, built-up tar and gravel roof. The building was expanded to
its current 55,000 square feet by additions to the rear in 1964, 1968 and 1972.
From 1963 until January 1991, CP&M conducted metal furniture fabrication and
component manufacturing operations at the Brownfields Property. All known impacts at
the Brownfields Property are believed to have resulted from manufacturing activities
conducted at the site during CP&M's operation of the facility.
Since acquiring the Brownfields Property in October 2014, PD has renovated the building
and has leased it to Axiom America LLC (Axiom) which currently operates a business
that sells and distributes supplies, parts and machinery used in the digital textile
decorating industry. Axiom does not conduct any manufacturing operations at the site,
but only sells and distributes equipment, parts and pre -packaged products. Inks

temporarily stored at the facility for sale/distribution are water -based and contain no
VOCs or HAPs (Hazardous Air Pollutants).
Redevelopment Plans:
Beyond the current use of the building located at the Brownfields Property, as described
above, the Prospective developer is exploring development opportunities for the other
parcels in uses that could include industrial, warehousing, office, retail or, with DEQ's
prior written approval, other commercial uses.
Site Ownership and Use History
After the its agricultural use and the razing of two former residences and all farm related
structures in 1958, and following the construction in 1962 of the original site building,
beginning in 1963, the Brownfields Property was used by CP&M to manufacture
components of metal furniture and to fabricate the metal furniture itself. Components
were welded, finished by electroplating (nickel, brass and chrome) and polished with
sealants and lacquers. All manufacturing operations took place inside the site building
and included the use of metal forming, cutting welding and buffing equipment, cleaning
and plating tanks, chemical drum storage, chemical waste treatment equipment, a paint
spray booth, and a drying oven. Ownership of the Brownfields Property changed hands in
1964 and in 1968, but CP&M continued furniture manufacturing operations until early
1991 when CP&M filed for Chapter 7 bankruptcy.
In June 1991, the Brownfields Property was acquired by High Point Bank & Trust
(HPB&T) through foreclosure. Initial environmental assessment and cleanup activities
and the first involvement of regulatory agencies occurred at the site during HPB&T's
ownership (see below for details).
HPB&T leased the property to Wilderness Systems in mid-1994 following a cleanup
effort undertaken by HPB&T (see below for details). Wilderness Systems manufactured
polyethylene kayaks at the site until December 1997.
HCS Properties acquired the Brownfields Property in late January 1998 and operated
fabric sales company, Steward Fabrics, and stored fabric, upholstery and furniture at the
site until HCS declared bankruptcy in 2011.
In November 2011, the Bank of North Carolina (BNC) acquired the Brownfields
Property through foreclosure action. The site was vacant and idle during BNC's
ownership. Finally, as described in the introduction, above, the PD acquired the
Brownfields Property in October 2014.
Environmental Assessment and Cleanup:
In an effort to evaluate and improve environmental conditions at the Brownfields
Property with an eye toward rendering it leasable and/or marketable, in December 1991,
HPB&T engaged ENCI Corp. to conduct initial environmental assessment and cleanup
activities at the site. Assessment and Cleanup activities included the following, listed in
chronological order:
W

• Permanent closure of one 1,000-gal, two 2,000-gal, one 4,000-gal and one
10,000-gal UST. All USTs were reportedly used for heating oil storage. The effort
created UST Incident #7540. Tank grave samples indicated releases had occurred
in two of the five USTs. Eighty-seven (87) tons of petroleum impacted soil was
excavated from the UST area and disposed of at Cherokee Sanford, Sanford, NC.
The complete excavation of impacted soil was hampered because bedrock was
encountered in the tank graves. UST Section issued a NFA for Incident #7540 to
property owner HCS Properties in March 2011. NFA issued pursuant to Risk -
based Assessment and Corrective Action protocols for these petroleum USTs.
• Assessment and cleanup of Cyanide impacted soil was undertaken in October
1991 in response to an Emergency Hazardous Waste Permit issued by the NC
Solid Waste Section. The permit was issued to ENSCI who did the work, and the
site was assigned EPA ID NCD982117590. The impacted soil was discovered
during soil excavation and cleanup efforts in the vicinity of the electroplating
room in the site building. Twenty-five tons of Cyanide contaminated soil was
stored in a rolloff container at the site. Treatment consisted of three rounds of
liquid sodium hypochlorite application. The treated soil was then blended with
diatomaceous earth and transported to GSX Services' TSD facility in Pinewood,
SC for disposal in January 1992.
• Initial groundwater assessment began at the Brownfields Property in January
1992. The work was conducted by ENSI on behalf of HPB&T as bankruptcy
trustee for CP&M. Five monitoring wells were installed subsequent to UST
closure activities. Methylene Chloride, Acetone, TCE and PCE were detected in
groundwater samples at concentrations exceeding 2L standards. The source of the
groundwater impacts was attributed to releases from the industrial sewer
discharge from beneath the plating room. Groundwater flow direction was
determined to be to the north-northwest.
• Hazardous waste removal and initial interior decontamination efforts were
undertaken in June 1993 by ENSCI on behalf of HPB&T. Removal included
2,730 gallons of liquid hazardous waste (cadmium oxide, nitric and chromic acid,
paint and related plating waste) which was transported to a licensed TSD facility
for disposal. In addition, 985 gallons of nonregulated liquid waste (surfactants and
oils) were removed and transported to licensed facilities for disposal. Nine rolloff
boxes of contaminated debris (empty metal and plastic 55-gal and smaller
containers, paper, wood, dust, fiberglass, glass and plastic) were transported to
USPCI for disposal as hazardous waste. All interior surfaces of the facility were
cleaned several times using high-pressure steam, hand scrubbing and a 2-ton floor
scrubber. All carpet and fixtures were removed from the building.
• Additional groundwater assessment was conducted by ENSCI for HPB&T in
January 1994. TCE, PCE and 1,2-DCE were detected in concentrations exceeding
2L standards. PCE and TCE were likely used in the pre -fabrication phases of
furniture manufacturing as degreasers and drying agents. In addition,
concentrations of cadmium, chromium, lead and nickel, likely from releases in the
electroplating room, exceeded 2L standards.
• The NC Superfund Section prepared a Preliminary Assessment (PA) in December
1996. Superfund determined that the absence of nearby drinking water receptors,

the site did not pose a significant threat to human health and the environment.
Superfund recommended the site be assigned a No Further Remedial Action
Planned status under CERCLA. As a result, the site was added to the IHSB
Priority Sites list in December 1996. At that same time, according to information
provided by subsequent owner High Point Bank & Trust, following the
excavation of impacted soil in the plating room, tenant Wilderness Systems
completed the task of filling the excavated plating room sump areas with concrete
and sealing the entire plating room floor with epoxy or urethane sealant.
• In late 1997, prior to its subsequent acquisition of the Brownfields Property in
January 1998, HCS engaged Geological Resources, Inc to conduct a pre -
acquisition ESA of the site. Limited groundwater assessment was conducted at
that time. Analytical results indicate a significant reduction in concentrations of
chlorinated hydrocarbons between the 1994 and 1997 sampling events. Metals
concentration had reduced to below remedial goals in the 1997 results. It was
concluded that groundwater contaminants had not likely migrated off of the
Brownfields Property.
• In 2006, in accordance with a Site Assessment Plan approved by the Superfunds
Section's IHSB, EnviroAssessments, LLC conducted a Site Assessment Report
(SAR) for the property. Groundwater, soil and sediment sampling was conducted
during the SAR. Analytical results of groundwater sampling confirmed the
presence of PCE, TCE, Vinyl chloride and cis-1,2 DCE in concentrations above
2L standards. Analytical results of soil sampling did not identify analytes in
excess of established soil remediation goals. Additionally, analytical results of
sediment sampling indicated no target analytes in excess of the established
remedial goals.
• In August 2010, additional soil and groundwater sampling was conducted at the
site. Petroleum compounds were detected in the area of the former UST basin in
concentrations that did not exceed then established Soil -to -Groundwater MSCCs.
PCE was detected in two of the four monitoring wells sampled at concentrations
exceeding 2L standards. TCE was not detected in any of the sampled wells.
• Prior to the BNC's acquisition of the Brownfields Property in November 2013,
additional environmental sampling was conducted by ECS in October 2013 to
evaluate the potential for vapor intrusion at the site building. Sub -slab soil gas
sampling was conducted at five locations within the building in accordance with
DWM sampling procedures. In addition, indoor air samples were collected using
Summa canisters at three locations within the building, also in accordance with
DWM sampling procedures. Sub -slab soil gas sample results indicated the
presence of a variety of VOCs, including PCE and TCE, but only PCE was
detected in concentrations exceeding the then established IHSB Acceptable
Industrial/Commercial Soil Gas Screening Concentration. Analytical results of
indoor air samples also detected a number of VOCs, but only TCE and
Naphthalene were detected at concentrations exceeding IHSB Acceptable Indoor
Air Concentrations. The analysis also detected these compounds in similar
concentrations in the background sample collected outside the building.
• Subsequent to the PD entering the Brownfields Program, and in recognition of the
results of previous VI assessment conducted at the site, in March 2017, ECS
al

conducted additional indoor air sampling under a Brownfields-approved sampling
plan. Seven additional indoor air samples and one outside background sample
were collected in accordance with DWM sampling procedures. Samples were
analyzed by EPA Method TO-15 for the VOCs cis-1,2-DCE, PCE, TCE and vinyl
chloride. Laboratory results detected PCE in all indoor samples and in the
background sample. PCE concentrations exceeded the DWM indoor air non-
residential vapor intrusion screening level (VISL) in two of the seven indoor air
samples. TCE was detected below the non-residential VISL in five of the seven
indoor air samples. TCE was not detected in the outside background sample.
Potential Receptors:
Potential receptors are: construction workers, on -site workers, visitors and trespassers.
Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property: soil,
groundwater, surface water and sediment, 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.
Soil
Soil sampling was conducted in the area of the former fuel oil USTs, in the area of the
former plating vats, and in the vicinity of the waste water treatment hookup to the POTW
sewer discharge. To the extent possible, petroleum impacted soil was excavated in the
UST tank basin, and cyanide impacted soil was excavated in the area of the former
plating vats. Residual soil impacts are known to exist above bedrock in the former UST
tank basin.
Groundwater
Groundwater sampling was conducted in the area of the former UST basin, but that
sampling disclosed concentrations of VOCs exceeding 2L standards. PCE-impacted
groundwater impacts still exist at the Brownfields Property in concentrations that exceed
2L standards, but concentrations have gone down substantially over the 18 years since
groundwater monitoring first began in 1992, and TCE was not detected in the analytical
results from the last sampling event, in 2010.
Surface Water and Sediment
Limited surface water and sediment sampling was conducted at the site in 2006, and the
analytical results indicated no target analytes exceeding established remedial goals.
Soil Vapor
External soil vapor sampling was not conducted at the Brownfields Property.
Sub -Slab Vapor
In October 2013, limited sub -slab soil vapor sampling was conducted at the Brownfields
Property, and the analytical results indicated the presence of various VOCs, but only PCE
was detected in concentrations exceeding IHSB's then established Acceptable
5

Industrial/Commercial Soil Gas Screening Concentration. TCE and naphthalene were
also detected in sub -slab soil vapor samples but at concentrations below screening limits.
Indoor Air
Limited initial indoor air sampling was also conducted in October 2013, and results
indicated only TCE and naphthalene were detected at concentrations exceeding the IHSB
Industrial/Commercial screening limits. A second, more extensive round of indoor air
sampling was conducted in March 2017. Analytical results indicated the presence of PCE
in all indoor samples collected as well as in the outdoor background air sample, but PCE
concentrations only exceeded DWM Non-residential VISLs in two of the seven indoor air
samples. TCE was detected in concentrations below the Non-residential VISL in five of
the seven samples.
Risk Calculations
The DEQ Risk Calculator was developed to evaluate the risk of multiple contaminants
and multiple exposure routes associated with contaminated environmental media at a site.
The risk evaluation procedures, equations, and default parameters used to create the
calculator follow the current USEP risk assessment guidance. The DEQ Risk Calculator
dated May 2019 was used to evaluate the following.
The Brownfields Property was evaluated as a whole and utilized the highest
concentration of detected contaminants from the most recent sampling of each media.
The risk calculations indicated the following based on available data, including the
following media: groundwater, residual soil (based on confirmatory soil data), soil gas,
indoor air, and fill soil samples:
DIRECT CONTACT SOIL AND RATER CALCULATORS
Receptor
Pathvsar
Carcinogenic
13�riIndes
Riskescee"?
Risk
S,A
NC
NC
NC
Resident..............................................................................................................................................................................................................................................................................
Groundwater Use*
NC
NC
NC
C
NC
NC
Non -Residential worker.........................................................S°'7...
.................
.... ..
...
......... ...........
Groundwater Use*
5-5E-45
0S
13E+1
YE
Construction Worker
SIA
NC
NC
NC
Soil
NC
NC
Nti C
Recreator.Trespasser
.............................................................................._..........................................................................................................................................................................................
Surface water
NC
NC
C
VAPOR IN M SION CALCULATORS
Receptor
PathR 3
inog
CarRiskenic
H iIndes
Riskeieee"?
Groundwater to Indoor Air
NC
NC
NC
Resident
..............................................................................................................................................................................................................................................................................
Soi Gas to Indoor Air
.............................................................................................................................................................................................................................................................................
NC
NC
NC
Indoor Air
NC
NC
NC
Groundwater to Indoor Air
3AE-05
9.1E+00
YES
Non -Residential iN"orker
.............................................................................................................................................................................................................................................................................
So>7 Gas to Indoor Air
.............................................................................................................................................................................
6.6E-05
1.8E+01
YES
Indoor Air
3-9E-06
4-4E-01
N4
Red shading LICR> 1 E-04 or HI> 1.
LICR = Lifetime Incremental Cancer Risk
HI = Hazard Index
Co

Given the restriction of land uses to no use other than industrial, warehousing, office,
retail or, with DEQ's prior written approval, other commercial uses, risks to residential
users were not calculated (NC). While the Hazard Index exceeded the target value of 1.0
for non-residential worker groundwater use, groundwater -to -indoor air and soil gas -to -
indoor air paths, the most recent indoor air sampling results indicate a HI value well
below the target value of 1.0. Additionally, groundwater analytical results have
demonstrated that detected concentrations of VOCs in site groundwater have decreased
substantially between the first and most recent groundwater sampling events, 1992 and
2010, respectively. And in the absence of sources of groundwater contaminants at the
Brownfields Property, it is reasonable to expect that VOC concentrations will continue to
decrease and that potential risks to public health will likewise further decrease in the
future.
Required Land Use Restrictions:
Based on the site -specific data provided to the Brownfield program, the site is suitable for
the intended reuses as long as the agreed upon land use restrictions (LURs) in the BFA
are abided by. LURs will include provisions addressing the following:
• Prohibition of child care or adult care centers or schools;
• Prohibition of the use of groundwater for any purpose;
• Prohibition of soil disturbance excepting certain landscaping, infrastructure repair
or work conducted within provisions of an approved EMP;
• Restrictions regarding soil import to or export from the site;
• Standard VI provisions
• No additional redevelopment in the absence of a DEQ-approved EMP;
• Annual report regarding physical redevelopment activities;
• No denial of access for DEQ's purposes, with reasonable advance notice;
• Deed notice regarding BFA being in -effect at the site;
• Prohibition of the use of known site contaminants;
• Monitoring well damage to be repaired by owner and or tenants; and
• Annual submittal of LURU by any owner of any portion of the property.
Future Property Management Unit (PMU) involvement:
All future redevelopment that may occur on the other four parcels included in the
Brownfields Property shall be undertaken under the provisions included in new EMPs
and shall be overseen by the PMU.
7