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HomeMy WebLinkAbout19055_Wake County Board of Ed_Phase I ESA appendix_20150612 Phase I Environmental Site Assessment Former Corning / AVX Facility Project 3900 Electronics Drive Raleigh, North Carolina PES Project Number: R15-125 June 12, 2015 Prepared For: Marlowe Land and Farm Inc. 3700 Computer Drive, Suite 200 Raleigh, North Carolina 27609 TABLE OF CONTENTS General Information ................................................................................ 4 1.0 Executive Summary .......................................................................... 5 1.1 Findings and Opinions ........................................................................................ 7 1.2 Conclusions ......................................................................................................... 7 1.3 Recommendations ............................................................................................... 7 2.0 Subject Property Description ......................................................... 10 2.1 Location and Legal Description ....................................................................... 10 2.2 Environmental Liens and Activity/Use Limitations ......................................... 11 2.3 Physical Setting ................................................................................................. 11 2.4 Subject Property and Vicinity Characteristics ................................................ 12 2.5 Description of Subject Property Structures and Improvements ................... 12 2.6 Current Uses of the Subject Property .............................................................. 13 3.0 Historical Use Information .............................................................. 13 3.1 Historical Background ...................................................................................... 13 3.1.1 City Directories ............................................................................................ 13 3.1.2 Aerial Photographs ..................................................................................... 13 3.1.3 Sanborn Fire Insurance Maps .................................................................... 15 3.1.4 Topographic Maps ...................................................................................... 15 3.1.5 Review of Prior Environmental Reports or Investigations ...................... 15 3.2 Historically Significant or Environmental Findings ........................................ 18 4.0 Federal, State, Local & Tribal Database Listings .......................... 18 4.1 On-Site Regulatory Issues............................................................................. 18 4.2 Off-Site Regulatory Issues ............................................................................ 20 5.0 Local Agency Records .................................................................... 21 6.0 Site Observations ............................................................................ 21 6.1 On-site Reconnaissance ................................................................................... 21 6.1.1 Site Operations, Processes, and Equipment ............................................ 21 6.1.2 Aboveground Chemical or Waste Storage ................................................ 22 6.1.3 Underground Chemical or Waste Storage, Drainage, or Collection Systems ................................................................................................................ 22 6.1.4 Electrical Transformers / PCBs .................................................................. 22 6.1.5 Releases or Potential Releases ................................................................. 23 6.1.6 Other Notable Site Features ....................................................................... 23 6.2 Non-ASTM Scope Concerns ............................................................................. 23 6.2.1 Radon ........................................................................................................... 23 6.2.2 Wetlands / Erosion and Soil Control Concerns ........................................ 24 6.2.3 All Other Concerns ..................................................................................... 24 7.0 Interviews ......................................................................................... 24 8.0 Off-site Reconnaissance ................................................................. 24 9.0 Product Information ........................................................................ 25 9.1 Purpose .............................................................................................................. 25 9.2 Scope of Services .............................................................................................. 25 9.3 Deviations .......................................................................................................... 26 9.4 Limitations.......................................................................................................... 26 9.5 Data Gaps ........................................................................................................... 27 9.6 Reliance .............................................................................................................. 27 10.0 User Provided Information ............................................................ 27 10.1 Specialized Knowledge ................................................................................... 27 10.2 Valuation Reduction for Environmental Issues ............................................ 27 10.3 Commonly Known or Reasonably Ascertainable Information ..................... 27 10.4 Owner, Property Manager, and Occupant Information ................................. 27 10.5 Reason for Performing Phase I ...................................................................... 28 10.6 Title Records .................................................................................................... 28 Appendices Appendix A: Site Maps Appendix B: Site Photographs Appendix C: City Directories Appendix D: Aerial Photographs Appendix E: Sanborn Maps Appendix F: Topographic Maps Appendix G: Prior Site Investigation Report Appendix H: Supporting Documentation Appendix I: Regulatory Records Documentation Appendix J: Qualifications of Assessor Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 4 General Information Project Information: Site Information: Former Corning / AVX Site 32.55 Acre Industrial Site PES Project No. R15-125 3900 Electronics Drive Raleigh, Wake County, NC Consultant Information: Client Information: Proctor Environmental Services, Inc. Marlowe Land and Farm Inc. 5113 Yachtsman Court 3700 Computer Drive, Suite 200 Raleigh, North Carolina 27615 Raleigh, NC 27609 Phone: 919-630-0721 Attn: Mr. Anderson Marlowe Inspection Date: June 7, 2015 Report Date: June 12, 2015 Site Assessor and Project Manager: Thomas A Proctor, P.G., RSM Senior Project Manager Environmental Professional Certification: I declare that, to the best of my professional knowledge and belief, I meet the definition of Environmental Professional as defined in 40 CFR Part 312. I have the specific qualifications based on education, training, and experience to assess a property of the nature, history, and setting of the subject property. I have developed and performed the all appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312. Thomas A. Proctor, L.G., RSM Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 5 1.0 Executive Summary Proctor Environmental Services, Inc. (PES) has performed a Phase I Environmental Site Assessment (ESA) in compliance with the ASTM E1527-13 Standard of the Former Corning / AVX Facility located at 3900 Electronics Drive in Raleigh, North Carolina. The previous occupant of the site, Corning Glass Works, sold its worldwide electronic components division to two electronics companies in 1987. According to a press release at the time, Corning said the AVX Corporation, the current owner and former site operator, would buy its capacitor operations in Raleigh, N.C., Biddeford, Me., and Singapore. Although not certain, it appears that, according to web-based patent office research, the manufacturing processes formerly used by Corning Glass and subsequently AVX at the Site were related to the manufacture of thin film tantalum oxide capacitors. A dielectric substrate having a non-tantalum electrically conductive film electrode formed thereon is disposed within a vacuum environment. A film of tantalum oxide is applied over the conductive film within a vacuum environment. The composite is then removed from the vacuum environment and disposed within an anodizing bath wherein an electrical current is passed through the tantalum oxide film, the current being substantially constant until a predetermined desired voltage is reached. Thereafter, a second electrically conductive film electrode is disposed over the so-formed tantalum oxide film. The Project consists of approximately 32.55 acres developed with approximately 139,000 square feet of heated manufacturing and administrative space recorded as Parcel Identification Number (PIN) 1715781482 by the Wake County Tax Assessor. The Project, originally developed with its current primary structure in 1963, is located in a highly developed commercial, light industrial and residential area north of downtown Raleigh, North Carolina. The Project is fronted to the north by New Hope Church Road, across which are two convenience stores, a commercial business park, a home and garden equipment shop, and a telephone switching station; to the east, across Atlantic Avenue, by a residential neighborhood called Brentwood; to the south, by several office buildings occupied by the Carolina Ballet and Newcomb and Company; and to the west, across the Seaboard railroad tracks, by several single and multi-tenant commercial buildings consisting of light industrial and commercial businesses. Municipal water and sewer are provided to the Project area by the City of Raleigh utilities; however it appears that a water-supply well (unknown as to whether it remains active) may be present on the east side of the main building. We were not able to access the small building in question so this remains an open question. Historical information researched during this ESA indicates that the Project Site was first developed at least as early as 1943, when what appears to be at a farm-related structure or residence was present. Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 6 Property Type/Use: Unoccupied industrial site Date First Developed: Approximately 1943 Total Acreage: Approximately 32.55 acres Parcel ID Number: 1715781482 Environmental Report Summary Report Section NFA De minimis BER REC CREC HREC 2.2 Environmental Liens and Activity/Use Limitations X 3.1 Historical Background X X 4.0 Federal, State, Local & Tribal Database Listings X X 5.0 Local Agency Records X 6.1 On-site Reconnaissance X X 6.1.1 Site Operations, Processes, and Equipment X X 6.1.2 Aboveground Chemical or Waste Storage X X 6.1.3 Underground Chemical or Waste Storage, Drainage, or Collection Systems X X 6.1.4 Electrical Transformers / PCBs X 6.1.5 Releases or Potential Releases X X X 6.1.6 Other Notable Site Features X 6.2.1 Radon X 6.2.2 Wetlands / Erosion and Soil Control Concerns X 6.2.3 All Other Concerns X 7.0 Interviews X 8.0 Off-site Reconnaissance X 9.5 Data Gaps X Acronyms in table: NFA: No Further Action Recommended. BER: Business Environmental Risk, as defined in the ASTM E-1527-13 standard. REC: Recognized Environmental Condition, as defined in the ASTM E-1527-13 standard. HREC: Historic Recognized Environmental Condition, as defined in the ASTM E-1527-13 standard. CREC: Controlled Recognized Environmental Condition, as defined in the ASTM E-1527-13 standard. Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 7 1.1 Findings and Opinions Any exceptions to, or deletions from, this practice are described in Section 9.4 of this report. 1.2 Conclusions PES has performed a Phase I Environmental Site Assessment in conformance with the scope and limitations of ASTM Practice E1527 of a developed, former industrial site known as the Corning / AVX Facility located at 3900 Electronics Drive in Raleigh, Wake County, North Carolina, the Property. This assessment has revealed evidence of several recognized environmental conditions (RECs) in connection with the Property, specifically: • Known groundwater, surface water (and possibly residual soil) contamination as a result of an historic release of chlorinated solvents; • The probable presence of asbestos-containing material in significant quantities within the Facility. It appears that someone has attempted to remove some of the probable ACM (floor tiles) from small areas of the Facility. • The probable presence of mold in significant quantities within the Facility; • The possible presence of lead paint within the Facility; • The possible presence of unknown quantities of chemicals and manufacturing materials that may be either listed or characteristic hazardous waste within the Facility due to the 50+ years of industrial activity and the large amount of residual equipment and materials left in the building when AVX left; and • The presence of known soil and groundwater contamination incidents that are both adjoining and topographically upgradient of the Property. 1.3 Recommendations Based on the findings of this ESA, PES recommends the following actions associated with the Site: • The interior and exterior of the primary on-site structure appears to have asbestos- containing material (ACM) in the form of floor tiles, as well as possibly mastic and ceiling tile material. Other ACM may be present but not observable during our Site walk-over. Our walk-through of the building revealed that as much as 50,000 square feet or more of possible ACM may be present. A significant amount of these materials appear damaged and possibly friable. As an asbestos survey was not included as part of these Phase I activities, we recommend that a thorough survey of the facility be conducted by a certified asbestos inspector; Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 8 • Numerous areas of the facility’s first floor have been flooded by rain penetrating the roof, causing the growth of mold in and on numerous ceiling tiles, walls, and carpeting. These areas should be assessed and remediated by a mold abatement contractor; • Many of the steel beams outside and inside the structure having badly peeling paint. As a lead-paint survey was not included within the scope of this work, we recommend that a certified lead inspector conduct a survey of the facility to verify the presence or absence of lead in the paint at the site; • Several areas of what appeared to be leaking (used?) oil or hydraulic fluid were present in the basement area below the first floor. The source or sources of this oil should be verified and repaired such that the leaks don’t continue and the leaked oil should be cleaned up and properly disposed of; • Based upon the most recent groundwater assessment summary report by Amec in regards to their November 2014 groundwater sampling event, it is our opinion that the horizontal and vertical extent of chlorinated solvent-impacted groundwater has not be fully delineated. The November 25, 2014 sample collected from shallow upgradient monitoring well MW-1A exhibited 420 ug/L of trichloroethene (TCE). TCE has a groundwater quality standard of 3 ug/L. Since the well is approximately 120 feet upgradient of the known primary source of groundwater contamination (the “dry well” located east of the former Chemical Storage Building), it’s possible that there’s another source or sources of impacted groundwater in the vicinity of the loading dock or from the northwest building corner. In addition, there are not “clean” (less than the constituent’s groundwater quality standard) shallow monitoring wells to the north or south of the known plume area. Of particular concern is the lack of a clean monitoring point to the north of the plume and east of the building. If there is another contaminant source upgradient of the known source then it’s possible that the contaminant plume could be migrating under at least the southern section of the building. In a hydraulically downgradient direction, it appears that shallow well MW-5A is the last shallow well located on the Site, and it’s impacted with 46 ug/L of TCE. Amec’s reporting uses a contaminant isopleth of 10 ug/L to indicate the leading edge of the dissolved TCE plume. This is more than three times TCE’s groundwater quality standard of 3 ug/L. As the next closest downgradient shallow well is MW-13A, located more than 350 feet from well MW- 5A and across Atlantic Avenue and in the Brentwood neighborhood, it’s possible that the dissolved shallow plume extends much closer to, and possibly beyond, the Site’s eastern property boundary. Based upon this, we recommend several additional shallow groundwater monitoring wells around the existing plume to fully delineate its degree and extent; Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 9 • NCDENR has established a non-residential vapor intrusion screening level for TCE of 4.35 ug/L in groundwater located within 100 feet of any structure. (The residential vapor intrusion screening level for TCE is 1.04 ug/L.) The most recent sample from upgradient monitoring well MW-1A exhibited 420 ug/L and is located within 100 feet of the structure. If groundwater concentrations exceed these screening levels then further investigation should proceed in a step-wise fashion, typically with the collection of soil gas samples and possibly the collection of indoor air quality samples. Based upon these findings we recommend that a soil-gas survey be conducted near or below the buildings floor slab in order to determine the likelihood of vapor intrusion into the building. Based upon the intended future use of the building, it may be prudent to do some in-door air quality testing as well; • The existing groundwater remediation system uses “pump and treat” technology whereby contaminated groundwater is extracted from remedial wells (13 at the Site) in and around the plume and the water is treated via an air stripper before discharge into the City of Raleigh’s Publically Owned Treatment Works (POTW) under permit. In 2009, Corning/AVX opted to stop operation of the full time pump and treat groundwater remediation system in anticipation of entering the Registered Environmental Consultant (REC) Program. The decision was ultimately made to not enter the Voluntary Cleanup Program and to repair and reactivate the remediation system. The City of Raleigh POTW permit was renewed on March 20, 2013 and the system was reactivated on March 27, 2013. According to Amec’s report, the “prestripper” water (extracted groundwater going into the stripper prior to treatment) exhibited a concentration of 0.66 ug/L of TCE and the “poststripper” water (treated and sampled prior to discharge) exhibited a concentration of 0.70 ug/L of TCE. In other words, the treated water came out of the treatment system with more contamination than before treatment. The Amec report doesn’t discuss these results further in regards to any problems associated with the system or whether repairs were subsequently made. Without a copy of the Site’s discharge permit, we don’t know if this discharge concentration is allowable but at a minimum it appears that the air stripper system is not effectively removing the solvents from the waste stream. We recommend further investigation into the efficiency of the Site’s treatment system. This groundwater remediation system was put in place at the site in the early 1990s, almost 25 years ago. The technology, although widely in use over two decades ago, is not used regularly anymore primarily due to the fact that it’s expensive to maintain and operate and often not very effective in decreasing the size of the contaminant plume or even keeping it stabilized from moving away from the source area and potentially off of the Site. In addition, new technologies, such as in-situ injection and bioremediation, have been developed in the interval that Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 10 are often more effective and treat the contaminated media to acceptable levels much quicker. An evaluation of the overall effectiveness of the remedial system at the site is beyond the scope of this effort. However, we recommend considering an evaluation of both the existing system’s effectiveness as well as available alternatives to determine if the contaminant plume can be cleaned up or stabilized before it leaves the property; • Upgradient and downgradient stream samples were collected by Amec during the November 2014 sampling event from the western side and eastern side of the Site from the perennial stream that runs through the property. According to their report, the upgradient sample did not exhibit a detectable concentration of any analytes while the downgradient sample contained TCE at a concentration of 0.05 mg/L which exceeds the 2L standard (groundwater) of 0.003 mg/L and is also above the surface water standard for Class C, Nutrient Sensitive Waters (NSW), of 0.030 mg/L based on Human Health Standards. This indicates that groundwater at the site is discharging into the stream that bisects the property and negatively impacting stream water quality. Amec does not report any further downstream sampling to determine the extent of surface water standards exceedances. We recommend finding where the groundwater is discharging into the stream and whether that discharge can be abated as well as collecting additional downstream samples to determine the degree and extent of surface water impact; and • Based upon our review of historical assessment and remedial activities, it appears that approximately 538 tons of solvent-contaminated soil were removed in May 1989 and disposed of off-site. The state cleanup action levels used for this soil removal were 100 parts per million (ppm) of total non-halogenated solvents and 1ppm halogenated solvents. Further information regarding the effectiveness of the source removal actions has not been discovered. However, given the significant improvements made with in-situ soil treatment technologies, if solvent-impacted soils remain in the source area and continue to leach contaminants into the groundwater, it may be prudent to consider treating these soils to reduce or abate further leaching of contaminants, thereby potentially reducing the time and costs associated with future groundwater monitoring and remediation. 2.0 Subject Property Description 2.1 Location and Legal Description The Project, located at 3900 Electronics Drive in Raleigh, North Carolina consists of approximately 32.55 acres of developed, unoccupied, former industrial space recorded as Parcel ID Number 1715781482 by the Wake County Tax Office. The Project, originally developed with its current structure in 1963, is located in a highly developed commercial, Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 11 light industrial and residential area north of downtown Raleigh, North Carolina. No legal description for the Site was provided to PES other than the Parcel Identification Number. 2.2 Environmental Liens and Activity/Use Limitations PES was not asked to provide an environmental lien search for the Site. The Site was not identified on any Activity Use Limitation (AUL) databases reviewed by EDR. According to the User of this PESA, Mr. Anderson Marlowe of Marlowe Land and Farm Inc., he is not aware of any environmental cleanup liens against the Property. 2.3 Physical Setting The geologic and hydrogeologic settings of a site are considered of interest since they may provide information related to the direction and physical mechanisms of contaminant migration, if present, from on-site and off-site sources. PES personnel reviewed information from the following sources with regard to the geology and hydrogeology of the Site and surrounding area: Topography Site Elevation (amsl*) Approximately 290 feet (West Side, Center) to 260 feet (East Side, Center) Surface Runoff / Topographic Gradient Generally from West to East Closest Surface Water Marsh Creek, approx. 1800 feet East Source of Information USGS Topographic Map, Raleigh East Quadrangle, 2002 Soil Characteristics Soil Types Brown to Red Micaceous Silty Sands Description Moderate infiltration rates; moderately well drained; fine to coarse textures Source of Information Law Environmental Site Characterization Report dated March 2, 1989 Geology/Hydrogeology Formation Injected mica gneiss and schist of the Raleigh Geological Belt within the Piedmont Physiographic Province of North Carolina Description Metamorphic saprolites and surficial residual clay-rich soils. Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 12 Geology/Hydrogeology Estimated Depth to First Occurrence of Groundwater Approximately 15 to 20 feet below land surface Primary Aquifer Fractured rock aquifer system Hydrogeologic Gradient West to East * amsl – Above Mean Sea Level 2.4 Subject Property and Vicinity Characteristics The Project consists of approximately 32.55 acres of developed, unoccupied, former industrial space recorded as Parcel ID Number 1715781482 by the Wake County Tax Office. The Project is located at 3900 Electronics Drive in Raleigh, North Carolina. The Project, originally developed with its current structure in 1963, is located in a highly developed commercial, light residential and residential area north of downtown Raleigh, North Carolina. 2.5 Description of Subject Property Structures and Improvements The Project is made up of one large (139,000 square feet of heated space) building consisting of a ground level manufacturing space surrounded by administrative, support offices and laboratories and a basement with a machine shop, a trade shop, a boiler room, stock room and storage. Three small buildings located to the south of the main building consist of a now-empty chemical storage building, a reportedly empty (building not accessible at the time of our site visit) maintenance shop, and a building used to house the aboveground components of the on-site groundwater remediation system. A Site Location Map is attached as Figure 1 and a Site Plan (Aerial) is attached as Figure 2 in Appendix A. Historical information researched during this ESA indicates that the Project was developed prior to 1943, when what appears to be a farm-related structure, possibly a residence, were observed. The basis of the current industrial structure was constructed in 1963. Photographs of the Site and surrounding properties can be found in Appendix B. The previous occupant of the site, Corning Glass Works, sold its worldwide electronic components division to two electronics companies in 1987. According to a press release at the time, Corning said the AVX Corporation would buy its capacitor operations in Raleigh, Biddeford, Maine, and Singapore. Although not certain, it appears that, according to web-based patent office research, the manufacturing processes formerly used by Corning Glass and subsequently AVX at the Site were related to the manufacture of thin film tantalum oxide capacitors. A dielectric Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 13 substrate having a non-tantalum electrically conductive film electrode formed thereon is disposed within a vacuum environment. A film of tantalum oxide is applied over the conductive film within the vacuum environment. The composite is then removed from the vacuum environment and disposed within an anodizing bath wherein an electrical current is passed through the tantalum oxide film, the current being substantially constant until a predetermined desired voltage is reached. Thereafter, a second electrically conductive film electrode is disposed over the so-formed tantalum oxide film. 2.6 Current Use of the Subject Property The Project consists of approximately 32.55 acres of developed, unoccupied, former industrial space. Several dozen UPS trailers are stored at and occupy the western parking lot of the Facility. 3.0 Historical Use Information 3.1 Historical Background Historical resources were available from 1938 until the present. The Site was undeveloped from at least 1938 until at least 1943, when what appears to be farm-related structure and possibly a residence were present until at least 1983. The basis of the current industrial structure was reportedly constructed in 1963. 3.1.1 City Directories Historical city directories were made available from EDR. City directories have tenant listings by address. Our review of the provided city directories, as documented in Appendix C, combined with our other investigatory work, did not reveal any information of environmental concern at the Site or surrounding properties. 3.1.2 Aerial Photographs Aerial photographs, as found in Appendix D, dated 1938, 1949, 1959, 1965, 1971, 1981, 1983, 1993, 2005, 2006, 2008, 2009, 2010 and 2012 were obtained for the Site. Review of the aerial photographs indicated the following: Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 14 3.1.2 Aerial Photograph Summary Year Site Adjoining Properties 1938, 1949 Lightly developed Farm land. Northern half has an apparent residence and outbuildings surrounded by farm land. Southern half appears partially wooded and undeveloped. Mostly agricultural and sparsely populated. Railroad tracks apparent along the western property boundary. 1959 Northern residence appears to be gone but some outbuildings remain. Both the northern and southern halves are partially cultivated but wooded along the drainage features. Increased agricultural activity and slightly more populous. Apparent future industrial site under construction immediately west of the Property’s northwest corner. Dirt racetrack apparent southwest of the site, across the railroad tracks. 1965 through 2009 Site appears fully developed on both northern and southern halves. Present day groundwater remediation building present south of the northern building from 1993 and onward. Decreasing agricultural usage and increasing commercial and residential development with the passage of time. Residential development underway to the adjacent east in 1965 and appears almost fully developed by 1981. South of the site undeveloped in 1965 with increasing development until 2005, when the area appears fully developed. Increasing commercial and industrial to the west of the site, across the railroad tracks. Industrial site identified in the 1959 aerial increases in size through 1993 but appears to be gone in 2005 and replaced by mixed use commercial property. Adjacent to the north appears very lightly developed in the 1965 aerial with increasing commercial development through the 1983 aerial when the area appears similar to present day. 2010, 2012 Northern half of Site appears developed as previous years but former building on the southern half is gone and what appears to be a cleared building pad in its place. Surrounding adjoining properties appear as they do today. The aerial photographs indicate the Site has been developed with apparently farm-related residences since at least 1938 and was cleared and the initial footprint of the present-day structure built after 1959 and before 1965. According to the Wake County Tax Office records, the site was developed with its present construction beginning in 1963. Our review of the provided aerial photographs, combined with our other investigatory work, did not reveal any information of environmental concern at the Site (other than the known presence of the on-site groundwater remediation system) or surrounding properties. Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 15 3.1.3 Sanborn Fire Insurance Maps As documented in Appendix E, no Sanborn Map coverage is available for the Site. 3.1.4 Topographic Maps The United States Geological Society (USGS) topographic quadrangle maps for the years 1943, 1951, 1968, 1980, 1981, 1987, 1993 and 2002 (Appendix F) were reviewed by PES personnel with the following findings: • The 1943 and 1951 maps show the Site as developed with what appears to be a farm-related structure or possibly a residence present in the south central portion of the Site; • The 1968, 1973, 1980, 1981, 1987, 1993, and 2002 maps show the Site developed with its two main structures on the northern and southern portions with smaller buildings showing up and disappearing over time. The most recent topographic map shows the Site occupied by only the two larger structures; and • As with the aerial photographs, the topographic maps show decreasing agricultural usage and increasing commercial and residential development with the passage of time. Residential development appears underway to the adjacent east in the 1968 map with the presence of roads. South and west of the site are also beginning to show development beginning with the 1968 map with increasing development until 2002, when the areas appears fully developed. Increasing commercial development north of the Site, across New Hope Church Road begins to appear in the 1973 map and increase over time until the 2002 map. Our review of the provided topographic maps, combined with our other investigatory work, did not reveal any information of environmental concern, beyond that which is currently known, at the Site or surrounding properties. 3.1.5 Review of Prior Environmental Reports or Investigations PES reviewed more than twenty electronic files on the NCDENR’s Inactive Hazardous Sites Branch Program (IHSB) of the North Carolina Superfund Section on-line file review website (http://portal.ncdenr.org/web/wm/sf-file-records). Due to the total volume of documents available (several thousand pages), all of them have not been included in this report but they can be reviewed at the above website. A number of the more relevant reports, beginning with the earliest report to the State’s overseeing regulatory agency of the release at the site in 1987 and ending with the most recent groundwater sampling report submitted in January of 2015, are in Appendix G. Other supporting documentation, Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 16 including the User Questionnaire and the ESI Form used in the preparation of this ESA can be found in Appendix H. Our review of the provided prior environmental reports, combined with our other investigatory work, revealed the following information of known environmental concerns at the Site. Information related to the following can be found in Appendix G. • A November 12, 1987 Pollution Incident Reporting Form (PIRF) for Incident No. 3548 indicated that “an injection well (concrete sump) tied to floor drains in virgin solvent storage shed was discovered during an environmental audit; preliminary soil sample analysis indicates high concentrations of chlorinated hydrocarbons: Corning Glassware reported findings to Solid and Hazardous Waste.” • A November 20, 1987 correspondence from Corning Glass to the North Carolina Department of Natural Resources and Community Development (NCDNRCD) states that the injection well was discovered during AVX’s pre-acquisition audit on October 19, 1987 and that AVX purchased the site on November 11, 1987. The letter also stated that facility personnel were unaware of any “catastrophic releases” of solvents into the dry well and that apparently small releases during Corning’s 22-year operation of the facility must have caused the contamination. The letter states further that there is no known usage of groundwater for human consumption within at least a quarter mile of the site. (This may resolve the issue related to the small building on the east side of the building, as stated previously.) Lastly, Corning states that they “assume responsibility for the remediation of the well as required by NCDNR&CD regulations.” • A November 25, 1987 correspondence from the NCDNRCD (now the NCDENR) to Mr. Blake Manuel of Corning Glass Works indicates that Mr. Jay Zimmerman of the NCDNRCD understands that “Corning Glass Works will accept responsibility for the injection well and will send our office a letter indicating this responsibility. It should be noted that injection wells such as this are not permitted in North Carolina.” The letter further requests that Corning Glass Works initiate steps to mitigate and assess the incident. • On March 2, 1989, Law Environmental, Inc. submitted to the NCDENR a “Report for Hydrogeological Characterization and Groundwater Analysis” describing their January 1989 initial, limited groundwater assessment activities. Based upon their findings of “man-made solvents in the two downgradient wells,” they recommended additional delineation of the solvent constituents. They found trichloroethene, tetrachloroethane, and toluene in their initial groundwater samples, among other solvents. In addition, their report indicated a shallow groundwater flow direction towards the east. Also of interest, the sample collected from the hydraulically Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 17 upgradient monitoring well, MW-1, exhibited a detectable concentration of trichloroethene. Well MW-1 appears to be approximately 100 feet upgradient from the release source, the previously noted dry well. • On July 17, 1991, a Notice of Violation (NOV) was issued to Corning Glass by the NCDENR for contravening the State’s groundwater quality standards by improperly discharging contaminants into the subsurface via an illegal “dry well.” The correspondence requested the preparation and submittal of a Corrective Action Plan (CAP) as well as the recommendation that Corning consider applying for an NPDES discharge permit in the event that discharging extracted and treated groundwater would be necessary. • A September 25, 1991 Remedial Action Plan (RAP) was submitted by Law Environmental outlining specifications for a pump and treat groundwater remediation system with treated effluent discharging under permit into the City of Raleigh POTW. • Multiple correspondence and reports between 1995 and 2013 were reviewed on- line. • A March 10, 2014 correspondence from the NCDENR Inactive Hazardous Sites Branch stated that the site could be cleaned up through the Registered Environmental Consultant (REC) program without direct Branch Staff oversight. • A February 10, 2014 correspondence from the NCDENR Inactive Hazardous Sites Branch to the AVX Corporation stated that the site had been included on the October 2014 IHSB Priority List, where sites are ranked in decreasing order of danger to public health and the environment. The site has a score of 41.47. (For comparison, the State’s highest scored site has a score of 63.73.) • On January 7, 2015, Amec Environment and Infrastructure, Inc. submitted to Corning a Groundwater Monitoring Report, which is the most recent groundwater data collected at the site and reported to the state. A review of the report indicates the following items of interest: o Shallow and “deep” groundwater at the site are migrating almost due east, towards Atlantic Avenue and Ingram Drive. o The mostly highly impacted shallow and deep monitoring wells are located immediately downgradient of the release area. The shallow TCE dissolved contaminant plume appears to be contained on the site, within the monitoring system, while the “deep” TCE plume appears to have migrated Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 18 very close to, and potentially under, Atlantic Avenue. The same applies to the “total chlorinated organic compounds” detected in the groundwater at the site. A detectable concentration (1.6 ug/L) of TCE was detected in deep well MW-13B during the May 2014 sampling event. No other tested analytes have been discovered in either of the two off-site wells, which are located about 150 feet east of Atlantic Avenue. The May 2014 sampling event indicates that impacted deep groundwater has now migrated off of the site and into the adjacent neighborhood. o It doesn’t appear that the degree and extent of the contaminant plume has been assessed in an upgradient direction (northwest of the monitoring well system) or towards the east and west of the release area 3.2 Historically Significant or Environmental Findings A reported release of chlorinated solvents into an on-site injection well (concrete sump) tied to floor drains in virgin solvent storage shed was discovered during an environmental audit in 1987. Assessment and remediation of the resulting soil and groundwater contamination have been on-going since that time period. 4.0 Federal, State, Local & Tribal Database Listings PES contracted EDR, Inc. to conduct a computerized regulatory database search in accordance with ASTM E 1527-13 standards. The purpose of the search is to identify certain properties and facilities in the vicinity of the Site (including the Site, as applicable) which are regulated by the United States Environmental Protection Agency (EPA) and various state and local environmental regulatory agencies. Detailed information pertaining to each database researched is presented in the EDR Radius Report, dated June 3, 2015, a copy of which is included in Appendix I. 4.1 On-Site Regulatory Issues The Site (previously Corning Glass and now the AVX Corporation) was identified on the following regulatory databases in the EDR report: • State and tribal-equivalent NPL • ERNS, the Emergency Response Notification System • NC Leaking Underground Storage Tank Incident 3548 (the injection well) • EPA FINDS – Facility Index System Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 19 • CERCLIS – NFRAP - No Further Remedial Action Planned • RCRA-CESQG – Conditionally Exempt Small Quantity Generator • FTTS – FIFRA and TSCA Tracking System • NC IMD – Incident Management Database • NC HWS – NC Hazardous Waste Section As a RCRA-CESQG handler, AVX was permitted to generate 100 kg or less of hazardous waste per calendar month, and accumulate 1000 kg or less of hazardous waste at any time; or generate 1 kg or less of acutely hazardous waste per calendar month, and accumulate at any time: 1 kg or less of acutely hazardous was; or 100 kg or less of any residue or contaminated soil, waste or other debris resulting from the cleanup of a spill, into or on any land or water of acutely hazardous waste; or generate 100 kg or less of any residue of contaminated soil, waste or other debris resulting from the cleanup of a spill, into or on any land or water of acutely hazardous waste during any calendar month, and accumulate at any time: 1 kg or less of acutely hazardous waste; or 100 kg or less or any residue of contaminated soil, waste or other debris resulting from the cleanup of a spill, into or on any land or water of acutely hazardous waste. Specifically, AVX was permitted to handle the following waste codes: • D001 wastes, (ignitable); • D002 wastes, (corrosive); • D005 wastes, (barium) • D008 wastes, (lead); • D011 wastes, (silver); • F002 wastes; • F003 wastes; • F005 wastes; • F006 wastes; • F007 wastes, (spent cyanide solutions from electroplating operations); • F039 wastes; • U002 wastes, (acetone); • U113 wastes, (ethyl esters) • U220 wastes, (benzene); • U239 wastes, (xylene); These hazardous waste listings are consistent to operations such as AVX, a manufacturer of electronic components. Passive components manufactured by AVX have historically included electrical components for automotive braking, cell phones, copiers, hearing aids, and locomotives. The wastes are indicative of the capacitor manufacturing operation conducted by both Corning and AVX which included electroplating operations. Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 20 4.2 Off-Site Regulatory Issues The EDR Radius Report identified the following potential off-site concerns associated with the adjacent and/or surrounding properties. The sites below are summarized in accordance with ASTM Approximate Minimum Search Distances. If a site is judged to not be of environmental concern to the subject Property due to some combination of its relative elevation, distance from the site, the environmental professional’s knowledge of the degree and extent, if any, of its contaminant plume, or some other reasonable factor, than it is not included in the summary below. • 3711 Tar Heel Drive - listed as a low priority (50E) leaking UST site from 1992 with both soil and groundwater contamination. Regulatory comments indicate that a CSA and CAP have been submitted and that the tank area needs to be further assessed. Given the site’s higher elevation and relative closeness to the Property (about 360 feet), this site would be considered a nearby REC • 3816, 3900 Tar Heel Drive and 1815 and 1818 Saint Albans Drive, are identified by EDR as Historical Auto Stations, located adjacent or very nearby and topographically upgradient of the Site. This is a listing of potential gasoline station sites that might, in the opinion of EDR, include service station establishments. This database falls within a category of information EDR classifies as High Risk Historical Records of past sites that typically create environmental concerns but may not show up in current government records searches. No releases are known to have been reported from these sites to the State regulatory agencies. • 1904 New Hope Church Road, Star Flite #52, a soil and groundwater contamination Leaking UST site from 1991 (Incident number 6896), located adjacent to the Property’s northwest corner, across the Seaboard Railroad tracks. The EDR report indicates that the site is considered an intermediate risk. Due to the relative topography of the incident site relative to the Facility, it’s unlikely that contamination would migrate from the incident site toward the subject Site. However, if this is a concern then it would need to be addressed by conducting soil and groundwater investigatory work in the Site’s northwest corner. With the exceptions of the 3711 Tar Heel Drive and Star Flite #52 sites, there is no regulatory evidence that any of the adjacent or surrounding properties have had any significant releases nor that they have adversely affected the Subject Site. Therefore, we do not consider these sites RECs. The EDR report identified additional off-site properties within one mile of the subject site; however, these additional sites are not anticipated to present an environmental threat to the subject site based on such factors as distance from the subject site, current regulatory status, and estimated groundwater flow direction. Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 21 5.0 Local Agency Records According to the City of Raleigh Fire Department, no responses by the Department, other than annual inspections, have been recorded at the Site. 6.0 Site Observations Site Reconnaissance Field Personnel Thomas A Proctor Reconnaissance Date June 7, 2015 Weather Conditions Clear, sunny, and warm Site Contact/Title Julian, security guard 6.1 On-site Reconnaissance The weather was clear and sunny with temperatures in the mid-80s at the time of the Site reconnaissance. Municipal water and sewer are provided to the Project area by the City of Raleigh public utilities. As shown in the photographs of the Site in Appendix B, the north side of the Site is developed with one large manufacturing building and several smaller support buildings and a large parking area full of UPS tractor trailers and the south side is mostly wooded, cleared, and no longer developed. The site is surrounded by a mix of commercial, light industrial and residential properties. As documented in the site photographs, the interior of the Facility has large quantities of manufacturing equipment, debris, possible residual chemical storage and waste, and process materials remaining since AVX left the Property. 6.1.1 Site Operations, Processes, and Equipment 6.1.1 Site Operations, Processes, and Equipment Item or Feature Observed REC Emergency generators No Air compressors No Hydraulic lifts Yes No Dry cleaning No Photo processing No Laboratory hoods and/or incinerators Yes No Waste treatment systems and/or water treatment systems Yes No Heating and/or cooling systems Yes No Other processes or equipment Yes No Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 22 6.1.2 Aboveground Chemical or Waste Storage 6.1.2 Aboveground Chemical or Waste Storage Item or Feature Observed REC Aboveground storage tanks Yes Unknown Drums, barrels and/or containers > 5 gallons Yes Unknown MSDS No Parts Washer No Other No 6.1.3 Underground Chemical or Waste Storage, Drainage, or Collection Systems 6.1.3 Underground Chemical or Waste Storage, Drainage or Collection Systems Item or Feature Observed REC Underground storage tanks or ancillary UST equipment No Sumps, cisterns, catch basins and/or dry wells Yes Unknown Grease traps No Septic tanks and/or leach fields No Oil/water separators No Pipeline markers No Interior floor drains Yes Unknown Other No Municipal water and sewer services are available to the vicinity of the Project Site. No underground chemical or waste storage, drainage or collection systems were observed on the Site. The above mentioned interior floor drains reportedly are piped to and ultimately discharge into the municipal sewer services. 6.1.4 Electrical Transformers / PCBs 6.1.4 Electrical Transformers/ PCBs Item or Feature Observed REC Pad or pole mounted transformers and/or capacitors Yes No Other equipment No Older transformers and other electrical equipment could contain polychlorinated biphenyls (PCBs) at a level that subjects them to regulation by the U.S. EPA. PCBs in electrical equipment are controlled by United States Environmental Protection Agency regulations 40 CFR, Part 761. One pad mounted transformer was observed adjacent to the on-site remediation building located near the known contaminant source area. The transformer was labeled as having been recently inspected by Progress Energy (either 2013 or 2014), indicating it is “PCB-free” and no staining was observed in the vicinity of the transformer. Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 23 6.1.5 Releases or Potential Releases 6.1.5 Releases or Potential Releases Item or Feature Observed REC Stressed vegetation No Stained soil No Stained pavement or similar surface No Leachate and/or waste seeps No Trash, debris and/or other waste materials Yes No Dumping or disposal areas No Construction/demolition debris and/or dumped fill dirt Yes Yes Surface water discoloration, odor, sheen, and/or free floating product No Strong, pungent or noxious odors No Exterior pipe discharges and/or other effluent discharges No Other No No evidence of releases or potential releases, with the exception of the known, historic solvent release behind the main building and the unknown dark liquid identified on the basement floor, Photographs 37 through 40 in Appendix B) was observed at the Site. 6.1.6 Other Notable Site Features 6.1.6 Other Notable Site Features Item or Feature Observed REC Surface water bodies No Quarries or pits No Wells Yes Yes Stormwater No Other site features No No water supply wells, stormwater features, or other notable site features were identified at the Site. It appears that the small “house” located east of the Facility and west of Atlantic Avenue does not contain a water-supply well for the site. 6.2 Non-ASTM Scope Concerns No Non-ASTM Scope concerns were assessed with the exception of the following items: 6.2.1 Radon According to the attached EDR report (Appendix H), the Project is located in an area designated as Zone 2, characterized by indoor average radon levels greater than or equal to 2 and less than or equal to 4 pCi/L. The EPA suggests that unless radon levels exceed 4 pCi/L no further action should be taken. In order to confirm the actual radon levels at the Project, a formal radon survey would be required. Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 24 6.2.2 Wetlands / Erosion and Soil Control Concerns According to the map in the attached EDR report (Appendix H), there are designated federal wetlands about 2,000 feet east of the Site. 6.2.3 All Other Concerns The Site is provided municipal water service for potable water purposes and lead is not a suspected concern from the municipal water supply. 7.0 Interviews PES interviewed Mr. Anderson Marlowe of Marlowe Land and Farm Inc., representing the Site’s ownership. Mr. Marlowe also completed the User Questionnaire found in Appendix H. According to Mr. Marlowe, he is aware of the site’s environmentally-related issues in regards to the known groundwater contamination and remediation, the potential for vapor intrusion issues associated with the known contamination, and the presence of ACM within the building’s interior. No representatives of Corning Glass or AVX were made available for interview purposes. 8.0 Off-site Reconnaissance In some situations, past and current uses of surrounding properties may pose a potential environmental concern to a subject site. PES personnel visually inspected, to the extent practical, surrounding properties for current site uses and evidence of past site uses. PES personnel also utilized readily available historical sources such as aerial photographs, topographic maps and city directories. The Project is fronted to the north by New Hope Church Road, across which are two convenience stores, a commercial business park, a home and garden equipment shop, and a telephone switching station. The Project is fronted to the east, across Atlantic Avenue, by a residential neighborhood called Brentwood. The Project is fronted to the south by several office buildings occupied by the Carolina Ballet and Newcomb and Company. The Project is fronted to the west, across the Seaboard railroad tracks, by several single and multi-tenant commercial buildings consisting of light industrial and commercial businesses. With the exception of the LUST at 3711 Tar Heel Drive and the Star Flite #52 site Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 25 discussed in Section 4.2 of this report, there is no regulatory evidence that any of the adjacent or surrounding properties have had any significant releases nor that they have adversely affected the Subject Site. 9.0 Product Information 9.1 Purpose The purpose of this Phase I Environmental Site Assessment (ESA) is to evaluate the property with respect to the range of contaminants within the scope of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) and petroleum products. 9.2 Scope of Services This ESA was conducted in substantial compliance with ASTM Designation: E 1527-13 - Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process. The intention of the ASTM E 1527-13 practice is “to permit a user to satisfy one of the requirements to qualify for the innocent landowner defense to CERCLA liability: that is, the practices that constitute ‘all appropriate inquiry into the previous ownership and uses of the property consistent with good commercial or customary practice’ as defined in 42 USC 9601(35)(B).” Specifically, this Phase I ESA included the following scope of services: (A) Site and Vicinity Reconnaissance - PES conducted a site and vicinity reconnaissance, the objective of which was to obtain information indicating the likelihood of the existence of “recognized environmental conditions” in connection with the subject property, as defined in ASTM E-1527-13. PES’s site and vicinity reconnaissance included an evaluation of the site and nearby properties with respect to existing conditions and with respect to obvious indications and evidence of past conditions. (B) Records Review - PES conducted a records review, the objective of which was to obtain and review records (of both current and historical significance) in order to help identify “recognized environmental conditions” in connection with the subject property. Those specific records reviewed, including those records which were sought and were not readily available or reasonably ascertainable, are identified in the report. (C) Interviews - PES conducted interviews with persons associated with the subject property and with appropriate local government officials in order to identify Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 26 “recognized environmental conditions” in connection with the subject property. The specific parties interviewed and the nature and scope of the interviews are described in the report. 9.3 Deviations This Phase I ESA substantially complies with the scope of services and ASTM E 1527- 13, as amended, except for exceptions and/or limiting conditions as discussed in Section 9.4. 9.4 Limitations This investigation is site-specific in that it relates to assessment of environmental conditions on the specific subject parcel of commercial real estate. This assessment does not address many additional issues raised in transactions such as purchases of business entities, or interests therein, or of their assets, that may well involve environmental liabilities pertaining to properties previously owned or operated or other off-site environmental liabilities. As stipulated by the ASTM E-1527-13 Process, this ESA does not formally address certain non-scope issues including, but not limited to the following: • Asbestos-containing Materials • Mold Growth in Structures • Radon • Lead-based Paint • Wetlands • Cultural and Historic Resources • Industrial Hygiene • Health and Safety • Ecological Resources • Endangered Species • Indoor Air Quality • High Voltage Power Lines • Underground Mine Shafts In accordance with the Client's standard scope of services, PES has performed cursory visual and/or regulatory inspections for the suspected presence of the following potential concerns, the findings of which are addressed in this report. • Radon • Wetlands Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 27 • Lead in Drinking Water 9.5 Data Gaps The following data gap was identified in the research and preparation for the Project: • We were unable to interview any key site managers as the facility has been out of operation for approximately two years and none were made available to us. 9.6 Reliance Marlowe Farm and Land Inc. (the “Client”; and the “Relying Party”) may rely on the contents of the ESA subject to the limitations placed on the scope, nature and type of PES’s services as stated in the ESA and subject to those Terms and Conditions as stated in PES’s contract with the Client. The Relying Party is the only party to whom PES grants the right to rely upon the ESA. No other party may rely on the ESA unless the express written consent of PES is first obtained. 10.0 User Provided Information 10.1 Specialized Knowledge PES was not provided with any specialized knowledge regarding the Site by the Client or the Site contact. 10.2 Valuation Reduction for Environmental Issues PES was not provided with any knowledge of valuation reduction for environmental issues associated with the Site by the Client or the Site contact. 10.3 Commonly Known or Reasonably Ascertainable Information PES was not provided with any commonly known or reasonably ascertainable information regarding the Site by the Client or the Site contact with the exception of the information provided in the User Questionnaire in Appendix H. 10.4 Owner, Property Manager, and Occupant Information The current owner of record for the Site is the AVX Corporation according to the City of Phase I Environmental Site Assessment Former Corning / AVX Facility 3900 Electronics Drive Raleigh, Wake County, North Carolina Page 28 Raleigh tax department. 10.5 Reason for Performing Phase I PES understands that the findings of this Phase I ESA will be used by the Client to evaluate the Site with respect to a pending purchase transaction in connection with the Site. The purpose of a Phase I ESA is to identify existing or potential Recognized Environmental Conditions (as defined by ASTM Standard E-1527-13) in connection with the Site. This ESA was also performed to permit a user to satisfy one of the requirements to qualify for the innocent landowner, contiguous property owner, or bona fide prospective purchaser limitations within the scope of Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) (42 U.S.C. §9601) liability. 10.6 Title Records A copy of the title records was not provided to PES. No evidence of environmental liens was identified by PES. Title and deed information for the Site obtained from the Wake County Tax Office is summarized in the following table. Grantee Grantor Date Book / Page AVX Corporation Corning Glass Works 11/10/87 4146 / 501