23068_Sir Walter Gun Club_DM_20221114

DECISION MEMORANDUM
DATE: November 14, 2022
FROM: Brad Atkinson/Sharon Eckard
TO: Brownfields Assessment File
RE: Sir Walter Gun Club
520 Hinton Pond Road
0 Hinton Oaks Boulevard
810 Silverpoint Drive
Knightdale, Wake County
Brownfields Project No. 23068-19-092
Based on the following information, it has been determined that the above referenced
site, whose intended use is for no uses other than industrial (including flex buildings),
office, retail, warehousing, hotel, associated parking, and subject to DEQ's prior written
approval, other commercial uses, can be made suitable for such uses.
Introduction:
The Prospective Developer (PD) is Merritt - MW 1, LLC, a manager -managed limited
liability corporation, headquartered at 2066 Lord Baltimore Dr., Baltimore, Maryland
21244. Merritt Properties, LLC is the managing member of Merritt - MW 1, LLC.
Merritt Properties, LLC's Project Manager is Nathan Robb, of the same address. The PD
purchased the brownfields property on May 12, 2021.
The Brownfields Property Application (BPA) was originally for four parcels (Wake
County PINS 1744479093, 1744476090, 1744566995, and 1744479612 totaling
approximately 46.212 acres; however, the PD did not purchase all of this property, and
Wake County has subdivided, recombined the parcels and reassigned numbers for the
remainder of that property, so that the Brownfields Property is now comprised of four
parcels (PINS 1744476090, 1744467994, 1744573498 and 1744565659) totaling
approximately 36.686 acres located at 810 Silverpoint Drive, 0 Hinton Oaks Blvd and
520 Hinton Pond Road in Knightdale, Wake County. The site is roughly bisected by a
buffered stream which flows from the southeast corner to the northwest corner of the
Brownfields Property. There are ponded and wetland areas at the Brownfields Property.
The parcels south of the stream were historically used by the Sir Walter Gun Club as a
recreational shooting range consisting of a combined pistol and rifle range and a
combined skeet and trap field. The former pistol range was located in an area that is now
south of the southern boundary of the Brownfields Property, and which underlies a
portion of the shopping center located immediately adjacent to the Brownfields Property.
Redevelopment Plans:
The PD intends to invest approximately $41.5 million to redevelop the site with five flex -
style buildings totaling approximately 271,450 square feet designed for industrial
Sir Walter Gun Club/23068-19-092/14Nov2022

(including flex buildings), office, and retail use. Redevelopment is limited to areas
outside the wetland on the topographic ridges of the Brownfields Property. Based on the
assessment and risk evaluation with the risk calculator, vapor mitigation is not required at
the site.
Site History:
The Brownfields Property was part of the historic Midway Plantation, much of which has
been subdivided into commercial lots for redevelopment. The former Sir Walter Gun
Club (Gun Club) site is located on one of the remaining undeveloped parcels. The Gun
Club leased a portion of the property from about 1958 until 1988 for use as a recreational
firing range. Range facilities historically operated by the Gun Club at the site consisted of
two adjacent rifle ranges with nominal target distances of 100 and 200 yards; a 50-yard
pistol range (which was not located on the Brownfields Property); and a combined skeet
and trap field. The rifle ranges included earthen backstops (impact berms), which were
approximately 10 feet high and appear to have been constructed from soil obtained
onsite. The skeet field was located immediately east of the 100-yard rifle range, which
was separated from it by an earthen side berm approximately 80 feet long and 7 feet high.
The pistol range, which has been removed and covered by commercial development, was
formerly located on a parcel immediately south of the Brownfields Property that was
subdivided and sold in 2005.
Historic use as a shooting range resulted in contamination of the soil with lead and
polycyclic aromatic hydrocarbons (PAHs). On November 9, 1988, Mr. Stanley Atwood, a
toxicologist with the North Carolina Division of Health Services, Waste Management
Superfund Branch, collected soil samples from the pistol range, rifle ranges, and the skeet
field for laboratory analysis of metals (arsenic, barium, cadmium, chromium, copper,
lead, mercury, and selenium) and semi -volatile organic compounds (SVOCs). The results
were reported in a January 31, 1989 internal memorandum from Mr. Atwood to the
Director of Budget and Analysis. In summary, the Atwood memorandum stated there
were high levels of lead in each of the three berms and low levels of several PAHs in the
berms at the pistol range and the 100-yard rifle range.
IHSB Site ID NONCD0000019: The Gun Club has been listed on the DEQ Inactive
Hazardous Waste Sites Priority List since at least 1991 (Site ID #NONCD0000019). In
an October 5, 2000 memorandum from Joe Grant, NCDENR Site Evaluation and
Removal Branch, to Charlotte Jesneck, Head, Inactive Hazardous Sites Branch, NC
Division of Waste Management, the NCDENR determined that the Gun Club site did not
warrant further action by the Site Evaluation and Removal Branch.
During August and September of 1991, limited excavation, removal, and screening of
soils from the impact berms was performed by Paragon Environmental Group, Inc.
("Paragon"), on behalf of the Gun Club. In a March 10, 1992 letter report to the Gun
Club, Paragon reported removing bullets and soil from the front (impact) face of each of
the three impact berms (100-yard and 200-yard rifle ranges and the 50-yard pistol range),
which was processed through a mobile, 2-deck vibratory screening plant. The bullets and
soil were reportedly excavated from each impact berm face to a depth of approximately
2
Sir Walter Gun Club/23068-19-092/14Nov2022

12 inches, from the toe of the berm slope to a height of 6 feet above the range floor.
Above the 6-foot level, the soil was excavated to a depth of approximately 8 inches. No
field observations or laboratory analytical results were provided in the report to explain
the choice of excavation depths. The screened soil (i.e., material passing the mesh
screen) was reportedly transported to the Sir Walter Gun Club facility in Creedmoor,
North Carolina for beneficial reuse as impact -berm material. Reportedly, nineteen 55-
gallon drums containing mixed bullets and gravel recovered from the soil were shipped to
Master Metals, Inc. (USEPA facility ID Bo. OHD097613871) in Cleveland, Ohio for
recycling. A total of 11,992.8 pounds of lead was reportedly recovered and smelted.
Additional environmental assessment activities were conducted at the former Gun Club
in 2010 (S&ME, Inc.), 2011(S&ME, Inc.), 2013 (AMEC Environment & Infrastructure,
Inc.), and 2020 (S&ME, Inc.). Assessment did not identify any impacts to on -site surface
water, sediment, or groundwater. Soil was identified at the site with lead concentrations
greater than NCDEQ's Industrial Preliminary Soil Remediation Goal (PSRG) for lead of
800 milligrams per kilogram (mg/kg). Soil in the shooting range impact berms was
analyzed for Toxicity Characteristic Leaching Procedure (TCLP) for lead and was found
to exceed the federal regulatory threshold of five milligrams per liter (mg/L) for disposal
of solid waste as non -hazardous (40 CFR § 261.24).
During the months of July 2021 and August 2021, remedial action was completed in
accordance with the approved Environmental Management Plan (January 15, 2021) and
the approved Remedial Action Plan (January 15, 2021). These remedial activities were
documented in the Remedial Action Completion Report (S&ME, Inc., December 21,
2021).
As a result of the remedial activities, lead -impacted soils with total lead above 400 mg/kg
and leachable lead at concentrations greater than 5 milligrams per liter (mg/L) as
analyzed by Toxic Characteristic Leaching Potential (TCLP) methods, were blended with
a metal stabilization product to regulate pH and form insoluble compounds so lead would
not leach from the soil into the environment. The areas of contaminated soil containing
lead and PAHs greater than their PSRGs were excavated, blended with a metal
stabilization compound called Enviroblend by CCI, and buried under a geotextile fabric
at a pre -approved location on the Brownfields Property named the "Soil Management
Area", at least five feet below the proposed final grade, in such a way as to minimize
contact by soil grading activities, construction activities, or future users of the property.
Soil treatment in this way with a metal stabilization product generally rendered the lead
non -leachable, but did not reduce the total lead concentrations in soil.
The Soil Management Area was covered with a geotextile, at least five feet of engineered
demonstrably clean backfill from the site compacted per engineering specifications, and
covered with asphalt pavement to be used as a parking lot. The Soil Management Area is
identified on the Brownfields Survey Plat. Generally all the soil represented by most of
the data on the Brownfields Agreement's Exhibit 2 was managed by this method and
placed in the Soil Management Area. See draft map and cross section appended to the
end of this Decision Memo.
Sir Walter Gun Club/23068-19-092/14Nov2022

Potential receptors:
Potential receptors are non-residential workers, construction workers, hotel guests, and
trespassers.
Contaminated Media:
DEQ has evaluated data collected from the following media at the subject property: soil;
groundwater, surface water, and sediment from the on -site stream. DEQ relies on the
following data to base its conclusions regarding the subject property and its suitability for
its intended reuse. Please see the Brownfield Agreement's Exhibit 2 for specific sample
locations, dates, and contaminants of concern (COCs).
Risk Calculations
Risk calculations were performed using the January 2022 DEQ Risk Calculator:
hgps:Hdeg.nc. goy/permits-rules/risk-based-remediation/risk-evaluation-resources.
For the purposes of looking at the site spatially, the site was divided into two source
areas: the Soil Management Area (soil only) and the remainder of the Brownfields
Property (post-remediation), that included post-remediation soil, groundwater, surface
water, and sediment.
Risk Calculator output for Soil Management Area. No data other than soil data is
included.
Risk for Individual Pathways I I i
Version Date: January 2022
Basis: November 2021 EPA RSL Table
Site ID: 23068-19-092
Exposure Unit ID: Soil Mana went Area
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
Carcinogenic
Risk
Hazardlodex
Risk exceeded?
Resident
Soil
2.4E-04
1.2E+00
YES
Groundwater Use*
NC
NC
NC
Non -Residential Worker
Soil
1.4E-05
9.4E-02
NO
Groundwater Use*
NC
NC
NC
Construction Worker
Soil
1.9E-06
2.4E+00
YES
Recreator/Trespasser
Soil
1.3E-04
6.7E-01
YES
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
NC
NC
NC
Non -Residential Worker
Groundwater to Indoor Air
NC
NC
NC
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
NC
NC
NC
The risk calculator output for the soil in the Soil Management Area, was based on the
highest concentrations of lead, the primary risk driver with a maximum concentration of
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Sir Walter Gun Club/23068-19-092/14Nov2022

11,600 mg/kg in these soils, and PAHs from soil across the site that was placed in the
Soil Management Area. Based on the risk calculator output, for the soil in the Soil
Management Area, residential, construction worker, and recreator/trespasser exposure
scenarios exceed both the acceptable regulatory carcinogenic risk range maximum of lE-
4 and the threshold non -cancer hazard index of 1.0 for direct soil exposure. However, it
should be noted that lead concentrations are not incorporated into the risk calculations in
the risk calculator and is simply listed in the risk calculator output as greater than
screening level (>SL), which for non-residential uses is 800 mg/kg.
However, due to the soil management activities including blending with a stabilization
agent, a cover, and capping with asphalt pavement, this exposure pathway is rendered
incomplete. Consequently, there is no anticipated residential, construction worker, or
recreator/trespasser exposure. That and adherence to the institutional controls provided
by the Brownfields Agreement should satisfactorily manage environmental risk from lead
and PAHs from these site soils.
Risk for Individual Pathways IsTrumsi
Version Date: January 2022
Basis: November 2021 EPA RSL Table
Site ID: 23068-19-092
Ex sureUnit ID: Entire site -excluding Soil Management Area
DIRECT CONTACT SOIL AND WATER CALCULATORS
Receptor
Pathway
CarcinogenicHazardlndex
Risk
Risk exceeded?
Resident
Soil
2.2E-06
7.5E-03
NO
Groundwater Use*
0.0E+00
5.8E-04
NO
Non -Residential Worker
Soil
1.2E-07
6.0E-04
NO
Groundwater Use*
0.0E+00
9.6E-05
NO
Construction Worker
Soil
1.5E-08
1.7E-02
NO
Recreator/Trespasser
Soil
1.2E-06
4.2E-03
NO
Surface Water*
0.0E+00
2.7E-05
NO
VAPOR INTRUSION CALCULATORS
Receptor
Pathway
Carcinogenic
Risk
Hazardhidex
Risk exceeded?
Resident
Groundwater to Indoor Air
0.0E+00
0.0E+00
NO
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
NC
NC
NC
Non -Residential Worker
Groundwater to Indoor Air
0.0E+00
0.0E+00
NO
Soil Gas to Indoor Air
NC
NC
NC
Indoor Air
NC
NC
NC
The risk calculator output for the remainder of the Brownfields Property that excludes the
Soil Management Area is based on in -situ post -excavation soil data, as well as
groundwater, surface water, and sediment data. Based on the risk calculator output for the
remainder of the Brownfields Property, the acceptable regulatory carcinogenic risk range
and the threshold noncancer hazard index of 1.0 are not exceeded for any of the risk
scenarios addressed by the risk calculator.
5
Sir Walter Gun Club/23068-19-092/14Nov2022

Groundwater
Groundwater is found between 16 and 23 feet below ground surface at the site.
Groundwater flow is to the northwest. All wells were sampled during a one-time event,
and no compounds were detected above 2L Standards; VOCs were not detected in site
groundwater even below 2L standards. There is no ongoing monitoring of groundwater
by another NCDEQ program, and there are no known off -site sources of contaminants to
groundwater. The groundwater wells onsite were abandoned prior to site redevelopment
activities.
Surface Water
Surface water within the property consists of two unnamed tributaries of Milbumie
Creek, which flow from southeast to northwest across the site. A former pond and stream
in the southwestern and western areas of the Brownfields Property no longer hold water,
presumably due to surface water improvements at the adjacent shopping center. Surface
water samples did not exceed NC 2B standards, the EPA National Recommended Water
Quality Criteria for aquatic Life & Human Health, nor North Carolina In -Stream Target
Values for Surface Waters (July 26, 2021)
Exterior Soil Gas
No exterior soil gas samples were collected because no source areas pertaining to the
presence of volatile organic compounds (VOCs) were identified at the Brownfield
Property, and VOCs were not detected in groundwater samples across the Brownfields
Property.
Sub -Slab Vapor
No sub -slab vapor samples were collected because no enclosed buildings, other than
small remnant concrete masonry block buildings that were demolished, or remnant slabs
existed on the Brownfields Property during the assessment phase.
Indoor Air
No indoor air samples were collected because no enclosed buildings, other than small
remnant concrete masonry block buildings that were demolished were present on the
Brownfields Property during the assessment phase.
Land Use Restrictions:
The Brownfields Agreement for this property will include standard land use restrictions,
including, the approved land uses; prohibition of residential, childcare, adult care, and
schools; no physical redevelopment without an EMP; redevelopment reporting,
restrictions on groundwater and surface water use, soil disturbance and fill/export of soil,
known contaminant uses, required final grade sampling; capping of Soil Management
Area; notices; access; deed; and land use restriction update provisions.
Based on the site -specific data provided to the Brownfields program, the site reuse is
suitable for the site as long as the agreed upon land use restrictions in the BFA are abided
by.
6
Sir Walter Gun Club/23068-19-092/14Nov2022

Property Management Issues:
Construction began in May 2021 under an approved EMP. Soil excavation, blending,
and placement of lead -impacted soil in the Soil Management Area occurred during July
2021 and August 2021. The first building (Building B3) of the five buildings planned
was completed in August 2022 with construction of two additional buildings expected by
the end of 2022. Two more buildings are scheduled to be constructed during 2023 which
are north of the first three.
Vapor intrusion was not a concern at this Brownfields Property based on known historic
uses and groundwater data. An occupancy letter was provided to the PD in May 2022.
7
Sir Walter Gun Club/23068-19-092/14Nov2022

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