Feasibility study · verdict: A specialist project; office uses fit better
Could this building become a surgery center? What it would take, in numbers
Executive answer
Why the question is legitimate
Act 20 (May 2023) removed the Certificate of Need requirement for ambulatory surgical facilities, so the state can no longer veto market entry (full analysis). Licensed-ASC counts statewide have grown since. The outpatient migration of procedures is real, the county is growing (evidence), and an adjacent 231-bed hospital campus with nine ORs anchors surgical referral flow. If a candidate building existed at $77/SF, the economics would be interesting. The question is whether this is that building.
What SC licensure actually requires of the building
ASCs are licensed under SC Regulation 61-91 (Standards for Licensing Ambulatory Surgical Facilities), administered by DPH, with construction plan review before building. The physical-plant baseline includes:
- operating/procedure rooms built to healthcare construction standards (structure, finishes, clearances);
- medical gas systems (piped O₂, vacuum, medical air) with code-compliant storage and alarms;
- essential electrical systems: generator-backed emergency power to life-safety and critical branches;
- ventilation to surgical standards: pressure relationships, air-change rates, filtration (ASHRAE 170-class requirements), far beyond office HVAC;
- sterile processing with clean/soiled separation; recovery (PACU) space; segregated patient/staff/soiled flows;
- life-safety code compliance for an ambulatory-healthcare occupancy, a different occupancy classification than business/office;
- plus the post-Act-20 indigent-care obligation (2–3% of adjusted gross revenue after year two) on the operating side.
The building, against that list
| Requirement | 125 Dillon Drive today (county record + listing photos) | Gap |
|---|---|---|
| Structure for healthcare occupancy | 1985 wood-frame construction on pier foundation | occupancy reclassification of wood-frame construction is possible only within strict code limits; equipment loads, vibration, and fire-rating demands typically force structural rebuild |
| Surgical ventilation & pressure control | residential-grade central electric HVAC (county record) | full replacement with hospital-grade air handling, ductwork, and controls |
| Medical gas | none | complete new piped-gas plant |
| Emergency power | none evident | generator, transfer switches, essential-system wiring |
| Sterile processing / PACU / flow separation | open office floor plan, core at studs | ground-up clinical layout; the current demolition is the only part that helps |
| Ceiling heights / interstitial space for services | single-story office with drop grid | unknown clearances; surgical services need substantial above-ceiling depth |
The cost reality
Credible published ranges put ASC development at roughly $2M–8M+ for a small center (site-dependent; 2-OR centers with equipment routinely exceed $4M all-in), with construction/fit-out typically 40–50% of total and equipment $750k–1M+ for two ORs. Even taking the friendliest numbers, conversion cost here would run a multiple of the $775,000 building price. The shell was built for office and clinic use, and that is where its value is; a true ASC ambition is better served by ground-up construction, where the budget goes into the facility rather than the conversion. (Cost figures are vendor/consultant-published ranges, not bids; we label them accordingly.)
What survives this analysis
- Office-based procedures that don't trigger ASC licensure (many ophthalmic, dermatologic, dental, and pain procedures done under local/minimal sedation in physician offices) remain plausible here: the building's clinical history was that class of use. Operators should verify the licensure line for their specific procedure mix with DPH and counsel.
- The owner-user practice case and behavioral-health case, uses whose facility requirements the building meets.
- For a true ASC ambition near this hospital: model ground-up construction or the conversion of purpose-built clinical space instead; the corridor analysis in the market page maps what exists.
Due diligence, for anyone who wants to test it
- Pre-design consultation with DPH on Reg 61-91 plan review for this shell (they will tell you quickly).
- Structural engineer's assessment of the wood-frame/pier system for ambulatory-healthcare occupancy.
- A healthcare architect's test-fit and ROM estimate; expect a number in the range above.
- Specialty-specific licensure determination for office-based procedure alternatives.
What would change this reading
- A structural assessment revealing steel or masonry primary structure behind the county's "wood frame" classification would reopen the question (the record says wood; records can be wrong, and that cuts both ways).
- Regulatory change creating a lighter "office-based surgery" licensure tier in SC.
- An operator whose procedure mix stays within office-based practice; this page's conversion analysis doesn't apply to them, and the building fits them today (see above).
- SC DPH — Standards for Licensing Ambulatory Surgical Facilities (Regulation 61-91) [T1 regulator]
- Act 20 of 2023 (CON repeal; indigent-care obligations) [T1 · 2023]
- Spartanburg County CAMA record (wood-frame construction, pier foundation, HVAC, condition) [T1 · 2026 extract]
- ASC development cost ranges (industry consultant/vendor publications — labeled as such) [T3/T4 · 2024–2026]
- Spartanburg Regional — Mary Black Campus (9 ORs, surgical services) [T2]
Last reviewed 2026-08-23. Feasibility research, not architectural, legal, or investment advice.