Anacostia_II_Wastewater_Pumping_Station_Surge_Tanks_Limited_Hazardous_Material_Survey.pdf

K

Engineers Scientists Planners

Anacostia WWPS – Surge Tanks Limited Hazardous Material Survey

Prepared for:

Prepared by:

August 2024

CDM Smith 10306 Eaton Place, Suite 220

Fairfax, VA 22030

PEER Consultants, P.C.

409 12th Street SW, Suite 603 Washington, DC 20024 ii PEER Consultants, P.C. ■ Engineers ■ Scientists ■ Planners

Anacostia WWPS Surge Tanks ■ 1700 Andalusia Lane, Capitol Heights, MD 20743 August 2024 ■ PEER Consultants, P.C. ■ Project No. 7849-005

CONTENTS

List of Acronyms ........................................................................................................................... iv

Executive Summary ...................................................................................................................... v

1.0 Introduction

2.0 Asbestos Survey

2.1 Regulatory Overview

2.2 Visual Assessment

2.3 Physical Assessment

2.4 Sample Collection

2.5 Sample Analysis

2.6 Findings and Recommendations

3.0 Polychlorinated Bisphenols (PCBs) Survey

3.1 Regulatory Overview

3.2 Sample Collection and Analysis

3.3 Findings and Recommendations

4.0 Lead-Based Paint (LBP) Survey

4.1 Regulatory Overview

4.2 Sample Collection and Analysis

4.3 Findings and Recommendations

5.0 General Comments/Limitations

iii

August 2024 ■ PEER Consultants, P.C. ■ Project No. 7849-005

APPENDICES

APPENDIX A: Aerial Site Maps (Enlarged)

APPENDIX B: Asbestos and PCB Results Summary (Tables 1 and 2)

APPENDIX C: Sampling Photo Log

APPENDIX D: ACM and PCB Chain of Custody and Laboratory Results

APPENDIX E: SaLUT Lead-Based Paint (LBP) Material Assessment

APPENDIX F: Asbestos Inspector Credentials

LIST OF FIGURES

Figure 1: Aerial View of Anacostia WWPS Surge Tanks ….......………………….……………….….2

Figure 2: Ground View of Surge Tanks………………………………………………………………...2

Figure 3: Sampling Location ≥ 0.7 mg/cm²: white/beige painted surfaces of surge tanks…..…

Figure 4: Sampling Location ≥ 0.7 mg/cm²: white/beige gooseneck fittings…….…………….……11 iv

LIST OF ACRONYMS

ACBM Asbestos Containing Building Material

ACM Asbestos Containing Material

AHERA Asbestos Hazard Emergency Response Act

BLDG Building

CFR Code of Federal Regulations

COC Chain of Custody

COMAR Code of Maryland Regulations

EPA Environmental Protection Agency

HA Homogenous Area

LBP Lead-Based Paint

LF Linear Feet

MDE Maryland Department of the Environment

NESHAP National Emission Standard for Hazardous Air Pollutants

NVLAP National Voluntary Laboratory Accreditation Program

OSHA Occupational Safety and Health Administration

PCB Polychlorinated Biphenyls

PEER PEER Consultants, P.C.

PLM Polarized Light Microscopy

SF Square Feet

RACM Regulated Asbestos Containing Material

WWPS Wastewater Pumping Station v

Executive Summary

PEER Consultants, P.C. (PEER) conducted a limited, non-destructive Hazardous Materials survey at the Anacostia Wastewater Pumping Station (WWPS), located at 1700 Andalusia Lane, Capitol Heights, Maryland on July 23, 2024. The survey was performed by an accredited asbestos inspector and an accredited lead-based paint inspector to identify suspect hazardous materials and provide information about the type, location, condition, and approximate quantities associated with the surge tanks.

Asbestos Containing Materials (ACM) Suspect ACM was sampled according to guidelines established in Environmental Protection

Agency (EPA) Regulation 40 CFR 763 Subpart E763.86 (the Asbestos Hazard Emergency

Response Act), Occupational Health and Safety Administration (OSHA), and the Code of

Maryland Regulations (COMAR) 26.11.21 (Control of Asbestos).

Six (6) bulk samples were collected from homogenous areas of suspect ACM and analyzed in an

NVLAP accredited laboratory using polarized light microscopy (PLM). Results of the laboratory analysis indicated that asbestos was not detected as greater than 1% in any of the samples collected, as shown in Table 1 of Appendix B. Sampling images are located in Appendix C.

Polychlorinated Biphenyls (PCBs) Suspect Polychlorinated Biphenyls (PCBs) were sampled and analyzed according to guidelines established within 40 CFR 761 – Polychlorinated Biphenyls (PCBs) Manufacturing, Distribution in

Commerce, and Use Prohibitions. EPA regulations stipulate PCB bulk product waste is a concentration of ≥ 50 parts per million (ppm).

Nine (9) bulk samples were collected from areas likely to be impacted by the demolition of eight

(8) surge tanks. All materials sampled during this investigation were reported as not-detected

(Table 2 of Appendix B) and are therefore not interpreted to require removal and disposal as

PCB Bulk Product Waste (exceeding 50 mg/kg (ppm)). Therefore, the laboratory findings indicate that the building materials that were analyzed are categorized as Excluded PCB Product, which is not regulated by the EPA under the Toxic Substances Control Act (TSCA). Sampling images are located in Appendix C.

vi

Lead-Based Paint (LBP) Suspect Lead-Based Paint (LBP) surfaces were examined according to guidelines established by the Maryland Department of Environment (MDE). Maryland Department of the Environment

(MDE) defines LBP as any paint or other surface coatings that contain lead equal to or exceeding

0.7 milligram per square centimeter (mg/cm²) or 0.5% by weight (5,000 parts per million).

Forty-three (43) painted surfaces comprising the exterior of the surge tanks, concrete, piping, and railings were evaluated via X-Ray Fluorescence (XRF) during this investigation. Testing results indicated the presence of lead-based paint (LBP) in excess of Maryland Department of the

Environment (MDE) standards on multiple surfaces. XRF readings indicated that LBP was present on the white and beige painted exterior surfaces: (a) of the surge tanks, (b) the associated piping atop the tanks, and (c) the gooseneck fittings at ground level, each ranging between 0.7-1.9 mg/cm2 (Appendix E).

This report should be read in its entirety prior to proceeding with any decisions regarding this property. The executive summary as presented provides a general overview to allow the reader to view the highlights of the report.

1.0 Introduction

PEER Consultants, P.C. (PEER) conducted a limited, non-destructive Hazardous Materials survey (the “Scope”) related to the proposed demolition of eight (8) surge tanks and associated components at the Anacostia Wastewater Pumping Station (WWPS), located at 1700 Andalusia

Lane, Capitol Heights, Prince George’s County, Maryland (the “Property”). The Scope was conducted on: July 23, 2024, by accredited Asbestos Inspector Travis Waller [PEER Consultants, 409 12th Street SW, Suite 603 Washington, DC 20024; 202-478-2060] and accredited Lead-

Based Paint Inspector Elijah Sinthaby [SaLUT, 1818 New York Avenue, NE Suite 231, Washington DC 20002; 301-595-3783] in general accordance with the proposal dated May 2024.

The purpose for this work was to identify suspect hazardous materials, via sampling or assumption, and provide information about the identity, location, condition, and approximate quantities within the proposed area of repair in the Chemical Building.

Suspect ACM was sampled according to guidelines established in Environmental Protection

Agency (EPA) Regulation 40 CFR 763 Subpart E763.86 (the Asbestos Hazard Emergency

Response Act). Suspect ACM was identified visually, documented, and assigned a homogenous area during an initial site walk and material inventory. Subsequently, suspect materials were then bulk sampled for later analysis at an accredited laboratory utilizing polarized light microscopy

(PLM).

Suspect Polychlorinated Biphenyls (PCBs) were sampled and analyzed according to guidelines established within 40 CFR 761 – Polychlorinated Biphenyls (PCBs) Manufacturing, Distribution in

Commerce, and Use Prohibitions. Samples were evaluated in a laboratory using EPA method

SW846 3540C/8082A to quantify PCB concentration to determine if the materials needed to be managed as PCB Bulk Product Waste per regulations contained in 40 CFR §§ 761.3, 761.20(a), and 761.62.

Suspect Lead-Based Paint (LBP) surfaces were examined according to guidelines established by the Maryland Department of Environment (MDE). Suspected LBP surfaces were analyzed onsite using a handheld X-Ray Fluorescence analyzer calibrated to a National Institute Standards and

Technology standard.

Figures 1 and 2 show an aerial and ground view of the pumping station’s extents and surge tanks, respectively. Enlarged images of Figures 1 and 2 can be found in Appendix A.

Figure 1: Aerial View of Anacostia WWPS Surge Tanks (Access Date: MDOT Aug 2024)

Figure 2: Ground View of Surge Tanks (Image Date: Aug 2024)

2.0 Asbestos Survey

2.1 Regulatory Overview

This asbestos survey was conducted on July 23,2024, by accredited building inspector Mr. Travis

Waller (License No. 230004470, Appendix F) in general accordance with sampling and safety guidelines outlined in EPA Regulation 40 CFR 763 Subpart 763.86 and OSHA Regulation

1926.1101.

The EPA’s regulations for asbestos fiber emissions and asbestos waste disposal practices are contained in the National Emission Standard for Hazardous Air Pollutants (NESHAP) 40 CFR

Part 61 Subpart M – National Emission Standard for Asbestos. Building materials are required to be classified prior to the initiation of renovation or demolition activities and disposed of properly once any ACM is disturbed.

EPA regulations state that a material is considered ACM if it contains greater than 1% asbestos.

NESHAP further classifies ACM into one of three categories: friable ACM, Category I non-friable

ACM, and Category II non-friable ACM.

• Friable ACM is any material containing greater than 1 percent asbestos that, when dry, can be crumbled pulverized, or reduced to powder by hand pressure.

• Category I non-friable ACM refers to asbestos containing packing, gaskets, resilient floor coverings, and asphalt roofing products, each containing more than 1% asbestos.

• Category II non-friable ACM refers to remaining non-friable materials excluded from

Category I, containing more than 1% asbestos.

NESHAP classifications advise the owner or operator of the proper treatment and handling of any regulated asbestos containing material (RACM) at the property. RACM describes friable asbestos material, Category I non-friable ACM that has become friable, Category II non-friable ACM that has or will be subjected to sanding, grinding, cutting, or abrading, or Category II non-friable ACM with high probability of being crumbled, pulverized, or reduced to powder during the course of demolition or renovation operations. NESHAP requires that RACM be removed prior to the commencement of demolition or renovation projects and where applicable, classifications from the survey performed can be viewed in Table 1 of Appendix B.

NESHAP projects are those that plan to strip, remove, dislodge, cut, drill, or similarly disturb a combined amount of RACM that is at least 260 linear feet on pipes, 160 square feet on facility components, or 35 cubic feet of facility components where area or length could not be measured prior to abatement. The owner or operator is required to provide written notification at least ten full working days prior to any RACM renovation or demolition operation, including paying applicable project fees. Additional information regarding regulations during NESHAP renovation and demolition of RACM can be found at epa.gov and should be reviewed thoroughly.

2.2 Visual Assessment

Suspect ACM are materials that may potentially contain asbestos but have neither been tested nor assumed to be asbestos. The locations of suspected ACM on or associated with the surge tanks were determined via a visual inspection.

Suspect materials were organized as homogenous areas. Homogenous areas are defined by

EPA guidelines as materials with uniform color and texture. EPA regulation CFR 40 763 stipulates that all suspected ACBM must be assumed to contain asbestos unless a homogenous area is sampled (per subsection 763.86) and tested (per subsection 763. 87) in which the material is found not to contain greater than 1% asbestos.

Below is a list of suspected ACM observed during the visual inspection that were bulk sampled and laboratory tested. Results of the laboratory analysis of suspect materials are located in the

Executive Summary, Section 2.6, and Appendix B.

Suspect ACM, Tested

• Smooth, white painted gray caulk o Location: Base of Surge Tanks o Condition: Damaged o HA and Sample IDs:

HA 1: BC13, BC14, BC15

• Rough, white painted red gasket o Location: Base of Surge Tanks o Condition: Damaged o HA and Sample IDs:

HA 2: GS19, GS20, GS21

2.3 Physical Assessment

Deleterious effects of asbestos primarily stem from its ability to be broken down into inhalable, fibrous form. Friability describes when hand pressure alone is capable of producing inhalable asbestos fibers. Specifically, the EPA defines friable ACM as any material containing greater than

1 percent asbestos that, when dry, can be crumbled pulverized, or reduced to powder by hand pressure. Included in this description is previously non-friable material, which has become friable due to damage. PEER assessed friability by physically touching suspect ACM (Appendix B).

2.4 Sample Collection

PEER sampled suspect ACM following the sampling protocols established in EPA regulation 40

CFR Part 763 Subpart E 763.86, (Asbestos Hazard Emergency Response Act (AHERA), Code of Maryland Regulations (COMAR), and Occupational Health and Safety Administration (OSHA) regulations. Representative samples were randomly collected from homogenous areas in accessible locations within the areas investigated. Water was sprayed on the suspect material prior to sample collection to minimize the release of fibers during sampling and duct tape was applied to disturbed areas after sampling to seal suspect material inside. The collected samples were sealed in plastic bags and labeled with the unique sample IDs using permanent marker prior to shipping the samples and the chain of custody form to the accredited laboratory for analysis.

2.5 Sample Analysis

Bulk samples were submitted with a chain of custody (COC) form to EMSL Analytical, Inc. (NVLAP

Lab Code: 200293-0) in Beltsville, MD. Samples were received by the lab on 07/26/2024 and the analysis was completed 08/02/2024. Bulk samples were analyzed using the Asbestos Analysis of

Bulk Materials via EPA 600/R-93/116 Method using Polarized Light Microscopy. Asbestos content is determined visually using this method. A copy of the COC can be found in Appendix D and test results can be found in Appendix B.

2.6 Findings and Recommendations

The selection of sample locations and frequency of sampling were based on PEER’s observations and the assumption that similar materials in the same area are homogeneous in content. PEER collected six (6) samples from two (2) homogenous areas of suspected ACM associated with the surge tanks on the Property. Table 1 of Appendix B summarizes sample information including

Sample ID, Material Type, Homogenous Area, Sample Description/Location, Percent (%)

Asbestos, Analysis Method, Friability, and Assessment Categories.

Results of the laboratory analysis indicated that asbestos was not detected as greater than 1% in any of the samples collected, as shown in Table 1 of Appendix B. Appendix D contains the sample Chain of Custody and laboratory reports from EMSL Analytical, Inc. PEERs understanding of the proposed work is the demolition of the eight (8) surge tanks and associated components adjacent to the pumping station. Laboratory analysis, visual inspection, and physical inspection determined the examined areas of the surge tank exterior, aluminum, metal railings and pipes on the upper level of the tanks were not ACM. Inaccessible areas and components associated with the surge tanks (i.e., underground pipes, interior surfaces) were not included in the scope of work of this investigation and may potentially contain ACM.

It should be noted that while PEER made a significant effort to provide a thorough investigation, suspect ACM may exist inside or beneath the scope area that was not identified during the investigation on July 23, 2024. If this suspect material is identified during the demolition process, it should be assumed to be ACM until sampling and laboratory analysis confirms or disproves the assumption. Any estimated quantities must be field verified.

Removal or disturbance of ACM/RACM must be done in accordance with OSHA regulations.

OSHA’s Asbestos in Construction (29 CFR 1926.1101) regulation requires the employer to notify employees and contractors to the presence and location of ACM. Regulations and guidelines of

NESHAP, OSHA, as well as federal, state, and local laws, should be thoroughly reviewed prior to commencing proposed work.

3.0 POLYCHLORINATED BISPHENOLS (PCBS) SURVEY

3.1 Regulatory Overview

The manufacture and use of PCBs were banned in the United States in 1979, and the subsequent phase out of PCB compounds began. PCBs were commonly used as plasticizing agents in caulking and glazing materials, additives in paints and floor finishes, sealants for heating systems and plumbing, and as insulators in electrical equipment. PCBs are federally regulated under 40

CFR 761 – Polychlorinated Biphenyls (PCBs) Manufacturing, Distribution in Commerce, and Use

Prohibitions.

EPA regulations stipulate PCB bulk product waste is a concentration of ≥ 50 parts per million

(ppm). Building materials coated or serviced with PCB bulk product waste (e.g., sealants, caulk, mastic, paints, etc.) at the time they are designated for disposal are to be managed as PCB bulk product waste if they are equal to or greater than 50 ppm (40 CFR §§ 761.3, 761.20(a), and

761.62). Manufactured PCB products that contain ≥ 50 ppm PCBs have been frequently identified in sealants and coatings on surfaces, and within expansion joints, therefore, these were the primary areas of focus during this investigation.

3.2 Sample Collection and Analysis

PEER inspected the surge tanks and documented visible, accessible areas of suspect PCB containing materials and prepared the sampling inventory. Note: PEERs area of focus was limited by the client only to the above ground areas of the surge tanks expected to be demolished.

Suspect materials included:

• Gray/Blue Paint (Small diameter pipe atop surge tanks)

• White Paint (Exterior of surge tanks)

• White painted, red gasket (top of surge tanks)

Nine (9) samples in total were collected from the areas expected to be affected by demolition activities. Samples were labeled, packaged, documented on the Chain of Custody (Appendix D), and shipped on ice to the EMSL Analytical Laboratory in Cinnaminson, NJ for analysis. Samples were received by the lab on 07/30/2024 and the analysis was completed 08/13/2024. Samples were prepared and analyzed using EPA method SW846 3540C/8082A.

Laboratory analysis determined that none of the samples analyzed had detectable levels of PCBs.

Detailed results are located in Appendix B, Table 2 and sampling images are located in

Appendix C.

3.3 Findings and Recommendations

All materials sampled during this investigation were reported as non-detected and are therefore not interpreted to require removal and disposal as PCB Bulk Product Waste [exceeding 50 mg/kg

(ppm)]. Therefore, the laboratory findings indicate that the building materials that were analyzed are categorized as Excluded PCB Product, which is not regulated by the EPA under the Toxic

Substances Control Act (TSCA). If at any time during the continuation of work, suspect materials are discovered, they should be presumed as PCB containing materials until testing determines otherwise.

4.0 LEAD-BASED PAINT (LBP) SURVEY

4.1 Regulatory Overview

Maryland LBP Assessment Standards

Within the State of Maryland, MDE; the overseeing regulatory agency defines LBP as any paint or other surface coatings that contain lead equal to or exceeding 0.7 milligram per square centimeter (mg/cm²) or 0.5% by weight (5,000 parts per million). In accordance with MDE’s rules, LBP impact determinations can be made through the use of an XRF analyzer or likewise through the laboratory analysis of collected component paint chip samples.

4.2 Sample Collection and Analysis

During this evaluation SaLUT’s Maryland Department of the Environment (MDE) accredited lead inspector Mr. Elijah Sinthaby performed painted material assessments along a series of targeted surfaces on the exterior of the surge tanks, on the painted concrete base, the blue painted small diameter piping atop the surge tanks, the white painted medium diameter piping atop the surge tanks, and the white railing/supports atop the surge tanks. The full LBP report is located in

Appendix E.

In accordance with standard LBP testing methodologies, in order to guarantee reading accuracy, prior to on-site tests the X-Ray Fluorescence (XRF) analyzer used during tests was calibrated to a National Institute of Standards and Technology (NIST) Standard. The scope area was then divided into upper and lower levels, with the upper being the aerial scaffolding at the top of the tanks and the lower being ground level.

Testing combinations were determined by component, substrate, appearance, and assumed paint history. Readings were then collected from along homogeneous areas within component equivalents. Post analysis, the XRF analyzer’s performance was further verified using the NIST standard. Using these procedures, the XRF device’s accuracy and performance was confirmed.

Altogether forty-three (43) XRF readings were collected from various painted components on and associated with the surge tanks. Visual inspection found that the exterior surfaces of the tanks, as well as the upper-level railings and pipes were extremely weathered, with paint peeling and chipping to various degrees. Certain portions of the tanks were also clearly repainted, likely explaining some of the color variation. XRF readings indicated that LBP (in excess of MDE standards) was present on the white and beige painted exterior surfaces of the surge tanks, and associated piping, and white painted gooseneck fittings at ground level adjacent to the tank, ranging from 0.7-1.9 mg/cm2. Though analyzing the entire surface of each tank is not feasible due to the large size of tanks, the spread of positive readings at multiple locations on each tank analyzed allows for the presumption that the entirety of all the tanks are LBP impacted.

4.3 Findings and Recommendations

In Summary, based on the results of XRF material analyses conducted at the Anacostia WWPS surge tanks, the LBP impacted surfaces are the entirety of the white/beige painted exterior of the surge tanks and all gooseneck fittings at ground level. Figures 3 and 4 depict LBP impacted surfaces. Blue painted pipes and white painted railings on the upper level, although observed as having poor surface conditions, did not return positive readings for LBP. (See Appendix E:

Attachment A XRF Results). At this time, there are no further recommendations.

Figure 3: Sampling Location ≥ 0.7 mg/cm²: all exterior, white/beige painted surfaces of surge tanks and piping on upper and lower levels.

White/beige painted surfaces Base/Top of surge tanks and piping

Lead Concentration: 0.7 – 1.9 mg/cm2

Figure 4: Sampling Location ≥ 0.7 mg/cm²: white/beige gooseneck fittings.

5.0 General Comments/Limitations

The results, findings, conclusions, and recommendations provided in this report are based on the conditions observed during the survey of the Property. The information provided in this report is relevant to the dates the survey was performed and does not necessarily represent conditions at a future date. The professional standard of care and skill used to conduct this survey is in general accordance with members of the profession practicing under similar conditions.

PEERs sampling and investigation was limited by the client to materials and locations expected to be disturbed by the proposed demolition activities. Material quantities listed within this document are estimates and are not intended to be used for removal bidding purposes; material quantities should be field verified.

This report is not a bidding document and contracts/consultants utilizing this report must derive their own conclusions regarding further investigation(s) prior to proceeding. This report has been prepared exclusively for CDM Smith and WSSC with respect to the proposed surge tank demolition and may not be relied upon by another person or entity without PEERs expressed written permission. PEER does not warrant the work of regulatory agencies, laboratories, or other

White/beige gooseneck fittings Base of surge tanks, ground level

Lead Concentration: 0.7 – 1.9 mg/cm2 third parties supplying information utilized in the development of this report and no warranty, expressed or implied, is made. PEER will not accept any liability for loss, injury claim, or damage arising directly or indirectly from any use or reliance on this report.

This report is issued with the understanding that the client, the property owner, or its representative is responsible for ensuring that the information, conclusions, and recommendations contained herein are brought to the attention of the appropriate regulatory agencies, if required.

Appendix A – Aerial View of Site

Map

Fig A: Aerial View – Anacostia WWPS Surge Tanks (Access Date: MDOT Aug 2024) 1

Fig B: Ground Level View – Anacostia WWPS Surge Tanks (Taken: Aug 2024) 2

Appendix B – Asbestos and PCB Results Summary

Appendix B – Table 1 – Anacostia Surge Tanks – Asbestos Results Summary – August 2024

1 PEER Consultants, P.C. ■ Engineers ■ Scientists ■ Planners

Sample ID Material Type HA Sample

Description/Location % Asbestos Analysis Method

Friable/Non- Friable

BC13 MISC 1

Smooth, white painted gray caulk – Base of surge tanks

None Detected PLM NF/ Damaged

BC14 MISC 1

Smooth, white painted gray caulk – Base of surge tanks

None Detected PLM NF/ Damaged

BC15 MISC 1

Smooth, white painted gray caulk – Base of surge tanks

None Detected PLM NF/ Damaged

GS19 MISC 2

Rough, white painted red gasket – Top of surge tanks

None Detected PLM NF/ Damaged

GS20 MISC 2

Rough, white painted red gasket – Top of surge tanks

None Detected PLM NF/ Damaged

GS21 MISC 2

Rough, white painted red gasket – Top of surge tanks

None Detected

PLM NF/ Damaged

Table 1 Notes:

• Sample IDs bolded and shaded gray are Asbestos Containing Materials (ACM) based on having greater than 1% asbestos as determined by laboratory testing.

• F – Friable

• NF – Non-Friable

• TSI – Thermal System Insulation

• MISC. – Miscellaneous

• LF – Linear Feet

• HA – Homogenous Area

• Quantities listed are estimates for inspection purposes and should be field verified for all other uses.

• Estimated quantities above should not be used in construction documentation or bids.

Appendix B – Table 2 – Anacostia Surge Tanks – PCB Results Summary – August 2024

1 PEER Consultants, P.C. ■ Engineers ■ Scientists ■ Planners

Sample ID Sample Description Sample Location Total PCBs (mg/kg)

GP1 Gray/Blue paint Small diameter pipe (<4” atop surge tanks)

None Detected

GP2 Gray/Blue paint Small diameter pipe (<4” atop surge tanks)

None Detected

GP3 Gray/Blue paint Small diameter pipe (<4” atop surge tanks)

None Detected

WP4 White paint Exterior of surge tanks None Detected

WP5 White paint Exterior of surge tanks None Detected

WP6 White paint Exterior of surge tanks None Detected

GS16 White painted red gasket Top of surge tanks

None Detected

GS17 White painted red gasket Top of surge tanks

None Detected

GS18 White painted red gasket Top of surge tanks

None Detected

Appendix B – Anacostia Surge Tanks – PCB Results Summary – August 2024

Table 2 Notes:

• Sample IDs bolded and shaded gray are materials having greater than 50 mg/kg (ppm) PCB concentration as determined by laboratory testing.

• Samples were analyzed via PCBs – Bulk sample, Caulk / Concrete / Paint Chips via EPA SW846-8082A

Appendix C – Sampling Photo Log

HA 2

Rough, white painted red gasket

Top of surge tanks None-detected

HA 1

Smooth, white painted gray caulk

Base of surge tanks None-detected

Hazardous Material Survey – ACM Sampling Images/General Locations Anacostia WWPS, Capitol Heights, Maryland August 2024 ■ PEER Consultants, P.C. Project No. 7849-005

Engineers ■ Scientists ■ Planners

HA

Description

Location % Asbestos

White/beige Paint Exterior of all surge tanks, gooseneck fittings

None-detected

Gray/Blue paint Small diameter pipe (<4” atop surge tanks)

None-detected

Hazardous Material Survey – PCB Sampling Images/General Locations Anacostia WWPS, Capitol Heights, Maryland August 2024 ■ PEER Consultants, P.C. Project No. 7849-005

Engineers ■ Scientists ■ Planners

Description

Total PCB (mg/kg)

Hazardous Material Survey – PCB Sampling Images/General Locations Anacostia WWPS, Capitol Heights, Maryland August 2024 ■ PEER Consultants, P.C. Project No. 7849-005

Engineers ■ Scientists ■ Planners

Description: White painted, red gasket Location: Top of surge tanks

Total PCB (mg/kg): None-detected

Hazardous Material Survey – LBP Sampling Images/General Locations

August 2024 ■ PEER Consultants, P.C. Project No. 7849-005

Engineers ■ Scientists ■ Planners

White/beige painted surfaces Top of surge tanks and piping

0.7 – 1.9 mg/cm2

White/beige gooseneck fittings Base of surge tanks, ground level

0.7 – 1.9 mg/cm2

Description Location

Lead Concentration

Description

Lead Concentration

Gray/Blue painted surfaces Piping at top of surge tanks

None-detected

White/beige painted surfaces Base of surge tanks, ground level

0.7 – 1.9 mg/cm2

Hazardous Material Survey – LBP Sampling Images/General Locations Anacostia WWPS, Capitol Heights, Maryland August 2024 ■ PEER Consultants, P.C. Project No. 7849-005

Engineers ■ Scientists ■ Planners

Hazardous Material Survey – LBP Sampling Images/General Locations

August 2024 ■ PEER Consultants, P.C. Project No. 7849-005

Engineers ■ Scientists ■ Planners

Description: White painted hand railing Location: Top of surge tanks

Lead Concentration: None-detected

Appendix D – Chain of Custody and Laboratory Results

OrderID: 192406694

OrderID: 192406694

United States Department of Commerce National Institute of Standards and Technology

Certificate of Accreditation to ISO/IEC 17025:2017

NVLAP LAB CODE: 200293-0

EMSL Analytical, Inc.

Beltsville, MD is accredited by the National Voluntary Laboratory Accreditation Program for specific services, listed on the Scope of Accreditation, for:

Asbestos Fiber Analysis

2024-01-01 through 2024-12-31

Effective Dates For the National Voluntary Laboratory Accreditation Program

This laboratory is accredited in accordance with the recognized International Standard ISO/IEC 17025:2017.

This accreditation demonstrates technical competence for a defined scope and the operation of a laboratory quality management system (refer to joint ISO-ILAC-IAF Communique dated January 2009).

Effective 2024-01-01 through 2024-12-31

Appendix E – SaLUT Lead- Based Paint (LBP) Material

Assessment

Engineering • Industrial Hygiene • Health and Safety

August 12, 2024 Peer Consultants LLC.

409 12th Street, SW Suite 603 Washington, DC 20024

Attention: Ricardo Martinez; P.E, BCEE. Environmental Management Director Travis Waller; PhD. Civil and Environmental Engineer (martinezr@peercpc.com);

(wallert@peercpc.com)

Subject : Washington Suburban Sanitary Commission (WSSC) Anacostia Waste Water Pumping Station Lead-Based Paint Evaluation of Above Ground Water Surge Tanks and Associated Components.

1700 Andalusia Lane Capitol Heights, MD 20743

Summary

Per your requests, on July 2024, Soil and land Use Technology, inc. (SaLUT ) conducted a lead-based paint (LBP) survey at the WSSC Capitol Heights Anacostia Waste Water Pumping Station, located on 1700 Andalusia Lane Capitol Heights, MD. The purpose of this assessment was to evaluate the LBP impact characteristics of each of the station’s eight (8) above ground tank’s painted surfaces and components.

The results of X-ray fluorescence (XRF) device direct surface measurements collected from the surge tanks and associated components during this inspection indicated LBP impacts throughout the stations above ground tanks’ surfaces. See attachment A: XRF Readings.

Background

The Maryland Department of the Environment (MDE); the state’s environmental regulatory body defines LBP as any paint or other surface coatings that contain lead equal to or exceeding 0.7 milligram per square centimeter (mg/cm²) or 0.5% by weight (5,000 parts per million). In accordance with MDE’s guidelines, LBP impact determinations can be made through the use of an XRF analyzer or likewise through the laboratory analyses of collected paint chip samples. During this survey, XRF direct surface measurements we employed as the primary assessment method.

mailto:martinezr@peercpc.com mailto:wallert@peercpc.com

Engineering • Industrial Hygiene • Health and Safety

Procedure

Upon meeting with the on-site point of contact at the station. SaLUT’s representative carried out calibrations of the XRF device using a National Institute of Standards and Technology (NIST) primary. This was performed to guarantee the device’s measurement accuracy and reliability.

During the survey the XRF analyzer was used in manners traceable to the device manufacturer’s operational specifications.

Results

The upper and lower areas of the above ground tank tested indicated the presence of LBP on these components’ painted surfaces. Although not every tank was tested based on the results of tested counterparts, the tanks which were not directly tested may be similarly presumed to be LBP impacted.

Conclusion

Based on the outcomes of the XRF device direct surface measurement carried-out during this survey, painted components of the Anacostia Waste Water Pumping Station’s above ground surge tanks may be considered to be LBP impacted.

SaLUT appreciates the opportunity to provide environmental services to Peer Consultants LLC. If you have any questions or require additional information, please contact me at (301)595-3783.

Sincerely, Jaylen Nchang Industrial Hygienist Risk Assessor Soil and Land Use Technology, Inc.

Attachments

Attachment A: XRF Readings

Attachment A:

XRF Readings

Component Substrate Side Condition Color Site Floor Units Results Pb

CALIBRATE Calibrate mg / cm ^2 Positive 1.2

CALIBRATE Calibrate mg / cm ^2 Positive 1.2

CALIBRATE Calibrate mg / cm ^2 Positive 1 tank metal UPPER PEELING BEIGE WSSC Anacostia roof mg / cm ^2 Positive 1 railing metal UPPER PEELING BEIGE WSSC Anacostia roof mg / cm ^2 Negative 0.01 railing metal UPPER PEELING BEIGE WSSC Anacostia roof mg / cm ^2 Negative 0.03 pipes metal UPPER PEELING BLUE WSSC Anacostia roof mg / cm ^2 Negative 0.3 pipes metal UPPER PEELING BLUE WSSC Anacostia roof mg / cm ^2 Negative 0.04 tank metal UPPER PEELING WHITE WSSC Anacostia exterior mg / cm ^2 Positive 0.9 tank metal UPPER PEELING WHITE WSSC Anacostia exterior mg / cm ^2 Positive 1.2 tank metal UPPER PEELING WHITE WSSC Anacostia exterior mg / cm ^2 Positive 1.7 tank base concrete UPPER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0 tank base concrete UPPER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0 tank base concrete UPPER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0 tank base concrete UPPER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0 tank base concrete UPPER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0 tank base concrete UPPER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0.01 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Positive 0.9 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Positive 1.2 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Positive 1.1 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Positive 0.8 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0.6 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Positive 1.9 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0.17 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0.2 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0.5 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0.26 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0.14 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0.07 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Positive 0.7 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0.5 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0.01 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Positive 0.7 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0.01 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0.01 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Positive 0.8 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Positive 0.8 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Positive 0.8 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Positive 1.2 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0.5 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0.07 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0.27 tank metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Negative 0.2 tank5 metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Positive 1.6 tank5 metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Positive 1.2 tank5 metal LOWER PEELING BEIGE WSSC Anacostia exterior mg / cm ^2 Positive 1.4

Component Substrate Side Condition Color Site Floor Units Results Pb

CALIBRATE Calibrate mg / cm ^2 Positive 1

Appendix F – Inspector

Credentials