FOWA_FINAL Phase II ESA_Report July 2017.pdf

Phase II Environmental Site Assessment Report

Fort Washington Marina 13600 King Charles Terrace Fort Washington, MD 20744

July 28, 2017

Prepared By

Ausangate Environmental LLC 145 Pine Needle Rd., Boulder, CO 80304

Prepared For

Hitachi Consulting Corp.

1 Monroe Street, Suite PE-08, Rockville, MD 20870

And

National Park Service

Fort Washington Marina Phase II ESA Report

Table of Contents

Abbreviations and Acronyms .................................................................................................................. iii!

Executive Summary ................................................................................................................................... 1!

1. ! Introduction ....................................................................................................................................... 10!

1.1. ! Purpose and Scope of Services .................................................................................................. 10!

1.2. ! Location and Site Description ...................................................................................................... 11!

1.2.1. ! Current Property Use ............................................................................................................................. 11 !

1.2.2. ! Surrounding Property Descriptions ........................................................................................................ 12 !

1.3. ! Environmental Setting .................................................................................................................. 12!

1.3.1. ! Topography ............................................................................................................................................ 12 !

1.3.2. ! Hydrology ............................................................................................................................................... 13 !

1.3.3. ! Soils ........................................................................................................................................................ 13 !

1.3.4. ! Geology .................................................................................................................................................. 13 !

1.4. ! Historical Information ................................................................................................................... 14!

1.5. ! 2016 Phase I ESA ....................................................................................................................... 14!

1.5.1. ! Summary of 2016 Phase I ESA Findings ............................................................................................... 14 !

1.6. ! Contaminants of Potential Concern ............................................................................................. 20!

2. ! Project Data Quality Objectives ...................................................................................................... 20!

2.1. ! Problem Statement ...................................................................................................................... 21!

2.2. ! Goals of the Investigation ............................................................................................................ 21!

2.3. ! Information Inputs ........................................................................................................................ 21!

2.4. ! The Boundaries of the Investigation ............................................................................................ 22!

2.5. ! Develop the Analytical Approach ................................................................................................. 22!

2.6. ! Performance or Acceptance Criteria ............................................................................................ 23!

2.6.1. ! Quality Control................................................................ ........................................................................ 23 !

2.6.1.1. ! Field Quality Assurance/Quality Control ................................................................................................ 24 !

2.6.2. ! Field Documentation .............................................................................................................................. 24 !

2.6.3. ! Field Quality Control Samples ................................................................................................................ 24 !

2.6.1. ! Background Samples ............................................................................................................................. 25 !

2.6.2. ! Analytical Laboratory .............................................................................................................................. 25 !

2.6.3. ! Laboratory Quality Control Samples ...................................................................................................... 25 !

2.7. ! Plan for Obtaining the Data ......................................................................................................... 25!

2.8. ! Data Review and Validation ......................................................................................................... 26!

3. ! Sampling Rationale and Field Activities ......................................................................................... 26!

3.1. ! Marina Boat Yard/Parking Lot Area (REC 1)

3.2. Pressure Washer Sump – AST (REC 2)

3.3. Used Oil and Antifreeze ASTs (REC 3)

3.4. Fiberglass Fabricators – Unlabeled 55-Gallon Drums (REC 4)

3.5. Fiberglass Fabricators – Heating Oil ASTs (REC 5)

3.6. Fiberglass Fabricators – Used Oil Containers (REC 6)

3.7. Fiberglass Fabricators – AST (REC 7)

3.8. Underground Storage Tanks (Additional Investigation Recommendation)

3.9. Historical USTs (Data Gap 1)

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3.10. ! Sample Summary Table .............................................................................................................. 29!

4. ! Results and Discussion ................................................................................................................... 30!

4.1. ! Field Activities and Analytical Results ......................................................................................... 30!

4.1.1. ! Marina Boat Yard/Parking Lot Area (REC 1) ......................................................................................... 31 !

4.1.2. ! Pressure Washer Sumps (REC 2) ......................................................................................................... 33 !

4.1.3. ! Used Oil and Antifreeze ASTs (REC 3) ................................................................................................. 33 !

4.1.4. ! Fiberglass Fabricators – Unlabeled 55-Gallon Drums (REC 4) ............................................................. 34 !

4.1.5. ! Fiberglass Fabricators – Heating Oil ASTs (REC 5) .............................................................................. 34 !

4.1.6. ! Fiberglass Fabricators – Used Oil Containers (REC 6) ......................................................................... 35 !

4.1.7. ! Fiberglass Fabricators – AST (REC 7) ................................................................................................... 35 !

4.1.8. ! Underground Storage Tanks (Additional Investigation Recommendation) ............................................ 35 !

4.1.9. ! Historical USTs (Data Gap 1) ................................................................................................................. 36 !

4.1.10. ! Analytical Results Summary Table ........................................................................................................ 37 !

4.2. ! Quality Assurance/Quality Control ............................................................................................... 38!

4.2.1. ! Duplicate Samples ................................................................................................................................. 38 !

4.2.2. ! Equipment Rinsate Blank Samples ........................................................................................................ 39 !

4.2.3. ! Trip Blank Samples ................................................................................................................................ 40 !

5. ! Conclusions and Recommendations .............................................................................................. 40!

5.1. ! Marina Boat Yard/Parking Lot Area (REC 1) ............................................................................... 40!

5.2. ! Pressure Washer Sump (REC 2) ................................................................................................. 40!

5.3. ! Used Oil and Antifreeze ASTs (REC 3) ....................................................................................... 41!

5.4. ! Fiberglass Fabricators – Unlabeled 55-Gallon Drums (REC 4) ................................................... 41!

5.5. ! Fiberglass Fabricators – Heating Oil ASTs (REC 5) .................................................................... 41!

5.6. ! Fiberglass Fabricators – Used Oil Containers (REC 6) ............................................................... 41!

5.7. ! Fiberglass Fabricators – AST (REC 7) ........................................................................................ 42!

5.8. ! Underground Storage Tanks (Additional Investigation Recommendation) .................................. 42!

5.9. ! Historical USTs (Data Gap 1) ...................................................................................................... 42!

5.10. ! Conclusions and Recommendations Summary Table ................................................................. 42!

5.11. ! Limitations and Signature ............................................................................................................ 44!

6. ! References ........................................................................................................................................ 45!

Figures ...................................................................................................................................................... 46!

Figure 1: Property Location Map ............................................................................................................ 47!

Figure 2: Decision Units ......................................................................................................................... 48!

Figure 3: Sample Locations – Eastern Portion ...................................................................................... 49!

Figure 4: Sample Locations – Western Portion ..................................................................................... 50!

Appendices ............................................................................................................................................... 51!

Appendix A – Photographic Log!

Appendix B – Soil Boring Logs!

Appendix C – Analytical Data!

Appendix D – Chain of Custody Forms!

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Abbreviations and Acronyms

AAI All Appropriate Inquiries

ACM Asbestos Containing Material amsl Above Mean Sea Level

AST Above Ground Storage Tank

ASTM American Society for Testing and Materials

AUL Activity Use Limitation

BER Business Environmental Risk

BGS Below Ground Surface

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFR Code of Federal Regulations

COC Chain-of-Custody

CREC Controlled Recognized Environmental Condition

DOI U.S. Department of the Interior

DPT Direct-Push Technology

DRO Diesel Range Organics

DU Decision Unit

EDR Environmental Data Resources, Inc.

EPA U.S. Environmental Protection Agency

ESA Environmental Site Assessment

GPS Global Positioning System

GRO Gasoline Range Organics

HREC Historical Recognized Environmental Condition

JSA Job Safety Analysis

LUST Leaking Underground Storage Tank

MDE Maryland Department of the Environment

MDNR Maryland Department of Natural Resources

MES Maryland Environmental Services

NCP National Oil and Hazardous Substances Pollution Contingency Plan (AKA, National Contingency Plan)

NFA No Further Action

July 28, 2017 iii

Abbreviations and Acronyms (continued)

NPL National Priorities List

NPS National Park Service

ORO Oil Range Organics

PID Photo Ionizing Detector

RCRA Resource Conservation Recovery Act

REC Recognized Environmental Condition

SAP Sampling and Analysis Plan

SVOC Semivolatile Organic Compound

TCLP Toxicity Characteristic Leaching Procedure

TEL Tetraethyl Lead

TPH Total Petroleum Hydrocarbon

USGS United States Geological Survey

UST Underground Storage Tank

VOC Volatile Organic Compound

ZHE Zero Headspace Extraction

July 28, 2017 iv

Executive Summary This section provides a summary of the Phase II Environmental Site Assessment (ESA) process for the Fort Washington Marina (Subject Property) Phase II ESA, including findings, opinions and conclusions.

To evaluate the environmental condition of the Subject Property prior to the transfer of management responsibilities of the marina from the Maryland Department of Natural Resources (MDNR) to the National Park Service (NPS), Ausangate was tasked, under subcontract to Hitachi Consulting Corporation, with conducting a Phase I ESA (Ausangate 2016) consistent with requirements set forth under the All Appropriate Inquiry (AAI) standards described in 40 CFR 312 and 33 CFR 137 and the American Society for Testing and Materials (ASTM) Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process (ASTM designation E1527-13).

During the Phase I ESA Ausangate identified two significant data gaps and seven recognized environmental conditions (RECs) associated with the Subject Property. Ausangate also identified one historical REC and made two additional investigation recommendations.

Subsequent to the Phase I ESA, Hitachi Consulting and NPS requested that Ausangate conduct a Phase II ESA to further evaluate the data gap associated with the historical underground storage tanks (USTs) (Data Gap 1), all of the RECs, and the additional investigation recommendation associated with the current USTs (see Section 1.5).

The objectives of a Phase II ESA are to collect the environmental samples and data necessary to determine whether there has been a release of hazardous substances (within the definition of the Comprehensive Environmental Response, Compensation, and Liability Act [CERCLA]), pollutants, or contaminants to the environment. The Phase II ESA followed the Standard Practice for Environmental Site Assessments: Phase II Environmental Site Assessment Process (ASTM designation E1903-11).

A summary of the Phase I ESA (Ausangate 2016) observations, conclusions, and recommendations is presented in Section 1.5.

This is a cursory summary of findings. The full report must be read in its entirety for a comprehensive understanding of these findings, opinions and conclusions.

Summary of Findings

Site Description and Use

The Subject Property consists of 8.31 acres located at 13600 King Charles Terrace, Prince George’s County, Fort Washington, MD 20744 (Figure 1). The property is owned by the U.S.

Department of the Interior (DOI), administered by the NPS, and until recently, was leased by MDNR. The property is currently managed by Coastal Properties Management, Inc.

Buildings and structures on the property include:

July 28, 2017 1

• The Main Marina Building, which includes the marina office, Proud Mary Restaurant, utilities, bathrooms/changing rooms with showers, and a laundry room.

• The marina has five docks (A, B, C, D, and G). All of the docks are floating except for dock C, which is the fuel dock.

• A workshop that formerly housed a fiberglass boat repair business called Fiberglass Fabricators.

• A trailer that is owned and occupied by Pat’s Boat Shop.

• Two sheds are located on the east side of the property, which are used by the Atlantic Kayak Rentals and Environmental Education Center.

• A floating barge used by the Prince George’s County Volunteer Fire Department is docked just east of Dock G and adjacent to the bulkhead and the haul-out/lift well.

Fort Washington Marina provides slips for up to 300 vessels and accommodates boats up to 60 feet. Marina services provided include gasoline and diesel fueling, sewage pump-out, a launch ramp, and WI-FI. Dock C, houses two fuel dispensers and two sanitary waste pump out stations. The fuel dispensers distribute gasoline and diesel fuel from two, 10,000-gallon underground storage tanks (USTs) located north of the Main Marina Building.

A used oil and antifreeze drop off facility was maintained by Maryland Environmental Services (MES) as part of the State Used Oil Program and is located on the northeast corner of the property. That facility has since been decommissioned.

Historical Information

Based on a review of the historical information, as early as 1937 until approximately 1957, agricultural plots appear to have been developed just north of the Subject Property, which extended onto the central portion of the property. Other than agriculture, the Subject Property remained forested and undeveloped until the marina was built in approximately 1960. The southern edge of the property, along Piscataway Creek, was extended south and southeast with fill by 1963. The basic configuration of the property changed little from the late 1960s through approximately 1994 when the property was developed into its present configuration.

The Subject Property was obtained by the DOI in 1974 through a legislative taking action.

Sampling Rationale and Field Activities

Based on historical information and observations made during the Phase I ESA (Ausangate 2016) a Sampling and Analysis Plan (SAP; Ausangate 2017) was developed for each investigation area (RECs, etc.) along with a list of contaminants of potential concern (COPCs), which determined the analytical suite for each sample collected and was used to guide the Phase II ESA sampling efforts.

Decision Units (DUs) are the smallest user-defined areas for which decisions will be made (e.g., no-further action, removal or remedial action) during the study. The DUs for this study were

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Decision Unit n samples planned n samples collected Analytical suite

Marina Boatyard/Parking Area (REC 1; 20 surface and 3 subsurface soil samples) 23 23 • Resource Conservation and Recovery Act (RCRA) 8 Metals

(As, Ba, Cd, Cr, Pb, Hg, Se, Ag)

• RCRA 8 Metals

Pressure Washer Sump – AST

(REC 2) 2 2

TPH – Diesel Range Organics (DRO) TPH – Oil Range Organics (ORO)

Volatile Organic Compounds (VOCs) Semivolatile Organic Compounds (SVOCs)

• RCRA 8 Metals

Used Oil and Antifreeze ASTs

(REC 3) 5 5

Total Petroleum Hydrocarbon (TPH) – Gasoline Range Organics (GRO)

TPH –DRO

TPH –ORO

• VOCs

• SVOCs

• RCRA 8 Metals

• TPH –GRO

Fiberglass Fabricators – Unlabeled 55-Gallon Drums

(REC 4)

5 5

TPH –DRO

TPH –ORO

VOCs SVOCs

• Pesticides

• Herbicides

• RCRA 8 Metals Fiberglass Fabricators – Heating Oil ASTs (REC 5) 1 1 •

TPH –DRO

TPH –ORO

SVOCs

• RCRA 8 Metals Fiberglass Fabricators – Used Oil

Containers (REC 6) 2 2 •

TPH –DRO

TPH –ORO

SVOCs

Fort Washington Marina Phase II ESA Report defined by each study location (i.e., Data Gaps, RECs, etc.; see Section 3, Figure 2, and Ausangate 2016).

The goal of the Phase II ESA was to determine whether a release of hazardous substances has occurred or may occur and the potential magnitude of associated environmental liabilities.

Therefore, discrete samples were collected at each sample location and evaluated individually to determine the distribution and potential maximum concentrations of contaminants.

Over the course of two days (6/20-21/2017), Ausangate collected 44 environmental samples that were submitted to an analytical laboratory for analysis. Sample locations for each DU are illustrated on Figures 3 and 4. A summary of the samples and analytical suite for each DU are presented in the following table:

July 28, 2017 3 n samples collected Analytical suite

Fiberglass Fabricators – AST

(REC 7) 1 0

RCRA 8 Metals

TPH –DRO

TPH –ORO

VOCs SVOCs

Underground Storage Tanks (Additional Investigation

Recommendation)

TPH –DRO

TPH –ORO

VOCs SVOCs

Historical USTs (Data Gap 1) 5 5

TPH –GRO

TPH –DRO

TPH –ORO

VOCs SVOCs

Tetraethyl Lead (TEL; associated with gasoline prior to 1996)

Conclusions and Recommendations

This section presents the analytical results and relevant discussion for each DU. Sample locations are shown on Figures 3 and 4. The analytical results are included in Appendix C and a summary table listing all analytical results exceeding screening levels is presented in Section 4.4.10.

Recognized Environmental Conditions

REC 1: Marina Boat Yard and Parking Lot Area

The marina boat yard and parking lot area have been used for dry storage of boats for up to 56 years and boat paint is known to contain high concentrations of heavy metals; therefore, the potential for heavy metals contamination within the surface and near-surface material of the boat yard and parking lot area were considered a REC.

• Analytical Results and Recommendations: Twenty surface soil samples (including two duplicates) and three subsurface samples were collected from 18 locations within REC 1 (Figure 3; Appendix A, photos 1-5). Concentrations exceeding screening levels and background values were detected for two of the RCRA 8 metals, arsenic (As) and chromium (Cr). The data indicate that metals contamination is widespread across the Marina boat yard/parking lot area but that it is distributed as ‘hot spots’, or small areas of elevated contamination.

Though exceedances of risk-based screening levels exist across REC 1, the screening levels used represent the most conservative scenario, that of a residential receptor.

Such a scenario may not be reasonably indicative of the actual risks represented by

July 28, 2017 4 metals contamination at REC 1 and therefore, Ausangate recommends evaluation of the site by a risk assessor and subsequent consultation regarding risk management of the area.

To help prevent further contamination of REC 1 from the storage and maintenance of boats, ensure that drop cloths are used beneath all stored boats and do not allow the storage of boats, vehicles, or other equipment, or hazardous substances or petroleum products over storm drains or the permeable areas of the parking lot area without secondary containment. Also ensure that proper equipment (e.g., dust-free vacuum system) is used to contain sanding byproduct when boat hulls are maintained.

REC 2: Pressure Washer Sump

Due to the inability to inspect the pressure washer collection sump, its 26 years of operation, and the likely presence of heavy metals and other contaminants from boat washing, the pressure washer collection sump was considered a REC.

• Analytical Results and Recommendations: Two samples were collected from the filter material in the pressure washer sumps using a hand auger. One sample was collected from near the north edge of the west sump and one from near the south edge of the east sump (Figure 3; Appendix A, photos 6-11).

Arsenic was detected above screening levels, but below the background value in sample REC1-FS-01 from the western sump. There were no other analytes detected above their screening levels. No further action is recommended for REC 2; however, Ausangate recommends regular cleaning of the material accumulated above the filter cloth to prevent further contamination of the filter material in the sumps. After the sump was sampled, Ausangate observed that the boat hoist engine was leaking oil onto the sump drain pad and into the sump itself (see Appendix A, photo 49); therefore, Ausangate also recommends that all equipment used by the Marina be well maintained and that drip pans be used to collect drips until the leak can be repaired.

REC 3: Used Oil and Antifreeze Above Ground Storage Tanks

The used oil and antifreeze facility was considered a REC due to the likelihood of a release of petroleum hydrocarbons and used antifreeze to the environment through the cracked catchment basin, and potentially from the catchment drain and potential illegal dumping.

• Analytical Results and Recommendations: The containment slab had not been removed prior to the fieldwork and the State of Maryland has committed to the collection of soil samples beneath and around the slab after its removal; therefore, Ausangate only collected one sample from 0-1 ft. bgs in the ditch area north of the containment slab (Figure 3; Appendix A, photos 45-48).

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The polycyclic aromatic hydrocarbon (PAH), benzo(a)pyrene was detected at 0.075 mg/kg, which exceeds the USEPA Region 9 (NPS-preferred) screening level of 0.016 mg/kg. Several other PAHs were also detected at concentrations below their screening levels. Low levels of TPH-DRO and TPH-ORO were also detected. Benzo(a)pyrene is found in the diesel range of petroleum hydrocarbons; therefore, the TPH-DRO and PAHs likely have the same source (e.g., diesel fuel or used oil contaminated with diesel fuel).

The presence of TPH constituents as well as related PAHs indicates that petroleum hydrocarbon contamination associated with the used oil and antifreeze recycling area have migrated into the drainage ditch to the north. It is also possible that some of the material was disposed of directly into the ditch. Though the most logical source of the contamination is from activities associated with REC 3 — pending analytical results from soil samples beneath and surrounding the AST containment slab — runoff from the adjacent roadway to the north cannot be ruled out as a potential contributor.

The used oil and Antifreeze area should remain a REC until the area is fully characterized by the State of Maryland. Ausangate further recommends that NPS work with the State to ensure that the full suite of analyses are conducted at REC 3 (see Section 3.3) as soon as possible and that subsequent remedial action is taken accordingly.

REC 4: Fiberglass Fabricators – Unlabeled 55-Gallon Drums

There were 8-10, unlabeled, 55-gallon drums stored on the ground on the northeast side of the Fiberglass Fabricators building. The drums were considered a REC, because the contents of the drums could not be confirmed and due to the poor condition of the drums.

• Analytical Results and Recommendations: Five surface soil samples (including one duplicate) were collected from four locations on the northwest corner of the Fiberglass Fabricators building (Figure 4; Appendix A, photo 12). All of the samples collected at REC 4 exceeded both the screening levels and background values for As and Cr, which included the highest As concentration measured at the Subject Property (see summary table in Section 4.1.10). Sample REC4-SS-04 also exceeded the USEPA Region 9 screening level for bis(2-ethylhexyl)phthalate. Other phthalates and TPH-DRO and TPH- ORO were also detected in the samples from REC 4. The phthalates detected, including bis(2-ethylhexyl)phthalate, are common plasticizers, which would be consistent with the materials that a boat repair shop would use. Such products could have been stored in, and leaked from the drums that were stored at REC 4.

The presence of contaminants above screening levels in all of the samples indicates that the area of contamination associated with REC 4 may be larger than the area of the drum storage area’s footprint. Furthermore, this location is bounded immediately to the northwest by the property boundary fence and it is possible that contamination associated with this area extends off-site.

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Ausangate recommends collecting more samples around REC 4, including on the adjacent property to the northwest, to determine the full extent of the contamination and to evaluate the possibility of other source areas of contamination in the vicinity. The analytical suite should focus on the detected analytes in the samples from this investigation (i.e., pesticides and herbicides can be removed from the COPC list).

REC 5: Fiberglass Fabricators – Heating Oil Above Ground Storage Tanks

Two, approximately 275-gallon heating oil ASTs were sitting on the soil with no secondary containment, a two-liter oil container, and a used oil filter containing oil were observed on the south side of the Fiberglass Fabricators building during the Phase I ESA site reconnaissance (Ausangate 2016). The ASTs and oil containers surrounding them were considered a REC due to poor handling and management of petroleum products and the potential for a petroleum release to the environment.

• Analytical Results and Recommendations: One surface soil sample was collected from 0-1 ft. bgs directly below the remaining AST at REC 5 (Figure 4; Appendix A, photo 44). The sample contained TPH-DRO at 501 mg/kg, which exceeds the Maryland Department of the Environment (MDE) Residential Soil Cleanup Standard of 230 mg/kg;

however, TPH cleanup standards are based on predicted toxic constituents; in the case of TPH-DRO, the concern would be PAHs and the analytical suite included analysis of these potential SVOC constituents via USEPA Method 8270C. There were no other toxic constituents detected at concentrations above their screening levels.

Ausangate considers the TPH-DRO concentrations a de minimis condition and recommends no further action at REC 5. ASTM (ASTM 2011) defines a de minimis condition as, “conditions that generally do not present a threat to human health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies.”

Ausangate further recommends that NPS establish protocols for the handling and management of petroleum products, hazardous substances, and pollutants and their containers at the property. This may be accomplished by the development of a Spill Prevention, Control, and Countermeasures (SPCC) plan.

REC 6: Fiberglass Fabricators – Used Oil Containers

To the west of the Fiberglass Fabricators building ASTs there were approximately six, 5-gallon containers, reportedly filled with used oil, sitting on the soil with no secondary containment.

Ausangate observed stained soil immediately south of the containers and stressed vegetation in the area. The used oil containers and evidence of stained soil were considered a REC due to the poor handling and management of petroleum products and the indication of a petroleum release to the environment. The used oil containers were removed from the Subject Property prior to the Phase II ESA sampling activities.

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• Analytical Results and Recommendations: Two surface soils sample were collected from 0-1 ft. bgs where the used oil containers had previously been stored (Figure 4;

Appendix A, Photos 13-14). The soils from both REC 6 sample locations exceeded the screening level and background values for As and Cr (see table in Section 4.1.10).

Sample REC6-SS-02 contained TPH-DRO and TPH-ORO concentrations of 3000 and 2500 mg/kg respectively, which were the highest concentrations for these analytes measured at the Subject Property. However, there were no detections of the individual SVOC constituents via USEPA Method 8270C, which would be the risk drivers (toxic constituents) associated with the TPH concentrations.

Ausangate considers the TPH concentrations a de minimis condition and recommends no further action at REC 6 for petroleum hydrocarbons contamination.

Though the REC 6 samples exceeded risk-based screening levels for As and Cr, the screening levels used represent the most conservative scenario, that of a residential receptor. Such a scenario may not be reasonably indicative of the actual risks represented by metals contamination at REC 6 and therefore, Ausangate recommends evaluation of the site by a risk assessor and subsequent consultation regarding risk management of the area.

Ausangate further recommends that NPS establish protocols for the handling and management of petroleum products, hazardous substances, and pollutants and their containers at the property. This may be accomplished by the development of a SPCC plan.

REC 7: Fiberglass Fabricators – Above Ground Storage Tank

An approximately 275-gallon AST was observed behind the Fiberglass Fabricators building at its northwest corner. The AST was unlabeled, rusted, and appeared to be in disrepair. Because the AST is unlabeled and no information for it could be obtained, and due to the poor handling and management of petroleum products and chemicals observed elsewhere at the building, the AST is considered a REC.

• Analytical Results and Recommendations: Ausangate was not able to collect the planned sample from REC 7 due to health and safety concerns from a hornet’s nest in the soil near the AST. Considering the contamination measured in soil samples elsewhere around the Fiberglass Fabricators building, Ausangate still considers the AST a REC and recommends that the hornet’s nest be exterminated and that a sample be collected from below the AST and analyzed for the COPCs detailed in Section 3. This would best be accomplished when further characterization of REC 4 is conducted.

Additional Investigation Recommendations

Underground Storage Tanks (USTs)

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Although there were no indications that the two, 10,000-gallon USTs currently used at the Subject Property have leaked, it is not uncommon for leak detection systems to fail or for small leaks to go undetected by fuel reconciliation calculations and leak tests. Leak detection systems will also not detect surface spills from fuel over fills. To confirm that the leak detection system is working properly and that there have been no petroleum hydrocarbon releases from the current USTs, four soil borings were placed around the UST tank slab and five subsurface soil samples were collected (including one duplicate; Figure 4; Appendix A, photos 25-33).

• Analytical Results and Recommendations: The only analyte detections at this DU were low levels of acetone in two of the samples; however, acetone is not associated with the petroleum hydrocarbons stored in the USTs and the likely source is from the nearby Fiberglass Fabricators shop. Ausangate recommends no further action at this location.

Ausangate further recommends that NPS establish protocols for the handling and management of petroleum products, hazardous substances, and pollutants and their containers at the property. The may be accomplished by the development of a SPCC plan.

Data Gaps

Data Gap 1: Historical USTs

Four historical USTs were reportedly removed from the subject property in 1990 and MDE reported that the UST’s case file was closed; however, Ausangate could obtain no documentation that the tank graves were clean or whether contamination was left in place. In the absence of confirmation sampling from the former tank graves, the site of the former USTs was considered a significant data gap. Five subsurface soil samples (including 1 duplicate) were collected from four locations in the vicinity of the historical USTs (Figure 4; Appendix A, photos 34-43).

• Analytical Results and Recommendations: Both TPH-DRO and TPH-ORO were detected at 4.47 and 8.8 mg/kg respectively in the western most soil boring, which are low levels (the screening level is 230 mg/kg for TPH-DRO). No other associated contaminants were detected. Based on the analytical results, field observations, and MDE’s closure of the case file, Ausangate recommends no further action at this location.!

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1. Introduction This Phase II Environmental Site Assessment (ESA) report was prepared by Ausangate Environmental LLC (Ausangate) for the Fort Washington Marina (Subject Property). The Phase II ESA was conducted according to the American Society for Testing and Materials (ASTM) Standard Practice for Environmental Site Assessments: Phase II Environmental Site Assessment Process (ASTM designation E1903-11).

This section defines the purpose and scope of services for the Phase II ESA, identifies the property and its environmental setting, and provides a summary of the Phase I ESA (Ausangate 2016) findings.

1.1. Purpose and Scope of Services

To evaluate the environmental condition of the Subject Property prior to the transfer of management responsibilities of the marina from the Maryland Department of Natural Resources (MDNR) to the National Park Service (NPS), Ausangate was tasked, under subcontract to Hitachi Consulting Corporation, with conducting a Phase I ESA (Ausangate 2016) consistent with requirements set forth under the All Appropriate Inquiry (AAI) standards described in 40 CFR 312 and 33 CFR 137 and the ASTM Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process (ASTM designation E1527-13).

The purpose of a Phase I ESA is to identify recognized environmental conditions (RECs) associated with the Subject Property. RECs are defined by ASTM E1527-13 as, “The presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release, a past release, or a material threat of a release of any hazardous substances or petroleum products into structures on the property or into the ground, groundwater or surface water of the property. The term includes hazardous substances or petroleum products even under conditions in compliance with laws. The term is not intended to include de minimis conditions that generally do not present a material risk of harm to public health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies.”

Data gaps were also evaluated. A data gap is defined by ASTM E1527-13 as, “a lack of or inability to obtain information required by this practice despite good faith efforts by the environmental professional to gather such information. Data gaps may result from incompleteness in any of the activities required by this practice, including, but not limited to site reconnaissance (for example, an inability to conduct the site visit), and interviews (for example, an inability to interview the key site manager, regulatory officials, etc.).”

Subsequent to the Phase I ESA, Hitachi Consulting and NPS requested that Ausangate conduct a Phase II ESA to further evaluate the data gaps and RECs identified at the Subject Property. A summary of the Phase I ESA (Ausangate 2016) observations, conclusions, and recommendations is presented in Section 1.5.

July 28, 2017 10

The objectives of a Phase II ESA are to collect the environmental samples and data necessary to determine whether there has been a release of hazardous substances (within the definition of the Comprehensive Environmental Response, Compensation, and Liability Act [CERCLA]), pollutants, or contaminants to the environment and to help determine the potential scope of environmental liabilities that are currently associated with the Subject Property.

1.2. Location and Site Description

The Subject Property consists of 8.31 acres located at 13600 King Charles Terrace, Prince George’s County, Fort Washington, MD 20744 (Figure 1). The property is owned by the U.S.

Department of the Interior (DOI), administered by the NPS, and managed by Coastal Properties Management, Inc. At the time of the Phase I ESA, the Subject Property was leased by MDNR.

Buildings and structures on the property include:

• The Main Marina Building, which includes the marina office, Proud Mary Restaurant, utilities, bathrooms/changing rooms with showers, and a laundry room.

• The marina has five docks identified as ‘A’, ‘B’, ‘C’, ‘D’, and ‘E’. Another dock is identified as Pier ‘G’, which is used for short-term docking/staging. All of the docks are floating except for dock C, which is the fuel dock.

• A workshop that houses a fiberglass boat repair business called Fiberglass Fabricators.

• A trailer that is owned and occupied by Pat’s Boat Shop. The trailer includes an office space and a workshop.

• Two sheds are located on the east side of the property. Both sheds are used by the Atlantic Kayak Rentals and Environmental Education Center, which has been onsite for 20 years. The same business has three floating docks attached to Dock G.

• A floating barge used by the Prince George’s County Volunteer Fire Department is docked just east of Dock G and adjacent to the bulkhead and the haul-out/lift well.

Utilities supplied to the Subject Property include:

• Electricity (supplied by PEPCO).

• Natural gas (supplied by Washington Gas).

• Water and sewer (supplied by Washington Suburban Sanitary Commission).

1.2.1. Current Property Use

Fort Washington Marina provides slips for up to 300 vessels and accommodates boats up to 60 feet (ft.). Marina services provided include gas and diesel fueling, sewage pump-out, a launch ramp, and WI-FI. Dock C, houses two fuel dispensers and two sanitary waste pump out stations. The fuel dispensers distribute gasoline and diesel fuel from two, 10,000-gallon underground storage tanks (USTs) located northwest of the Main Marina Building. The boatyard has a 35-ton boatlift for service and winter storage, and a pressure washing facility. Boats are

July 28, 2017 11 stored in the eastern portion of the property throughout the year and in the parking lot area during the winter. The boatyard can reportedly store approximately 120-140 boats during the offseason.

Pat’s Boat shop provides on-site boat repairs.

Paint and fiberglass work were provided by Fiberglass Fabricators at the time of the Phase I ESA. Fiberglass Fabricators has subsequently vacated the Subject Property.

The Main Marina Building provides offices for marina staff and shower, bathroom and laundry facilities for the public. Attached to the Main Marina Building is the Proud Mary Restaurant.

The Atlantic Kayak Rentals and Environmental Education Center provides kayak rental services, tours of the area, and environmental education programs.

There is a gazebo and two picnic areas with tables and BBQ facilities for use by marina customers.

At the time of the Phase I ESA site visit, Maryland Environmental Services maintained a used oil and antifreeze recycling drop-off location with three above ground storage tanks (ASTs) on the northeast corner of the property. The drop-off location has subsequently been closed.

The Prince George’s County Volunteer Fire Department maintains a floating clubhouse east of Dock G. They also keep boats and fire-fighting equipment at the facility.

1.2.2. Surrounding Property Descriptions

The Subject Property is bordered to the south and east by Piscataway Creek (Figure 2). A small community boat ramp and dock lie to the west with undeveloped land belonging to Fort Washington beyond. King Charles Terrace Road provides access to, and borders the Subject Property to the north. Beyond King Charles Terrace road lies a community pool and tennis courts and residential communities, the closest of which are accessed via Reid Terrace Court and Reid Circle to the northeast and Queens Lane to the northwest.

1.3. Environmental Setting

This section describes the physical setting of the Subject Property.

1.3.1. Topography

The Subject Property is located at an approximate average of 5 ft. above mean sea level (amsl) with the highest portion of the site located at the Fiberglass Fabricators property (Figure 2) at approximately 30 ft. amsl. The property typically slopes from north to south with surface runoff from properties adjacent to and north draining onto the Subject Property. Evidence of surface drainage onto the subject property was observed during the 6/28/16 site reconnaissance visit (Ausangate 2016). Drainage on the northeastern edge of the property is directed through a

July 28, 2017 12 shallow ditch to the east, which ultimately flows offsite and into a stormwater drain into Piscataway Creek.

A series of stormwater intakes are located throughout the Subject Property, which drain surface water runoff into Piscataway Creek. Stormwater intakes are also located along King Charles Terrace Road, which collect runoff from the road and surrounding properties. A diagram of the stormwater drain system is included in Appendix G of Ausangate (2016).

1.3.2. Hydrology

The Subject Property is bordered to the south by Piscataway Creek, which flows west into the Potomac River approximately 0.8 miles to the northwest.

The depth to shallow groundwater at the Subject Property was not reported; however, based on the site’s proximity to Piscataway Creek, it is likely less than 20 ft. below ground surface (bgs).

Groundwater flow will typically follow the topographic gradient, which at the Subject Property is from north to south. In the proximity of surface water bodies, groundwater will typically flow towards that water body. This also suggests that the local groundwater flows from north to south (into Piscataway Creek).

The Subject Property receives drinking water from the Washington Suburban Sanitary Commission. There are no drinking water wells located on the property.

1.3.3. Soils

Based on information provided in the Environmental Data Resources (EDR) report (Ausangate 2016), the dominant soils in the general area of the Subject Property are Beltsville, silt loam.

These soils are moderately well drained, with moderately fine, to fine textures. Layers of lower hydraulic conductivity are present, impeding the downward movement of water. Their corrosion potential for uncoated steel is classified as high.

Much of the surface of the Subject Property is gravel. According to the property’s former General Manager, the gravels in the main parking area to the east of the Main Marina Building are used to drain the surface of the property into a series of French drains located beneath the main parking lot. The French drains flow into the adjacent stormwater drains and subsequently into Piscataway Creek. The historical topographic maps (Ausangate 2016) indicate that at least a portion of the southeastern edge of the property appears to be fill, though the source of that fill is unknown.

1.3.4. Geology

According to the EDR report, bedrock occurs at greater than 60 inches bgs in the Subject Property area. The area is underlain primarily by Aquia Formation sandstones, which are composed of fine, to medium-grained, poorly sorted to well-sorted material (Glaser 2003).

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1.4. Historical Information

Historical uses of the subject property were determined based on a review of readily available, reasonably ascertainable historical data, including historical topographic maps and aerial photographs.

Based on a review of the historical information, as early as 1937 until approximately 1957, agricultural plots appear to have been developed just north of the Subject Property and extending onto the central portion of the property. Other than agriculture, the Subject Property remained undeveloped until the marina was built in approximately 1960 and the southern edge of the property, along Piscataway Creek, was extended south and southeast with fill by 1963.

The basic configuration of the property changed little from the late 1960s through approximately 1994 when the property was developed into its present configuration.

The Subject Property was obtained by the DOI in 1974 in a legislative taking action.

1.5. 2016 Phase I ESA The Phase I ESA (Ausangate 2016) was consistent with requirements set forth under the AAI standards described in 40 CFR 312 and 33 CFR 137 and the ASTM Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process (ASTM designation E1527-13).

1.5.1. Summary of 2016 Phase I ESA Findings

Ausangate identified two significant data gaps and seven RECs associated with the Subject Property. Ausangate also identified one historical REC and made two additional investigation recommendations. The Findings, Conclusions, and Recommendations from the Phase I report (Ausangate 2016) are as follows:

Data Gaps

Ausangate identified two significant data gaps during the Phase I ESA.

Data Gap 1: Historical USTs

Four historical USTs were reportedly removed from the subject property. They include two, 4,000-gallon gasoline tanks and one, 4,000-gallon diesel fuel tank that were installed in 1960, and a 560-gallon heating oil tank installed in 1988. The four USTs were reportedly removed in 1990, meaning that the 4,000-gallon tanks had been in the ground for 30 years. MDE reported that the UST’s case file (# 90-0957-PG) was closed, but Ausangate could obtain no documentation that the tank graves were clean or whether contamination was left in place. It would be typical for USTs of such age to have leaked and for surface spills due to fuel handling around the tank to be more prevalent considering different historical operating standards. In the absence of confirmation sampling from the former tank graves, the site of the former USTs was considered a significant data gap.

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• Recommendation: Ausangate recommends that NPS make an additional effort to obtain confirmation paperwork from its internal files and/or from the lessee (MDNR), as MDE has reported that their files were destroyed under a document retention policy. In the absence of confirmation that no contamination was left in the tank graves, NPS had three options for addressing the site:

1. Assume that the site is completely clean;

2. Consider the site a controlled recognized environmental condition and place activity use limitations on the site (e.g., limit disturbance of the site); or,

3. Conduct a subsurface investigation and collect soil samples to confirm the presence or absence of petroleum hydrocarbon contamination associated with the former USTs. NPS chose to collect soil samples at this location.

Data Gap 2: Fiberglass Fabricators Conex Storage Box

Ausangate could not inspect the Fiberglass Fabricators shop or a white Conex storage box used as chemical storage by Fiberglass Fabricators. A “No Smoking” sign was attached to the door of the Conex box, indicating that it contained flammable substances.