GSA Regional Office Building Phase I Environmental Site ...Berger) conducted a Phase I Environmental...

GSA Regional Office Building Phase I Environmental Site Assessment 301 7th Street SW Washington, DC 20024

Prepared for:

301 7th Street SW Washington, DC 20024 Prepared by:

The Louis Berger Group, Inc. 1250 23rd Street NW Washington, DC 20037 September 2014

Phase I Environmental Site Assessment GSA Regional Office Building, Washington, DC

The Louis Berger Group, Inc. TOC-i September 2014

Table of Contents Title

List of Acronyms ......................................................................................................... TOC-iii Executive Summary ........................................................................................................ ES-1 1.0 Introduction ............................................................................................................. 1-1 2.0 Site Description and History .................................................................................... 2-1

2.1 Location and Legal Description ............................................................................................ 2-1 2.2 Site and Vicinity Characteristics ........................................................................................... 2-1

2.2.1 General Site Description ........................................................................................ 2-1 2.2.2 Vicinity Characteristics .......................................................................................... 2-2

2.3 Information Reported by User Regarding Environmental Liens or Specialized Knowledge of Environmental Issues .................................................................................... 2-2

2.4 Current Uses of the Site ........................................................................................................ 2-3 2.5 Past Uses of the Site .............................................................................................................. 2-3

2.5.1 General Property History ........................................................................................ 2-3 2.5.2 Historical Property Ownership (Deed Review) ..................................................... 2-4

2.6 Current Uses of Adjoining Property ..................................................................................... 2-4 3.0 Environmental Records Review ............................................................................... 3-1

3.1 Environmental Database Review of the Site and Surrounding Area ................................. 3-1 3.1.1 Federal Records ...................................................................................................... 3-2 3.1.2 State, Local, and Tribal Records ............................................................................ 3-5 3.1.3 Other Records ......................................................................................................... 3-7

3.2 Historical Use Information .................................................................................................... 3-9 3.2.1 Aerial Photograph Review...................................................................................... 3-9 3.2.2 Historical Fire Insurance Maps ............................................................................. 3-10 3.2.3 City Directory .......................................................................................................... 3-11 3.2.4 Topographic Maps ................................................................................................. 3-12 3.2.5 Wetlands ................................................................................................................. 3-12

3.3 Additional Record Sources .................................................................................................. 3-12 3.3.1 Prior Reports .......................................................................................................... 3-12 3.3.2 Site Contacts .......................................................................................................... 3-13

4.0 Information from Site Reconnaissance and Interviews ............................................ 4-1 4.1 Methodology and Limiting Conditions ................................................................................. 4-1 4.2 General Site Setting ............................................................................................................... 4-2 4.3 Site Observations ................................................................................................................... 4-2 4.4 Hazardous Materials and Unidentified Substance Containers in Connection with

Identified Uses ....................................................................................................................... 4-4 4.5 Hazardous Material Containers and Unidentified Substance Containers

(Not Necessarily in Connection with Identified Uses) ........................................................ 4-5 4.6 Chemical Storage Tanks ....................................................................................................... 4-6 4.7 Odors ...................................................................................................................................... 4-6 4.8 Pools of Liquid ....................................................................................................................... 4-6 4.9 PCB Electrical Components and Indications of Other PCBs ............................................. 4-7 4.10 Heating and Cooling .............................................................................................................. 4-9 4.11 Stains or Corrosion ................................................................................................................ 4-9 4.12 Drains and Sumps ................................................................................................................ 4-10 4.13 Public Storm and Sanitary Sewers ...................................................................................... 4-10 4.14 Potable Water Supply ........................................................................................................... 4-10 4.15 Air Emissions ........................................................................................................................ 4-10 4.16 Vapor Intrusion ..................................................................................................................... 4-10 4.17 Zoning .................................................................................................................................... 4-10 4.18 Pesticides/Herbicides/Agrochemical ................................................................................. 4-11


The Louis Berger Group, Inc. TOC-ii September 2014

Table of Contents, Continued 4.19 Ponds and Lagoons .............................................................................................................. 4-11 4.20 Stained Soil or Pavement and Stressed Vegetation .......................................................... 4-11 4.21 Waste Disposal Practices and Waste Disposal ................................................................. 4-11 4.22 Wastewater ............................................................................................................................ 4-11 4.23 Water Wells or Dry Wells ..................................................................................................... 4-11 4.24 Septic System ........................................................................................................................ 4-11 4.25 Flood Zone Data .................................................................................................................... 4-12 4.26 Electromagnetic Fields ......................................................................................................... 4-12 4.27 Fill Material ............................................................................................................................ 4-12 4.28 Environmental Liens or Activity and Use Limitations ........................................................ 4-12 4.29 Specialized Knowledge of Environmental Issues ............................................................... 4-12 4.30 Commonly Known or Reasonably Ascertainable Information .......................................... 4-13 4.31 Valuation Reduction for Environmental Issues .................................................................. 4-13 4.32 Owner, Property Manager, and Occupant Information ...................................................... 4-13

5.0 Conclusions and Recommendations ........................................................................ 5-1 6.0 Limiting Conditions, Deviations and Data Gaps ....................................................... 6-1 7.0 Qualifications of Environmental Professionals Conducting this Assessment ........... 7-1 8.0 References ............................................................................................................... 8-1

Figures Figure 1. Site Location Map ......................................................................................................................... 1-2 Figure 2. Site Aerial Map ............................................................................................................................. 1-3

Tables Table 1. RCRA Facilities within 0.5 mile of the Site .................................................................................. 3-3 Table 2. LUST Cases within 0.5 mile of the Site ........................................................................................ 3-5

Appendices Appendix A User Provided Information

User Questionnaire Transaction Screen Questionnaire FOIA Requests Correspondence

Appendix B Site Photographs Appendix C Historic Maps and Aerial Photographs

Sanborn Fire Insurance Maps Historic USGS Topographic Maps Historic Aerial Photographs City Directories

Appendix D Environmental Database Report Appendix E Professional Profiles


The Louis Berger Group, Inc. TOC-iii September 2014

List of Acronyms ACM Asbestos-Containing Materials AIHA American Industrial Hygiene Association ASTM American Society for Testing and Materials AST Aboveground Storage Tank CERCLA Comprehensive Environmental Response, Compensation and Liability Act CERCLIS Comprehensive Environmental Response, Compensation and Liability Information

System CERCLIS NFRAP CERCLIS No Further Remedial Action Planned CORRACTS Corrective Action Reports DDOE District Department of the Environment EDR Environmental Data Resources, Inc. ERNS Emergency Response Notification System ELAP Environmental Laboratory Approval Program ESA Environmental Site Assessment FIFRA Federal Insecticide, Fungicide and Rodenticide Act FINDS Facility Index System FOIA Freedom of Information Act FUDS Formerly Used Defense Sites HMIRS Hazardous Materials Tracking System HUD United States Department of Housing and Urban Development LAST Leaking Aboveground Storage Tank LBP Lead-Based Paint LQG Large Quantity Generator LUST Leaking Underground Storage Tank MSL Mean Sea Level NPL National Priorities List NVLAP National Voluntary Laboratory Accreditation Program OEPA Ohio Environmental Protection Agency O&M Operations and Maintenance ODI Open Dump Inventory OSHA Occupational Safety and Health Administration PADS PCB Activity Database System PCB Polychlorinated Biphenyls ppm Parts Per Million pCi/l Picocuries Per Liter RCRA Resource Conservation and Recovery Act RCRA-TSD RCRA Treatment, Storage and Disposal Facility REC Recognized Environmental Condition RFI RCRA Facility Information ROD Record of Decision SCL State Equivalent CERCLIS List SHWS State Hazardous Waste Site SQG Small Quantity Generator SWLF Solid Waste Landfill Facilities TCLP Toxicity Characteristic Leaching Procedure TRIS Toxic Chemical Release Inventory System TSCA Toxic Substances Control Act TSD Treatment, Storage and Disposal Facility TSQ Transaction Screen Questionnaire USACE United States Army Corps of Engineers USDA United States Department of Agriculture USEPA United States Environmental Protection Agency USGS United States Geological Survey UST Underground Storage Tank


The Louis Berger Group, Inc. Page ES-1 September 2014

Executive Summary On behalf of the U.S. General Services Administration (GSA) The Louis Berger Group, Inc. (Louis Berger) conducted a Phase I Environmental Site Assessment (ESA) on May 9, 2014 of the approximately 150,000-square foot, GSA Regional Office Building (ROB) parcel located at 301 7th Street SW in Washington, DC (the “Site”). The Site is currently owned by GSA. GSA intends to exchange the Site and another GSA-owned site for the acquisition of construction and related services to be used to repair and renovate the existing GSA Headquarters building at 1800 F Street NW and up to three historic buildings within the Department of Homeland Security (“DHS”) Headquarters Campus located in southeast Washington, DC. The GSA ROB property is the subject of this Phase I ESA.

The Site is located in the southwestern quadrant of Washington, DC, approximately 1,300 feet south of the National Mall. The Site is bordered on the north by railroad tracks used by the MARC commuter rail and CSX to transport chemicals, on the east by 7th Street SW, on the south by D Street SW, and on the west by the 9th Street SW underpass. The area surrounding the Site houses federal and private office buildings as well as the L’Enfant Plaza Metro Station. The purpose of this Phase I ESA is to determine any obvious areas or potential sources of environmental concern for liabilities that might exist at the Site; identify to what extent these sources are likely to impact the Site; and to report on our findings to assist GSA in assessing the need for any further investigations or analytical work that may be required to accurately determine the presence and extent of any detected or suspected contamination. The ESA was conducted in accordance with the scope and limitations of the American Society for Testing Materials (ASTM) Standard E 1527-13, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process; Title 40 of the Code of Federal Regulations (CFR) Part 312, Innocent Landowners, Standards For Conducting All Appropriate Inquiry (AAI); and the “due diligence” regulations of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and Section 9601 (35)(B) of the Superfund Amendment and Reauthorization Act (SARA). Based on the data obtained during the Site reconnaissance, review of maps and photographs, review of environmental regulatory databases, and interviews with property owners and persons familiar with the Site and its history, Louis Berger identified the following Recognized Environmental Condition (REC) and Controlled REC (CREC). Louis Berger did not identify any Historic RECs (HRECs).

RECOGNIZED ENVIRONMENTAL CONDITIONS

PCB contamination in a transformer vault drain - PCB-containing transformers were replaced in 1991. PCB-contaminated concrete was documented during the removal project in the PCB Transformer Removal and PCB Removal and Transformer Replacement Report from Hill International. PCB cleanup and testing activities occurred between 1991 and 2006 until levels were found to be below the cleanup standard for low-occupancy, porous sufaces, no change in use (25 ppm) and the vaults were encapsulated with two layers of paint. However, a



1991 report indicates that in 1989, PCB contamination was discovered in a drain located in the northwest transformer vault. Based on review of historical documentation and interviews with site personnel, no records indicate that the drain contamination was further investigated. Documentation could not confirm where the drain leads, but it is assumed to connect to the sanitary sewer system. Additional testing is warranted to confirm the presence or absence of elevated PCB levels in the drain.

CONTROLLED RECOGNIZED ENVIRONMENTAL CONDITIONS

Controlled PCB levels in the transformer vaults – The transformer vaults have been cleaned below the regulatory threshold (25 ppm) for low occupancy, porous surface areas with no change in use. The vaults are encapsulated with two layers of paint in accordance with EPA regulations. The PCB levels in the transformer vault are below regulatory levels. If there is a change in use of the transformer vaults and the area is no longer considered low occupancy, the area may need to be cleaned to more stringent regulatory standards. Further, it is recommended that GSA continue to maintain the double-painted transformer vault floors. The northwest transformer vault floor was found to be in need of re-painting.

OTHER RECOMMENDATIONS Based on interviews with site personnel, site reconnaissance and records review, Louis Berger identified other potential environmental concerns that do not meet the criteria of RECs, HRECs or CRECs, but may present current or future environmental concerns:

Former fluorescent bulb crusher – According to interviews with Site personnel a fluorescent bulb crusher was operated in the O&M paint room. The bulb crusher was removed around 2012. After removal, pieces of broken bulb were observed in the paint room. Although the pieces of broken bulb were subsequently discarded, no specific mercury cleanup activities reportedly occurred following the removal of the bulb crusher. Therefore, it is possible that mercury residue is present in the paint room. Suggest testing the vicinity of the former bulb crusher for mercury residue. If found, the area should be cleaned in accordance with applicable regulations.

Rusted SUVA 123 Refrigerant Drums – Two SUVA 123 refrigerant drums are located in the paint room. Both drums are rusting at the bottom because they are subjected to standing water leaking into the paint room. Standing water in the paint room should be removed and prevented. The two drums containing SUVA 123 should be inspected for leaks and protected. If the integrity of the drums appears to be compromised, the contents should be transferred into another container.

Standing Water in Paint Storage Room – As mentioned above, standing water persists within the paint storage room. Because this room contains various paints, solvents and



chemicals and formerly housed a fluorescent bulb crusher, it is possible that the standing water contains mercury or other chemicals. Suggest removing standing water and testing before disposal to determine if it should be characterized as hazardous.

Standing Water throughout the Building – Standing water was observed throughough the basement of the ROB. Suggest removing and controling standing water throughout the facility basement. Where standing water persists, ensure that chemicals are elevated above the standing water.

Dispose of Unused Chemicals – Around 25 drums of lithium bromide were observed during the Site reconnaissance. Removing these and other unused chemicals and disposing or storing them in accordance with applicable regulations will minimize the future potential risk for leaks or spills.

AST – No information was available on testing of the existing ASTs. Suggest regular inspection and testing of ASTs and cleanup of any spillage.

Manage existing asbestos-containing material (ACM) and lead-based paint (LBP) – Previous reports have documented the presence of ACM and LBP throughout the building. ACM and LBP should be managed in accordance with applicable regulations. ACM and LBP are outside of the scope of this Phase I ESA and are therefore not discussed further in this report.

In addition, it is possible that contamination may exist along the railroad tracks from railroad ties treated with creosote or other substances, leaks from trains, oil (potentially containing PCBs) spread along the railroad to suppress dust, and/or reported or unreported spills of hazardous materials. Therefore, if excavation is planned near the railroad tracks as part of a building renovation project, a subsurface investigation is recommended. Louis Berger did not conduct a formal deed or title search of previous owners or uses of the Site, and this information was not furnished by GSA. However, based on the available information, Louis Berger believes it has obtained adequate data to determine potential historic uses of the Site, and no data gaps were identified that significantly affected our ability to identify recognized environmental conditions associated with the property. Any deviations from ASTM Standard Practice E 1527-13 are described in Section 6.0 of this report.


The Louis Berger Group, Inc. Page 1-1 September 2014

1.0 Introduction On behalf of the U.S. General Services Administration (GSA) The Louis Berger Group, Inc. (”Louis Berger”) conducted a Phase I Environmental Site Assessment (ESA) on May 9, 2014 of the approximately 150,000-square foot, GSA Regional Office Building parcel located at 301 7th Street SW in Washington, DC (the “Site”). The Site is currently owned by GSA. GSA intends to exchange the Site and another GSA-owned site for the acquisition of construction and related services to be used to repair and renovate the existing GSA Headquarters building at 1800 F Street NW and up to three historic buildings within the Department of Homeland Security (“DHS”) Headquarters Campus located in southeast Washington, DC. The exchange would allow GSA to leverage the value of the existing underperforming properties and create opportunities consistent with the private development goals of southwest Washington, DC. Only the GSA Regional Office Building property is the subject of this Phase I Environmental Site Assessment (ESA). The Site is located in the southwestern quadrant of Washington, DC, approximately 1,300 feet south of the National Mall. The Site is bordered on the north by railroad tracks, on the east by 7th Street SW, on the south by D Street SW, and on the west by the 9th Street SW underpass. The area surrounding the Site houses federal and private office buildings as well as the L’Enfant Plaza Metro Station. Based on discussions with the current property owner and a review of historical information, the Site has supported some form of development since at least 1888 with the current structure being constructed from 1931-1935. The Site location is depicted in Figures 1 and 2.

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The ESA was conducted in accordance with the scope and limitations of the revised American Society for Testing Materials (ASTM) Standard E 1527-13, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process, which includes and satisfies the U.S. Environmental Protection Agency’s (EPA’s) “All Appropriate Inquiry” rule; and the “due diligence” regulations of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and Section 9601 (35)(b) of the Superfund Amendment and Reauthorization Act (SARA). The cited regulations require that “all appropriate inquiry” be made into the presence, or likely presence of hazardous materials or petroleum products in, on, or at the Site due to release to the environment; under conditions indicative of a release to the environment; or under conditions that pose a material threat of a future release to the environment, which are defined as recognized environmental conditions (RECs). In addition, other environmental issues and conditions that, in the opinion of the environmental professional conducting the assessment, would not be considered RECs are identified in this assessment. These may include controlled RECs, historical RECs or de minimis conditions. The Phase I ESA also includes a review of environmental agency databases; historical maps, photos, and documents; visual observation of the Site and adjoining properties; readily available data provided by federal, District of Columbia, and local sources; and interviews with the Site owners and representatives. This report presents the findings and recommendations of the ESA conducted at the Site. The ESA was performed to advise GSA of potential environmental liabilities associated with the Site, if any. The purpose of this assessment was threefold:

1. To determine any obvious areas or potential sources of environmental concern for liabilities that might exist at the Site;

2. To determine to what extent these sources are likely to impact the Site; and

3. To present a report of findings that will assist GSA in assessing the need for further

investigations or analytical work that may be required to accurately determine the presence and extent of any detected or suspected contamination.



2.0 Site Description and History

2.1 Location and Legal Description The Site is located at 301 7th Street SW on D Street SW between 7th and 9th Streets SW in Washington, District of Columbia. The Site Location Map (Figure 1) and the Site Aerial Map (Figure 2) depict the general location and layout of the Site. The Site is identified as Tax Lot 802, Square 410 and Tax Lot 812, Square 434. The parcel is currently owned by the U.S. General Services Administration.

2.2 Site and Vicinity Characteristics

2.2.1 General Site Description The 150,000-square-foot Site consists of a seven-story structure with basement and roof levels. A paved driveway/parking area surrounds the structure on the north and west. Loading docks and a trash compactor are located at the northwest portion of the building within this paved area. Floors one through seven house offices for GSA and DHS characterized by typical administrative uses. The basement level contains a parking garage, transformer vaults, storage rooms, operation and maintenance shops, mechanical housing, and trash and recycling room. The roof of the structure supports chiller rooms, a cooling tower, and electrical feeds for the L’Enfant Metro across D Street SW as well as chiller rooms and other equipment for the Site itself. The Site has been developed in some way since at least 1888. Construction on the current structure located on the Site started in 1931 and was completed in 1935. Multiple modifications and renovations, mainly to the interior of the building, have occurred since its construction. Although the Site is zoned by the District of Columbia as Commercial and is within the C-3-C District, federal property owners are not required to follow zoning regulations. Figure 2 is an aerial map of the Site and general project area. A completed Transaction Screen Questionnaire (TSQ) form is presented in Appendix A. Representative photographs of the Site taken during the May 2014 Site visit are presented in Appendix B. Historic USGS topographic maps of the area ranging from 1885 to 1994, historic aerial photographs of the Site area ranging from 1949 to 2012, City Directories of the Site area, and historic Sanborn Fire Insurance Maps for the Site vicinity are included in Appendix C.

Environmental Setting The Site is generally flat with a topography gradient to the northeast. Site elevation is approximately 28 feet above sea level. The Site is located in the Coastal Plain Physiographic Province. Soils are considered to be within the Urban Land soil map unit. The area has been disturbed and developed



and therefore it is likely that fill material is present. There are no wetlands or streams located on the Site. The Site is almost entirely covered with impervious surfaces. The only vegetation present on the Site is a small amount of ornamental plants on the south and east sides of the building. General Observations Based on field reconnaissance, Louis Berger observed the Site to be in good to fair condition with no obvious evidence of accidental releases to the environment. The former location of the closed and removed underground storage tank (UST) was inspected, and no evidence of the UST presently exists on site. The active aboveground storage tanks (ASTs) and associated fill and vent pipes were inspected. Some minor staining within the secondary containment of the primary AST and piping was observed, but Louis Berger considers this to be a de minimus condition. No staining was observed around the fill port. The ROB contains office space on floors one through seven. The roof houses elevator machine rooms and cooling equipment. No staining was observed on the roof. The basement contains a parking garage, loading dock, transformer vaults, operations and maintenance rooms, storage rooms, and equipment. Standing water was observed in several locations, but no odors or staining was detected. No staining was observed within the transformer vaults. Paint and cleaning supplies were observed within the ROB. The storage of these items appeared adequate with no evidence of significant spilling or staining. Solid waste is discarded in on-site dumpsters and trash compactors. No signs of dumping, distressed vegetation or soil staining were observed during the 2004 Phase I ESA or during the May 2014 Site visit.

2.2.2 Vicinity Characteristics The Site is located in the southwestern quadrant of Washington, DC approximately 1,300 feet south of the National Mall and 3,100 feet east of the Potomac River. Land uses in the general vicinity of the Site are predominately federal, local public, mixed use, commercial, or parks and open spaces with some low to medium density residential further to the south. General vicinity characteristics are shown in Figures 1 and 2.

2.3 Information Reported by User Regarding Environmental Liens or Specialized Knowledge of Environmental Issues

The current property owner representatives have indicated that they are not aware of any environmental liens or any environmental issues in connection with the Site. In addition, no records of such liens or issues have been made available to Louis Berger and none are expected to exist.



2.4 Current Uses of the Site The Site is currently used primarily as an administration building for the National Capital Region of the General Services Administration (GSA). In addition to GSA administrative space, the Site also supports office space for the DHS. The roof contains elevator machinery and cooling equipment for the Site as well as other mechanical and cooling equipment for the L’Enfant Metro Station located to the south across D Street SW. The Site includes on-site gym facilities for employees.

2.5 Past Uses of the Site

2.5.1 General Property History Based on interviews with Site personnel, records review and field reconnaissance the Site has changed significantly over the years. The earliest available historical record, a 1888 Sanborn map, showed that the documented uses of the site at the time were as a lumber yard, a religious school, residential dwellings, and stores and shops. By 1928, the Site still housed the lumber yard and dwellings on its western side. However, the Sanborn map indicated that the eastern side contained flats, dwellings, and stores including an ornamental plaster works, a carpenter shop, and a drug store. The federal government acquired the Site in 1930-1931 as the site for a Federal Warehouse to serve as a central depot for supplies intended for other federal government agencies. The first phase of the two phase project commenced in October 1931. A seven-story reinforced concrete structure was constructed on the western portion of the Site at this time. Beginning in 1932, the seventh floor served as office space with the other floors designed as storage space. Supply distribution was provided by the Baltimore and Potomac Railroad located adjacent to the north through use of a rail spur located on the north side of the first floor and loading docks for trucks in the basement and on the south side of the first floor. The first occupants of the offices were the General Supply Committee within the Department of the Treasury as well as the Office of Public Buildings and Public Parks. The Department of the Treasury Public Works Branch relocated to the Federal Warehouse in October 1933. The eastern side, and second phase, was completed in November 1935 providing many more office spaces to the Federal Warehouse. The recently formed Procurement Division of the Treasury Department began to occupy office and warehouse space following completion of the second phase (DCHPO, 2013). During World War II, the Site served as a supply depot for a wide variety of items. Soon after its formation in 1949, GSA used the Site as offices for its headquarters (DCHPO, 2013). From 1931 to 1957 the Site was likely used mainly as warehouse and office space; however, other undocumented uses were also possible. Full conversion of the remaining warehouse space into office space occurred at the Site in 1957. Additional significant building modernization activities occurred in 1964. Between 1970 and the 1990s, numerous small projects were completed to upgrade equipment, conduct repairs and suit changing tenant needs. None of the historical documentation indicates other historical uses of the Site beyond warehousing and office space. Historical photos contained in the DC State Historic Preservation



Office Determination of Eligibility Form were reviewed and no photos showed evidence of past uses involving hazardous materials. However, Ms. Gretsky-Williams and Mr. Hanshaw, who are both long-term GSA employees and building occupants, both recall commercial printing operations and photo development operations on the second floor. It is unknown when the photo development occurred. Commercial printing activities stopped around 1995. The type of materials used for photo development is unknown. Commercial printing activities would have used hazardous cleaning solvents. Ms. Gretsky-Williams was not aware of any spills or violations associated with printing or photo development. GSA was not able to provide records documenting these activities. At the time of the 2004 Phase I ESA the Site housed office space for GSA, DHS, and the U.S. Department of Education.

2.5.2 Historical Property Ownership (Deed Review) Site deeds were not provided to Louis Berger. Based on the information from the current property owner, the Site has been owned by the U.S. Government since 1930-1931. Prior to U.S. Government acquisition, the site supported development as far back as 1888 according to Sanborn fire insurance maps. The supported past uses include a lumber yard, religious school, carpenter shop, drug store, ornamental plaster works, dwellings, flats, and other stores. Following U.S. Government acquisition, the Site was redeveloped beginning in 1931 with completion of the full structure in 1935. The constructed building was primarily used as storage and office space for much of its history with other uses such as printing and photograph development suggested through discussion with current owners. Current uses are solely as office space for federal government departments. Louis Berger was unable to review deed and title information back to the year 1940; however, additional sources including Sanborn maps are available to confirm previous uses. Louis Berger has no reason to believe historical property ownership is a concern with respect to identifying recognized environmental conditions or other potential environmental issues of concern on the Site.

2.6 Current Uses of Adjoining Property The Site is bound by railroad tracks to the north, 7th Street SW to the east, D Street SW to the south, and an alley and the 9th Street SW underpass to the west. Federal and commercial office buildings and the L’Enfant Plaza Metro Station surround the Site. Through site reconnaissance, the railroad appears to be in good condition. However, as stated in the 2004 Phase I ESA, it is possible that contamination may exist along the railroad tracks from railroad ties treated with creosote or other substances, leaks from trains, oil (potentially containing PCBs) spread along the railroad to suppress dust, and/or reported or unreported spills of hazardous materials. North of the railroad tracks are a public open space, Hancock Park, and the Federal Aviation Administration building. Federal structures housing offices for the U.S. Department of Health and Human Services and the National Renewable Energy Laboratory Washington, DC Office are located to the west of the Site. Across D Street SW to the south are the Department of Housing and Urban Development and L’Enfant Plaza and Metro Station. A private office building with ground-level retail



shops is located to the east of the Site. Other buildings in the surrounding area house other federal agencies, private offices, and commercial and retail operations. Several adjoining properties were reported in the EDR report as RCRA-CESQG, DC UST, DC AST, or DC HIST UST. None of these properties currently has violations and none is believed to pose a threat to the Site. There were no obvious observations of any environmental conditions that would affect the Site. Past uses of adjoining property is discussed in Section 3.2.2.



3.0 Environmental Records Review

3.1 Environmental Database Review of the Site and Surrounding Area

The regulatory review for the Site consisted of a database review of federal and state potential hazardous waste generators and facilities located within a specific radius of the Site that have environmental concerns and could, therefore, have a potential environmental impact on the Site. The radius and data search review was provided by EDR of Milford, Connecticut, Inquiry Number 3935946.2s, dated May 7, 2014 and encompasses data lists maintained by EDR from database information supplied primarily by the United States Environmental Protection Agency (USEPA) and the District Department of the Environment. The EDR Radius report is presented in Appendix D. All database profiles were performed to ASTM standard criteria. The databases maintained by EDR include, but are not limited to, the following:

National Priorities List (“NPL”) and Delisted NPL Sites

Corrective Action Reports (“CORRACTS”)

Comprehensive Environmental Response, Compensation and Liability Information System (“CERCLIS”)

CERCLIS No Further Remedial Action Planned (“CERCLIS-NFRAP”)

Resource Conservation and Recovery Act (“RCRA”) - Treatment, Storage and Disposal Facilities (“RCRA TSD”)

RCRA Hazardous Waste Large Quantity Generators

RCRA Small Quantity Generators

Emergency Response Notification System

State Hazardous Waste Site List (“SHWS”)

State Solid Waste Landfill Facilities (“SWF/LF”)

Leaking Underground Storage Tank Database (“LUST”)

Aboveground Storage Tank Database (“AST”)

State Registered Underground Storage Tanks (“USTs”)

State Voluntary Cleanup Program (“VCP”) Sites

Sites with Controls (“AUL”).

1



3.1.1 Federal Records The EDR Report identified the Site and/or other facilities in the Site vicinity on the following federal databases:

RCRA-Conditionally Exempt Small Quantity Generator (CESQG): This database includes information on sites which generate, transport, store, treat, and/or dispose of hazardous waste as defined by the RCRA. Conditionally exempt small quantity generators generate less than 100 kilograms (kgs) of hazardous waste, or less than 1 kg of acutely hazardous waste per month.

RCRA-Small Quantity Generator (SQG): This database also includes information on sites which generate, transport, store, treat, and/or dispose of hazardous waste as defined by the RCRA. Small quantity generators generate between 100 kg and 1,000 kg of hazardous waste per month.

CERCLIS No Further Remedial Action Planned (CERC-NFRAP): These archived sites are sites that have been removed and archived from the inventory of CERCLIS sites. Archived status indicates that, to the best of EPA’s knowledge, assessment at a site has been completed and that EPA has determined no further steps will be taken to list this site on the NPL, unless information indicates this decision was not appropriate or other considerations required a recommendation for listing at a later time. This decision does not necessarily mean that there is no hazard associated with a given site; it only means that, based upon available information, the location is not judged to be a potential NPL site.

The EDR report identified the Site on the RCRA database as a RCRA non-generator and a RCRA-CESQG.

RCRA NonGen/NLR: The Site is listed as EPA ID No. DCP000003596 (this number is currently inactive). As of April 24, 2012, the Site was designated as a non-generator, indicating that the facility does not presently generate hazardous waste. The Site was historically designated as a RCRA-CESQG in February 2012. As a CESQG, the Site previously generated ignitable hazardous waste such as paint solvent. No RCRA violations were identified.

RCRA-CESQG: The Site is listed as EPA ID No. DCR000505198 (this number is currently active) and was identified as a CESQG in March 2012. According to the EDR report, the Site previously generated hazardous waste containing mercury. Based on interviews with site personnel, the facility previously operated a fluorescent bulb crusher. Waste generated from the bulb crusher contained mercury and was characterized as hazardous. The facility stopped operating the bulb crusher later in 2012. The used bulbs are now managed intact as Universal Waste. The last RCRA compliance inspection was conducted on February 25, 2014. No violations were identified.



The following facilities have been identified within the federal records search database:

Four CERC-NFRAP sites were identified within 0.5 mile of the Site.

o 2009 Presidential Inauguration located at 1000 Independence Avenue NW (0.16 mi upgradient from the Site). The site was assessed between 2008 and 2009. The EPA determined that no further federal action is needed and the site was archived in December 2011. According to a telephone conversation with Charlie Fitzsimmons with the USEPA, this record is regarding deployment of resources in advance of the 2009 presidential inauguration. No spill or contamination occurred. Therefore, this facility does not pose a concern to the Site.

o Hubert H. Humphrey Building located at 200 Independence Avenue (0.41 mi downgradient from the Site). Unspecified contaminants were discovered at the site in April 1991. The site was assessed and archived in May 1992.

o Food & Drug Administration located at 200 C Street SW (0.45 mi downgradient from the Site). Unspecified contaminants were discovered at the site in April 1998 and the site was archived shortly after discovery. A preliminary assessment was subsequently conducted in August 1996. The site is still identified as an archive site. Based on the distance from the Site and its location downgradient from the Site, no adverse impacts to the Site are anticipated.

o EPA Mail Rooms located at 1200 Constitutional Avenue (0.5 mi downgradient from the Site). The site was assessed in October 2001 and archived in December 2011. Based on the distance from the Site and its location downgradient from the Site, no adverse impacts to the Site are anticipated.

Three RCRA-SQGs and 22 RCRA-CESQGs are located within 0.5 mile of the Site. The facilities identified are summarized in Table 1.

Table 1. RCRA Facilities within 0.5 mile of the Site

Direction Distance (ft)

Facility Name and Address

Classification Comments

SW 606 L’Enfant Plaza955 L’Enfant Plaza SW

SQG No violations found.

NW 1,092 Smithsonian Institution – South Mall Zone 1100 Independence Ave NW

SQG The facility has received notices of violation. All of the reported violations have been written informal and the facility has achieved compliance.

NNW 1,071 Smithsonian Institution Arts 900 Jefferson Drive

SQG The facility has received two notices of violation. Both were written informal and the facility has achieved compliance.

WSW 83 901 D St SW CESQG No violations found.




Facility Name and Address Classification Comments

WNW 643 National Transportation Safety 490 L’Enfant Plaza East

CESQG No violations found.

SW 657 L’Enfant Colony, LLC CESQG No violations found.NW 933 Dept of Energy -

Washington CESQG The facility has

received two notices of violation. Both were written informal and the facility has achieved compliance.

SW 1002 USPS - Headquarters CESQG The facility has received one notice of violation. It was written informal and the facility has achieved compliance.

WSW 1250 Potomac Center South CESQG No violations found.WSW 1250 Potomac Center North CESQG No violations found.WSW 1250 Potomac Center CESQG No violations found.

ESE 71 Constitution Center CESQG No violations found.ESE 600 400 6th Street SW CESQG No violations found.

N 657 US Department of Transportation – Orville Bldg

CESQG The facility has received two notices of violation. Both were written informal and the facility has achieved compliance.

E 715 Holiday Inn Capitol CESQG No violations found.ENE 716 Capital Gallery CESQG No violations found.ENE 716 Smithsonian Institution

at Capital Gallery CESQG No violations found.

SE 819 Commons at Town Square Apartments


NE 907 Smithsonian Institution – National Air & Space Museum


ENE 943 Federal Center Plaza II CESQG No violations found.E 1091 CVS Pharmacy #0283 CESQG No violations found.

ESE 1160 500 E Street CESQG No violations found.WSW 1204 445 12th Street CESQG No violations found.

E 1263 Federal Center Plaza 1 CESQG No violations found.ESE 1269 400 Virginia Avenue,

LLC CESQG No violations found.



3.1.2 State, Local, and Tribal Records The EDR Report identified the Site and/or other facilities in the Site vicinity on the following state local and tribal databases:

DC Underground storage tank (UST): The UST database contains registered USTs.

DC Historic UST: During the process of a database upgrade, all facilities that the UST Program was unable to confirm their existence were removed from the working UST Database.

DC Leaking Underground Storage Tank (LUST): The LUST database contains an inventory of reported leaking underground storage tank incidents.

DC Aboveground Storage Tank (AST): The AST database contains registered ASTs.

The EDR report identified the Site in the Underground storage tank (UST) database. The Site is not identified in any other state or local databases.

UST: The Site is identified as having one, 3,000 gallon diesel UST that is permanently out-of-service.

The following facilities have been identified within the state records search database:

LUST: Fifteen DC LUST sites are located within 0.5 mile of the Site. The facilities identified are summarized in Table 2.

Table 2. LUST Cases within 0.5 mile of the Site

Direction Distance

(ft) Facility Name and

Address Status Comments

Equal/Higher ElevationSW 829 Exxon

970 D Street SW Case closed

4/25/89 1989 – gasoline contaminated soil.

SW 606 L’Enfant Plaza North of C Bldg 955 L’Enfant Plaza N

Case closed1/24/92

1990 heating oil contamination of groundwater and soil.

SW 1,149 Comsat Corporation950 L’Enfant Plaza SW

Case closed6/23/1993

1992 – heating oil contamination of soil.

SW 848 Post Office L’Enfant Plaza 1025 Frontage Road SW

Case closed7/29/96


W 2,294 Bureau Engraving/Printing 301 14th Street SW

Case closed8/22/90

1990 – kerosene, unknown contamination of soil.

Lower ElevationESE 775 400 6th Street SW Case closed

1/22/91 1990 – heating oil contamination of soil.

SE 972 DPW450 6th Street SW

Administrative Closure 8/19/08

2000 – gasoline, diesel contamination of soil.

SE 972 DC Fire House450 6th Street SW

Case closed12/30/87

1987 – gasoline, diesel contamination of soil.




Facility Name and Address Status Comments

NE 1,121 Federal Aviation Building 600 Independence Ave SW

No Further Action 11/15/06


E 1,265 New CFL Bldg415 4th Street SW

No Further Action 9/20/99

1999 – gasoline contamination of groundwater and soil.

ESE 1,419 Chevron USA Inc.501 4th Street NW

Case closed4/14/97

(closure date or reported

date incorrect)


SW 1,748 Wasa Marina1300 Maine Avenue SW

Case closed4/23/10


WSW 1,795 Mandarian Hotel1330 Maryland Ave S

Case closed6/17/03

1999 – gasoline, heating oil, and diesel contamination of soil. 2002 – gasoline and heating oil contamination of groundwater and soil

NNE 2,383 National Gallery of Art600 Constitution Ave

Case closed4/6/92

1992 and 1998 – diesel contamination of soil.

SE 2,424 DC Public Schools401 I Street SW

Case closed2/14/11


Mr. Deepak Singh, Environmental Protection Specialist with the District Department of the Environment (DDOE), provided clarification on the case closure status. Administrative closure refers to cases closed by the UST Branch because of administrative errors (i.e., duplicate cases for the same address, no confirmed UST release, etc.). NFA refers to cases where the site may still have residual contamination, but remediation can cease, as no further cleanup is needed because the site satisfies the conditions of UST regulations using the DDOE Risk Based Corrective Action Guidance and Standards. When the site only meets residential standards, an institutional control NFA will be issued. Case closed refers to all other LUST cases closed after cleanup was completed. These are usually minor releases that resulted in quick cleanup and may or may not include risk assessment and vapor intrusion analysis. All three designations for closed sites refer to cases that were closed in the DDOE system and do not pose a significant risk to human health or the environment. All of the LUST cases located within 0.5 mile of the Site have been closed. None of the facilities adjacent to the Site have reported LUST cases. Of the 15 sites identified, 13 are identified as closed or administrative closure. The remaining two are designated as NFA. Both facilities are located close to 0.5 mile and downgradient from the Site. Based on the closed status and location of these two facilities, no adverse impact to the Site is anticipated.



USTs: 23 UST facilities were identified within the search distance. Aside from the LUST cases identified above, no violations were reported. Therefore, no adverse impacts to the Site are anticipated.

DC Hist UST: 9 historic USTs were identified within the search distance. This list represents facilities that the UST Program was unable to confirm. The list was finalized in December 1999. The closest record is referred to as “GSA 900 D Street SW” and is located on D Street west of the 9th Street Expressway. Based on interviews with Site personnel and records review, only one former UST was identified associated with the GSA Site. This UST was closed in 1995. It is possible that the historic record was a duplicate entry. Therefore, no adverse impact to the Site is anticipated. Based on available information, none of the other potential historic USTs located within 0.5 mile of the Site are anticipated to adversely impact the Site.

ASTs: Three registered AST facilities were identified within the search distance. No AST violations were reported. The Site has two active ASTs, but was not identified on this database. The source of the data is the Department of Consumer and Regulatory Affairs. However, ASTs in the District of Columbia are registered with the Fire and EMS Department.

3.1.3 Other Records

The EDR Report identified the Site and/or other facilities in the Site vicinity on the following state local and tribal databases:

RCRA-Non-Gen/NLR: This database includes information on sites that do not currently generate hazardous waste, but have generated hazardous waste in the past.

Integrated Compliance Information System (ICIS): The ICIS supports the information needs of the national enforcement and compliance program as well as the unique needs of the National Pollutant Discharge Elimination System (NPDES) program.

Facility Index System/Facility Registry System (FINDS): The FINDS database contains both facility information and ‘pointers’ to other sources that contain more detail.

PA Manifest: A manifest is a document that lists and tracks hazardous waste from the generator through transporters to a disposal facility. The State of Pennsylvania maintains a manifest database.

NY Manifest: The State of New York maintains a manifest database.

EDR Historic Auto Stat: EDR has compiled a list of potential historic gas station/filling station/service station sites that were available to EDR researchers.

EDR Historic Cleaners: EDR has compiled a list of potential dry cleaner sites based on EDR’s search of national collections of business directories. EDR’s review was limited to those categories of sources that might, in EDR’s opinion, include dry cleaning establishments.

The EDR report identified the Site in the following additional databases: Integrated Compliance Information System (ICIS), Facility Index System (FINDS) and Pennsylvania (PA) Manifest.



ICIS/FINDS: The Site is identified as ICIS No. 1012122746. According the EDR report and additional information obtained from the U.S.EPA website, the Site received formal enforcement actions in 1989 and 1996. The enforcement action identified in the EDR report is associated with the former UST: RCRA 9006 AO For Comp And/Or Pen (UST). No other information is provided regarding the historical enforcement actions.

PA Manifest: The Site generated hazardous waste on March 1, 2012 that was disposed of by Cycle Chem, Inc. of Lewisbury, PA. According to the EDR report, the waste included 100 gallons of a liquid characterized as D001 (ignitable waste), 50 gallons of a liquid characterized as F002 (spent halogenated solvents), 50 gallons of a liquid characterized asD001, and 50 gallons of a liquid characterized as F003 (spent non-halogenated solvents).

The following facilities have been identified within the other records search database.

RCRA NonGen: 8 facilities were identified within the search distance. These facilities are not currently generating hazardous waste and are not anticipated to pose a concern to the Site.

NY Manifest: 2 facilities on the NY Manifest database were identified within the search distance. No violations were reported and no adverse impacts to the Site are anticipated.

PA Manifest: 12 facilities on the PA Manifest database were identified within the search distance. No violations were reported and no adverse impacts to the Site are anticipated.

EDR US Hist Auto Stat list: 5 historic gas stations/filling station/service station sites were identified within the search distance. Of these, two are identified adjacent to the Site: one is located on the eastern side of 7th Street SW and the second is located on D Street west of the 9th Street Expressway. No historic auto stations were evident on the Sanborne Fire Insurance maps, which go back to 1888. An auto repair shop is evident on the 1959 Sanborn map south of where the D Street facility was identified. The facility is no longer evident in the 1977 map as the L’Enfant Plaza metro station was constructed in the area. No evidence of an auto station along 7th Street was identified in the Sanborn maps. Based on available information, none of the identified potential historic auto stations are anticipated to adversely impact the Site.

EDR US Hist Cleaners: 4 historic potential dry cleaner sites were identified within the search distance. The closed record is located at 461 L’Enfant Plaza SW at the current location of the Department of Energy Building. The Site has been developed as a government/commercial building since at least 1968 according to aerial imagery. Based on available information, none of the identified potential historic cleaners are anticipated to adversely impact the Site.

The EDR report listed 20 orphan sites (i.e., sites that were not able to be mapped due to inadequate address information). A few of the listed orphan sites are GSA buildings, but none of them include the Site. One CERC-NFRAP site and one brownfield site were identified, but neither is located within the Site vicinity. The remaining sites generally consist of spills or RCRA current or historic generators that do not appear to be located within the Site vicinity. Therefore, there are no known facilities, operations, spills, or incidents on or within a reasonable distance of the Site that would be expected to have had an adverse environmental impact on the Site.



3.2 Historical Use Information

3.2.1 Aerial Photograph Review EDR provided historic aerial photographs of the Site vicinity. The aerial photographs are provided as Appendix C. Aerial photographs of the Site are provided for the years 1949, 1951, 1963, 1968, 1971, 1981, 1984, 1988, 1994, 1998, 2000, 2005, 2007, 2008, 2009, 2011, and 2012, and are summarized below. No obvious indications of environmental concerns are revealed in any of the photographs.

1949 – The Site appears to be fully developed and contains the GSA Regional Office Building structure that currently occupies the property. The adjacent sites to the east and west appear to be lightly developed with open space as well as smaller structures of undetermined type. The land to the south of the Site appears to be a densely developed residential area containing row houses and other smaller structures. The railroad tracks bordering the north side of the property are evident in the imagery. A clearing appears to be located immediately to the north of the tracks surrounded by smaller houses and row homes. 1951 – No significant changes are evident within the property itself or the adjacent properties except for the presence of trees or some other undetermined vegetation on the east side of the Site adjacent to 7th Street SW. 1963 – No significant changes are evident within the property itself except for the removal of the vegetation adjacent to 7th Street SW that was evident in the 1951 imagery. The railroad tracks adjacent to the north of the property are still evident in the imagery. However, all other adjacent properties show significant changes. Almost all row houses and smaller structures surrounding the property that were present in the 1951 imagery appear to have been cleared. Further north of the railroad tracks and the adjacent clearing a larger structure appears to have been constructed in the parcel between 7th and 9th Streets SW that previously contained row houses. New roadways appear to be in various states of completion. These roads appear to be arterial and other higher capacity thoroughfares as opposed to the lower capacity residential type roads present in the earlier imagery. 1968 – No significant changes are evident within the property itself. The railroad tracks adjacent to the north of the property are still evident in the imagery. However, all other adjacent properties show significant changes. Most previously cleared areas surrounding the Site appear to have been developed and now contain larger structures and buildings with at least one building still in the process of construction. The imagery clearly shows the U.S. Department of Housing and Urban Development structure immediately south of the Site across D Street SW. Part of the property to the west of the Site and south of the railroad tracks is still cleared. 1971 – No significant changes are evident within the property itself. The previously cleared area to the west of the Site and south of the railroad tracks is now possibly developed but the type



and level of development is unclear in the imagery. Additionally, the L’Enfant Plaza structure which straddles 9th Street SW appears to be partially or fully constructed. 1981 – No significant changes are evident within the property itself. All previously cleared areas now contain some form of development. 1984 – No significant changes are evident within the property itself. 1988 – No significant changes are evident within the property itself. The area to the west of the Site and south of the railroad tracks now contains the larger structure, the Aerospace Building. 1994, 1998, 2000 – No significant changes are evident within the property itself. 2005 – The area on the northern portion of the Site immediately south of the railroad tracks appears to be used for outdoor parking. 2007, 2008, 2009, 2011, 2012 – No significant changes have occurred to the Site since the 2005 aerial photograph.

3.2.2 Historical Fire Insurance Maps Sanborn Fire Insurance Maps of the Site or Site vicinity were obtained for 1888, 1904, 1928, 1959, 1977, 1984, 1988, 1990, 1991, 1992, 1994, and 1998 (see Appendix C). A summary of each map including Site and Site vicinity details is provided below. 1888 – The Site is divided into a western portion, designated Square 410, and an eastern portion, designated Square 434, with 8th Street SW dividing the squares. The northern section of Square 410 contained the Church and Stephenson Lumber Yard. This area housed lumber sheds, outdoor lumber piles, and an office. Across an alley the southern portion of Square 410 contained twelve two-story row houses with frontage on D Street SW. The northwestern corner of Square 434 housed the Academy of the Sacred Heart of Mary. The eastern portion of this square contained eleven row structures mainly supporting stores with frontage on 7th Street SW or C Street SW. Areas to the south and east contained one and two-story dwellings, stores, and churches as well as a brewery fronting C and D Streets SW. To the west of Square 410, across 9th Street SW, was the Baltimore and Potomac Railroad Freight Station supported by railroad tracks to the north of the Site. Further north of the railroad tracks was a public square and additional dwellings, stores, and churches. 1904 –Square 434 in the eastern portion of the Site contained furniture and drug stores and a cobbler shop. A sausage and ice factory was located to the east of Square 434 of the Site fronting C Street SW. A railroad spur was constructed to connect to the sausage and ice factory. No other significant changes from the 1888 map are evident.



1928 – There were no evident changes to Square 410 in the western portion of the Site. In the eastern portion of the Site, within Square 434, the former location of the Academy of the Sacred Heart was designated as flats. Some of the stores on the eastern side of Square 434 remained and included an ornamental plaster works, a carpenter shop, and drug store. However, some of the stores were designated as dwellings. The area to the east of the Site was the Virginia Apartments and a meat packing location. The former rail spur is no longer evident. Additionally, passageways underneath the railroad tracks north of the Site provided access to areas north of the Site from both 7th and 9th Streets SW. The open space north of the railroad tracks was designated a park. 1959 – There were significant changes to the Site from the 1928 map. The area that previously contained Squares 410 and 434, the 8th Street SW right-of-way, and some of the C Street SW right-of-way was now U.S. Government property housing the Federal Warehouse. A rail spur has been extended to the Federal building. The area immediately south of the Site still contained dense residential dwellings, stores, and churches. Although the park north of the Site and adjacent railroad tracks remained, it appeared that the dwellings further north were no longer there. The map did not indicate anything existing in most of that area. 1977 – The Site was designated as U.S. Government Occupancy and was occupied by the Federal Warehouse. No other changes to the Site were evident. There were significant changes to the Site vicinity compared the 1959 map. No residential dwellings, flat, or stores existed anymore on properties the west, south, or east of the Site. Directly south of the Site across D Street SW contained a structure designated as Federal Office Building. Unknown office structures occupied the spaces to the west, southwest, southeast, and east of the Site. Ninth Street SW seemed to pass underneath both D Street SW and the railroad tracks north of the Site as well as a new structure, L’Enfant Plaza East and shopping center, located south of D Street SW. Federal office buildings occupied areas north and northwest of the Site and adjacent railroad tracks. 1984 – There were no evident changes to the Site or Site vicinity from the 1977 map. 1988 –There were no significant changes to the Site from the 1984 map. The structure to the west of the Site across 9th Street SW and south of the railroad tracks was marked as offices of the Aerospace Center. No other changes to the Site vicinity were evident. 1990, 1991, 1992, 1994, 1998 – There were no evident changes to the Site or vicinity after the 1988 map.

3.2.3 City Directory The City Directory records that are available are from 1931 to the present. The Site is incorrectly identified in the City Directories between 2006 and 2013 as various businesses including the National Zoological Park Visitor Center, a locksmith, civil rights commission, Federal election commission, Federal Energy Regulatory Commission, Integrity National Corporation and the Smithsonian Institution. The City Directories between 1948 and 1936 correctly identify the Site as the U.S. Bureau of Treasury. The 1931 City Directory identifies the Site as Spangler Geo batteries and Niepold Inc. art gds, which may have been two of the businesses evident in the Sanborn maps. No evidence of battery



manufacturing was evident on the Sanborn maps. The 1926 City Directory identifies the Site as Eichler Jos radio specialties and Lustine Motor Supply Company, which may also have been two of the businesses evident in the Sanborn maps. Adjacent uses reported in the City Directories appear to be consistent with historic Sanborn maps.

3.2.4 Topographic Maps Louis Berger reviewed USGS topographic quadrangle maps (Washington West, Alexandria, and Mount Vernon quads) from 1885 to 1994 (see Appendix C). The elevation of the Site is 28 feet above sea level with the general topography of the vicinity characterized by higher elevations to the south and west with lower elevations to the north and east (USGS, Washington West Quadrange, 1983; Alexandria Quadrange, 1994). The 1885 and 1894 maps show the parcels where the Site is currently located; however, no other information is evident. The 1947 through 1994 maps show the existing Regional Office Building on the Site. Greater density of development and construction of arterial roads and highways is evident on the maps beginning in 1965. The 1971 through 1994 maps show the Federal Office Building south of the Site across D Street SW as well as the existing office structures to the northwest, southwest, southeast, and east of the Site. The railroad tracks north of the site are evident in each topographic map. Review of the other topographic maps does not reveal any recognized environmental conditions or other potential environmental issues of concern.

3.2.5 Wetlands The EDR Radius Report did not identify any U.S. Fish and Wildlife Service National Wetland Inventory (“NWI”) wetlands on the Site. Based on field reconnaissance, the Site has little vegetated areas. The limited areas that are vegetated do not contain wetlands.

3.3 Additional Record Sources

3.3.1 Prior Reports The following prior reports or information documenting conditions on or uses of the Site and vicinity were reviewed by Louis Berger:

Greenhorne & O’Mara, Inc. 2004. Phase I Environmental Site Assessment GSA Regional Office Building.

Apex Environmental, Inc. 1995. Underground Storage Tank Closure Report.

MACTEC Engineering and Consulting, Inc. 2003. Report of Hazardous Materials Survey. Regional Office Building.

Tidewater, Inc. 2005. PCB Core Sampling and Analysis Report.

Tidewater, Inc. 2006a. PCB Core Sampling and Analysis Report (2nd and 3rd Rounds of Sampling).



Tidewater, Inc. 2006b. PCB Core Sampling and Analysis Report (Final Round of Sampling).

Hill International, Inc. 1991. PCB Removal and Transformer Replacement.

OMC Environmental. 1992. PCB Wipe Sampling. OMC Project No. 038-GSARB1-58.

M.A. Cecil & Associations, Inc. 2000. PCB Evaluation. Order No. GSA P-11-00-DC-0218

GSA. N.D. Scope of Work, Environmental Cleanup of Federal Government Transformer Vault Concrete Floors.

MasiMax Resources, Inc. 2002. Contract Number: GS11P01MQD0056.

Applied Environmental, Inc. 2000. PCB Transformer Sampling GSA Regional Office Building.

3.3.2 Site Contacts Information concerning the Site and the local area was obtained from the following individuals:

Daniel DiRito, GSA Property Manager (Key Site Manager), current property owner representative and occupant. In-person interview and guided site reconnaissance on May 9, 2014 and follow-up telephone conversation on June 6, 2014. Mr. DiRito has worked as the GSA Property Manager for the past two years and provided information on the current uses of the property.

Don Hanshaw, GSA Construction Representative, current property owner representative and occupant. In-person interview on May 9, 2014. Mr. Hanshaw has worked for GSA since 1978. Mr. Hanshaw provided information on current and past uses of the property.

Suzanne Hill, GSA Regional Environmental Planning Officer, current property owner representative and occupant. In-person interview on May 9, 2014. Ms. Hill has worked for GSA for the past seven years and provided information on current uses of the property.

Kelly Holland, GSA Industrial Hygienist, current property owner representative and occupant. Telephone conversation with Ms. Holland on May 14, 2015. Ms. Holland has worked for GSA for the past 22 years. She completed the User Questionnaire on April 29, 2014 and provided a CD of environmental records. Aside from the known lead, asbestos and past PCB contamination, Ms. Holland is not aware of any previous environmental spills or hazards in the building.

Trish Gretsky-Williams, Branch Manager, GSA Safety and Environmental Compliance and Fire Protection, current property owner representative and occupant. Telephone conversation with Ms. Gretsky-Williams on May 16, 2014 and August 5, 2014 and in-person discussion on July 24, 2014. Ms. Williams has worked for GSA for the past 23 years. She provided information on the PCB program. Aside from the known lead, asbestos and past PCB contamination, Ms. Gretsky-Williams is not aware of any previous environmental spills or hazards in the building.

Mario Reyas, Facilities Engineer, current property owner representative and occupant. Mr. Reyas has worked for GSA for the past three years. Mr. Reyas escorted the Environmental Professional through a portion of the building and roof.



Joe Kelly, Facilities Representative and current occupant. Mr. Kelly has worked for the GSA for the past seven years. Mr. Kelly escorted the Environmental Professional to the basement transformer vaults on July 25, 2014.

Shakira Pleasant, FOIA Officer, District Department of the Environment. Ms. Pleasant responded to a FOIA request on June 9, 2014. According to Ms. Pleasant, no incident, environmental or fire reports regarding any fires, spills or environmental discharges have been reported at the Site.

Charlie Fitzsimmons, USEPA CERCLIS Program. Mr. Fitzsimmons provided information on the 2009 Presidential Inauguration CERCLIS-NFRAP site during a telephone conversation on June 2, 2014.

Deepak Singh, Environmental Protection Specialist, District Department of the Environment. Email with Mr. Singh on June 3, 2014. Mr. Singh provided information regarding LUST case designation and cleanup standards.

Scott Rice, USEPA PCB Program. FOIA request and telephone conversations on September 23 and 29, 2014. Mr. Rice responded to an EPA FOIA Request regarding PCB cleanup activities at the ROB. EPA was unable to provide any documentation in their FOIA response dated August 14, 1014. Based on telephone conversations on September 23 and 29, 2014, Mr. Rice has worked with Ms. Gretsky-Williams on PCB cleanup activities at several GSA facilities. However, the ROB was not among the facilities he recalls working on. Mr. Rice has been with EPA since 1998. The PCB activities at the ROB began prior to his tenure, and before the new PCB regulations promogulated in 1998 requiring an approved workplan.

Information provided by these sources is included throughout this Phase I ESA report.



4.0 Information from Site Reconnaissance and Interviews

4.1 Methodology and Limiting Conditions On May 9, 2014, Louis Berger’s Ms. Heather Unger and Ms. Erin Hagan completed a field reconnaissance of the Site and a general examination of adjacent and nearby properties. The weather was sunny and in the 70’s. Photographs from the site visit are included in Appendix B. Ms. Unger conducted a follow-up review to inspect the drain in the NW transformer vault on July 25, 2014. The objective of the reconnaissance was to evaluate the Site conditions and obtain information indicating the likelihood of any potential RECs in connection with the Site that may exist prior to the potential land swap of the property. The Site was visually observed using a systematic approach to provide information regarding the following:

Obvious stained soils or distressed vegetation on the Site;

Waste generated and stored onsite;

Discarded waste;

Current uses and past uses of the Site, adjoining properties, and surrounding area;

Geologic, hydrogeologic, and topographic conditions;

Structures; and

Roads. The following was physically and/or visually observed during the Site visit:

The building exterior, adjacent roadways and railway;

The underground parking garage and tunnel;

The entire basement level, which included the AST rooms; transformer vaults, boilers and other mechanical equipment, paint storage room, O&M chemical room, plumbing shop, carpenter shop and fluorescent bulb storage area;

Mechanical areas on the 7th floor;

Building rooftop containing chiller equipment and elevator control rooms;

Representative common areas (lobby, hallway, elevators, bathrooms, etc.) on the first, second and seventh floors;

Loading docks on the first floor; and,

Representative office space on the second floor.



4.2 General Site Setting The Site is generally flat and almost entirely paved. Local topography slopes to the northeast. the Site is located in a developed government use/commercial portion of Washington, DC. Land use in the immediate vicinity of the Site includes a MARC commuter rail to the north, L’Enfant Plaza Metro station and other government and commercial properties.

4.3 Site Observations The Site is currently used by GSA and DHS as office space. As indicated previously, the Site is currently developed and has been developed to some degree since at least 1888. The present structure on the Site was constructed from 1931 to 1935. The Site has very little pervious land and vegetation and is almost predominately covered by the building and driveway/parking pavement. Office space occupies all seven floors of the existing building. The roof houses elevator machine rooms and cooling equipment. The basement contains a parking garage, loading dock, transformer vaults, operations and maintenance rooms, storage rooms, and equipment. The building is heated by district steam and chillers are used for cooling. Pepco is the building electricity supplier. The building is connected to the District of Columbia public water and sewer system. An emergency generator is housed in the basement and tested approximately once per month. Natural gas was used in the former 5th floor cafeteria, which is no longer in use. A natural gas hot water heater may be in use in the gym located in the basement level. The parking garage was observed to be in good condition with no obvious stains. The tunnel entrance located in the parking garage was visually observed and found to be empty. Two active aboveground storage tanks (ASTs) for diesel fuel associated with the emergency generator were observed on the basement level of the building. The main AST, which reportedly has a capacity of 1,500 or 1,000 gallons, is surrounded by a short brick wall used for secondary containment. Minor staining was observed within the secondary containment area and surrounding the AST piping. This staining is considered to be a de minimus condition. The 500-gallon day tank is double-walled for secondary containment. No staining was observed around the day tank. The exterior AST fill pipes and vents appeared to be in good condition. The building contains four fire suppression water tanks. Three of the four tanks are presently out of use. The building also contains two inactive ASTs that were formerly used for condensate. Recovered refrigerant was observed in ten metal containers on wooden pallets in the basement. An inactive 3,400 lb AST was observed next to the pallets. It was labeled as containing CFC-11, CFC-113 or HCFC-123. No staining or spills were observed. A chemical storage container located in the vicinity of the recovered refrigerant contained used oil and air compressor oil. No staining or spills were observed. Standing water was observed in several areas on the floor associated with water pipe leakage or condensation. Absorbent socks were used in some of these areas to absorb the leaking water. No



sheen was observed on the surface of the standing water. Numerous drains are located on the basement level. No sheens were observed in the drains. The parking garage drains into the public sewer system. Several transformer vaults are located in the basement. Discussion with the current owner indicated that the concrete floor of some of these vaults had shown signs of staining potentially due to PCB spills but that these areas had been cleaned. There was no evident sign of staining in any of the transformer vaults during the 2014 site visit. However, there was signage on the entry door of at least one vault indicating that personal protective equipment such as gloves and boot covers were mandatory. The operations and maintenance (O&M) chemical storage room contained numerous 55-gallon drums and other smaller sized containers of lithium bromide, glycol, refrigerant, and water treatment chemicals as well as several empty containers. Lithium bromide was used with the inactive absorber associated with the older chiller system. Lithium bromide is no longer used at the facility, but several containers were observed within the O&M room and the paint storage room. Some minor surface staining (white) was observed on the chemical room floor. No leaking drums/containers or major staining was observed. The chemical storage room also contains hypochlorite solution used for the building water treatment system, which is located in the chemical room. An outside contractor maintains the water treatment system and associated waste. The O&M paint storage room contained paint, sealants, cleaners, refrigerant containers, and other chemicals (lithium bromide, SUVA 123 refrigerant) in cabinets and on the floor. No chemical staining was observed; however, there were several rusted drums and cans and rust staining on the floor. According to Mr. DiRito, a bulb crusher was formerly located in the paint storage room. No crushed bulbs or other evidence of the bulb crusher was observed during the Site visit. The fluorescent lamp storage room was observed to be in good condition. Used fluorescent bulbs are now managed intact as universal waste. Some small hydraulic equipment was observed in the plumbing shop. Minor surface stains were observed, but Louis Berger considers this to be a de minimus condition. The carpenter shop appeared to be in good condition. Two battery backup systems were observed in the basement. The batteries included lead-free labels. No staining was observed on the floor under or around the batteries. The rooftop chillers and elevator machine rooms were reviewed during the site reconnaissance. No staining was observed. The rooftop cooling towers and elevator rooms appeared to be in good condition with no obvious spills or staining. A portion of the roof contains a cooling tower operated by the DC Metro for the adjacent L’Enfant Metro Station. This area was inaccessible during the Site visit. The building exterior appeared to be in good condition. The adjacent rail appeared to be in good condition with no obvious staining on the side facing the ROB. Some small trash was observed within



the railroad ROW, but no significant dumping was observed. Adjacent sidewalks and roadways appeared to be in good condition.

4.4 Hazardous Materials and Unidentified Substance

Containers in Connection with Identified Uses According to the Mr. DiRito and Ms. Holland, the O&M paint room previously housed a bulb crusher used to crush mercury containing light bulbs. Crushed mercury bulbs are regulated as hazardous waste. Mr. DiRito indicated that the bulb crusher was removed around 2012 and that he observed debris (i.e., broken bulbs) located in the paint room after the bulb crusher had been removed. No crushed bulbs were observed during the 2014 Site visit. No evidence was provided indicating that the paint room was tested for mercury residue or cleaned following removal of the bulb crusher. Used bulbs are now stored intact and disposed as universal waste. The facility is currently classified as a CESQG under EPA ID No. DCR000505198. The facility does not regularly generate hazardous waste. The facility generated small quantities of hazardous waste in the past when it operated the fluorescent bulb crusher. The facility occasionally will generate small quantities of other hazardous waste (i.e., used solvents). The last RCRA compliance inspection was conducted on February 25, 2014. No violations were identified. Based on discussions with the current property owners and the May 2014 Site reconnaissance, small quantities of hazardous or potentially hazardous materials are stored at the Site. These substances consist of small various paint products, hydraulic fluid, solvents, cleaning products including coil cleaners, and universal wastes. The substances are housed in the basement level of the building within operations and maintenance rooms and in storage cabinets. The elevator rooms also contain storage cabinets with small quantities of chemicals. The O&M chemical storage room contained 23 55-gallon drums of lithium bromide, one empty SUVA 123 refrigerant drum, one container of glycol and plastic containers of hypochlorite. Two drums labeled as Isotron trichlorofluormethane are now being used to store glycol. As previously mentioned, the lithium bromide was formerly used with the old chiller system and is no longer used. Glycol is used in the chiller to prevent freezing and hypochlorite is used in the water treatment system, which is located within the chemical storage room. An outside contractor maintains the water treatment system and associated waste. One unidentified green drum was observed in the room. Some minor surface staining (white) was observed on the chemical room floor. No leaking drums/containers or major staining was observed. Lithium bromide is not listed as a CERCLA hazardous substance, SARA Section 302 extremely hazardous substance, or as containing hazardous substances under the Clean Air Act or the Clean Water Act. However, according to the safety data sheets (SDS), chemical waste generators need to determine if discarded lithium bromide should be regulated as a hazardous waste. Minor white residue associated with dried lithium bromide was present in the chemical storage room. This is considered to be a de minimus condition. SUV 123 refrigerant contains a SARA-regulated substance:



2,2-Dichloro-1,1,1-trifluoroethane. Spent refrigerant can be reused if handled and stored according to regulatory standards. The O&M paint storage room contained paint, sealants, cleaners, two drums of SUVA 123 refrigerant, a few drums of lithium bromide, and other chemicals in cabinets and on the floor. No chemical staining was observed; however, there were several rusted drums and cans and rust staining on the floor, including the SUVA 123. Recovered refrigerant was observed in ten metal containers on wooden pallets in the basement. No staining or spills were observed. Some small hydraulic equipment was observed in the plumbing shop. Minor surface stains were observed, but Louis Berger considers this to be a de minimus condition. Hydraulic fluids are used in the trash compactor located adjacent to and outside the building. No staining was observed. According to interviews with Site personnel, commercial printing operations and photo development operations formerly occurred on the second floor. It is unknown when the photo development occurred, but it is believed to have ended more than 20 years ago. Commercial printing activities ceased around 1995. The type of materials used for photo development is unknown. Commercial printing activities would have used hazardous cleaning solvents. Ms. Gretsky-Williams was not aware of any spills or violations associated with printing or photo development. GSA was not able to provide records documenting these activities. According to the 2004 Phase I ESA, a sign was observed during Site reconnaissance activates indicating that a dry cleaning operation once operated on the basement level. As reported in the 2004 report, the dry cleaning operation ended several years prior and was limited to dropping off and picking up garments with actual cleaning performed off the premises. This sign was not observed during the 2014 Site reconnaissance. ACM and LBP are known to existing within the building, but are not included in the scope of this ESA. No other hazardous materials were identified by the property owners or discovered during the May 2014 site visit.

4.5 Hazardous Material Containers and Unidentified Substance Containers (Not Necessarily in Connection with Identified Uses)

Based on interviews with Site personnel and the May 2014 Site reconnaissance, no hazardous material containers or unidentified substance containers were identified that are not believed to be connected with current or past identified uses.



4.6 Chemical Storage Tanks

Underground Storage Tanks (USTs) No USTs were observed during the Site visit. According to the current property owner, the only UST that was operated at the Site was removed. According to the 2004 Phase I ESA, a 3,000 gallon UST was previously located beneath the alley adjacent to the west side of the building. A UST Notification and closure report detailed activities performed in the process of the excavation of the tank. The storage tank had held No. 2 diesel oil fuel for use in an emergency generator at the Site. The tank had been out of service for several years and was permanently closed and removed in February 1995 in accordance with federal and District of Columbia regulations. An investigation was performed by District of Columbia Department of Consumer and Regulatory Affairs (DCRA) personnel. The excavated tank was disposed of off Site. Soil samples collected from the excavation pit at the time of removal showed no indication of elevated petroleum constituent levels and, therefore, there was no need for additional investigations or remediation. Aboveground Storage Tanks (ASTs) According to the current property owner, two diesel ASTs are located onsite. Observations during the Site visit confirmed the presence of two ASTs located on the basement level that provide fuel for the emergency generator. The main AST, which reportedly has a capacity of 1,500 or 1,000 gallons, is surrounded by a short brick wall used for secondary containment. Minor staining was observed within the secondary containment area and surrounding the AST piping. This staining is considered to be a de minimus condition. The 500-gallon day tank is double-walled for secondary containment. No staining was observed around the day tank. No records of AST testing were provided. The exterior AST fill pipes and vents appeared to be in good condition. The building contains four fire suppression water tanks. Three of the four tanks are presently out of use. The building also contains two inactive ASTs that were formerly used for condensate. An inactive 3,400 lb AST was observed adjacent to the chiller. No staining or spills were observed.

4.7 Odors Louis Berger did not observe any unusual odors at the Site during the site reconnaissance.

4.8 Pools of Liquid Standing water was observed in several areas on the basement floor associated with water pipe leakage or condensation. Absorbent socks were used in some of these areas to absorb the leaking water. No sheen was observed on the surface of the standing water.



4.9 PCB Electrical Components and Indications of Other PCBs

Based on the information provided by the current property owner and reported in the 2004 Phase I ESA, PCB materials had previously been located on the Site but have since been removed. The following equipment was found to historically contain PCBs:

Electrical transformers – removed in 1991, subsequent cleanup activities

Oil circuit breakers (OCBs)– retrofilled in 2000

Mineral oil transformers – retrofilled between 2000 and 2002 PCB Transformers Electrical transformers containing PCBs was housed in the transformer vault rooms located on the basement level. A report from Hill Environmental dated December 1991 confirms that the PCB-containing transformers were replaced and provides documentation of disposal. The report indicates that in 1989, PCB contamination was discovered in a drain located in the northwest transformer vault. The drain still exists today and GSA has no record of additional sampling or cleanup activities regarding the drain. The 1991 report also details a GSA self-implemented PCB-contaminated concrete testing and removal. The notice provided in the report indicates that:

Although final PCB testing found the site to be generally safe, no testing program can guarantee that unsafe levels of PCBs are not present in isolation. Therefore, additional testing for PCBs is recommended in the event that there is any: demolition, reconstruction and/or alterations of the transformer vaults or adjacent structures; and in the event that the property is sold.

According to a PCB Procedures Memorandum included in the Hill Report, EPA Region 3 staff indicated at the time that:

Surfaces in restricted access areas may be cleaned to a level less than 100 micrograms of PCB per 100 square centimeters and encapsulated. The EPA regulation does not define encapsulation, in conversations with EPA it was learned that acceptable methods would include the application of paint or approximately one inch of concrete. It is [Chief, Operations Branch] recommended that this approach be utilized as an interim procedure where complete decontamination to less than 10 micrograms/100 cm2 will be delayed. In the rare event that complete decontamination is not practicable, encapsulation should be used as a final solution.

PCB cleanup activities at the Site continued through 2006. According to the GSA Environmental Cleanup of Federal Transformer Vault Concrete Floors Scope of Work, the cleanup objective was to decrease PCB levels to a maximum of 25 ppm, which is EPA’s threshold for low occupancy areas, porous surface, no change in space use). The following is a timeline of major actions:



August 21, 1992 – PCB grid sampling was conducted by OMC Environmental in the west, south and northwest transformer vaults in accordance with EPA’s “Verification of PCB Spill Clean-up by Sampling and Analysis” procedure. Results for the west, south and northwest vaults indicated no contamination while spot contamination was noted in the southeast and north vaults. According to the report, signs should be posted and booties should be worn when entering the southeast and north vaults.

Cleanup activities occurred in the 1990’s using the EPA-approved double-wash rinse extraction method. PCB wipe samples and core samples were taken until levels were below 25 ppm. If levels exceeded 25 ppm, additional cleaning was conducted and the area was re-tested.

2004 – During the 2004 Phase I ESA, the concrete floors in some of the basement transformer vaults were assumed to be contaminated with PCBs from past spills based on a 2003 Environmental Conditions Report prepared by Apex Environmental Inc. (GSA was unable to provide a copy of this document). Further testing was recommended to determine the extent to which contamination is present and whether potential renovation/demolition debris would require disposal at an approved facility. According to Ms. Gretsky-Williams, the potentially PCB-contaminated concrete was cleaned and removed using a PCB double wash/rinse extraction method. Following the cleanup, core borings were performed in the suspected contaminated areas confirming that the PCB levels of the concrete did not exceed regulatory thresholds. Once cleanup levels were below 25 ppm, the transformer vault floors were voluntarily encapsulated with two layers of paint.

December 16, 2005 – Tidewater, Inc. was retained to conduct final PCB core sampling in transformer vaults TV-N and TV-SE. Three core borings were collected from TV-N and nine core borings were collected from TV-SE. The core borings were collected to a maximum depth of 7.5 cm following cleaning activities conducted by C&R Environmental. All of the samples collected, except sample number SEV-26 (PCB concentration of 240 ppm detected), were below the cleanup standard of 25 ppm. Low levels of PCBs (between 0.05 and 2.3 ppm) were detected in the other samples.

January 24, 2006 and March 17, 2006 – Tidewater, Inc. was retained to collect concrete core samples from transformer vault TV-SE. The first round of sampling results indicated that the sample collected from SEV-26 contained a PCB concentration of 240 ppm. The third round of sampling conducted on March 17, 2006 contained a PCB concentration of 65 ppm. Tidewater recommended further cleanup/decontamination and confirmatory sampling in areas above the cleanup standard.

April 28, 2006 – Tidewater conducted one final core sample from TV-SE, which had elevelated levels of PCBs during the last round of core sampling. The sample collected was 2.8 ppm, which is below the cleanup standards of 25 ppm.

PCB Oil Circuit Breakers M.A. Cecil & Associates, Inc. conducted sampling of transformer OCBs on June 14th and 19th, 2000. All three OCBs were found to contain elevated levels of PCBs (above 50 ppm), with one OCB containing over 500 ppm of PCBs. All three OCBs were retrofilled, with the third retrofill occurring on September 27, 2000. Additional sampling by Enviro-management, Inc. (EMI) on December 19, 2000



found that all three OCBs had levels below 25 ppm. According to Ms. Gretsky-Williams, the three OCBs were subsequently removed. PCB Mineral Oil Transformers In 1999, PCB contamination was detected in mineral oil transformers, which should not have contained any PCBs. Tidewater collected bulk oil samples from the mineral oil transformers on November 23, 1999. All of the transformers sampled contained at least 29.2 ppm of PCBs. Only one sample exceeded 500 ppm (Transformer no. 638 – Main was detected with a concentration of 4,400 and 4,810 ppm). The transformers were retrofilled and resampled. Sampling conducted in 2001 and 2002 detected PCB levels above 50 ppm, but below 500 ppm. According to Ms. Gretsky-Williams, the contaminated mineral oil transformers were ultimately removed. Other Potential PCB-Containing Equipment According to a hazardous waste assessment conducted by MACTEC in 2003, the ROB went through a comprehensive lighting renovation. Fluorescent light ballasts observed during the site visit included “No PCBs” labeling. Based on information from the building manager and the 2003 site visit, no PCB-containing fluorescent ballasts are expected to be located within the building. The 2004 Phase I ESA reported that the trash compactor located on the paved surface adjacent to the northwestern portion of the building was installed after the mid-1980s. Therefore, the hydraulic fluid used in this equipment should not contain PCBs.

4.10 Heating and Cooling The building is heated by district steam and chillers are used for cooling. Natural gas was used in the former cafeteria, which is no longer present. A natural gas hot water heater may be in use in the gym located in the basement level.

4.11 Stains or Corrosion Due to the building age, some corrosion or staining was evident on metal piping and drains in the basement. The O&M paint storage room contained two drums of SUVA 123 refrigerant that had rusted bottoms due to staining water. The drums were not observed to be leaking. Minor surface staining was observed within the AST secondary containment area and surrounding the AST piping. The piping did not appear to be leaking. As previously mentioned, minor white residue associated with dried lithium bromide was present in the chemical storage room. Louis Berger considers these stains and residue to be a de minimis condition.



4.12 Drains and Sumps There are several drains located on the Site within the building. These are located on the basement level in multiple rooms and in the parking garage. No order or sheen was observed in any of the drains.

4.13 Public Storm and Sanitary Sewers The Site is served by the District of Columbia combined sewer system (CSS) with both stormwater and wastewater carried by the same lines. There is very little pervious area associated with the Site and therefore stormwater infiltration is likely negligible. The eastern portion of the site drains into a storm sewer located along 7th Street SW. The western portion of the building drains into a storm sewer located at 9th and D Streets.

4.14 Potable Water Supply

There are no drinking water wells on or serving the Site. The Site is served by the District of Columbia water distribution system, DC Water. The municipal water supply originates from McMillan Reservoir and is treated prior to distribution.

4.15 Air Emissions The ASTs associated with the emergency generator are ventilated to the outside alley. There are no other sources of air emissions on the Site.

4.16 Vapor Intrusion According to the USEPA, vapor intrusion occurs when there is migration of volatile chemicals from contaminated soil or groundwater into an overlying building. Based on a records review, interviews with site personnel and site reconnaissance, no sources of vapor intrusion are believed to exist at the Site or in the Site vicinity.

4.17 Zoning The District of Columbia Office of Zoning has designated the Site as within the C-3-C District (DCOZ, 2014). Zone C-3-C is a commercial district that specifically permits medium to high density development for major business and employment including office, retail, housing, and mixed uses. However, structures owned by the federal government are not required to follow zoning controls. The adjacent properties are also zoned as C-3-C.



4.18 Pesticides/Herbicides/Agrochemical The readily available information did not identify that regulated pesticides, herbicides, and agrochemicals were used, mixed, or disposed of on the Site. No pesticides, herbicides, or agrochemicals were observed during the 2014 Site visit. The Site has been fully developed for over 80 years therefore the application of any pesticides, herbicides, or agrochemicals would be unnecessary.

4.19 Ponds and Lagoons Based on a review of aerial and topographic maps and Site observations, there are no natural or stock ponds or lagoons on or near the Site.

4.20 Stained Soil or Pavement and Stressed Vegetation No chemical stains or stressed vegetation were observed on the Site exterior during the site visit in 2014. The 2004 Phase I ESA reported minor staining around the hydraulic tank and lines associated with the trash compactor located outside on the paved area north of the building. According to the DDOE FOIA Officer, no spills, fires or environmental discharges have been reported at the Site.

4.21 Waste Disposal Practices and Waste Disposal Louis Berger did not observe evidence of discarded or buried waste or trash on the Site. Waste generated by the Site is disposed of into on-Site dumpsters that are equipped with a trash compactor. As previously mentioned, the facility has an EPA ID number, but does not currently generate hazardous waste. If hazardous waste is generated, the waste is temporarily staged on-site until pickup and disposal by outside contractors.

4.22 Wastewater The Site is connected to the DC sanitary system. The Site does not generate wastewater from any other uses.

4.23 Water Wells or Dry Wells No water wells or dry wells were observed or suspected to exist on the Site.

4.24 Septic System

The Site is connected to the city sewer system. There is no septic system on or serving the Site.



4.25 Flood Zone Data Electronic flood zone data available through the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM) program, was provided by EDR, for the Site area. According to the EDR map, the Site is not located within either the 100-year or 500-year floodplain.

4.26 Electromagnetic Fields No high voltage transmission lines are located on the Site. The basement of the Site building contains several transformer vaults. There is a transmission line associated with the railroad tracks adjacent to the Site to the north.

4.27 Fill Material No fill material was observed onsite. Based on discussion with the current owner and the 2014 site visit, there is no evidence of fill material of an unknown origin on the Site. However, according to the 2004 Phase I ESA, the Urban land soils at the Site commonly contain fill material. A 2001 environmental impact statement indicated that a grassy area between the building and the parking area did contain fill material. Evidence of fill material at the Site was not evident during review of other sources.

4.28 Environmental Liens or Activity and Use Limitations The current owner, who has owned the property since the 1930s, has not reported any environmental lien, activity use limitations, or comparable encumbrances upon the property.

4.29 Specialized Knowledge of Environmental Issues GSA provided numerous documents to Louis Berger describing previous assessments and other investigations pertaining to the environmental condition of the Site. These documents include information on asbestos, lead, and PCBs and applicable abatement actions as well as past UST removal. A user questionnaire completed by Mr. DiRito and Mr. Hanshaw and a TSQ completed by Kelly Holland from GSA are included in Appendix A. A Phase I Environmental Site Assessment was conducted by Greenhorne & O’Mara, Inc. in 2003 as part of the Regional Office Building renovation project. This earlier Phase I ESA contained a TSQ and other environmental documents current as of 2003.



4.30 Commonly Known or Reasonably Ascertainable Information

Aside from the information incorporated into this report, GSA did not provide Louis Berger with any information indicating they were or were not aware of commonly known or reasonably ascertainable information that would help identify conditions indicative of releases or threatened releases that could materially impact the Site.

4.31 Valuation Reduction for Environmental Issues GSA did not provide Louis Berger with any information related to a reduction in the value of the property due to environmental issues. No such reduction is expected.

4.32 Owner, Property Manager, and Occupant Information

According to property review, interviews, and information gathered during the field reconnaissance, the Site is currently owned by the U.S. General Services Administration. Information provided by current property owners and other individuals with knowledge of the Site is provided throughout this document where appropriate.


The Louis Berger Group, Inc. Page 5-1 August 2014

5.0 Conclusions and Recommendations Louis Berger performed a Phase I ESA of the GSA Regional Office Building located at 301 7th Street SW in Washington, DC. The Phase I ESA was conducted in general conformance with the scope and limitations of ASTM Practice E 1527-13. Any exceptions to, or deletions from, this practice are described in Section 6.0 of this report. Based on the data obtained during the Site reconnaissance, review of maps and photographs, review of environmental regulatory databases, and interviews with property owners and persons familiar with the Site and its history, Louis Berger identified the following REC and CREC. Louis Berger did not identify any HRECs.

RECOGNIZED ENVIRONMENTAL CONDITIONS

PCB contamination in a transformer vault drain - PCB-containing transformers were replaced in 1991. PCB-contaminated concrete was documented during the removal project in the PCB Transformer Removal and PCB Removal and Transformer Replacement Report from Hill International. PCB cleanup and testing activities occurred between 1991 and 2006 until levels were found to be below the cleanup standard for low-occupancy, porous sufaces, no change in use (25 ppm) and the vaults were encapsulated with two layers of paint. However, a 1991 report indicates that in 1989, PCB contamination was discovered in a drain located in the northwest transformer vault. Based on review of historical documentation and interviews with site personnel, no records indicate that the drain contamination was further investigated. Documentation could not confirm where the drain leads, but it is assumed to connect to the sanitary sewer system. Additional testing is warranted to confirm the presence or absence of elevated PCB levels in the drain.

CONTROLLED RECOGNIZED ENVIRONMENTAL CONDITIONS

Controlled PCB levels in the transformer vaults – The transformer vaults have been cleaned below the regulatory threshold (25 ppm) for low occupancy, porous surface areas with no change in use. The vaults are encapsulated with two layers of paint in accordance with EPA regulations. The PCB levels in the transformer vault are below regulatory levels. If there is a change in use of the transformer vaults and the area is no longer considered low occupancy, the area may need to be cleaned to more stringent regulatory standards. Further, it is recommended that GSA continue to maintain the double-painted transformer vault floors. The northwest transformer vault floor was found to be in need of re-painting.



OTHER RECOMMENDATIONS Based on interviews with site personnel, site reconnaissance and records review, Louis Berger identified other potential environmental concerns that do not meet the criteria of RECs, HRECs or CRECs, but may present current or future environmental concerns:

Former fluorescent bulb crusher – According to interviews with Site personnel a fluorescent bulb crusher was operated in the O&M paint room. The bulb crusher was removed around 2012. After removal, pieces of broken bulb were observed in the paint room. Although the pieces of broken bulb were subsequently discarded, no specific mercury cleanup activities reportedly occurred following the removal of the bulb crusher. Therefore, it is possible that mercury residue is present in the paint room. Suggest testing the vicinity of the former bulb crusher for mercury residue. If found, the area should be cleaned in accordance with applicable regulations.

Rusted SUVA 123 Refrigerant Drums – Two SUVA 123 refrigerant drums are located in the paint room. Both drums are rusting at the bottom because they are subjected to standing water leaking into the paint room. Standing water in the paint room should be removed and prevented. The two drums containing SUVA 123 should be inspected for leaks and protected. If the integrity of the drums appears to be compromised, the contents should be transferred into another container.

Standing Water in Paint Storage Room – As mentioned above, standing water persists within the paint storage room. Because this room contains various paints, solvents and chemicals and formerly housed a fluorescent bulb crusher, it is possible that the standing water contains mercury or other chemicals. Suggest removing standing water and testing before disposal to determine if it should be characterized as hazardous.

Standing Water throughout the Building – Standing water was observed throughough the basement of the ROB. Suggest removing and controling standing water throughout the facility basement. Where standing water persists, ensure that chemicals are elevated above the standing water.

Dispose of Unused Chemicals – Around 25 drums of lithium bromide were observed during the Site reconnaissance. Removing these and other unused chemicals and disposing or storing them in accordance with applicable regulations will minimize the future potential risk for leaks or spills.

AST – No information was available on testing of the existing ASTs. Suggest regular inspection and testing of ASTs and cleanup of any spillage.

Manage existing asbestos-containing material (ACM) and lead-based paint (LBP) – Previous reports have documented the presence of ACM and LBP throughout the building.



ACM and LBP should be managed in accordance with applicable regulations. ACM and LBP are outside of the scope of this Phase I ESA and are therefore not discussed further in this report.

In addition, it is possible that contamination may exist along the railroad tracks from railroad ties treated with creosote or other substances, leaks from trains, oil (potentially containing PCBs) spread along the railroad to suppress dust, and/or reported or unreported spills of hazardous materials. Therefore, if excavation is planned near the railroad tracks as part of a building renovation project, a subsurface investigation is recommended.



6.0 Limiting Conditions, Deviations and Data Gaps This investigation was limited to the review of available records, interviews with local officials and persons familiar with the Site, and an on-site visual inspection. The site inspection was limited to observation of surficial conditions only. Such an inspection cannot be expected to reveal all oil or hazardous materials or situations that might be present on-site; some hazardous materials or conditions may exist and not be detected because they are beyond the scope of this study. The ESA was restricted to the Scope of Services as defined herein. No representations or warranties are made concerning the nature or quality of the air, soil, water, building materials, or any other substances on the Site, other than the visual observations as stated in this report. The investigation was conducted in a manner consistent with that level of care and skill exercised by environmental professionals currently practicing under similar conditions and was based on information made available to the representatives of Louis Berger. All documents prepared by or furnished by Louis Berger pursuant to this project are to be used in the context of the Scope of Services contracted. This document is not intended or represented to be suitable for reuse by the client or others on modifications of the project scope. Reuse or release to third parties without the expressed written permission of the consultant is prohibited. As described previously, Louis Berger did not conduct a full title search as part of this Phase I ESA and did not obtain title information back to the year 1940. However, Louis Berger believes it has obtained adequate data to determine potential historic uses of the Site, and no data gaps were identified that significantly affected our ability to identify recognized environmental conditions associated with the property. No other deviations from ASTM Standard Practice E 1527-13 occurred during the performance of the ESA.



7.0 Qualifications of Environmental Professionals Conducting this Assessment

This assessment was conducted by Ms. Heather Unger, an Environmental Professional, with assistance from Ms. Erin Hagan. The professional qualifications of Ms. Unger and Ms. Hagan are presented in Appendix E. In accordance with the requirements of ASTM Standard E1527-13, I declare that, to the best of my professional knowledge and belief, I meet the definition of Environmental Professional as defined in 40 CFR Part 312.10. I have the specific qualifications based on education, training, and experience to assess a property of the nature, history, and setting of the subject property. I have developed and performed the all appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312. __________________________________ Date: September 29, 2014 Heather Unger, Environmental Professional The Louis Berger Group, Inc. 350 Eagleview Blvd., Suite 250 Exton, PA 19341-1178 Direct Dial: (610) 280-4028 Cell: (610) 731-4600



8.0 References Apex Environmental, Inc. (1995). Underground Storage Tank Closure Report.

ASTM Standard E1527-13 “Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process,” ASTM International, West Conshohocken, PA, 2013, www.astm.org.

Applied Environmental, Inc. (2000). PCB Transformer Sampling GSA Regional Office Building. Aucott, M, McLinden, M & Winka, M. (2003) Release of Mercury from Broken Fluorescent Bulbs,

Journal of the Air & Waste Management Association, 53:2, 143-151, DOI: http://www.tandf online.com/doi/pdf/10.1080/10473289.2003.10466132, accessed June 5, 2014.

DC GIS. 2014. DC Atlas Plus. District of Columbia Office of the Chief Technology Officer. Available

at: http://atlasplus.dcgis.dc.gov/, accessed May 30, 2014.

DCHPO. 2013. DC State Historic Preservation Office Determination of Eligibility Form, Property Information for GSA Regional Office Building. District of Columbia State Historic Preservation Office.

District of Columbia Office of Zoning (DCOZ). 2014. DC Zoning Map. Available at: http://maps.dcoz.dc.gov/, accessed May 29, 2014.

Dupont. Material Safety Data Sheet for SUVA 123 refrigerant. Available at: http://www.3eonline.com/ImageServer/NewPdf/5cb53264-dd88-47f3-b77d-7fbff54287d7/5cb 53264dd8847f3b77d7fbff54287d7.pdf. accessed June 5, 2014.

Environmental Data Resources, Inc. (2014, May 2). The EDR Radius Map Report with GeoCheck. (Inquiry Number: 3935946.2s, GSA Regional Office Building).

Environmental Data Resources, Inc. (2014, May 9). The EDR Aerial Photo Decade Package. (Inquiry Number: 3935946.9, GSA Regional Office Building).

Environmental Data Resources, Inc. (2014, May 8). The EDR-City Directory Abstract. (Inquiry Number: 3935946.5, GSA Regional Office Building).

Environmental Data Resources, Inc. (2014, May 7). Certified Sanborn® Map Report. (Inquiry Number: 3935946.3, GSA Regional Office Building).

Environmental Data Resources, Inc. (2014, May 8). EDR Historical Topographic Map Report. (Inquiry Number: 3935946.4, GSA Regional Office Building).

Greenhorne & O’Mara, Inc. (2004). Phase I Environmental Site Assessment GSA Regional Office Building.

GSA. (n.d.) Scope of Work, Environmental Cleanup of Federal Government Transformer Vault Concrete Floors.

Hill International, Inc. (1991). PCB Removal and Transformer Replacement.



Kuhns, J. Undated. Material Safety Data Sheet for Lithium Bromide. Available at: http://www.hms-beagle.com/MSDS/Lithium_Bromide.pdf, accessed May 29, 2014.

M.A. Cecil & Associations, Inc. 2000. PCB Evaluation. Order No. GSA P-11-00-DC-0218.

MACTEC Engineering and Consulting, Inc. (2003). Report of Hazardous Materials Survey. Regional Office Building.

MasiMax Resources, Inc. 2002. Contract Number: GS11P01MQD0056.

OMC Environmental. (1992). PCB Wipe Sampling. OMC Project No. 038-GSARB1-58.

Tidewater, Inc. (2005). PCB Core Sampling and Analysis Report.

Tidewater, Inc. (2006a). PCB Core Sampling and Analysis Report (2nd and 3rd Rounds of Sampling).

Tidewater, Inc. (2006b). PCB Core Sampling and Analysis Report (Final Round of Sampling).


Appendix A Property and Site Vicinity Information

User Questionnaire Transaction Screen Questionnaire FOIA Requests Correspondence


User Questionnaire


Transaction Screen Questionnaire


FOIA Requests

5/13/2014 Public Records Tracker™- Public Record Request Web Portal

https://dcfems.secureprtportal.com/pages/createrequest.aspx?contid=fb513db7-aa85-42c8-8141-8966ce30d240 1/2

Public Record Request Portal

New Request - Request Details

Name: Heather Unger Update Account

Organization: Not Provided

Address: 350 Eagleview Blvd

Exton, PA 19341

Country: United States

Email: [email protected]

Phone: 610-280-4028

Subject: GSA Regional Office Building

Delivery Method: Electronic Copy

Type of Request: Public Records Request

Requestor Type: Commercial Use

By accepting below, I verify that I have selected the appropriate requestorcategory and affirm that I am williling to pay fees associated with my categoryand my request.

Request Details: I am conducting a Phase I Environmental Site Assessment on behalf of the U.S. General Services Administration for the GSA Regional Office Building located at 301 7th Street SW in Washington, DC.

As part of the Phase I requirements, I am requesting incident/environmental/fire reports regarding any fires, spills or environmental discharges that have occurred at the property.

Thank you.

I have supporting documentation for this request.

Signature Code:

Sign Request: 259202 Correct Code

To offically sign this request electronically you need to enter the SignatureCode in the Sign Request textbox. This will act as your signature on yourRequest.

Mrs. Heather M. Unger The Louis Berger Group 350 Eagleview Boulevard Suite 250 Exton, PA 19518

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION Ill

1650 Arch Street Philadelphia, Pennsylvania 19103-2029

August 14, 2014

RE: Freedom of Information Act Request EPA-R3-20 14-008851 PCB Cleanup at GSA Office, 301 7th Street SW, Washington, DC 20024

Dear Ms. Unger:

This is in response to your Freedom of Information Act request listed above regarding PCB information at the GSA Washington, DC site. The Land and Chemicals Division of Region III EPA searched its records and consulted its Toxics Branch, including Scott Rice, and found no responsive information for this request.

You may appeal this response to the National Freedom oflnformation Officer, U.S. EPA, Records, FOIA and Privacy Branch, 1200 Pennsylvania Avenue, NW (2822T), Washington, D.C. 20460, E-mail: foia [email protected]. Only items mailed through the United States Postal Service may be delivered to 1200 Pennsylvania Avenue, NW. If you are submitting your appeal via hand delivery, courier service or overnight delivery, you must address your correspondence to 1301 Constitution Avenue, NW, Room 6416J, Washington, D.C. 20004. Your appeal must be made in writing, and it must be submitted no later than 30 calendar days from the date of this letter. The Agency will not consider appeals received after the 30 calendar day limit. The appeal letter should include the request number listed above. For quickest possible handling, the appeal letter and its envelope should be marked "Freedom of Information Act Appeal."

If you have any questions, please contact Mr. Baldwin of my staff at (215) 814-33 86.

Sincerely,

C(;~oPi#L U ;;;;;{~yazqu~ Environmental Protection Specialist Land and Chemicals Division


Correspondence

1

Unger, Heather

From: Kelly Holland - WPMABF <[email protected]>Sent: Monday, June 09, 2014 8:59 AMTo: Unger, HeatherCc: Suzy Hill - WPDBA; Patricia Gretsky-Williams - WPMABF; Stewart, MargaretSubject: Re: Updates to the ROB Phase I ESA

Hi Heather. 1) The vault cleanup was a self-implementing cleanup, meaning it wasn't mandated by a regulatory agency. So there isn't a "No Further Action" letter from EPA. 2) Likewise the entry and PPE restrictions are self-imposed (by GSA). In an abundance of caution, GSA Building Managers have been advised to follow certain procedures for entering/working in all transformer vaults. Primarily the use of gloves and booties. Kelly Holland GSA Industrial Hygienist Facilities Management & Services Program Division 301 7th Street, S.W., Room 2080 Washington, DC 20407 office: (202)708-5255 cell: (202)439-0493

On Thu, Jun 5, 2014 at 1:15 PM, Unger, Heather <[email protected]> wrote:

Thanks for confirming, Kelly. I reviewed the PCB report that you provided – it appears to describe the last of several soil borings in the transformer vault and confirms that the PCB levels were below the regulatory threshold. Was the PCB cleanup regulated by the EPA or District Department of the Environment? Do you have any record of a No Further Action letter or any type of use restriction associated with the concrete?

Heather Unger, LEED AP Project Scientist | Energy Services

Direct: 610.280.4028

Mobile: 610.731.4600

This message, including any attachments hereto, may contain privileged and/or confidential information and is intended solely for the attention and use of the intended addressee(s). If you are not the intended addressee, you may neither use, copy, nor deliver to anyone this message or any of its attachments. In such case, you should immediately destroy this message and its attachments and kindly notify the sender by reply mail. Unless made by a person with actual authority conferred by The Louis

2

Berger Group, Inc., (LBG) the information and statements herein do not constitute a binding commitment or warranty by LBG. LBG assumes no responsibility for any misperceptions, errors or misunderstandings. You are urged to verify any information that is confusing and report any errors/concerns to us in writing.

From: Kelly Holland - WPMABF [mailto:[email protected]] Sent: Thursday, June 05, 2014 10:02 AM To: Suzy Hill - WPDBA Cc: Patricia Gretsky-Williams - WPMABF; Unger, Heather; Stewart, Margaret Subject: Re: Updates to the ROB Phase I ESA

Correct. To our knowledge there are no remaining USTs. Only ASTs.

Kelly Holland

GSA Industrial Hygienist

Facilities Management & Services Program Division

301 7th Street, S.W., Room 2080

Washington, DC 20407

office: (202)708-5255

cell: (202)439-0493

On Thu, Jun 5, 2014 at 9:59 AM, Suzy Hill - WPDBA <[email protected]> wrote:

Kelly and Trish,

Thanks for the reports, Heather was wondering if this is confirmation that there are no USTs left in the building.

Thanks.

3

Suzanne Hill

Regional Environmental Planning Officer

Office of Planning & Design Quality

U.S. General Services Administration, NCR

301 7th ST. SW

Room 4004


Phone: 202.205.5821

Cell: 202.870.7949

On Wed, May 28, 2014 at 4:44 PM, Suzy Hill - WPDBA <[email protected]> wrote:

Great thanks! Yeah I don't know where to find the APEX report. I'll ask the asset manager to see if they have it.

Suzanne Hill




301 7th ST. SW

Room 4004


Phone: 202.205.5821

Cell: 202.870.7949

4

On Wed, May 28, 2014 at 1:58 PM, Kelly Holland - WPMABF <[email protected]> wrote:

Suzy,

I'm not finding the Apex Environmental Conditions report. You guys would have that?

However, did find UST and PCB reports.

Kelly Holland

GSA Industrial Hygienist

Facilities Management & Services Program Division

301 7th Street, S.W., Room 2080


office: (202)708-5255

cell: (202)439-0493

On Wed, May 28, 2014 at 10:16 AM, Suzy Hill - WPDBA <[email protected]> wrote:

Hi Kelly and Trish,

Thanks for your help in getting the Phase ESA updated. I believe Heather is still awaiting the following information:

A copy of the September 2003 Environmental Conditions Report from Apex Environmental Final PCB clean‐up activities Confirm that there are no USTs left at the building.

Any luck tracking this information down?

5

Thanks,

Suzy

Suzanne Hill




301 7th ST. SW

Room 4004


Phone: 202.205.5821

Cell: 202.870.7949

1

Unger, Heather

From: Phill, Fianna (DDOE) <[email protected]>Sent: Tuesday, June 03, 2014 9:08 AMTo: Unger, HeatherCc: Singh, Deepak (DDOE)Subject: LUST Information

Dear Heather, Please see a response from Mr. Singh, he asked me to email you in his absence. Please do not hesitate to contact either of us if you have additional questions. Best Regards, Fianna ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ Heather, I will be out of office for this week. However, I can let you know the meanings of various closed case labels mentioned. Administrative closure refers to cases closed by UST Branch because of administrative errors, reasons such as duplicate cases for the same address being opened at the case time, a release from a UST was not confirmed, maybe AST, etc. NFA refers to cases where the site may still have residual contamination, but remediation can cease, as no further clean up action is needed as the site satisfies conditions of UST regulations, using our Risk Based Corrective Action Guidance and standards, if the site only meets residual standards an institutional control NFA will be issued. The cases that mention just as closed cases refer to all other LUST Cases closed after cleanup was completed, usually these are minor releases that resulted in quick cleanup and may or may not include risk assessment and vapor intrusion analysis. There is no major different with a case closure and NFA status, providing the site has been cleaned. They all refer to cases closed in our system that do not pose a significant risk to the human health or the environment. DC UST Branch uses our Risk Based Corrective Action guidance manual‐tier 1 and tier 2 standards, to assess the risk and decide when to close a case. Vapor Intrusion refers to risk that are directly from soil vapors/groundwater, which is consider or maybe required for specific cases, before closing the case. Recently we have been more persistent In requiring vapor intrusion analysis for corrective action where gasoline or chlorinated solvent releases have occurred, our DCRBCA has some guidance on this and we will develop DC‐VI Guidance next year, in the interim EPA/ITRCs can be used.

See our website for DCRBCA Guidance and Chapter 62 of our regulations for additional information. http://ddoe.dc.gov/publication/dc‐risk‐based‐corrective‐action‐dcrbca‐or‐risk‐based‐decision‐making‐dcrbdm‐process http://ddoe.dc.gov/sites/default/files/dc/sites/ddoe/publication/attachments/Chapter%2062%20‐%20Reporting_of_Releases_Investigation_0.pdf Thanks, Deepak K. Singh | Environmental Protection Specialist District Department of the Environment (DDOE) Toxic Substances Division, Underground Storage Tanks Branch 1200 First St. NE, 5th floor Washington, DC 20002 voice: 202 535 2634

2

e-fax: 202 481 1383 [email protected] http://green.dc.gov/

Sincerely, Fianna Phill, MSc., BSc. Chief Underground Storage Tank Branch Toxic Substances Division, ESA Government of the District of Columbia District Department of the Environment 1200 First Street, NE, 5th Floor, Room 538 C Washington, DC 20002 Tel: 202-535-2326 (Direct) 202-535-2600(Main) Cell: 202-302-8181 Fax: 202-535-1383 Email: [email protected] UST Webpage: http://ddoe.dc.gov/service/underground-storage-tanks-ust-and-lust DDOE Website: www.ddoe.dc.gov

From: Unger, Heather [mailto:[email protected]] Sent: Monday, June 02, 2014 05:16 PM To: Singh, Deepak (DDOE) Subject: LUST Information Hello Deepak, I am conducting a Phase I ESA for the GSA building located at 301 7th Street SW and I am looking for some information regarding closed LUST cases that I believe are in your Ward. Most of the LUST cases within the search distance are listed as “closed.” However, there is one site, LUST No. 2001011 listed as “Administrative Closure” and there are two sites (LUST No. 2003062 and LUST No. 99121) listed as NFA, which I assume means “No Further Action.” Can you explain the differences between “closed,” “administrative closure” and “NFA”? If a LUST case is closed, what standards are being satisfied? Does the assessment process consider vapor intrusion? Thank you, Heather Unger, LEED AP Project Scientist | Energy Services

Phone: 610.280.4000 Direct: 610.280.4028 Mobile: 610.731.4600


Appendix B Site Photographs

Photo 2. Alley located on west side of building (former UST Location)Photo 1. ROB from D Street looking east

Photo 3. West side of the ROB (previous location of underground diesel storage tank)

Photo 4. Staining in parking area adjacent to the north side the ROB

Photo 5. Trash compactor located within paved area north of the ROB

Photo 6. Loading dock area on north side of the ROB

Photo 7. Railway located adjacent to the Site to the north

Photo 8. Close-up of minor debris located within railbed

Photo 9. Parking garage on the basement levelPhoto 10. Inactive 3,400 lb refrigerant storage tank on

the basement level

Photo 12. Propylene glycol drum on the basement levelPhoto 11. Recovered refrigerant stored on the

basement level

Photo 13. Transformer vault (Room B23) Photo 14. Battery storage room

Photo 15. Glycol stored in trichlorofluoromethanedrums in the O&M chemical room

Photo 16. Drums stored in the O&M chemical room

Photo 17. Lithium bromide drums stored in the O&M chemical room

Photo 18. Suva 123 refrigerant stored in the O&M chemical room

Photo 19. Empty containers stored in the O&M chemical room

Photo 20. Water treatment chemicals stored in the O&M chemical room

Photo 21. Chemicals stored in the O&M chemical room Photo 22. Pipes and drain in the steam room

Photo 23. Degreasers and other cleaning products in the paint room

Photo 24. Paint and other items stored in the paint room

Photo 25. Paint cans stored in the paint roomPhoto 26. Rusted Suva 123 refrigerant drums stored in

the paint room

Photo 27. Five gallon drums of paint, floor coatings, and cement compounds in the paint room

Photo 28. Inactive condensate tank in basement

Photo 29. Active 500 gallon AST associated with the emergency generator in the basement

Photo 30. Stain within secondary containment area within emergency generator room

Photo 31. Pipes connected to ASTPhoto 32. Active 1,000 or 1,500 gallon AST associated

with the emergency generator

Photo 33. Additional battery room Photo 34. Plumbing shop room

Photo 35. Items stored in safety cabinet on the basement level

Photo 36. Drain in the NW transformer vault found to previously contain elevated levels of PCBs

Photo 37. Another photo of the drain located in the NW transformer vault Photo 38. NW transformer vault floor

Photo 39. Another photo of the NW transformer vault floor


Appendix C Historic Maps and Aerial Photographs

Sanborn Fire Insurance Maps Historic USGS Topographic Maps Historic Aerial Photographs City Directories


Sanborn Fire Insurance Maps

Certified Sanborn® Map Report

GSA Regional Office Building

301 7th Street SW


Inquiry Number: 3935946.3

May 07, 2014

Certified Sanborn® Map Report 5/07/14

Site Name:GSA Regional Office Building301 7th Street SWWashington, DC 20024

Client Name:The Louis Berger Group350 Eagleview BlvdExton, PA 19341

Contact: Heather UngerEDR Inquiry # 3935946.3

The Sanborn Library has been searched by EDR and maps covering the target property location as provided by TheLouis Berger Group were identified for the years listed below. The Sanborn Library is the largest, most completecollection of fire insurance maps. The collection includes maps from Sanborn, Bromley, Perris & Browne, Hopkins,Barlow, and others. Only Environmental Data Resources Inc. (EDR) is authorized to grant rights for commercialreproduction of maps by the Sanborn Library LLC, the copyright holder for the collection. Results can be authenticatedby visiting www.edrnet.com/sanborn.

The Sanborn Library is continually enhanced with newly identified map archives. This report accesses all maps in thecollection as of the day this report was generated.

Certified Sanborn Results:

Site Name: GSA Regional Office BuildingAddress: 301 7th Street SWCity, State, Zip: Washington, DC 20024Cross Street:P.O. # 2002525.012Project: GSA Regional Office BuildingCertification # ED77-44FC-A18D

Library of Congress

University Publications of America

EDR Private Collection

The Sanborn Library LLC Since 1866™

The Sanborn Library includes more than 1.2 millionfire insurance maps from Sanborn, Bromley, Perris &Browne, Hopkins, Barlow and others which trackhistorical property usage in approximately 12,000American cities and towns. Collections searched:

Sanborn® Library search resultsCertification # ED77-44FC-A18D

Maps Provided:

1998

1994

1992

1991

1990

1988

1984

1977

1959

1928

1904

1888

Limited Permission To Make CopiesThe Louis Berger Group (the client) is permitted to make up to FIVE photocopies of this Sanborn Map transmittal and each fire insurance mapaccompanying this report solely for the limited use of its customer. No one other than the client is authorized to make copies. Upon request madedirectly to an EDR Account Executive, the client may be permitted to make a limited number of additional photocopies. This permission isconditioned upon compliance by the client, its customer and their agents with EDR's copyright policy; a copy of which is available upon request.

Disclaimer - Copyright and Trademark noticeThis Report contains certain information obtained from a variety of public and other sources reasonably available to Environmental Data Resources, Inc. It cannot beconcluded from this Report that coverage information for the target and surrounding properties does not exist from other sources. NO WARRANTY EXPRESSED ORIMPLIED, IS MADE WHATSOEVER IN CONNECTION WITH THIS REPORT. ENVIRONMENTAL DATA RESOURCES, INC. SPECIFICALLY DISCLAIMS THEMAKING OF ANY SUCH WARRANTIES, INCLUDING WITHOUT LIMITATION, MERCHANTABILITY OR FITNESS FOR A PARTICULAR USE OR PURPOSE. ALLRISK IS ASSUMED BY THE USER. IN NO EVENT SHALL ENVIRONMENTAL DATA RESOURCES, INC. BE LIABLE TO ANYONE, WHETHER ARISING OUT OFERRORS OR OMISSIONS, NEGLIGENCE, ACCIDENT OR ANY OTHER CAUSE, FOR ANY LOSS OF DAMAGE, INCLUDING, WITHOUT LIMITATION, SPECIAL,INCIDENTAL CONSEQUENTIAL, OR EXEMPLARY DAMAGES. ANY LIABILITY ON THE PART OF ENVIRONMENTAL DATA RESOURCES, INC. IS STRICTLYLIMITED TO A REFUND OF THE AMOUNT PAID FOR THIS REPORT. Purchaser accepts this Report "AS IS". Any analyses, estimates, ratings, environmental risklevels or risk codes provided in this Report are provided for illustrative purposes only, and are not intended to provide, nor should they be interpreted as providingany facts regarding, or prediction or forecast of, any environmental risk for any property. Only a Phase I Environmental Site Assessment performed by anenvironmental professional can provide information regarding the environmental risk for any property. Additionally, the information provided in this Report is not to beconstrued as legal advice.

Copyright 2014 by Environmental Data Resources, Inc. All rights reserved. Reproduction in any media or format, in whole or in part, of any report or map ofEnvironmental Data Resources, Inc., or its affiliates, is prohibited without prior written permission.

EDR and its logos (including Sanborn and Sanborn Map) are trademarks of Environmental Data Resources, Inc. or its affiliates. All other trademarks used herein arethe property of their respective owners.

3935946 - 3 page 2

Sanborn Sheet Thumbnails

This Certified Sanborn Map Report is based upon the following SanbornFire Insurance map sheets.

1998 Source Sheets

Volume 2, Sheet 202 Volume 2, Sheet 204

1994 Source Sheets


1992 Source Sheets


1991 Source Sheets


3935946 - 3 page 3

1990 Source Sheets


1988 Source Sheets


1984 Source Sheets


1977 Source Sheets


3935946 - 3 page 4

1959 Source Sheets


1928 Source Sheets


1904 Source Sheets


1888 Source Sheets


3935946 - 3 page 5

1998 Certified Sanborn Map

ED

77-44FC

-A18D

Order Date:EDR Inquiry:

Client:

Site Name:

Address:

City, ST, ZIP:

Certification #

Copyright: 1998

5/7/2014 5:58:02 PM3935946.3

The Louis Berger Group

GSA Regional Office Building

301 7th Street SW

Washington DC 20024

ED77-44FC-A18D

This Certified Sanborn Map combines the following sheets.Outlined areas indicate map sheets within the collection.

Volume 2, Sheet 202

Volume 2, Sheet 204

0 Feet 150 300 600

3935946 - 3 page 6

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