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6.0 PARCEL EVALUATION6.1 POTENTIAL IMPACT FROM ACTIVITIES AT PARCEL I
The activities undertaken within Parcel 1 have been evaluated and ranked from low to high in order of their potential to significantly impact the subject parcel and potentially impede transfer to the GSA for real property disposal. Significant impact in this text has been defined as pollutant concentrations in the soil and/or groundwater that may require mitigative action by the regulatory agencies. Interpretation of historical activities on Parcel 1 indicated the subject parcel has some potential for significant impact to have occurred in identified localized areas. Review of current operations on Parcel 1 indicated that there is a low-to-moderate potential for operations in and around buildings to have impacted Parcel 1 except for localized contamination identified. Table 7 summarizes the potential impact from buildings and specific areas in Parcel 1. This table also provides our rationale for making this assessment. Table 7 identifies our recommendations for evaluating those areas that have a potential to impact Parcel 1.
6.2 POTENTIAL IMPACT FROM ADJACENT PROPERTIES
Operations and activities from adjacent Parcels II, V, and VI have a low to no potential to have impacted Parcel 1. Rockwell performed soil investigations in Parcels V and VI and chemicals analyzed were detected at concentrations that do not appear to pose a significant threat to human health and the environment. Historical operations at Parcel II have a low potential to have impacted Parcel 1 via surface water flow. Groundwater flow is in a southerly direction and therefore is not expected to flow from Parcel II to Parcel 1.
Nine off-site properties were identified as being within proximity of possibly impacting Parcel 1. These sites have a potential to impact Parcel 1.
6.3 SELECTION OF PROPERTY CATEGORY FOR PARCEL 1
As part of the property disposal process, an EBS is prepared to classify a parcel into one of seven categories. These seven categories have been placed into two groups: Uncontaminated Properties (Group 1) and All Other Properties (Group 2). The seven categories are defined below.
Group 1- Uncontaminated Properties
Category 1: Real Property on which no hazardous substances or petroleum products (or their derivatives, including aviation fuel and motor oil) have been stored for one year or more, known to have been released, or disposed of on the property.
According to the Statement of Work, (SOW) provided by NASA, certain properties can be identified as "uncontaminated" under CERCLA 120(h)(4) even though some limited quantity of hazardous substances or petroleum products have been stored, released or disposed of on the parcel. The available information for these properties must indicate that the storage, release, or disposal that occurred was associated with activities that would not be expected to pose a threat to human health or the environment. Examples of property which could be upgraded to uncontaminated, are as follows: '
Group 2 - All Other Properties
Category 2: Properties where only storage of hazardous substances or petroleum products has occurred, but no release, disposal or migration from adjacent properties has occurred.
Category 3: Properties where storage, release, disposal and/or migration of hazardous substances or petroleum products has occurred, but at concentrations that do not require a removal or remedial action.
Category 4: Properties where storage, release, disposal, and/or migration of hazardous substances or petroleum products has occurred, and all remedial actions necessary to protect human health and the environment have been taken.
Category 5: Properties where storage, release, disposal and/or migration of hazardous substances or petroleum products has occurred, and removal, and/or remedial actions are under way, but all required remedial actions have not yet been taken.
Category 6: Properties where storage, release, disposal, and/or migration of hazardous substances or petroleum products has occurred, but required response actions have not been implemented.
Category 7. Properties that are unevaluated or require additional evaluation.
The above-listed categories do not account for third-party contributions, ie., the migration of hazardous substances or petroleum hydrocarbons from off-site properties that are not associated with the NASA Downey facility. Properties for this EBS have been categorized based on activities that are not a direct result from off-site operations.
Properties in the first four categories would be suitable for transfer by deed. In addition, property transfer may occur if the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 12001)(3)(B) covenant requirements are met for remedial actions. These requirements (CERCLA Section 120(h)(3)(A)(ii) and Section 120(h)(3)(C)) indicate property transfer could be made If the construction and installation of an approved remedial design has been completed, and if the remedy has been demonstrated to the (USEPA)· Administrator to operate properly and successfully. The carrying out of long-term pumping and treating, or operation and maintenance, after the remedy has been demonstrated to the Administrator to be operating properly and successfully, would not preclude the transfer of the property.
Properties in categories 5, 6 and 7 are considered unsuitable for transfer until all necessary remedial actions have been taken or if CRCLA Section 120(h)(3)(B) requirements are adequately addressed.
Only property in the first four categories would be suitable for transfer by deed. Properties in categories 5, 6 and 7 are unsuitable for transfer until all necessary remedial actions have been taken and the propertY is reclassified into one of the first four categories. All remedial action is considered to have been taken if the construction and installation of an approved remedial design has been completed, and the remedy has been demonstrated, to, the satisfaction of the regulatory agencies, to be operating properly and successfully. It may also be possible to obtain regulatory approval for property categorized as a 5, 6, or 7 solely on the basis of petroleum contamination to be made available for transfer if the petroleum contamination does not pose a threat to human health or the environment.
Historical operations carried out on Parcel 1 have a low-to-moderate potential for impact on the Parcel with the exception of localized contaminated areas identified. Table 7 lists for each building and associated areas in Parcel 1 their potential impact to Parcel 1. Based on the information provided for Parcel 1, we have categorized a majority of buildings and areas in Parcel 1 as Group 2, Category 3 or better suitable for transfer. However, we have identified several areas and buildings as currently undergoing investigations to identify potential contamination and possible remediation, if necessary. These include Building 1, Zones 4, 5, and 7 near clarifier, degreaser, and sump locations generally the chem mill area (Table 7), and specific areas/features in Buildings 25, 41, 61, 244, 277, and 287. These areas are categorized as Group 2- Category 7 and may be transferred if all necessary remedial actions have been taken or if CRCLA Section 120(h)(3)(B) requirements are adequately addressed.
Written historical records of the activities and operations of commercial facilities that operated prior to acquisition of the subject facility by the USAF in the 1940s are not available. Information associated with these operations are typically mentioned in historical overviews in general terms without indicating specific building usage or operations.
Subsurface soil and groundwater quality data are needed for those areas where historical activities suggest a high likelihood for potential impacts.
Historical operations carried out on Parcel 1 have a low-to-moderate potential for impact on the Parcel except for localized contaminated areas identified. Table 7 lists for each building and associated areas in Parcel 1 their potential impact to Parcel 1. Based on the information provided for Parcel 1, we have categorized a majority of buildings and areas in Parcel 1 as Group 2, Category 3 or better suitable for transfer. However, we have identified several areas and buildings as currently undergoing investigations to identify potential contamination and possible remediation, if necessary. These include Building 1, Zones 4, 5, and 7 near clarifier, degreaser, and sump locations generally the chem mill area (Table 7), and specific areas/ features in Buildings 25, 41, 61, 244,-277, and 287.
Property transfer may occur if the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 120(h)(3)(B) covenant requirements are met for remedial actions. These requirements (CERCLA Section 120(h)(3)(A)(ii) and Section 120(h)(3)(C)) indicate property transfer could be made if the construction and installation of an approved remedial design has been completed, and if the remedy has been demonstrated to the (USEPA) Administrator to operate properly and successfully. The carrying out of long-term pumping and treating, or operation and maintenance, after the remedy has been demonstrated to the Administrator to be operating properly and successfully would not preclude the transfer of the property.
Our groundwater assessment, based on recent investigations (Earth Tech, 1997) suggests that the groundwater beneath the Parcels1 have been impacted by VOCs. We understand that the presence of this impacted groundwater may not prevent the transfer of the subject property. We recommend that additional soil and groundwater investigations be performed to better assess the source ofVOCs, their distribution and the direction ofgroundwater flow.
8.0 CERTIFICATION OF THE ENVIRONMENTAL BASELINE SURVEY
Foster Wheeler Environmental has conducted this EBS on behalf of NASA. We have reviewed practically reviewable and reasonably ascertainable records that are made available by NASA and Rockwell, and conducted VSIs of Parcel 1 at the NASA Industrial Plant, Downey, California
The information contained within this EBS is based on records made available and, to the best of our knowledge, is correct and current as of August 1, 1996.
Certified by: Date:
Approved by: Date:
Document received from the EPA by subpoena doesUU not have a signature on it.