United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01-92/065
June 1992
SEPA Superfund
Record of Decision:
Brunswick Naval Air Station
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NOTICE
The apPendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement, but adds no further applicable information to
the content 01 the .document. All supplemental material is. however. contained in the administrative record
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50272-101
REPORT DOCUMENTATION 11. REPORT NO.
PAGE EPA/ROD/ROl-92/065
I ~
3. Recipienta Acc:easion No.
4. 1hIe 8nd Sub1I1Ie
SUPERFUND RECORD OF DECISION
Brunswick Naval Air Station (OU1), ME
First Remedial Action - Final
7. Author(s)
s. Report Date
06/16/92
6.
8. Perfonnlng Organlzadon RejpI. No.
8. Pwrfonnlng Orglllnizadon Name 8nd Add.....
10. Projec1lT88kJWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
1~ SpoM«Ing Organization Name 8nd Addr88a
U.S. Environmental Protection
401 M Street, S.W.
washington, D.C. 20460
13. Type 01 Report & Period Cc.verecI
Agency
800/000
14.
15. Supplemenl8ry No-
PB93-963701
18. Abetnc:t (UmIt: 200 worda)
The 3,094-acre Brunswick Naval Air Station (NAS Brunswick) site is an active military
facility located south of the Androscoggin River between Brunswick and Bath, Maine.
The primary mission of the Base is to operate and maintain P-3 Orion aircraft for the
U.S. Navy antisubmarine warfare operations in both the Atlantic Ocean and
Mediterranean Sea. Land use in the area surrounding the Base is primarily
residential, with an elementary school, hospital, and college located 1 mile west of
the site boundary. The southern edge of the Base borders coves and estuaries of
Harpswell Cove. Ground water underlying the site is described as a potential source
of drinking water, but NAS Brunswick currently is serviced by a public water supply
system. NAS Brunswick, which first became active in the 1940's during World War II,
has many areas onsite that were used for disposal of hazardous materials. Two former
landfill areas, known as Sites 1 and 3, are in the central portion of the Base and
were used for the disposal of waste oil, food waste, solvents, pesticides, petroleum
products, paint wastes, and isopropyl alcohol. Site 1 was utilized from 1955 to 1975
and Site 3, from 1960 to 1973. Since 19&3, the Navy and EPA have conducteci several
investigations regarding the past usage and disposal of hazardous substancE~s. These
(See Attached Page)
17. ~t An8Iy8Ia .. DncrIpto18
Record of Decision - Brunswick Naval Air Station (OU1), ME
First Remedial Action - Final
Contaminated Media: soil, sediment, gw
Key Contaminants: VOCs (DCE), metals (arsenic, chromium, lead, mercury)
b. Idendfler8l~EncIecI Terma
Co COSA 11 FIekIIGr~
18. AYlllability SIaIemenI
-.
19. Security ClaM (Thia Repor1)
None
20. Security Clasa (This Page)
NnnA
21. No. of Pages
106
I
~ Pril:e
(See ANSl-Z39.18)
See 11I61rUC1i01l6 on Revel8e
272(4-77)
(Formerly NT1$.35)
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EPA/ROD/ROl-92/065
Brunswick Naval Air Station (OU1), ME
First Remedial Action - Final
Abstract (Continued)
revealed contamination of the soil, sediment, and ground water in Sites 1 and 3 with
VOCs and metals. This ROD addresses containment of the buried wastes at the Site 1 and
3 areas and recovery of contaminated ground water to prevent further migration. Future
RODs will address additional ground water plumes and other source OUs. The primary
contaminants of concern affecting soil, sediment, and ground water are VOCs, including
methylene chloride and DCE; and metals, including arsenic, chromium, lead, and mercury.
The selected remedial action for this site includes the construction of a low
permeability RCRA cap over the landfills and a slurry wall around the waste to divert
clean water away from the landfills. Approximately 16 million gallons of contaminated
ground water, contained by the cap and slurry wall, will be pumped using extraction
wells and treated by chemical oxidation, flocculation, clarification, and filtration to
remove the metals and ultraviolet (UV) oxidation to destroy VOCs. This grour..d water
will be treated in one onsite system concurrently with the Eastern Plume ground water
(dealt with in a separate ROD) in order to be most cost effective. The prefe!rred
discharge method for the treated water will be to the local POTW once the wat:er meets
pretreatment levels. Final discharge from there will be into the Androscoggin River
under a CWA NPDES permit. Treatability tests will be performed before designing the
treatment system. A ground water monitoring system will also be implemented to confirm
that the containment system is functioning properly, and institutional contrc)ls will be
implemented to prevent future use of the landfills or groundwater. The esti~mated
present worth cost for this remedial action is $7,842,000, which includes an O&M cost
of $1,432,000 over a 3D-year period.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific soil/sediment clean-up goals were
not provided, as the risks presented by these media are within the acceptable range
established by EPA. A target clean-up level for mercury in soil/sediment is specified
at 1 mg/kg based on a food-web analysis, as mercury was the only contaminant identified
which demonstrates a propensity to bioaccumulate in terrestrial food chains.
Chemical-specific ground water clean-up goals are based on SDWA MCLs and include
arsenic 50 ug/l; vinyl chloride 2 ug/l; methylene chloride 5 ug/l; 1,2-cis-DCE 70 ug/l;
1,2-trans-DCE 100 ug/l; chromium (total) 100 ug/l; lead 15 ug/l(action level); and
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l RECORD OF DECISION
FORA
I. REMEDIAL ACTION
AT
SITES 1 AND 3
I NAVAL AIR STATION BRUNSWICK, MAINE
l June 1992
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RECORD OF DECISION
FORA
REMEDIAL ACTION
AT
SITES 1 AND 3 ,
NAVAL AIR STATION BRUNSWICK, MAINE
June 1992
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Contents
NAVAL AIR STATION BRUNSWICK
RECORD OF DECISION
TABLE OF CONTENTS
Page No.
DEClARATION. . . . . . . . . . . . . . . . '. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1
DECISION SUMMARY. . . . . . . . 0 . . . . . 0 . 0 . . . 0 . . . . . . . . . . 0 . 0 0 . . . o. 5
I. 'SITE NAME, WCATION, AND DESCRIPTION. . . .. . .00. . . 0 5
ll. SITE mSTOR Y AND ENFORCEMENT ACTIVITIES 0 . . . . . . .. 9
A LAND USE AND REsPONSE HISTORY. . . 0 . . . . . . . . . . . . .. 9
B. ENFORCEMENT HISTORY. . . . . . . . . . . . 0 . . . . . . . . . . . .. 10
m. COMMUNITY PARIIaPATION '.,'.'. 0 . 0 . 0 . o. . . .. . - . 0 0 '12
IV. SCOPE AND R01.E OF RESPONSE ArnON. . 0 . . - . 0 . . 0 o. 13
V. SUMMARY OF SITE CHARAcrER1S11CS ... - . . - - 0 . . - . . 0 14
VI. SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . . . .. 17
Vil. DEVELOPMENT AND SCREENING OF ALTERNATIVES.. 24
A STATUTORY REQUIREMENTS/REsPONSE OBJECTIVES 0'" 24
B. TECHNOLOGY AND ALTERNATIVE DEVELOPMENT AND '
SCR.EENING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 24
vm. DESCRIPTION OF ALTERNATIVES 0."""""""" 27
IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF
, AL'IERNATIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 33
X. THE SELECTED REMEDY. 0 . . . . . . . . . . . . . . . . . . . . . . 0 . .. 39
A CLEANUP LE~I.-S ......"........................ 39
B. DESCRIPTION OF REMEDIAL COMPONENTS. . . . . . . . . ~ .. 42
XI. STATUTORY DETERMINATIONS 0'0",,""'000" - - . 0 54
A THE SELECTED REMEDY ]S PROTECI'lVE OF HUMAN
, HEALTH AND THE ENVIRONMENT. . 0 0 . . . . 0 . .0 0 0 .. 54
B. THE SELECTED REMEDY ATIAINS ARARs . . . . . .. . 00.; 54
C. THE SELECTED REMED]AL ACT]ON ]S COST-
EfFE.crJVE, ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ." . 60
Do
,THE SELECTED REMEDY UTIU~ PERMANENT
SOLUTIONS AND ALTERNATIVE TREATMENT OR
RESOURCE RECOVERY TECHNOLOGIES TO THE
MAx:IMIJM. Ex:1:£Nr P.R.A.crICA.BlE. ...' - . . . . . . . . . . .. 62
E.
Tm SE1E:TED REMEDY SA11SfIES THE PREPERE.NCE
FOR TREATMENT WHICH PERMANENTLY AND
SIGNIfICANTLY REDUCES THE TOXICTY, MOBUJ'IY, '
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NAVAL AIR STATION BRUNSWICK
RECORD OF DECISION
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TABLE OF CONTENTS
continued
Contents
Page No.
OR VOLUME OF THE HAzARDous SUBSTANCES AS A
PRINCIP.AL ELE~NT .......................... 62
XII. DOCUMENT A nON OF SIGNIFICANT CHANGES. . . . . . .. 63.
XIII. STA1E ROl.E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 64
APPENDICES
APPENDIX A
APPENDIX B
APPENDIX C
'APPENDIX D
APPENDIX E
APPENDIX F
APPENDIX G
Media-specific Data SummaI)' Tables
Risk Calculations: Baseline Risk Assessment
Risk Calculations: Future Use Scenario
Applicable or Relevant and Appropriate Requirements
Responsiveness Snmma'Y
MEDEP Letter of Concurrence
Admini"trative Record Index and Guidance Documents
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Figure
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5
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NAVAL AIR STATION BRUNSWICK
RECORD OF DECISION
LIST OF FIGURES
Page No.
Site ~~tiQD ~ . . . . . . . . . . . . . . . . . - . . . . . . - . . . . . . . . . . . . . .. 6
Approximate Locations of Sites 1 and 3 ......... . ~ . . . . . . . . . . . .. 7
Approximate Location of Cap, Slurry Wall, and Extraction Wells. . .. 43
Geologic Cross-Section A-A' for Proposed Slurry Wall. . . . . . . . . . . .. 44
Geologic Cross-Section B-B' for Proposed SlmTy Wall. . . . . . . . . . .. 45
RCRA Guidance - Final Cover System. . . . . . . . . . .. . . . . . . . - . . . .. 47
Schematic Flow Diagram for Water Treatment. . . . . . . . . . . . . . . . .. 50
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NAVALAlR STATION BRUNSWICK
. RECORD OF DECISION
LIST OF TABLES
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ContaminaTJts of Concern. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 18
Summary of Risk Estimates. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 20
Summary of Remedial Alternatives. . . . . . . . . . . . . . . . . . . . . . . . .. 26
Proposed Cleanup Levels. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 41
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DECLARATION
SITE NAME AND LOCATION
Naval Air Station (NAS) Brunswick, Sites 1 and 3
BrunswU:k, Maine
STATEMENT OF BASIS AND PURPOSE
This decision document. presents a selected remedial action that wID provide
contamment of landfill wastes and cont~minated groundwater at Sites 1 and 3 on the
NAS Brunswick in Brunswick, Maine. This decision document was developed in
accordance with the Comprehensive Environmental Response, Compensation, and
Liability Act as amended by the Superfund Amendments and Reauthorization Act
of 1986, 3Dd, to the extent practicabl~ the National Contingenq Plan. Through this
document, the Navy plam 10 Temedy tbe threat to human health, we~ or the
environment posed by contaminated gI'oundwateT, leachate, surface water, and
sediment associated with Sites 1 and 3. This decision is based on the Administrative
Record for the site. The Anmini~trative Record for this site is located at the Public
Works Office at NAS Brunswick.
The State of Maine Department of Environmental Protection (MEDEP) and the V.s.
Environmental Protection AgeDJ:j (USEPA) concur with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from Sites 1 and 3, if' not
addressed by implemeniing the response action selected in this Record of Decision
(ROD), may present an ;mm;nent and substantial endangerment to public health,
welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
This action addresses the principal threat posed by Sites 1 and 3 by preventing
. .-endangerment of public health, welfare, or the environment by implementation of
this ROD through -containment of the vaste ..and ftCOVery of -mntaminated
groundwater to prevent further migration to Mere Brook.
The se~ yemedy indudes ~~:lil\.L'--Dt by amstmetiDg t cap over the 1aDMi1k
and a sluny wall around the waste to divert clean water away from the landfills.
Cont~mi"a.ted groundwater cont~inM by the cap and sluny wall will be pumped
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using extraction wells and treated by chemica] oxidation, flocculation, clarification,
and filtration to remove inorganic compounds, and ultraviolet/oxidation to destroy
organic compounds prior to discharge. ElimiDating leachate seeps will mitigate
swface water and sediment contamination iD Mere Brook.
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It is expected that treatment of cont~rninated groundwater from Sites 1 and 3 will be
treated concurrently with groundwater extracted from the Eastern Plume, a plume
emanating from a separate source on the base. Treatment. of the combined waste
streams was considered because of the similar contaminants, the low flow rate of
groundwater from Sites 1 .and .3, the short ~ of the Si1es 1 and 3 remedy's
pump-and-treat component, and concurrent remediation schedules.
The preferred discharge method for treated water is the local wastewater treatment
facility; however, the Brunswick Sewer District has not yet agreed to accept this
additional hydraulic loading from the groundwater treannent system. Treated water
must meet the pretreatment standards established by the locaJ wastewater treatment
facility. Ultimate diS{1wJe is to the.Androscoggin ~ Wi a ~n~a1 Pollutant
Dischar~ Eiminaticn System permit. Before designing the 'treatment system,
treatability tests will be conducted to provide information on tbe compounds and
concentrations likely present in the effluent Other options for effluent discharge
considered in the Feasibility Study include surface water (i.e., Mere Brook),
. groundwater infiltration, and the Town of Brunswick storm sewer system.
Before start-up of the groundwater extraction system, the Navy will submit a
monitoring program for approval by the MEDEP and the USEP A The purpose of
the monitoring program is to confirm that the containment system is effective.
STATUTORY DETERMINATIONS
The selected remedy is protective of hu.maI1 health and the environment, complies
with federal and state requirements that are legally applicable or relevant and
appropriate to the remedial action, and is cost-effective. . This remedy uses
permanent solutions and alternative treatment technologies .to the maximum extent
practicable and satisfies the statutory preference for remedies that employ treatment
that reduces toxicity, 'mobility, or volume as a principal element. Because this
remedy will result in hazardous substances remaining on site, a review will be
,conducted by the Navy, the USEPA, and the MEDEP witbili five years after start-up
of the containment and extraction well system to ensure that the remedy continues
to provide !IIId""qJI,r~ protection of hnmatJ health and the environment. Ibis review
wiD be 1"ftft"'1'1~ at Jast ew:ry five years as long as hazardous substances remain on
site above health-based cleanup levels. .
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The foregoing represents the selection of a remedial action by the Department of the
Navy and the U.S. Environmental Protection Agency, Region I, with concurrenc(~ of
the Maine Department of Environm ntaJ Protection.
Concur and Recommend for imme iate implementation: .
By: \ ~ .~ A \ e: \'2- ::J~,- '.1-
Thomas A D4UDeS
Title: Captain CEC, U.S. Navy
Comm~nn,g Officer
Northern Division
Naval Facilities Engineering Command
By: H.~t{~ 1h1J~
Date:
10 June 1992
Title: Captain, U.s. Navy
Commanding Officer
Naval Air Station
Brunswick, Maine
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The foregoing represents the selection of a remedial action by the Department of the
Navy and the U.S. Environmental Protection Agency, Region I, witb concurrence of
tbe Maine Department of Environmental Protection.
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Title: Regional Arlmini..trator, USEPA
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DECISION SUMMARY
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I. SITE NAME, WCATlON, AND DESCRIPTION
The U.S. Naval Air Station (NAS) Brunswick is a National Priorities list (NPL) site.
There are currently 13 areas (Sites) within NAS Brunswick under investigation. 'This
Record of Decision (ROD) relates to the contam;nation at Sites 1 and 3. These sites
were grouped together based on their proximit;y and commnn historical land use (Le.,
landfill areas).
NAS Brunswick is located south of the Androscoggin River between Brunswick and
Bath, Maine, south of Route 1 and between Routes 24 and 123 (Figure 1).
Undisturbed topography at NAS Brunswick is characterized by low, undulating hills
with deeply incised brooks; ground surface elevations range from mean sea ]level
(MSL) in lowland dnt;~ge atQS and the Harpswell Cove estuary, to over 110 feet
MSL west and southeast of tbe soutbem end of the runwa.ys. Topography in the
developed areas of the base has been modified by constrUction, with ground swrface
elevations generally ranging from 50 to 75 feet above MSL
NAS Brunswick is located on 3,094 acres. The operations area (138 acres) lies east
of tbe two parallel runways and consists of numerous office buildings, a steam plant,
fuel farm, barracks, recreational facilities, base housing, hangars, repair shops, and
other facilities to support NAS Brunswick aircraft. Forested areas (approximately
48 pe:rcent), grasslands (approximately 28 percent), and paved areas (approximately
12 percent) comprise most of the base property. Paved areas are mostly flight r.m1ps
and runways. The remaining 12 percent of the base includes the operations area
(approximately 5 percent) and miscellaneous shrubland, marsh, and open water. The
southern edge of the base borders coves and estuaries of the Gulf of Mainel Atlantic
Ocean.
Property uses surrounding NAS Brunswick are primarily suburban and rural
residential, with some commercial and light industrial uses along Routes 1, 24, and
123. An elementary school, a college, and a hospital are located within 1 mile of the
-.;.western base boundaIy. .
~~e general area of Site 1 covers more than 60 acres,altbougb the specific 8r'e8 of
~)m~nted refuse disposal is muCh smaller, apprQYim~tely 85 acres. Site 3,
amtiguous to Site 1, occa.pies an area of app1....:...Ate1y 15 acres (Figure 2). The
8.5-acre disposal. area at Site 1 is currently an open, slightly rolling, grass-covered
field bordered to the north, west, and east by woodlands, and to the south by the
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FIGURE 1
SITE LOCATION MAP
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LEGEND
1m A_II8IA
". SITU' A..o~ ~~OP
........ lMn op
ACCESS COMTIIOlLIO
A ..n-Ttft
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SCALI" flit
1118
APPROXIMATE LOC FIGURE 2
SITE:SATION OF
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Weapons Compound and steep embankments bordering the Mere Brook beaver
marsh. Site 3 is next to Site 1 to the southwest, and currently consists of a small
knoll covered with grass and a pine grove.
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Lowland areas along the Mere Brook beaver marsh are heavily ~ooded. The slopes
, along portions of the brook are typically very steep in areas next to the landfill.
Leachate seeps have been consistently observed at the base of slopes next to Site 3,
as well as south of Site 1 (see Figure 2).
Groundwater associated with the site is not used for potable purposes or any other
uses. The base is connected to a public water supply acimini~tered by the Brunswick
- Topsham Water District, with the exception of the golf course. The golf course,
area is distant from Sites 1 &Ild 3 and is not affected by groundwater flow from
Sites 1 and, 3. Mere Brook, south of Sites 1 and 3, receives drainage from the
runways as well as runoff and leachate from the landfills. The brook is not
commonly used for recreational activities in the reaches near Sites 1 and 3 because
access to the area is re5tticted. Mere Brook flows into the Atlantic Ocean at
Harpswell Cove, which is designated as a potential aquaculture area by the State of
Maine. Harpswell Cove supports various commercially important fish species. For,
more information concerning natural resources at Sites 1 and 3, refer to Appendix Q
. of the Draft Final Remedial Investigation (RI) report.
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II. SITE HISTORY AND ENFORCEMENT ACI1VITIES
A. LAND USE AND RESPONSE HISTORY
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NAS Brunswick is an active facility supporting the U.S. Navy's antisubmarine warfare
operations in the Atlantic Ocean and Mediterranean Sea. The base's primary
mission is to operate and maintain P-3 Orion aircraft. . NAS Brunswick first becune
active in the 1940s during World War ll, and underwent major expansion in the
1950s. .
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Sites 1 and 3 are located within a restricted area in the central portion of NAS
Brunswick (see Figure 2). Historical records indicate that the Site 1 landfill was 'Used
from 1955 to 1975. Material reponedly disposed of in this landfill included garbage,
food waste, refuse, waste oil, solvents, pesticides, petroleum products, paint wastes,
aircraff and automobile parts, and various cbemicals.
Site 3 is defined as the area across from Site 1, next to the access road into tbe
Weapons Compound (see Figure 2). Historical information repons that Site 3
operated as a disposal area from 1960 to 1973. Wastes disposed of at this site
included solvents, paints, and isopropyl alcohol. A more detailed description of tbe
history of Sites 1 and 3 can be found in the Draft Final RI Report at page 6-1 and
6-3. No waste material was observed at Site 3 and only low-level soil contamiTu~tion
(i.e., 1.1 milligram per kilogram [mg/kg] of chlordane was the highest detection) was
reported (E.C. Jordan Co., 1990a). Although Site 3 was originally believed to be a
separate disposal area from Site 1, field sampling activities did not show a clear
delineation between these two sites.
Based on the proximity of the two sites, common historical land use, and
hydrogeologic characteristics, the impacts of past disposal practices from Sites 1 and
3 cannot be distinguished Therefore, these areas of contamination are combined
and discussed as one site. Test pit information and field sampling .results were \!Sed
to estimate the combined size of tbe landfills at 10 acres. The waste estimate is
based on test pit data and boring logs. The waste in the trench area of the landfill
is appromnately 20 feet in the deepest areas with the depth of waste decreasing to
the east and west. An average depth of 15 feet was assumed to estimate: an
. approximate combined refuse volume of 300,000 cubic yards (cy) for Sites 1 and 3.
Environmental c:ont:tmination was observ~d in several media at Sites 1 and 3,
iTlr]l1ding sWls, grOJ1ndwa1er, )f'~~n~te/setfim~nt, and E11ft~- water/sedim.en1.
Cuu.Anl;h~...~ detected above badgrmmd Jeve1s iN-b'de polynn~ arom.
hydrocarbons (PAHs) and pesticides m soil; volatile organic compounds (VOCs) and
inorganic ~ m groundwata; iDorgaDic compounds, VOCs, and semivoLati1e
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organic compounds (SVOCs) in leaclme; and inorganic compounds in surface wat~r.
The source area for this contamination is considered to be the landfill (Sites 1 and
3) located north and west of the Weapons Compound. No single, well-defined source
of contamination has been identified in the landfill.
B. ENFORCEMENT HISTORY
The enforcement histmy at Sites 1 and 3 is summarized as follows:
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In 1983, an Initial Assessment Study (lAS) WBi ~Jetf'd deUlj)j~g
historicaJ hazardous maierial usage and waste disposal practices at
NAS Brunswick.
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In 1984, a Pollution Abatement Confirmation Study was conducted.
These studies recommended further investigation of seven of the nine
hazardous waste sites originally identified.
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In 1987, NAS Bnmswick was placed on the U.S. Environmental
Protection Agency's (USEPA's) NPL
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The Remedial Investigation/Feasibility Study (RI/FS) process was
begun in 1987 for tbe seven sites.
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In February. 1988, the first Technical Revi.ew Committee (TRC)
meeting was held. The me meetings have been held quarterly since
that initial meeting. .
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Two sites were added to the RIfFS program in 1989, as well as tbe
two additional sites originally identified in the IAS.
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Two other sites were added to the program in 1990.
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In 1990, the Navy entered into a Federal Facility Agreement (FFA)
with the USEP A and the Maine Department of Environmental
Protection (MEDEP) regarding the cleanup of environmental
contamina.tion at NAS Brunswick. The FF A sets fonh the roles and
responsibilities of each agency, contains de.a1mnes for the investigation
and cleanup of hazardous waste sites, and establishes a mechanism to
rao1vc dj"vtt's .1:Imnng" !be ~gf"nM"'c
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In August 1990, the Navy completed Draft Final RI and Phase I FS
reports (E.c. Jordan Co., 1990a and 199Ob). ne..Draft Final RI
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Report described field sampling investigations, geology, ~md
hydrogeology, and presented contamination and risk assessments. The
Draft Final Phase I FS identified remedial action objectives, ,and
developed and screened remedial alternatives for the nine original sites
stUdied ;n the Draft Fmal RI. The Navy submitted Draft Final
Supplemental RI Reports for Sites 5, 6, 12, and 14 and FS Sites 5, 6,
and 12 in August and July of 1991, respectively (E.C. Jordan Co.,
1991a and 1991b). .
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Cm'emly.. the Navy is snu3y.ing 13 si1es UDder 1hC Inct~ lI~1ion
Restoration Program (IRP) (see Figure 1).
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Because the Navy is committed to providing a timely response to envirOnme]ltal
contamination at NAS Brunswick, a strategy was developed to expedite the RIfFS
process. This strategy involves identifying the sites for which enough information
exists to proceed to the ROD and design phases of the process. Separate timetables
have been established for completing the Final FS reports and RODs for these siltes.
. The Navy has identified Sites 1 and 3, and the groundwater associated with Sites .4,
11, and 13 (referred to as the Eastern Plume) as distinct areas of contaIIrination and .
believes the remedial process can be initiated. Focused Feasibility Studies (FFSs)
for Sites 1 and 3 and Site 8, and an FS for nine other sites (Sites 2, 4, 5, 6, 7, 9, 11,
12, and 13) have been submitted to the regulatory agencies for review (E.C. Jordan
Co~ 1991c, 1991d, and 1991e).
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III. COMMUNIlY PARTICIPATION
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Throughout the site's. history, the community has been active and involved.
Community members and other interested parties have been kept abreast of site
activities through informational me~tings, fact sheets, press releases, public meetings,
and TRC meetings.
In August 1987, the Navy established an information repository for public review of
site-related documents at the Curtis Memorial Library in Brunswick. On
December 3~ 1991, the Navy pJaced the Proposed Plan for Sites 1 and 3 in the
information repository at the Curtis Memorial Library. The Administrative Record
for Sites 1 and 3 is available for public review at NAS Brunswick in the Public Works
office. A notice and brief analysis of the Proposed Plan was published in the local
newspaper, The Times Record on December 3 and 10, 1991.
The TRC has been an important vehicle for community participation. The TRC was
established in early 1988 and COIbprises the Na~ USEPA, MEDEP.. and various
community represematives. The community members of the TRC include
representatives from Brunswick, Harpswell, and Topsham as well as the Brunswick
Area Citizens for a Safe Environment (BACSE). The mc also has representatives
from the Brunswick-Topsham Water District. The mc meets quarterly, reviews the
. technical aspects of the program, and provides community input to the program.
In September 1988, the Navy released a Community Relations Plan that outlined a
program to address public concerns and keep citizens informed about and involved
in remedial activities. On August 16, 1990, the Navy held an informational meeting
at the Jordan Acres School in Brunswick to discuss the results of the RI.
On December 12, 1991, the Navy held an informational meeting and public hearing
to discuss the results of the Supplemental RI and the cleanup alternatives preseIIted
in the Phase I FS and FFS. The Navy also presented its Proposed Plan describing the
preferred alternative for remediation at Sites 1 and 3 and the Eastem Plume.
During this meeting, the Navy, its consultants, and regulatory representatives
answered questions from the public and accepted formal romments. During a public
comment period from December 6, 1991 through January 24, 1992, the Navy
.;;;accepted comments on the alternatives presented in the FS, FFS, and the Proposed
Plans for Sites 1 and 3 and the Eastern Plume, ad on any ()ther 1ioc:uments
previously released to the public. The corresponding responses to comments are .
included in Appendix E, ResponsiveDess ~nmnuny, and are availab1e tbroujb the
iDformatioD ~.
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IV. SCOPE AND ~OLE OF RESPONSE ACl10N
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Tbe selected remedy for Sites 1 and 3 at NAS Brunswick was developed by
combining components of different source control and management of migration
alternatives to create a comprehensive approac~ for site remediation. Tbe remt:dy
includes containment by constructing a cap over the landfills and a slurry wall ar01md
the waste to divert clean water away from the landfills. CoJ1t~min~ted groundw2Lter
contained by the cap and slurry wall will be pumped using extraction wells and
treated by ultraviolet (UV)/oxidation to destroy the organic compounds before
disrh~Tging 1be treated water. The Bnmswick Publicly Owned TreG,1:ment Works
(POTW) is the preferred discharge location; however, the POTW bas yet to commit
to accepting this discharge. These remedial actions will minimi7.e the human health
and ecological risks associated with exposure to contaminated groundwater :md.
leachate sediment. . .
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V. SUMMARY OF SITE CHARACfERISTICS
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The nature and extent of cont;!min~tion at Sites 1 and 3 is summarized by medium
ill the following paragraphs. A list of contaminants and range. of concentrations
detected in each medium is included in Appendix A A cOhlplete discussion of the
site characteristics can be found in the Draft Final RI Report on pages 6-6 through
6.59.
SOIL/WASTE AREA
Soil boring and test pit samples were collected to identify amtamm;!nts in the surface
and subsurface soils at Sites 1 and 3. Contamination detected in subsurface soil
boring samples was considered to be low. Low levels of pesticides and
polychlorinated biphenyls (PCBs) were detected in surface and shallow test pit soil
samples. Pesticides typically totaled less than 0.050 mg/kg, with the exception of one
~,t pit location where five pesticide mmpaw:Lds ~e reponed with a total
amcentration of 2.1 mg/kg. PCBs were found in eigbt of !be 32 test pit son samples
at cODcentrations less than 1 mg/kg. VOCS typically were not detected in test pit
soils, although a variety of SVOCs were identified. The VOCS tested for include
compounds in common industrial solvents, fuels, and degreasers that could have been
disposed of in the landfills at Sites 1 and 3. A group of SVOCs called P AHs were
detected in surface and shallow soils at Sites 1 and 3. The concentration of P AHs
in the shallow soils was typically 1 to 8 mg/kg, witb the highest Teported value of
24 mg/kg. P AH compounds are components of coal and hydrocarbon fuels that
survive the combustion process. The historical use of coal and fuels at NAS
Brunswick may account for the presence of P AHs in soils across the base. Metals
also were detected in the soils at Sites 1 and 3. The metals detected above naturally
occurring background levels include lead and mercury.
Inorganics were found in all soil borings, but typically were restricted to aluminum,
iron, magnesium, and manganese, with concentrations of these elements consistent
with background levels. The elements chromium, lead, arsenic, and zinc were
reported in several cases, but these inorganics were typically found in soil samples
from clay-rich soils. .Concentrations were low, and consistent with background
...concentrations observed in clays.
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GROUNDWATER
Grmmdwater at Sites 1 and 31lows in the uvg bu1den soil2Dd bedrock formations.
The overburden soil at NAS ~ unswick is a ~bca:ified fuu~.a.tion com~tibg of a sand
layer, a transition layer, and a silty clay layer. The sand, transition, and silty clay
layers make up the Prr'5nmp"cot FOT1ft~-riOD, which occurs on top of the bedrock.
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The thickness of 1he Presumpscot Forma'tion varies from 40 to 80 feet in the Sites 1
and 3 area, with tbe silty clay layer having a thickness of 20 to 40 feet. This unit of
soil was deposited on the bedrock during the late glacial marine submergence of
southern Maine. The variability of soil types in the Presnmpscot Formation 'Was
caused by tbe glacial retreat and sea level cbanges that occmred when 1h~' soils were
deposited. The saturated thickness of the Presumpscot Formation, or thickness of
the overburden that contains groundwater, varies from 20 to 60 feet across Sitc~s 1
and 3, and tbe groundwater discharges into Mere Brook and nearby tributaIies.
Groundwater has not been observed to flow through the silty clay layer on top of the
bedrock due to 1he low permeability of the silty day; ~, groundwater does flow
in the fractures and joints of the bedrock (E.C. Jordan Co., 1990a). Contamin~l.ted
groundwater observed above the silty clay layer has not been noted in the bedrock
aquifer and is not expected to migrate through the silty clay into the bedrock aquifer.
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Groundwater cont~min~tion from the landfill consists primarily of VOCs, metals, and
inorganic am:1pOUDds. The VOCs include both cbInrin~t~ S()1vents and fuel-I~ued
compounds. The amu;;ulJdhODS U d11Ul~ateQ S1)h~u!S dete~ in grounrlwater
typically wer~ less than 02 mil.1.igw:ns per liter (mg/L), and total fuel-related VOCs
had a maximum concentration of 1.1 mgjL. Metal and inorganic compounds were
sporadically detected above Maximum CoDt:lminant Levels (MCUi). The maxiDlum
. concentration of metals and inorganic compounds include arsenic (107 micrograms
per liter [pgjL]), chromium (llpgjL), cyanide (34 p.gfL), iron (962 mgjL), ]lead
(60 p.g/L), nickel (78 p.gjL), sodium (181 mgjL), and zinc (2,500 ".gJL). Pesticides,
P AHs, and PCBs were not detected in groundwater at Sites 1 and 3.
LEACHATE SEEPS, SURFACE WATER, AND SEDIMENT
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CoDt:lminated leachate generated from the landfills at Sites 1 and 3 seeps out along
the steep banks of Mere Brook and the tributary next to Sites 1 and 3 (see Figure 2).
Seven seep locations were identified along the steep bank of Mere Brook. 111ese
seeps are a result of groundwater outbreak and are located above the elevation of
Mere Brook and do not discharge directly to the brook. These leachate seeps were
sampled for organic and inorganic compounds. In addition, surface soils were
collected adjacent to the leachate outbreak areas to characterize the impatt of
leachate on surrounding soils. These leachate seeps typically contain trace levels of
''''-WOCs, 'SVOCs, -pesticides, and inorganics, -Gut do Dot contain PCBs. .:One lr.a("Mte
location detected VOCS at a m:nnmum concentration of 1.3 mgIL VOCs detected
in leachate include vinyl chloride; 1,I-dichloroethylene (DCE); 1,1-dichloroethane
(DCA); trichJorocth"JeDe ITCE\. ~ J 1 ? , tr1'nt,.'h]n"Ptt1'U1ln~
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VOCs also were reported in sediment samples and include 1,I-DCA; TCE; 1,1,1-
.trichloroethane (TeA), etbylbemene, I.11d ~W-tetrachloroethane.
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SVOCs were reponed iD o.n1y two seep locations at ~ maximum concentration of
0.064 mgjL SVOCs were only reported in one seep sediment sample at a maximum
concentration of 6.8 mgJkg.
, Pesticides were detected only in one of four sampling r~11"rl" DichJorodiphenyl-
trichloroethane (DDT) (0.17 p,gJL), dichlorodiphenyldichloroethylene (DDE)
(0.40 p,g/L), and dichlorodiphenyldichloroethane (DDD) (0.36 p,g/L) were the
compounds reported PCBs were not observed in learh~te or' se.rlimp.n1 from Sites 1
and 3 seep locations, and pesticides were not detected m seep sediment samples.
Jnorganics were a1so detected at elevated levels in aD seven ~~t'h~ samples. High
levels of alwDinum (0.400 to 119 mgJL); calcium (15 to Z73 mg!L); magnesium (1.9
to 36 mgjL); and iron (11.5 to 2,510 mgjL) were typically found, and the elements
arsenic (0.027 to 0.0590 mgjL); chromium (0.011 to 0.151 mgjL); copper (0.039 to
0.686 mg/L); cobalt (0.057 to 1.240 mgjL); mercury (0.0003 to 0.019 mgjL);
vanadium (0.062 to 2.6 mgjL); and zinc (0.033 to 24.8 mg/L) were commonly
detected. Cyanide (0.010 to 0.027 mgfL) was also found in several seeps (Le.,
LT-30~ LT-303, LT-304, and LT-305), but was not consistently detected in all
sampling rounds. Mercury was found in leachate from five of the seven seeps in all
sampling rounds; concentrations ranged from 0.3 (LT-303) to 19.3 p,gjL (LT-304).
Sediments at seep locations typically have concentrations of inorganics consistent with
background values for sands and clays.
More than 20 surface water and sediment locations were sampled along Mere Brook.
Low levels of VOCs (i.e., less than 0.030 mgjL) were detected in two surface water
samples. Elevated levels of metals were detected at two different surface water
locations. These same metals have been detected in the leachate and groundwater
flowing beneath Sites 1 and 3. Two of the metals, iron and zinc, were also detected
at elevated concentrations in the upgradie~t, background sampling locations.
P AHs were detected in Mere Brook sediments next to Sites 1 and 3. These
compounds also were detected in Mere Brook sediment upgra.dient of Sites 1 and 3
from background stream sampling locations. The concentrations of P AHs in the
background sampling locations are similar to those detected in sampling locations
next to Sites 1 and 3. P AHs also were detected in surface and subsurface soDs from
",'the Sites 1 and 3 landfill area at concentrations ranging from 0.6 to 24 mgjkg. As
"Itated, .p AHs are components of coal ad hydrocarbon lueIs that .survive 'the
combustion process, and they may be present from the historical and current use of
mal ud fuels at NAS Brunswick.
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V1. SUMMARY OF SITE RISKS
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A baseline risk assessment was performed to estimate the potential risks to human
health and the enviromnent from exposure to cont~minants ~ociated with Sites 1
and 3. The human health risk assessment followed a four-step proce~ss:
(1) contaminant identification, which identified those hazardous substances that,
given the specifics of the site, were of significant concern; (2) exposure assessment,
w1ricb identified actual or potential exposure pathways, characterized the potenttilly
exposed populations, and determined the extent of possible exposure; (3) toxicity
asse~mem, which considered the types and magJIitude of ~verie health efU:dS
associated with exposure to hazardous substances; and (4) risk characterizati.on,
which integrated the three earlier steps to summarize the potential and actual risks
posed by hazardous substances at the site, including carcinogenic ~LDd
noncarcinogenic risks. The results of the baseline risk assessment are summarized
in the following subsections.
The contaminants of concern identified for Sites 1 and 3, listed in Table 1, ~ere
selected for ev~uation in the human health risk assessment and include 15 surf~e
and nine subsurface soil, 16 groundwater, 13 surface water, and 21 leacbate
contaminants of concern. These contaminants constitute a representative sUQset of
all the contaminants identified during the RI. The contaminants of concern were
selected to represent potential site-related hazards based on toxicity, concentration,
frequency of detection, and mobili~ and persiste~ ~ the environment. A surmnaI)'
of the health effects of each CODt~minant of concern is presented in Appendbt Q,
pages 0-122 through 0-151 of the Draft Final RI Report.
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Human health risks were quantitatively evaluated based on potential exposurc~ to
contaminants of concern under both current (including worker exposure) and future
land-use (e.g., Tesiden~) scenarios. Several hypothetical exposure pathways were
developed to reflect possible exposure to hazardous substances detected in soils,
groundwater, surface water, sediment, and leachate. The following is a brief
summary of the exposure pathways evaluated. A more thorough description ca:Jl be
found in Appendix Q of the Draft Final RI Report.
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Because access to these sites is currently oontrolled, long-term repetitive exposure to
~ils, seitiments, and surface water is not considered likely. In addition, exposure to
: -groundwater is not considered likely as this area of NAS BrUnsWick is serviced 'by a:
public water supply system. No exposure routes were considered to present a risk
to bnmJln heabh under present Jand.use ~nitirinns However. bel"Sll1~ the role of
the baseline 1isk assessment is to address riskS associated with the site in 1be abs=ce
of any r~media1 action; including institutional controls, potential risks under a future
. residential scenario were estimated The evaluated exposure pathways iDcJude-d
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TABU! 1
CONTAMINANTS OF CONCERN
SITES 1 AND 3
ROD: SireS 1 AND 3
HAS BRUNSWICK
............
SURFACE SOIL
SUlStlRFACE SOIL
Arsenic
Cadmium
Chromium
Copper
Cyanide
DDT
Lead"
Manganese
Mercury
;; Nickel
PAHs
PCBs
1,1,2,2-Tetrachloroethane
Vanadium
Zinc
Arsenic
BIs(2-ethylhexyl)phthalate
Cadmium
DOt
Dieldrin
Lead
Manganese
PAHa
PCB,
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GROUNDWATER
Arsenic
Aluminum
BariuM
Chlorobenzene
Chromium
i,i-DlcNoroethane
1,2-Dlchloroethylene
Ethylbenzene
LGad
Manganese
Methylene Chloride
Nickel
Sodium
Toluene
Vinyl Chloride
Xylene
SURFACE WATER
SEDIMENT
lEACHATE
Antimony
Arsenic
Beryllium
Cadtnlum
Chromium
Cyanide
DOT
1,4-Dlchlorobenzene
1,1-Dlchloroethane
1,2-Dlchloroethylene
Ethylbenzene
Lead
Manganese
Mercury
Nickel
1,1,2,2,-Tetrachloroelhane
Trichloroethylene
Vanadium
Vinyl Chloride
Xylene
Zinc
Note:
See Appflndhc A for the r.nge and hquencyof ~on of each conlamlnant of concern.
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Lead
Manganese
Zinc
Arsenic
Bis(2-ethylhexyl)phthalate
Cadmium
Chromium
Copper
PAHs
lead
Manganese
Mercury
Nickel
1,1,2,2-Tetrachloroethane
Vanadium
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direct contact and incidental ingestion of soil, sediment, surface water, and leachate,
and ingestion of groundwater. These scenarios were based on the exposure
parampte!S listed in Tables Q-23 through Q-28 in Appendix Q of the Draft Final RI
Report. Average and Jn~yiml1m exposure estimates were generated assuming
exposure to the average and the maximum concentration of each contamin~mt
detected in that particular medium. A Sl1mm~ny of the total incremental carcinogenic
risks and summary Hazard Indices (Ins) for each exposure pathway are presented
in Table 2. The chemical-specific risk eStimates for each exposure pathway me
presented in Appendix B.
Since the release of the Draft Final RI Report, USEP A bas developed an additional
guidance and standard default exposure scenario for use in evaluating exposure to
groundwater. The assumptions include a 7o-kilogram adult who' consumes 2 liters
of water per day, 350 days per year, for a 3O-year exposure duration. These risks are
summarized in Table 2 and chemical-specific risk estimates are presented in
Aw'"nrli~ C of this ROD. .
ExceSs lifetime cancer risks were estimated for each exposure pathway by multiplying
the exposure level by the chemical-specific cancer slope factor (CSF). CSFs have
been developed by USEP A from epidemiological or animal studies to reflect a
conservative "upper bound" of the risk posed by potentially carcinogenic oompoUI:lds.
Tbat is, the true risk is unlikely to be greater than the risk predicted. Tbe resulting
risk estimates are expressed in scientific notation as a probability (e.g., 1 x l~ for
1/1,000,(00) and indicate (using this example) that an individual is not likely to h,~ve
more than a one-in-a-million chance of developing cancer over 70 years as a result
of site~related exposure to the compound at the stated concenttation. Curr,ent
USEP A practice considers carcinogenic risks to be additive when assessing exposure
to a mixture of hazardous substances.
The m was also caku1ated for each pathway as USEP A's measure of the potentia]
for noncarcinogenic health effects. The m is the sum of Hazard Quotients (HQs),
which are calculated for each chemical by dividing the exposure level by the
reference dose (RID) or other suitable benchmark for noncarcinogenic health effe,cts.
RIDs have been developed by USEP A to protect sensitive individuals over the oourse
of a lifetime, and they reflect a daily exposure level that is likely to be without an
'. ..~le risk of an adverse health effect. . RIDs are derived from epidemiological
or Slnim91 studies and incorporate uncertainty factors to help ensure that adverse
bealth effects will not occur. The HQ is often expressed as a single value (e.g., 0.3)
~di~B the DUO of 1he stated ~e as ~ 10 the RiD uhJe (m this
example, the exposure as characterized is Ci}'plux:...ately o=-tbird of an aceepulble
exposure level for the given compound). The HQ is only considered additive for
~~ that ~ the w= or ~m toxic endpoints. . .
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TAaLE 2
SU8lMA1n' OF R1sIt EsnIA'TD
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TOTAL' TOTAL TOTAL TOTAL
HI CAlICO RISIC ftl CANCER RISt(
tIg8SIion of and Dermal Consact with Soil (0-15 feet)
~uIt Resident ().Q2 3x1cf 0.1 5x1tr
~WDMr 0.D03 2k1tf om 4x10"
ingestion of and Dermal Contact with L.eacha18 Surface Water
Child (ages 1~) 0.05 8x10~ 0.2 7x10.
Child (ages 7-12) 0.06 1x10. 0.2 8x10.
~gestion of ~ Dermal Consact with I .""'We Sediment
~ .. WS) DJ)4 4x1Xf D.3 21110-
Child (ages 7-12) 0.04 "x1tf 0.3 2x1t)"
Ingestion of and Dermal. Contact with Surface Soils (0-2 feet)
Child (ages 1~) 0.0008 1x10. 0.01 2x10"
Child (ages 7-12) 0.C007 1x1!t 0.01 2x10"
Ingestion of and Dermal Contact with Sediment
Chi1d (ages.1~) 0.04 1x1D' 0.04 2x1!t
Child (ages 7.12) 0.3 2x1/t 0.3 3x10.
~gestion of Groundwater
Adult 0-6 6!cta' 20 Sx10'
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See Appendices B and C for chemical-specific risk estimates for .ach exposure pathway.
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Risk estimates developed as part of this baseline risk assessment were eva1uatl:d
using tbe USEP A criteria and target risk range to identify tbe need for remedial
actions at this site. Those chemicals present at Sites 1 and 3 at concentrations in
. excess of health-based criteria or the target risk range were identified for ead1
exposure pathway and appropriate target clemup levels were developed.
Carcinogenic riskS in excess of l
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runways upstream of Sites 1 and 3. Mere Brook is not being addressed directly by
the remedy for Sites 1 and 3 because there are additional upstream sources of
contamination. Information will be identified by the Navy regarding these potential
sources a,.,d will be presented to the USEP A and MEDEP. If upstream sources of
contamination that can be attributed to past disposal are identifie~ these newly
identified sites would fall under authority of the Comprehensive Environmental
Response, Compensation, and liab~ Act (CERaA) and would be included in the
Navy's IRP. H Dot under the IRP, the Navy will take appropriate steps to ensure that
mte and federal ~ are met regarAiJ\8 iOW'", jCPntjfj"-d ~ NAS
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The environmental risk assessment concluded that iron and zinc in the portion of
Mere Brook adjacent to Sites 1 and 3 may cause some adverse impacts to aquatic
organisms. The concentrations of iron and zinc downstream of Sites 1 and 3 and at
monitoring locahoDS in Harpswe1l Cove are below their respective A WOe. All other
contan:rlnatIU in M~ Brook '\\"ere detected below levels amsidered to presCJl1
ecological risk. Visual observations of tbe Mere Brook ~tem made daring the
RI did not identify any areas of stressed vegetation or gross impacts of contamination
other than the leachate seeps.
. Tbe selected remedy for Sites 1 and 3 will eliminate the discharge of contaminated
groundwater from tbe landfill areas to Mere Brook. This will result in a decrease
in the amount of iron and zinc in Mere Brook. Surface water concentrations will be
monitored to evaluate contami~nt reduction over time. H long-term monitoring
data show that concentrations of iron and zinc are not decreasing, additional
remedial measures will be evaluated. However, because iron and zinc have been
detected above their A WQC upstream of Shes 1 and 3, it may not be possible to
achieve target deanup JeveJs as a result of relr'p1lia 1 action at Sites 1 and 3.
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Mercury has been detected in the sediment around these leachate areas. Because
some environmental receptors (e.g., earthworms, small birds, and roden1S) could feed
iD these areas, they may be exposed to mercury. The results of a quantitative food-
web analysis indicates that potential exposure to mercury from these areas could
..QUSe adverse impacts to these orpnim1S. The same food-web analysis indicates that
all other conf~min~nts in the sediment around the leachate areas were detected
below levels considered to present an ecological risk. The food-web analysis is
presented in Appendix Q of the Draft Final RI Report. Jmplementation . of the
seleaed remedy will ~1imin~t~ )eaf},9te seeps and prevent further conf~mination of
Kd~Dt in the vic:iDity of the seeps. While the ~~ia1 .rti
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the sediment will be monitored to assess the effectiveness of these processes in
minimizing further impact to the Mere Brook ecosystem.
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.Actual or threatened releases of bazardous substances from this site, if not addressed
by jmplementing the response action selected in this ROD, might present em
imminent and substUltial endangerment to public health, welfare, or the
environment. The objective of the selected remedial action is to cease the discharge
of cQTJ1amm~1ed grcnmdwa1er under Sites 1 and 3, remediate the groundwater, and
by 50 doing, c1ean up the surface water, leachate, and related sediments.
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VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
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A. STAroTORY REQVIREME~'TS/RESPONSE OBJECTIVES
Under its legal authorities, the leo:d agencys (Le., Navy) primary responsibility at
NFL and similar sites is to undertake remedial actions that are protective of human
health and the environment. In addition, Section 121 of CERaA est~h1ic;:hes several
other statutory requirements and preferences, including a requirement that the Navy's
remedial action, when complete, must comply with all federal and more stringent
state enviramnenta1 standaYds, requirements, criteria or lUuiUrtions, unless a waiver
is invoked; a requirement that the Navy select a remedial action. that is cost-effective
and that uses permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable; and a preference for
remedies in which treatment that permanently and significantly reduces the volume,
toxicity, or mobility of the hazardous substances is a priilcipal element over remedies
not invoMng such trJ>~tml"-Yi1 Ff':D"I~rl;~l alternatives were deve10ped to be amsistent
with these congressional "'~T\da.~
Based on preliminary information relating to the types of contaminants,
environmental media of concern, and potential exposure pathways, remedial action'
objectives were established to aid in the development and screening of alternatives.
. These remedial action objectives were established to mitigate existing and future
potential threats to public heahh and the environment:
.
to reduce the generation and migration of ~m;T\~tP.d
groundwater
.
to reduce the potential risk associated with ingestion of
c:ont~min~1".d groundwater . . .
.
to minimize future negative impacts to Mere Brook .and
the sediment in the leachate seeps resulting from the
discharge of contam;n~ted groundwater and leachate
.
to reduce the concentrations of metals (iron and zinc) discharging to
Mere Brook
B. TEcHNOLOGY AND AL1ERNATIVE DEVELOPMENT AND SCREENING
CERCLA and the National Contingency Plan (NCP) set forth the procas by wbid1
remedial actions are. evaluated and selected. In accordance with these requirements,
a range of alternatives was ~loped for the site..
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Remen1::11 action ~ltern::ltives for NAS Brunswick were developed to meet the
following requirements: (1) the alternative adequately protects public health and the
environment; (2) the alternative can attain chemical-specific Applicable or Relevant
aDd AppropriBte Requirements (ARARs) and can be implemented in a man:D.er
consistent with location- and action-specifir. ARARs; (3) the alternative uses
permanent treatment technologies to the mC1Ximum extent practicable; (4) the
alternatives developed are capable of achieving a remedy in a cost-effective manner,
considering short- and long:term costs; and (5) the alternatives that pPTTT"~11entJy ~md
significantly reduce the toxicity, mobility, or volume of hazardous substances will be
selected, to the maximum extent practicable.
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Alternatives for Sites 1 and 3 were developed by combining treatment technologies
to form a range of feasible alternatives that address contamination in the medi~L of
concern (i.e., groundwater and leachate). Alternatives were developed that range
from no action to containment to permanent treatment.
The RIfFS screened tedmologies based on site- and ~J;'II:frlJg ~~rtmstics.
These technologies were combined into Temedial action alternatives.. The Phase I
FS presented tbe Temedial alternatives developed by combining the technolo!,ries
identifie9 in the previous screening process in the categories denoted in
Section 300.430(e)(3) of the NCP. The purpose of the initial screening was to
narrow the number of potential remedial actions for further detailed analysis wltrlle
preserving a range of options. Eacb alternative was then evaluated and scree]oed
according to its implementability, effectiveness, and cost.
Five of the six TeIIledial action alternatives screened in the Phase I FS were retained
for detailed analysis and are presented in Table 3. In addition, a true No Action
Alternative (Le., involves no remedial actions and includes no costs) was developed
and included as part of the detailed elevation. The only alternative e1im1n~t~ from
further consideration included source removal and ~lAhOD and ground~l.ter
extraction and treatment This alternative was eliminated because excavation and
handling of the estimated 300,000 cy of waste was considered to be cost-prohibitive
and more hazardous than leaving it in place~
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TABLE 3
SUMMARV OF REMEDIAL ALTERNATIVES: SITES 1 AND 3
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HAS BRUNSWICtC
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ALTERttATIVE
CoMPoNENTs
, .3-A: No Action
, ,3-8: Minimal Action
No additional remedial actions
Institutional controls and deed restrictions
Environmental monitoring
, ,3-C: Containment
Cap
Subsurface hydraulic barrier
Groundwater extraction wells
Water treatment
Dischar!18 d 1rBated water
Institutional controls and deed re.stridlons
Environmental monitoring
Passive groundwater collection
Water treatment
Discharge of treated water
Institutional controls and deed restrictions
Environmental monitoring
, ,3-D: Passive Groundwater
CoIlectionfTreatment
',3-E: Cap/Groundwater
Extraction fTreatment
Cap
Groundwater extraction wens
Water treatment
Discharge of treated water
Institutional controls and deed restrictions
Environmental monitoring
',3-F: Cap/Passive
Groundwater CoUedion/Treatment
Cap
Passive groundwater collection
Water treatment
. Discharge of treated water
Institutional controls and deed restrictions
Environmental monitoring
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VIII. DESCRIPTION OF AL'lERNATIVES
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This section summarizes each alternative evaluated. Detailed alternative descriptions
can be fOUDd at pages 3-5,3-7 through 3-10, 3-14 through 3-44,,3-63 through 3-72,
3-87 tbTougb 3-91, and 3-106 through 3-107 of the FFS.
AL~~1~4:NOAcnON
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This altematiye was developed and evaluated iD the FFS to serve as a baseline for
N\mFTicnn wjth the other rC"mpiti~l a1tP.Tnati~ UDder ~ideratiOD. Under the No
Action Alternative, no active measures would be taken to yeduce or contain
contamination emanating from the landfills. No costs would be incurred if this
alternative were implemented. This alternative would not meet the cleaIlup
objectives of the site.
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ALTERNATIVE l,3-B: MINIMAL ACI'lON
This ahemative would consist of the following components:
.
institutional controls and land-use restrictions
environmental monitoring'
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Under the Minima] Action Alternative, no active measures would be taken to reduce
or contain contamination emanating from the landfill. Institutional controls would
consist of posting warning signs around the landfill and near the leachate seeps (the
site is, currently fenced and access is limited). Restrictions to future development
would be' incorporated to restrict land use should the base be closed.
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The environmental monitoring program would 'monitor the migration and discharge
of contaminated groundwater to Mere Brook. In addition to groundwater., sm1:ace
water, sediment, and leachate seeps would be sampled and analyzed for the
contaminants of C9ncern. The environmental monitoring 'program would be
submitted for regulatory review and would include a proposed sampling freque][1CY.
Data collected under this program would provide information necessary to assesS the
'4spersioD and degradation of contamination etnanating from the landfill. :Ibe
environmental monitoring program would continue for 30 y~.
Estimated Tune For Design and Construction: 6 mOnlks
EstimIZted Tune For Operation: 30 years
EstitnIIU4 CizpitIzl Cost: $10,000
Estimated Operation and Maintenance Cost (net premzt worth): $788,()()(J'4'
EstimIZted Total Cost (net presenJ worth): $1,147,000.
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ALTERNATIVE 1,3-C: CONTAINMENT (slurry wall, cap, - aDd groundwater
extraction and treatment)
This. alternative consists of the following components:
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sluny wall
&.ap
groundwater extraction wells
groundwater treatment.
disch(,lTge of treated water
institutional controls and land-use restrictions
environmental monitoring
.
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The landfill would be amtained by a 1ow-peflN"~'bi1ny alp 4md shmy wall. The
contamment system.would minimize the amount of dean water (e.g., precipitation,
snowmelt, or groundwater) coming in contact with the waste, and therefore minimi7,e
leachate production. .
. To achieve more rapid lowering of groundwater within the waste, and to prevent
further migration of contaminated water to Mere Brook, extraction wells would be
installed to pump the water contained within the sluny wall. This contaminated
water would be treated before discharge.
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The FFS evaluated several treatment processes (e.g., pretreatment, air stripping, and
UV /oxidation) and discharge options for extracted groundwater. It is expected that
groundwater would be pretreated to remove inorgania and then treated using a
IN/oxidation technology to destroy organic lY1ImImm:rTrtL Beca:iJse of 'the small
volume of water and shon duration of pumping for this alternative, it would be cost-
effective to combine the flow from the Sites 1 and 3 extraction wells with
groundwater pumped from the Eastern Plume and treat the flows concurrently. This
assumes that the Eastern Plume treatment plant is on-line when pumping at Sites 1
-..and 3 commences.
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Options evaluated for discharge of treated water include surface water (e.g., Mere
Brook), groundwater (e.g., upgradient reinjection), the Brunswick Sewer District's
POTW, and the Town of Brunswick's storm sewer system. The preliminary
evaluation in the FFS identified discharge to the P01W to be the best option for this
site; however, the POTW has not yet committed to accepting this discharge.
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Because Alternative 1, 3-C does not remove the waste from tbe site, institutional
controls consisting of fencing and signs would be maintained. In the event the base
is closed, land-use restrictions would be enacted to prevent furore development of the
Sites 1 and 3 area. .
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A long-term monitoring program would be developed and submitted for regulatory
agency remw. This program would monitor the media of concern and provide
information on the effectiveness of the remedy- This program would c:ontmue for a
minimum of 30 years.
EstimaJed Tune For Design and Construction: 25 years. .
Estimated Time For Operation: 1 year (groundwater extraction only)
Estimated Capital Cost: $3,874,000 .
Estimated Operation and Maintenance Cost (net present worth): $1,432,00'0.
Estimated Total Cost (net present worth): $7,842,000.
.
Net present wonb costs are based on a 10 pe1<:eDt discount factor 2md
30 years of operation .
ALTERNATIVE 1,3-D: PASSIVE GROUNDWATER COLLECTION AND
TREATMENT
This alternative consists of the following components:
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groundwater collection
groundwater treatment
discharge of treated water .
institutional controls and land-use restrictions
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Contaminated groundwater would. be collected by either a downgradient collection
trench sunounding the site or extraction wells placed within the landfill. 1ibe
collection trench would be placed to a depth of approximately 25 feet below grO\md
surfare (bgs). A perforated polyvinyl chloride (PVC) pipe would allow water to flow
to centrally located sump pumps. The collected water would be pumped and treated
at a treatment plant. If an extraction system were used, it would be designed to
-contain and collect the contjlminated groundwater before it discharges to Mere
Brook.
Collected groundwater wowd be .treated using the saDie pretre~tm~l't w"nn]Oi~es
and treatment options. described in the FFS report. Air stripping and UV/oxidation
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are the process options for VOC removal tbat were retained after alternative
screening. . .
Both metals and VOC treatment would occur in the same treatment plant. Based
on groundwater modeling, it is estimated to take betWeen 18 and 73 years to collect
aDd treat the groundwater to cleanup levels. More than 610 million gallons of water
are estimated to require treatment. Because of the time required to treat the
groUDdwateT and the amoU11t of water to be treated, this alternative would not be
combined with the groundwater treatment proposed for the Eastern Plume, and a
tepala:te UV(nwm facility wou]d be amstruded. TI'P~t,..d water would be preimlPly
discharged to the POTW if this option is acceptable to the POTW, as described for
Alternative l,3-C.
Institutional controls would be required in this alternative, as described for
Alternative 1,3-C, because the untreated waste would remain on site. Land-use
restrictions woUld be enacted if NAS Brunsw:ick is dosed in the future. An
~v~u~nta1 monitoring program would be implemented to assess 1be effectM:ness
of the pumping system at capturing the contaminat-ed groundwater. The
environmental monitoring program would be submitted for regulatory review and
would include a proposed sampling frequency.
Estimated Time For Design and Construction: 2.5 years
Estimated Time For Operation: 18 to 7.3 yetn
Estimated Capital Cost: $2,710,000
Estimated Operation and MainJenmu:e Cost (net present warth): $6,821,000.
. Estimated Total Cost (net present worth): $12,938,000.
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Net present wonh costs are based on a 10 percent discount factor and
30 years of operation
ALTERNATIVE 1,3-E: CAP AND GROUNDWATER EXTRACTION AND
TREATMENT
This alternative would consist of the following components:
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cap
groundwater extraction
. groundwater treatment
discharge of treated water
institutional conu-ols and land-use restrictions
environmental monitoring
.
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lnsta11a1lon R~ltn atlon PI 091 an.
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The cap would be mnstructed over the landfill as described in Alternative 1,3-C.
Tbe groundwater extraction system would consist of groundwater extraction w,~lls
placed within the landfill to contain and collect the contaminated groundwater before
it discharges to Mere Brook. Based on groundwater modeling. it is eai~tP.d to t~e
. between 18 and 73 years to achieve cleanup goals in the grOUDdw~r- More t112]]
610 million gallons of water are estimated to require treatment.
Groundwater would be treated and discharged as desaibed for Alternative 1,3-D.
Because waste would remain on site, institutional controlS and land-use restrictions
would be required as described in Alternative 1,3-C. Results of the environmental
monitoring program would provide information necessary to assess the perlormaDce
of the groundwater extraction system. The environmental monitoring program would
be submitted for regulatory review and would include a proposed sampling frequency.
Estimated Time For Design and Construction: 25 years
Estimated Time For Operation: 18 to 73 years
£stimJIted CApilal Co5t: $3,152,000
Estimated Operation and MainteNlllCi! Cost (net P'~ WOIth): $7,066,tXXJ-
Estimated Total Cost (net present worth): $13,591,000.
.
Net present worth costs are based on a 10 percent discount factor and
30 years of operation
ALTERNATIVE l,3-F~ CAP AND PASSIVE GROUNDWATER COLLECTION AND
TREATMENT
This alternative would consist of the following components:
.
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cap
gro11J1dwaW' collection
groundwater treatment
discharge of treated water
institutional controls and land-use restrictions
environmental.monitoring
.
.
.
.
This alternative is the same as Alternative l,3-E with the exception that a
. downgradient interceptor trench would be used to collect amt~min~ted groundwater
rather than an extraction well system. The collection trench would be the same as
that described for Alternative l,3-D. As with Alternative 1,3-D, between 18 and
73 years WODld be IcQW:red.to achieve groundwater ~ p1s and more 1ban 610
million gallons of water would require treatment. Resu1ts of tbe CIlVironmental
monitoring program would p.rovide infonnation DeCeSsaJy to assess the perfOl1Wmce
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of the groundwater extraction system. The environmental monitoring program would
be submitted for regulatory review and would include a proposed sampling frequency.
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EstimDJed Tune For Design and Con.struction: 25 years
Estimated Tune For Operation: 18 to 73 years
Estimated Capital Cost: $3,965,000
EstimI:11ed Operation Dnd MainJenJ11l&e Cost (net presenJ wo11h): $6,821,000.
Estimated Total Cost (net present worth): $14,744,000*
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30 years of operation
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IX. SUMMARY OF TIlE COMPARATIVE ANALV~IS OF ALTERNATIVES
Section 121(b)(l) of CERaA presents severa] factors that, at a miT1imum, the Navy
is required to ~ideT in its assessment of alternatives. Building upon these spec:ific
statutory mandates, the NCP articulates nine evahra:tion cri1eria to be used in
assessing the individ.ual remedial alternatives.
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A detailed analysis was performed on the alternatives using the nine evaluation
criteria to select a site remedy. The following is a summary of the comparisoD. of
each alternative's strengths and weaknesses with respect to the nine evaIuation
criteria. These criteria and their definitions are as follows:
Threshold Criteria
The two threshold criteria described below must be met for the alternatives
to be eli£ib1e for selection in accordance with the NCP.
1.
Overall protection of bUlllAfI heahh and the en~irollmeDt
addresses whether or not a remedy provides adequate
protection and describes how risks posed through each pathway.
are eliminated, reduced, or controlled through treatmcmt,
engineering controls, or institutional controls.
2.
. Compliance with ARARs describes how the alternative complies
with cbemica1-, location-, and action-specific ARARs, or otber
criteria, advisories, and guidance.
Prima", Ba)ancin~ Criteria
The fonowing five aiteria a:re used to ~ate and eva1uate 1he e1ement!i of
one alternative to another that meet the threshold criteria.
3.
Long.term effectiveness and permanence evaluates 'tbe
effectiveneSs of altema.tives in protecting human health and the
.environment after response objectives have been met, in terms
of the tnagrtitude of residual risk and the adequacy ~md
~41eliability of controls. .
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&edDCtioJl 01 tnnM~, II"nhili-" or ¥o1ume through treatmeDt
eva}l1ng 1he tlt-........ent ter1mn1ogies by the degree of ezpec:ted
reduction in toxicity, mobility, or wlume of hazardous matedal.
. This criterion also eva1uat~ the iJreversibiJity of the treatment
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process and the type and quantity of residn~lc; rem~ining after
treatment.
Short-term effectiveness addresses tbe period ()f time needed to
achieve protection aDd any adv~rs~ impacts on human healtb
and the environment that may be posed during the construction
and implementation period, until the remedial action objectives
are achieved.
ImplL"JfteDtability assesses the ability to construct and operate
the technology; the reliability of the technology; the ease of
undertaking additional remedial actions; and the ability. to
monitor the effectiveness of the remedy.. . Administrative
feasibility is addressed in terms of the ability to obtain
approvals from other agencies. This criterion also evaluates the
availability of required resources, such as equipment, facilities,
specialists, and ~p~M1y.
7.
Cost evaluates the capital and operation and maintenance costs
of each alternative, and provides an estimate of the total
present wonh cost of each alternative.
Modifvin2 Criteria
The modifying criteria are used in the final eva1uation of remedial alternatives
'generally after public comment on the RIfFS and Proposed Plan has ~D
received.
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State acceptaDee addresses whether, based on its review of the
R1JFS and Proposed Plan, 'the state concurs with, opposes, or
. has no comment on the alternative the Navy. proposed for the
remedial action. .
The State of Maine has provided comments on the proposed
. plan and has documented its concurrence with the remedial
action in the letter of concurrence presented in Appendix F of
.this ROD. .
9.
Community acceptance addresses whether the public c:oncurs
with the Navy's Proposed PJaD.Co...UII.l'iity a("'~1~I~n~ of the
Proposed Plan was evaluated based on comments received at
the public hearings and nnnng the ~ubW: commf!t1t period.
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This is documented in tbe Responsiveness Summary preseD.ted
in Appendix E of this ROD.
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The state acceptance criterion has been addressed by incorporating comn1f~nts
received from the state on the Proposed Plan. The state is a party to the FF A :md
bas had the opportunity to review and comment on all documents. Community
acceptance criterion is addressed as part of the Responsiveness Summary in
Appendix E of this ROD.
Following the detailed analysis of each individual sltp.m~tiv~ a comparative analysis,
focusing on the relative performance of each alternative against seven of the Dme
criteria, was conducted. This comparative analysis can be found in Table 4-1 of the
FFS.
The section below presents the nine criteria and a brief snmmary of each alternative
and its strengths .and weaknesses according to the detailed and comparative analyses.
~n Protectioa or HWIIU Health.&ad tile EDvjro~~t
The selected alternative will reduce contaminant concentrations in groundwater,
surface water, stream sediments, leachate seeps, and leachate sediment to levels
. protective of human health and the environment. The other three treatmlent
alternatives would provide a similar degree of protection. However, the selec:ted
alternative includes an upgradient slurry wall to diven groundwater around the
buried waste. This component of the alternative will decrease the amount of
contaminated water to be extracted and treated compared to the other tbree
treaunent alternatives. The time required to achieve the remedial action objectJlves
for the selected alternatives is estimated 10 be about one to' tWo years, while the
other treatment alternatives are estimated to require between 18 and 73 years to
achieve the objectives.
The No Action and Minimal Action Alternatives would not achieve overall
protection of human health and the environment because the cleanup objectives
would not be achieved. .
Compliance with Applicable or Relevant and Appropriate Requirements
The selected alternative and the three other treatment alternatives would meet all
ARARs. The No Action and Minimal Action Alternatives would not meet ARARs .
br~1~ of the CODt1m~ re1~~ of ftmtM!rimmb: from the Ismrifin 10 the
groundwater discharging to Mere Brook.
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Final treatment standards for groundwater will be based on discharge requirements.
For the preferred discharge optio~ discharge to tlte POTW, treatment standards will
be set such that the POTW will not be in violation of its National Pollutant
Discharge F:1imin"tjon System (NPDES) permit. These standards could be more
. stringent than M CI..s. ..
,
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Long-term Effectiveness and Permanence
The selected alternative will divert groundwater around the waste and limit rainwater
infiltration into the )andfi11 , The volume of contaminated groundwater remaining
beneath tbe cap will be extracted and treated so that it will not discharge to Mere
Brook. The remedial action objectives are estimated to be achieved in about one to
two years. The contaminant source will not be remediated but the generation of
contaminated groundwater will be minimi7.ed.
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The other treatment alternatives would meet the remedial action objectives because
contamina~ groundwater would be extracted or colleaed and uea1ed on a
continu.a1 basis. Eacl1 of these options would provide a ~.. ....nf!1rt remedy but wou1d
require between 18 and 73 years to achieve the. remedia 1 action objectives and would
treat a much greater volume of contaminated groundwater.
Neither the No Action Alternative nor the Minima] Action Alternative would provide
. long-term effectiveness. The site would continue to pose a risk to humans and the
environment.
Reduction of Toxicity, Mobility, or Volume through Treatment
The selected alternative will reduce the toxicity, mobility, and volume of
contamin~ted groundwater through treatment. An estimated 16 million gallons of
con1am;.oSItl'.il groundwater, which would otherwise di.vMTge to Mere Brook, will be
extracted and treated.
The other treatment alternatives would reduce toxicity, mobility, and volume through
treatment These alternatives would rely on natural flushing to decrease contaminant
levels in groundwater and would require long-term treatment of contaminated
groundwater to achieve the remedial objectives. A much greater volume of
groundwater would require treatment in each of these alternatives.
The No Action Alternative and the 1\.finima1 Action Alternative would not reduce the
1DIici1y7 mobiH1;y, or vo1nmP. of rontMftmj\..u. wl"!mCfO .D) 1:re1"I..~pt WDU1d be
,. 1.. d
JnVOne .
WOO292A6.080
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Short-term Effectiveness
The selected alternative and the other. three treatment alternatives have similar
short-term effectiveness evaluations. Local truck traffic will increase because of 'the
ttansponation of construction materials and equipment to and from the site.
Environmental impacts will be minimal and a:e limited to the removal of trees to
facilitate construction activities.
Tbe No Action Alternative and the Minimal Action Alternative would not result in
my adverse impacts to the public and the environment.
Implementability
All the alternatives evaluated in the FFS are implementable. All the necessary
construction services required for the treatment' alternatives are available. The
extraction and treatment technologies proposed for the remedial' action .are
imp1cmemable and have been fU('cessfully de-mnnstT.atea at other sites. The
prefeIred option of disc:1mging tteated W3ter to the POTW must be approved by the
Brunswick Sewer District before it can be implemented. If the applli:ation for
discharge to the pom is not approved, another discharge option would be required.
Other discharge options include recycliDg the water back into the aquifer by
. upgradient recharge or discharge to surface water on base. Hazardous waste disposal
sites able to accept waste from Superfund sites have been identified. These disposal
sites would be used if the pretreatment metals sludge was determined to be
hazardous. Coordination with base security would be required to obtain acass to
the securen area to conduct monitoring and consttuction activities. .
Cost
The capital, operation and mamtenance, and total costs for each alternative are
provided as part of Section Vll, Description of Alternatives. Although the se1ected
aliemative does not have the lowest estimated capital cost of the four tteatment
alternatives, it does' have the lowest operation and maintenance cost and total cost.
The higher capital cost is due mostly to the slurry wall component in the selected
alternative. The lower operation and maintenance and total costs are a result of the
1'educed groundwater treatment time.
.State Acceptance
~
As a party 10 the FFA, 1he S1ate af MaiDe has pnMded 1DI.""'1Ir"-I.k em tile RIfFS ami
the proposed p1an and 1m documented its c:cm.wuence with the remedial Etion as
Installation Restoration Proiram
WOO29246.080
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stated in Section XIII of this ROD. A copy of the State's letter of concurrence is
presented in Appendix F of this ROD.'
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~mmunity A.captaDce
Community acceptance of the Proposed Plan was evaluaLed based on comments
received at the public meetings and during the public comment period. This is
documented m the Responsiveness S111mT1~ty presented in Appendix E of this ROD.
if.. .
Instal~tion Restoration Program
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, x. THE SELECTED REMEDY
The selected remedial alternative chosen for Sites 1 and 3 (i.e., Alternative 1,3-C)
is a compreMnsive remedy having source control and management of migr.:uion
components. It is designed to contain tbe buried waste and ",;"m,b-e the migration
of contaminants from the landfill by reducing the water flowing through the waste.
A. CLEANuP LEvELs
~up ~ls ha\'e been established for CO!)httninsmts of concern in each mema
' identified in the baseline ,risk assessment. that were found to pose an unacceptable
risk to either public health or the environment. The media of concern are
groundwater, surface water, and leacbate sediments. Ceanup levels have been set
based OD the appropriate MARs (e.g., drinking water MCLs) if available. In the
absence. of a chemical-specific ARAR, or other suitable criteria to be considered, a
1~ excess cancer risk level for each carcinogenic contaminant or a concentration -
corresponding to an m of 1.0 for each noncarcinogenic cont~min:.!nt was used t~, set
cleanup levels for each exposure pathway. Periodic assessments of the protection
afforded by remedial actions will be made as tbe remedy is being implemented and
at the completion of the remedial action. If the remedial action is not found tCI be
protective, further action sball be required.
1. Groundwater
Because the aquifer at and beyond the compliance boundary of the site is classified
as GW-A, which is a potential source of drinking water, MCLs and non-zero
M-aYimnm Contamin~nt Level GoaJs (MCLGs) established under the Safe Drinking
Water Act (SDWA) are MARs.
Cleanup levels for known and probable carcinogenic CuJ.Upuuud5 (Classes A and B)
have been set at the appropriate MCL. Ceanup levels for the Oass C, D, and E
compounds (possible carcinogens not classified and no evidence of carcinogenicity)
have also been set at the MCL. In the absence of an MCl., a proposed drinking
water standard, or other suitable criteria to be considered (i.e., health advisory or
state standard), a cleanup level was derived for carcinogenic effects based on a 1~
excess cancer risk level considering the'ingestion of groundwater.
. .
Ceanup levels for compounds in groundwater .exmoirlng noncarcinogenic effects have
been set at the Ma.. In the absence of an Me..., ~1~nl1p levels far noncarcinogellic
effects bage been set at a Je\1e1 thought to be without appredabIe risk of an adver.se
effect when expoSW'e occurs over a lifetime (HI = 1.0).
~rogram
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Table 4 summarizes the cleanup levels for carcinogenic and noncarcinogenic
contaminants of concern identified in groundwater.
These groundwater cleanup ~e1s must be met at the completion of the Temedial
action at the points of compliance. These cleanup levels are consistent with ARARs
for groundwater and attain USEP A's risk m~n3.Eement goal for remedial actions (i.e.,
carcinogenic risk 1evel between 10-' and 10") unless the Me.. is outside the risk
range. The MCL for arsenic is set at 0.050 p,g/L and has a residual risk greater
iliml~ .
Risks presented by the soils at Sites 1 and 3 are within the acceptable range
established by USEP A; therefore, residual risk remainine after implementation of the
remedial action will also be in the acceptance range. Although soils/waste will not
be removed or treated, containment technologies are generally considered
appropriate for landfills where treatment is impracticable because of the volume and
heterogeneity of the waste (USEPA, 1990). Therefore, no Taxget Oeanup Levels
have been set for soils at Sites 1 and 3.
2. Other Cleanup Levels
Based on the results of the ecological risk assessment, remedial action objectives
were developed to reduce exposure to or contaminal1t concentrations in surface water
and leachate sediments around Mere Brook. Surface water Target Cleanup Levels
for iron and zinc were proposed at the contammants' A WQC for purposes of
determining whether the contribution from Sites 1 and 3 to Mere Brook has been
alleviated; leachate sediment Target Oeanup Levels for mercury were derived based
on the food-web analysis. .
Ecologial Target ~np Levels for COlJb.h.;liah~ in leamme seeps and surface
water were set at A WQC or risk-based levels. For zinc:: and iron (e.g., surface water
contaminants), the Target Oeanup Levels were the AWQC; for soil/sediment
conta.minarits ( e.g., mercury) the cleanup levels were based on assumed exposure and
risk conditions. Mercury was the only contaminant identified in the baseline risk
assessment to present. a propensity to bioaccumulate and bioD'SlgTlify in tenestrial
food chains. Other contaminants (e.g., VOCS and inorganic metals) do Dot exhibit
Jhe same behavior and, therefore, were not considered to present a risk to terrestrial
~receptors (E.c. Jordan Co., '1990a). The Target Ceanup Level of I1Dg/kg for
mercury was developed using the same food-web 'analysis as in the baseline risk
asseismMtt DDs ~1 ~Sltes the bi~"""Tnnbvon of COTII...1..;.~ withW a food
web and can be used to e~t.iwate an acceptable soll/sediment concentration that is
protective of higher trophic level organisms. Ecological Target Oeanup Levels are
also presented in Table 4.
Installation Restoration Program
. WOO292A6.1110
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TABLE 4
PROPOSED CLEANUP LEvEL.s FOR SITES 1 AND 3
ROD: Sms 1 AND 3
HAS BIMCSW1CK
MEDIUM
MAXIMUM,
CoNcENTRAU* "
TA1mET
CLEANuP,
I.£Y£L
RATIONALE
RESIDUAL.
RISK'
-
Human Health
Groundwater
Arsenic
107 pg/L 50 pg/L MCL,.3 1 x1 ()'3(C)
180 pg/L 2 pg/L MCL' 4.5x10.5(C)
460 1IQ/1. 5 pg/L MCL(P) 4.4x10.7 (c)
140 pg/~ 70 JI9/L MCL3 0.2 (nc)
140 pg/L 100 pg/L MCL3 0.1 (nc)
11 pg/L 100 pg/L MCL 0.6 (nc)
60 pg/L 15 pg/L MCL NA
(action level)
78 pgjL 100 pgfL MCL(p)2 0.1 (nc)
Vinyl Chloride
Methylene Chloride
" .2-Dichioroett1yIene (as)
1 .2-Dichloroethylene '(trans)
Chromium (total)
Lead
Nickel
Ecological
Leachate soil/sediment
Mercury
3.3 mg/kg
1 mgfkg
Risk-
based
ftGt88:
MCL .
MCL(P) .
NA .
mgjkg .
IIG/L .
1 .
2 -
3 -
4 -
5 -
Maximum Contaminant Level
Proposed Maximum Contaminant Level
quantitative dose-respon18 data are not available
milligrams per kilograms
micrograms per liter
The MOl for 81'18nic Is currently under rwiew; USEPA ,.1.
MCL(P) Is equal to MCLG.
USEPA '1991 b.
. ",.MEG for VInyl Q\Ioride Is 0.15 pg/L
. 40) Indlcatn C8I'Cinog8nic oompounda and tnc) Indicat8& IIOIlcardllogenic oompoundl
, WOO292A6.T80\l
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B. DESCRIPTION OF REMEDIAL COMPONE~
The Navy's selected alternative is designed to contain the buried waste and minimize
the migration of contaminants from the landfill by reducing the amount of water
flowiDg through tbe waste. This alternative includes the following components:
.
slurry wall
cap
groundwater extraction wells
ga1mdwa1er tt~fTn,."t
discharge of treated water
institutional controls and land-use restrictions
environmental monitoring
.
.
.
.
.
.
51uI'I)' Wall
The slurry waD would be placed around the landfi11 (with the exception of me
Weapons Compound area), and would divert dean groundwater flow Mound the site.
preventing groundwater contact with the landfill waste material (Figure 3). Because
tbe slurry wall would be sealed into the underlying silty clay, and would have a
permeability of 10~ to 10.7 centimeters per second (em/see), mi"imal groundwater
. would flow beneath or through tbe wall. Tbe location of the slurry wall in Figure 3
was estimated by computer sinmlation of the groundwater flow system. The actual
placement of the wall will depend on further geotechIrica1 explorations in the area,
wbich are expected to be part of the pre-design efforts. Figures 4 and 5 show
cross-sections of site geology, limits of waste, and the groundwater table interpreted
from RI test pits and borings. The cross-sections also sbow the proposed location of
tbe slurry wall. The final location of the slurry wall would be outside the limits of
waste. Additional geotechnical borings, during the predesign phase, will more
accunte1y map the location of the silty day 1ayer beneath the site..
Cap
A low-permeability cap would be placed over the landfill area to reduce the amount
of rainfall infiltration and thereby reduce "leachate production. The cap would also
extend over the slurry wall to prevent desiccation of the slurry wall. The m~rimum
. . permeability of the low-penneability soil (or day) layer would be !xU)"' an/see. The
landfill cover would be designed to meet or exceed Resource Conservation and
Recovery Act (RCRA) guidance as desaibed in the USEP A document. Design and
Ctmstnu:tion of RCRA/CERCLA Final Covers (USEPA, 1991b) and sound
engineering design practices. Site-specific conditions will be considered in
determining the most effective cap design. A typical cover system is composed .of a
Installation Restoration Program
WOO29246.080
42
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I LtOtNO
e UT1!NT ell' PIIOI'OMD CAP
n PWOf'OSID 1lUM't W>\U.
, - LDCAnoot
.--- ~ ell' COIfJIIIIlUD
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Sins' AM) I u.IllfUl
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~ .o1-TlYI ~AT1!1
. 'LOW OOAtCTIOOt tAstO 001
C~E" ---~TIOOt
... A-a8lAn lOCATIDIt ell'
PROPOSEb EXTAACTIOfI WEI
I
.
FIGURE ~
. APPROXIMATE LOCATION OF CAP
9LURRY WALL, AND EXTRACTION WELLS
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A
WEST-
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TRANSItION
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LEGEND
-",-",-
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WATER LEVEL DATA FROM
OCT. t.l.
llTEAPRfTIVE GROUNDWATER'
'ABlE BASED ON COWUTER
SIMUlATION
PROPOSED CAP
I
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SCALE If fEET
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200 400
YERTICAL EXAGGERATION I:t
..to."
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GEOlOGIC DESCRIP11ONS1
SAtt) . TAN TO LIGHT 8ACMNF. INI). 'RACE TO Lrm.U~DIUU
SAND. TRACE nT, POOII. Y ORADtD.LOOSE to ~Du.t
DENSE. DRY TO SATURATED, SUOImy S1RATFIED WR" DE"1".
TRANSitION. BnOWNTOORAYFR"NDANDILTY.FMIAm. TRACE ClAY,
' , S1RA TIFED WRit su AND ClAYltNSES, POOfW. Y ORADED, tof
TO SlIOIRl Y I'tAS1IC, tofT "IUCES. SA 1URAtED.
SLTYClAY - ORAY,SLTYClAYTOOlAYEYSUIROCkFloun,.r.tEDIUM'O
IlKiIt I'lASTICITY, VEnt' SOFT, SATURATED.
NO": NOFUI AIlE BUfD ON AN
IfTEIlPAETATIOH 01' AIMlAIlE
IU8SUllFACE UPlOilATIONS,
Ac fUAl COftDltlOH8 MAY VARY
'ROM THOBE SHOWN,
FIGURE 4
GEOLOGIC CROSS SECTION A-A' '
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NORTH
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SOUTH
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o S
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LEGEND
~
WATER LEYEL DATA
FROM OCT. ....
. HOT!: "'«)fIUI Alii IAII!D ON AM
"T!APfII!TATIDN 01' AVAILAIU!
IU8SURFACE EIIPlOflATIONt.
ACTUAL CONDITIONS MAY \MAY
"110M THOSE SHOWN.
GEOLOGIC bncRlPn0H8r
SAND
. ...-,
~_._~._,-~
PROftOSI:D CAp
. TAN TO lIO", BROWN'" lAND, tRAcE '0 lrmE t.tE0IUM
SAND. 'MCE 8U. POoAl Y ORADED,lOOSETO foEbIuM
DENSE. DRY TO SATURAttO. suonTi. Y S'MTIFI£O WIT" DEPTtf.
TRANSrrlON . lAOWNTOORAYFM SAtGANOSl.TY.FWEllANO, TAACECIAY
IrM '1F1EO WITH au AND aAY U:NSn. POont. Y GRADED NON
'0 SlIGlfJl Y PlASrlC, !KIT If PlAets. SAJURATrD. .
81.TV ClAY . OMY. 8I.TY CtAYTOCtAttYlU 1fb:K FlounU~D!IJM '0
iilGii PlASTIC,". VERY lOfT. SAtURATED.
..TERPRETIYE GROUNDWATER
--",=,.- TABLE BASED ON CQlFUTER
SIMUlATION
ReALE .. tEn
, . ,
o 200 400
VERTICAL EXAGGERATION S:'
FIGURE 5
GEOLOGIC CROSS SECTION 8-8'
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vegetative top cover layer, a drainage layer, and a bottom hydraulic barrier that ca.ri
. be either a 2-foot recompacted clay layer .or a combined system of a 2-foot
recompacted clay layer overlain by a synthetic membrane at least 20 mils thick. The
cap described in this remedy, and used far cost-esrirn:!ting purposes, is the latter
composite cover system (F.igure 6).
The proposed cap would cover approximately 12 acres, encompassing most of the
. area designa.ted as Sites 1 and 3. A small portion (Jess than 0.3 acres) of Sne 1
located within the Weapons Compound was not incJuded in the cover system.
Althou.gh waste has been uncovered in this area, much of it is 3S-l;nmp-d to have been
removed duriDg construction. Only a small area within the Weapons Compound is
believed to contain waste and computer simulations of groundwater flow did not
show a difference between the effects of a cap including or excluding this area.
Therefore, the cap would not extend into the Weapons Compound, and wouJd
comply with the security regulations for this area of the base. Should the Weapons
Compound be closed, the Navy would evaJuate the need for extending the cap to
include that ponion of the Weapons Compound which is also part of the landfill
area. In addition, the proximity of Site 3 to the steep bmk of Mere Brook makes
a complete cover system over the entire site infeasible. However, there is .no
evidence of disposal in or along the banks of Site 3; this area comprises natural
undisturbed soils. .
The combined effect of the cap and slurry waij would reduce the groundwater table
to a level below the depth of waste. The cover system would requb'e little
maintenance and periodic post-cJosure inspections would be conducted to ensure
proper integrity. All repairs to the cover system would be made, as necessary, based
on these inspections. The grass would be mowed and reseeded as necessary.
PeriodiC inspections and mowing could be performed by base personnel as pan of
the normal maintenance routine for the secured area. Inspection and maintenance
of the cap system would be addressed in the operations aDd m:lmt~:lnce plan that
would be deveJoped by the Navy and reviewed and approved by appropriate
reguJatory agencies at the time of remedial design.
Groundwater Extraction WeDs
A groundwater extraction system would be designed and installed to remove
contaminated groundwater trapped beneath the cap and within the slurry wall (see
. Figure 3). Approximately 16 million gallons of water (Le.,1me pore volume) would
be removed and treated. Capturing this CODt:!min:tted water would prevent it from
discharging to Mere Brook. These extraction wells would decrease the time required
for this water to drain naturally. The extraction weDs included in the selected
remedial alternative will facilitate the collection of the v~ of contaminated
!I
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. . . . . . . . . . . . . . . . . . . . . . . . A A A . . . . . . . . . . . . -
' . . . . . . . . . . . . . . . . . . . . . . . A . . . A . . . . . . . . . . A
_...................A................~...................A.A.......A.........A.-
existing GTound SUTf8ce
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- "'Gr8d8d Landfill Surface
B
24- Fill
. .
1fr~Gnd
Buffer Layers
20-mi!. PVC Liner
24. Clay
Graded landfill
Surface
Final Cover (... above)
Existing Ground Surface
,
;
Not To Scale
FIGURE 6
RCRA GUIDANCE FINAL COVER SYSTEM
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groundwater remaining beneath the landfill following installation of the slurry wall
and reduce the time required to lower groundwater to levels located below the waste.
The extraction wells will pump at relatively low flow rates to ensure sustainable flow
rates. The pumping rates proposed for the extraction well system were developed
using Theis equations and assumptions (Theis, 1935). Based OD the location and
proposed pumping rates for these extraction wells, the opening .1long the southern
portion of the slurry wall is not expected to influence this component of the selected
remedial alternative. The extraction well progam will remove the volume of
contamin~ted water rem~ining within the landfill area (i.e, one pore volume), which
is estim~ted to be approximately 16 million ga.llons. 'The pore vo]nm~ of water
removed as part of the extraction well program represents the most signfficantly .
c:onrnminated portion of the groundwater system and will prevent this CODtamination
from discharging to Mere Brook. The selected remedial alternative will both lower
the water table to levels located below the waste and remove the estimated one pore
volume of water contained within the confines of the slurry wall and landfill cap.
Groundwater extraction at the Sites 1 and 3 landfill is not expected to result in
subsidence. Additional c:maction of ~ at this site.is not anticipated or
proposed, following the removal {)f the estimated one pace VQ!ume of water-
The final number of extraction wells will be determined based on data generated
during the design phase modeling program. The exact number and location of the'
. wells would be determined during remedial design. Actual pumping rates would be
determined by pumping tests conducted after extraction well installation.
The extraction wells would be drilled to the underlying silty clay surface. The
average depth to the silty clay in this ponion of the landfill is estimated at
approximately 40 feet bgs. Two 6-inch diameter wells with 30-foot saeens would be
installed in the borings. It is estimated that the entire aquifer-saturated thickness
would be intercepted by the screens. The boreholes would be backfilled and sealed
wnb bem~ Protective ~an~ would be msta1Ied and cemented in place. Each
well would contain a submersible pump capable of extracting gromidwater at a rate
of up to 60 gallons per minute (gpm). The protective casing would not penetrate the
hydraulic barrier layer. However, the well risers would and the geomembrane would
be sealed to the risers using a geomembrane pipe boot. This wen design has been
assumed for cost~on purposes and may be altered during the remedial design.
. Several piezometers would be installed in conjunction with the extraction wells to
,~uate the bydrauJic performance of the extraction well system. tPiezometers would
provide water level information during the pumping of extraction wells that would
be used to ~te aqnif~ tnlftCnliccivity, storage ftVllfFici~. and sustainable yjcIds.
The piezometers would be located both in the' direction of and perpendicular to
groundwater now. The piezometers can be monitored after the pumps are shut off
WOO29246.080
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to determine the effectiveness of the containment system in keeping water out of the
waste. '
Two types of aquifer testing would be performed at the site; ,(1) step-drawdoWD
tests, and (2) constant-discbarge tests. Step-drawdown tests provide data M well
efficiency, contaminant capture, localized aquifer properties, and short-term well
yields. Constant-disrh:lTge tests are used to evaluate drawdown effects, recbarge
boundaries, and large-scale aquifer pt~es that influence long-tem1 contamin.mt-
capture efficiency and operation of the groundwater extraction system. '
Based on calculations, estimated flow rates, Jmd analytica1 models, it is estimated 1tbat
,one pore volume (estimated to be 16 million gallons of water) may be removed in
approximately 142 days (based on an estimated 78 gpm pumping rate). This time
estimate would increase if the pumping rate is decreased. It should be noted that the
time estimates are based on several assumed variables, in particular the fraction of
organic carbon values, and that actual de.aJ11Jp times may be considerably longer.
Groundwater 'Ji'pAtmpnt
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The extracted groundwater would be pumped to a central treatment plant located
outside the Weapons Compound for 'the pretreatment of dissolved metals and
treatment of VOCs. It is possible that contaminated groundwater from Sites 1 and
3 would be treated concurrently with groundwater from the Eastem Plume. 'Ibis
scenario is considered feasible because of the similar contaminants (i.e.,VOCs), the
low flow rate of groundwater from Sites 1 and 3, and the short duration of time
(estimated to be 142 days) that would be required to pump and treat tbe
groundwater remaining beneath the cap and within the slurry wall.
An FS descn"bing the alternatives for the Eastern Plume has been submitted to the
regulatory agencies for review. A ROD for an Interim R~media1 Action for the
Eastern Plume has been submitted and also describes the concurrent water treatr:nent
scenario. The ROD for the Eastern Plume will be subject to the same public rf'~ew
, and comment as this ROD.
,A schematic Dow diagram of the pretreatment process is shown in Figure 7. "Ibis
system was developed for cost-estimating purposes to remove primarily iron and
~GaDganese. However, the final pretreatment system would be designed to remove
inorganic compounds to the appropriate discharge limits (ie., MCU m pretreatDlent
standards based OIl the P01W's NPDES permit) aDd q,nMDttaDons W1 would not
intafere with VOC 1ft--clC"~ A 1rcatabiJity test wou1d be ftlMnded prlar to design
Installa on Restoration Program
WOO29]46.080
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GROUNDWATER
FROM EXTRACTION
WELLS AT SITES
1 AND 3
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OXIDANT (OPTIONAL) POL VMER
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SLUDGE
THICKENING
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DEWATERING
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DISPOSAL OF
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, DISCf.tARGE OF
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FIGURE 7
SCHEMATIC Flaw r"AGRAM
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to ensure the proper removal efficiency md/ or. the need for my modifications in the
pretreatment process. If other inorganics such as arsenic md lead are present above
their respective discbarge limits, modifications to tbe system would be made. This
may jnch1de C'dning pretreatment steps such as the addition of lime to reduce MSeJ:1ic
and lead concentrarions to below discbarge limits.
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Once the metals are removed, the water would be treated to remove or reduce
VOCs. The organic ront~minants of concern would be destroyed using a technology
known as UV / oxidation. This technology destroys organic compounds in water
through chemical oxidation enhanced by exposure to UV li,ght. Reagents typially
used with UV loxidation include ozone (0,) and hydrogen peroxide (HZ02). (So]ne
vendors use other proprietary oxidmts.) Under these conditions, 03 and HzOz nre
rapidly converted to hydroxyl radicals. In addition, organic molecules absorb energy
from the UV light, promoting reactions with hydroxyl radicals. The combined effe:cts
of UV light and concentrated hydroxyl radicals synergistically promote rapid
breakdown of organic molecules. In the oxidation process, organic cont~minants :are
broken down into simp~ TJontulI~dous substances sud1 as amon' dioxide, water,
salts, organic and inorganic acids, or other by-products. A treatability test would
provide information on the compounds md concentratiODS likely to be present in the
effluent.
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. Treatability studies would be required before full-sca1e design of a UV /oxidation
system. These studies would determine which process option would provide better,
more cost-effective treatment for t~ given conditions at Sites 1 and 3. Treatability
tests would provide -information on the by-products created, the need for polishing
'the treated water with activated c:aTbon, and approximate process rosts and operating
conditions. The resulting effluent would be sampled to ensure that the water meets
appropriate discharge standards.
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Discharge of"lftated Water
Several options were evaluated for discharge of treated water: .
surface water (e.g., Mere Brook)
groundwater (e.g., infiltration)
Brunswick Sewer District's POTW
Town of Bnmswick storm sewer system
The preferred option for discharge is piping the water to tie into the base sanitary
sewer system (Brunswick Sewer District POTW). The Navy WOD1d need to obtain
permission from the Brunswick Sewer District to discharge treated effluent to the
system. r= POTW's NPDES permit does DOt aurently have pretreatment st.an&ards
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for the compounds that may be detected in the treated water. Pretreatment
standards are standards that apply to users of the POTW who contribute pollutants
that interfere with or pass through the POTW. Pretreatment standards then become
effluent limits on the user, in this case NAS Brunswick. These standards would be
developed by the POlW to ensure that the POTW remains in compliance with its
NPDES permit and sludge use and disposal practices. Regulations for land
application of sludge have been set for the metals cadmium, cbromium, copper, lead,
mercury, nickel, and zinc for both mnimnm permissible concentrations and
maximum loading limits (on a kilogram/hectare basis). A maximum permissible
.m~n1T4ItioD level has also be= set fur PCBs.
The additional flow from the treatment plant would Dot cause the POlW to exceed
its capacity. The design flow rate for the POTW is 3.85 million gallons per day
(mgd). Average flows are currently 2.8 mgd, or about 73 percent of capacity. The
cost of discharging treated water to the POTW cannot be estimated because
pretreatment requirements are not yet known. Flow from NAS. Brunswick is
am=uy ~tered, muJ ~ woWd be .1 = for the maQ5ed flow.
Institutional Controls and Land.Use Restrictions
This alternative requires institutional controls and land.use restrictions to prevent
future use of the landfills or groundwater. Security is strictly enforced at Sites 1 and
3 because these sites are within the fenced area near the Weapons Compound. At
. Site 3, signs are posted warning of pesticides bnried in 1he area. Additional warning
signs would be pasted around the landfill area and near leachate seeps. Restrictions
on land use would be incorporated by NAS Brunswick to prevent future land use of
the landfills and groundwater affected by the lanrlfil1s.
EaviroDJDeDtal Monitoring
The long.term environmental monitoring program would monitor groundwater flow
and quality. Surface wat1:%', sediment, and leachate seeps would also be sampled and
analyzed for the contaminants of concern. Data collected under this program would
provide information necessary to assess the effectiveness of the cap and slurry wall
at dive~g clean water around the site and preventing further contamination of
groundwater. In addition, the monitoring program would assess the dispersion and
degradation of contamination ~at has already emanated from the landfill. The
monitoring program wowd be submitted for regulatoJY review and would identify the
sampling locatioDS and sampling frequency. At a minimum. the environmental
monitming program wouJd C01.hl.nefor 30 years.
;nstanation Restoration Pnijjiim
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Five-year reviews would also be required as part of the environmental monitor.ing
program. In addition to making recommendations regarding future remedial actions,
the five-year reviews would assess the performance of the containment system l'be
NAvy would also conduct a risk assessment as part .of the five-year review to ensure
continued protection of public health and the environment. The results of the risk
assessment would be used to determine the need for additional remedial action'S.
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W00292A6.080
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XL STATUTORY DETERMINATIONS
The remedial action selected for implementation at NAS Brunswick Sites 1 and 3 is
consistent with CERCLA and, to the extent practicable, the NCP. The selected
remedy is protective of hum:ln beahh and the environment, att~iT1~.ARARs, and js
cost-effective. The selected remedy also satisfies the statutory preference for
treatment that permanently and significantly reduces the toxicity, mobility, or volume
of hazardous substances as a principal element. Additionally, the selected remedy
uses alternate treatment technologies or. resource recovery technologies to the
m:ly;mmT) extent practicable.
.A.
THE SELECTED ~MEDY IS PROTECTIVE OF HUMAN HEALTH AND TIlE
ENVIRONMENT .
The remedy at Sites 1 and 3 will permanently reduce the risks posed to human health
and the environment by eliminating, reducing, or controlling exposures to human and
environJDemaJ r~tors through tr~ ~ amtto)s, and institutional
controls. '!be pJa~ of a cap wiD eHminate direct contact and incidental
ingestion exposure to residual soD contaminants and the implementation of
institutional control on groundwater use will prevent exposure to contaminated
groundwater during remediation. The cap and slurry wall will effectively lower the
groundwater table, reducing the amount of contaminated groundwater discharging
to Mere Brook and the leachate seep areas. Moreover, the selected remedy will
result in human exposure levels that ar~ within the 10-- ta 10'" incremental cancer
risk range and that are within the HI of 1.0 for noncarcinogens. Finally,
implementation of the selected remedy will not pose unacceptable shon-t~rm risks
or cross-media impacts. .
B. THE SELECTED REMEDY A1TAlNS ARARs
This remedy will attain an tbe substantive, non.proceduraI ponions of federal and
state ARARs that apply to Sites 1 and 3. AR.ARs for Sites 1 and 3 were identified
during both the RI and FFS. Appendix D presents tabular SIlmm~nies of all ARARs
previously identified, including the regulato!)' citation and a brief snmmary of the
regulatory requirement and i~ consideration in the remedial process. The following
narrative presents a summary of key AR.ARs and their applicability to the selected
--remedy. .
Feder.tJ and state reguJ:lnons identified for .Sites J .and 3 indnne:
WOO29246.080
. mstiDition Restoration PIDglUJ
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Chemical-specific ARARs
.
Safe Drinking Water Act (SDW A) - MCLs and non-zero MCLG:s
.
Resource Conservation aDd Recovery Act (RCRA) - MCLs
.
Maine Drinking Water Rules
Oean Water Act (CWA) - AWQC
.
.
Maine Regulations Relating to Water Quality Criteria for Tcmc
Pollutants
.
Oean Air Act - National Ambient Air Quality Standards.
Maine Ambient Air Quality Standards
.
The following chemica1-spedfic policies, aiteria, and guidelines were also corisidered:
.
. Maine Department of Human Services Rule 10-144A, CMR
Chapter 233 - Maximum Exposure Guidelines (MEGs)
.
USEPA RIDs
.
USEP A Human Health Assessment Group Cancer Slope Factors
(CSFs)
Location-Specific ARARs
'.
.
Maine Natma1 Resources Protection Act
.
Natural Resources Protection Act
.
Maine Standards for Oassification of Minor Drainages
Maine Standards for Oassification of Groundwater
.
Maine Site Location Development Law and Regulations
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Action-Specific ARARs
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RCRA - General Facility Standards
.
1\. eRA - Prepuedness and Prevention
.
RCRA - Contingency Plan and .Emergency Procedw-e.s
.
RCRA - Releases from Solid Waste Management Units
.
RCRA - Oosure and Post-closure
.
RCRA - Miscellaneous Units
.
Maine Hazardous Waste Management Rules
.
Maine Landfill Disposal Regulations
Occupational Safety and Health Administration (OSHA) - General
Industry Standards .
.
.
OSHA - Safety and Health Regulations
OSHA - RecordkeepiDg, Reporting, and Related Regulations
.
.
CW A - Pretreatment Standards for P01W Discharge
.
CWA - NPDES
.
Maine Water Pollution Control Law: Conditions of licenses
Maine Water Pollution Control law: Certain Deposits and Discharges
Prohibited
.
.
Underground Injection Control Program
.,.Maine Rules to Control the Subsurface Discharge of Pollutants by
Well Injection
ibe foDmring policies, Clite1Us, and guide1ines (Le., TBes) will also be considered
during the implementation of the remedial action:
. WOO292.46.oso
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MEDEP, Bureau of Water Quality Control, Policy Number 10: "1be
Discharge of Hazardous Substances to Groundwater of the State"
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Federa.1 and State Drinking Water Regulations. The chemicaJ-speciik ARARs
identified for Sites 1 and ;.. can be applIed to the selected remedy in tWo mannen.
In the instance of drinking water standards, MCLs and other guidance and criteria
to be considered (TBCs) were used in the developmtllt of target cleanup levels for
the remediation of groundwater at the site. Drinking water standards may also be
used separately, or in conjunction with surface water standards, in the development
of discharge limits for treated groundwater.
In the development of groundwater cleanup levels, the groundwater in the aquifer
underlying the site is classified by the state as GW-A, a drinking water source. 1be.
quality and safety of drinking water sources is regulated by the SDWA and Maine
Drinking Water Rules. MCLs are enforceable standards under the SDWA that
represent the maximum level of contaminants that is acceptable for users of public
drinking water supplies. MCLs are relevant and CI.}Ip~u!,~~ ~~e, while ~the
groundwater on and off site is oot currently ~ as a drinking water source, 'the
groundwater underlying NAS Brunswick potentially could be used as a drinking water
source in the future.
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. Target cleanup levels for groundwater at Sites 1 and 3 were developed based on the
results of the baseline risk assessment Federal and state MC1.s were the first order
of standards used in establishing cleanup levels. .For those contaminants for wbich
no MCU were available, other criteria and guidelines (i.e., TBCs) were used 'lECs
used 4uring the risk assessment and in establishing cleanup levels included Maine
MEGs, USEPA RIDs, and USEPA CSFs.
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ChefT'1l'J1l-5pedfic ARARs and risk-based target cleanup levels v4ll be met by
extracting the contaminated groundWater within the Jandfill and reducing leachate
generation by containing the waste. Contaminated groundwater CUITently discharges
to Mere Brook, via leachate seeps, immediately downgradient of the landfill.
Federal and State Water Quality Criteria. In developing discharge limits for treated
groundwater, drinking water standards and surface water standards identified under
chemical-specific ARARs may be applicable to the selected remedy depending on
the choice of discharge option. The selected remedy considers three options for
discharge of treated groundwater. The Navy's preferred option is discharge of
tmited water to the Bnmswick POTW. Under this option, dicrJulrae limits wculd
be ~ on faetors regnJated by the P01W's NPDES permit, pretrea!ment
regulations, and water pollution coDtrollaws, which will be discussed under action-
specific ARARs. Because final discharge from the POTW would be to the
~Program
WOO292A6.080
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Androscoggin River, federaJ A WQC and Maine Water Quality Criteria are ultimately
applicable to this discharge option.
Pretreatment standards are being developed with the Brunswi~k POTW. Both the
Pretreatment StaDdards and CW A ~DES will be attained upon successful
establishment of pretreatment standards for discharge from the groundwater
tre.J! tmPIlt plant.
Another option for the discharge of treated groundwater would be groundwater
reinjection As required by Underground Injection Control Programs, to be dienlcsed
under action-specific ARARs, federal and state MCLs and MEGs would apply to the
development of discharge limits. To reinject groundwater, MCLs and :MEGs would
be attained through treatment of contaminated groundwater.
The final option for discharge of treated groundwater would be directly to a surface
water source on NAS Brunswick. This action would be governed by NPDES and
Water Pollution Control Regulations, to be discussed under action-specific ARARs.
Howevex, these regulations would TequiTe development of discharge limits that
comply with federal and state Water Quality Criteria. Compliance with NPDES and
Water Pollution Control Regulations would be through treatment of contaminated.
groundwater to final discharge limits and regular monitoring of the effluent.
Federal and State Air Quality Regu.Iatjons. The treatment te.t'nnoJogies proposed in
the selected remedy will Dot create any Dew sources of air emissions. Therefore,
many federal and state regulations governing air quality do not apply to the selected
remedy. The only air qua,lity standards that are applicable are particulate standards
promulgated under the Clean Air Act and Maine Ambient Air Quality Standards.
The particulate standard would apply to remedial construction activities associated
\\ith the slimy wall 4UJd cap. These ~nit~rds would be mt~;,,~.d through monitoring
and, if necessary~ use of dust suppreSsion techniques or engineering controls.
State Location-specific ReguJations. All of the location-specific ARARs that apply
to the selected remedy are based on the close proximity of the site to 'Mere Brook.
The Maine Natural Resources Protection Act provides that removal of soils or other
..activities conducted adjacent to streams must not cause unreasonable soil erosion,
cause unreasonable harm to significant wildlife habitats, unreasonably interfere with
'. ~tural water flow, lower water quality, or unreasonably cause or mcrease flooding.
Chapter 305 of the MEDEP regulations provides further standards for ~rosion
control and IOil ~V4ition. J"T1~11¥nt~tio.n of the ~J".{Yd remedy wouJd not
impact the drainage or natural flow of Mere Brook.. ~ «tJlboJ measures wiD
be employed during COnstruction to minimi7.e soil/sediment from entering ~ere
Brook.
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Portions of tbe Maine Site Location Development Law, and associated regulations,
apply to this site. Tbe law and regulations provide that new development, wbich
handles hazardous waste, cannot have an adverse effect on the natural environment
or pose aD unreasonable risk of discharge to a significant groundwater aquifer.
Penions of Chapter 375, which form the no adverse enviromnentaI effect standards
regulation of natural drainageways, runoff, erosion, sedimentation control, ~l11d
groundwater quality will be attained by the selected remedy. As previously
mentioned, implementation of the selected remedy would not impact the drainage
and flow of Mere Brook. Sedimentation and erosion controls will be employed to
nUni1nize son/~i~nt entering Mere Brook. Cnmpo71P-nts of the St'Jerted I'~.dy
will be designed to remediate groundwater and to prevent further impact to 1the
environment.
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. Federal and State Hazardous Waste Regulations. The applicability of RCRA ;!l11d
Maine Hazardous Waste Regulations depends on whether the wastes are RCRA-
hazardous wastes as defined under these regulations. To date, there is no
infonmtion available (i.e., manifests) to indicate that RCRA-regulated~.a1s
were disposed of at Sites 1 and 3. However, beca~ toxic constituents are preSirnt
in the waste materials and groundwater at Sites 1 and 3, many portions of the federal
and state hazardous waste regulations are relevant and appropriate to the selected
remedy.
RCRA General Facility Standards, Preparedness and Prevention, and ContingeJrlCY
Plan and Emergency Procedures will be attained during construction and operation
of the groundwater treatment plant. The treatment plant, which will be located
outside the Weapons Compound Area, will be secured to prevent access 'by
unauthorized personnel. The facility will be designed, maintained, constructed, and
operated to minimhe the possibility of an unplanned release that could threaten
''Inman h~ 1th OI' the environment. During reJTIe.dia 1 construction, safety and
comm1mication eywpll1ent will be ins1a1led at the site, and 1oca1 authorities wiD be
familiarized with site operations. Contingency plans will be developed cLIld
implemented during site work and treatment plant operation. A program will be
developed for handling, storage, and recordkeeping, in accordance with Maine
Hazardous Management Rules.
A groundwater monitoring program will be developed for Sites 1 and 3 in accordance
.with RCRA Releases from Solid Waste Management UDits and Cosure and p()st-'
Oosure regulations. .
During U'e4I"'~D1 of ~~.,..~:n.:MrtM groundwater, c}n"vc f'rInt1Inm,g some tclXic:
constituents will. be produced. A component of groundwater treatment includes
laboratory analysis of this sludge, .including Toxicity Characterlstic uA('hate
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Procedure (TCLP) testing. If the sludge fails TCLP testing, this material will be
considered hazardous. As a characteristic hazardous waste, RCRA regulations
including Land Disposal Restrictions, will apply and the sludge will be treated and
disposed of in a RCRA Subtitle C faci1i1y.
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Because toxic constituents are present on site, OSHA regulations protecting worker
health and safety at hazardous waste sites are applicable to the implementation and
long-term operation of the selected remedy. Site workers will have completed
training requirements and will have appropriate health and safety equipment on site.
C.nntT~ctors ud subcontractors working on site will follow health and safety
procedures.
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Federal and State NPDES, Water Pollution Control, and Underground Injection
Regulations. As mentioned, many action-specific ARARs will regulate the discharge
of treated groundwater. The three discharge options for the selected remedy include:
(1) Brunswick POTW, (2) reinjection to groundwater, and (3) direct discharge to
smfa.ce~. DicM1M"ge of treated groundwater to the BIUI1SWia POTW is the
Navy's 'J'Tefetred option; however, final approval has not been obtained from the
P01W. CWA Pretreatment Standards for POTW Discharge would be attained
through treatment of the groundwater to these standards. Indirectly, CW A NPDES
is an applicable regulation, because the final discharge is to the Androscoggin River
and the Brunswick POTW has a current NPDES permit.
If discharge to the PO'IW is not acceptable, a second alternative is 1{) reinject treated
water back to groundwater. The federal Underground Injection Control Program
and M~e Rules to Control the Subsmface Discharge of Pollutants by Well Injection
are applicable to this discharge option. These regulations would require and be
attained through establishment of standards for the treatment of groundwater that
attain federal and state drinking water standards and guidance values.
The third discharge option would be to send treated groundwater directly to a
surface water source on NAS Brunswick. The CW A NPDES aDd Maine Water
Pollution Control Laws would apply to this method of discharge. Under this option,
aD NPDES permit would need to be obtained. In the course of obtaining that
permit, discharge limits for the treatment plant effiuent would be established.
Federal and state water quality criteria would be used in the development of final
~charge limits.
.,
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THE SELEc'lED REMEDw. ACrION IS COST.EFF.EcrJVE
The selected remedy is cost-effective; that is, the remedy affordS overaIl effectiveness
proportional to its costs. In se)~-1"ting this remedy, once the Navy identified
Installation Restoration Program
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alternatives that are protective of human bealth and the environment and that attafu
ARARs, the Navy evaluated the overall effectiveness of each alternative by assessing
the relevant three criteria: (1) long~term effectiveness and permanence; (2) reduction
in toxicity, mobility, and volume through treatment; and (3) short-term effectiveDf~ss,
in combination. The relationship of the overall effectiveness of the selected remedial
alternative was determined to be proportional to its costs. The costs of this remedial
alternative are:
Estimated Capital Cost: $3,874,000
EstimtIJed Operation and Maintenance Cost (net presen1 wonhj: $1,432,000.
Estimated Total Om (net present worth): $7,842,000-
.
Net present worth costs are based on a 10 percent discount factor ~lDd
30 years of operation.
The least expensive alternative is clearly the No Action Alternative, estimated to cost
nothing ~11~ it would not require any additional ~ols or lPon;toriDg. 1be
Minimal Action ~ is expected to cost approximately $1.1 million. The
selected remedy is also relatively iDexpensive at approximately $7.8 million.
The cost of the three flushing alternatives only differ by approximately 10 percf~nt,
even though they offer varying degrees of containment (Le., cap or no cap) ~LDd
different systems for groundwater collection (ie., downgradient inter~ptor trench or
extraction wells). For example, for Alternative 1,3-D, there is 'only a $1.2 million
difference iD tbe total present worth cost of the alternative because of the lower
capital COSt of installing eight extradion wells instead of a ~foot-Iong intercef't()r
trench (E.C. Jordan Co., 1991c). '
Because the total costs of the groundwater collection and treatment alternatives ,are
so mni1aT, the alternatives should be compared' on the basis of their effe~1:iv~~i in
meeting response objectives, compliance with federal and state ARARs, and the
relative ease of implementing the alternative within the constraints imposed by !be
sites' location. .
All the alternatives considered., except No Action and Minima:! Action, are proteotive
of human bealth and the environment, meet ARARs and response objectives, and
, . ~'.~ve trimi18T Jong-term effectiveness and permanence.....while the selected remedy
does not have the lowest estimated capital cost of the four treatment alternatives, it
does bave the lowest estimated operation and maintenance cost and estimated total
cost. This is due to the fact tbat groundwater tw'tmP!nt would ~ have to be carried
out for nearly as long in ~e selected remedy.
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D.
THE SELECI'£D REMEDY UTWZES PERMANENT SOU.JTIONS AND ALIERNA11VE
TREATME~'T OR RESOURCE RECOVERY TECHNOLOGIES TO THE MAxiMUM
EXTENT PRACTICABLE
The Navy identified those aItenmrlves that attain ARARs and that are protective of
human health and the environment. tbe Navy also identified which alternative
utilizes permanent solutions and alternative treatment technologies or resource
recovery technologies to the tnaJLiwaBl extent practicable. This determiTUltion was
made by deciding which one of the identified alternatives provides the best balance
of tr4ide-offs amoDg ~\'es in terms of: (1) IDDg-tmn ....Ffprtiv~ .and
permanence, (2) reduction of toxicity, mobility, or volume through treatment,
(3) short-term effectiveness, (4) implementability, and (5) cost. The balancing test
emphasized long-term effectiveness and permanence and the reduction of toxicity,
mobility, and volume through treatment; and considered the preference for treatment
as a principal element, the bias against off-site land disposal of untreated waste, and
community and state acceptance. The selected remedy provides the best balance of
trade-offs among the alternatives.
E.
THE SELEcn:D REMEDY SA11SFIES THE Plu.1'r.;KE.NCE FOR TREATMENT WHICH
PERMANENTLY AND SIGNlFICANnY REDUCES THE ToXJCI1Y, MOBILm, OR
VOLUME OF THE HAzARDous SUBSTANCES AS A PRINCIPAL ELEMENT
The principal element of tbe selected remedy is the management of migration of
contaminated groundwater. This element addresses the primaJy threat at Sites 1 and
3, contamination of groundwater under Sites 1 and 3, which expresses itself in surface
water and leachate seeps on the banks of Mere Brook. The selected remedy satisfies
the statutory preference for treatment as a principal element by pumping
groundwater from Sites 1 and 3 and treating it with UV I oxidation, before discharging
the treated wmer. .
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XII. DOCUME!'."TATION OF SIGNIFICANT CHANGES
t
Tbe Navy presented a Proposed Plan for remediation of Sites 1 and 3 on
December 12, 199L The preferred alternative iDr1nrled amstructing a cap over the
landfills and a sluny wall around the waste to prevent dean water from entering the
landfills. Contaminated groundwater contained by the cap and slurry wall will be
pumped and treated by UV IQyjil~tion to destroy the orpnj& compounds before it is
discharged. Because the design of the cap must consider site-specific conditions ,that
will be identified during the pre-design studies, alternatives to the cap design
identified in the P1 oposed PJan could be idt.utifred and should be evaluated.
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Tbe principal component of the selected remedy will be the placement of a multi-
layered cap over those areas in or contiguous with Sites 1 and 3 and COnstructiOIl of
a sluny wall around the sites. - The cap and sluny wall will reduce' the infiltration of
water into the waste and thereby reduce the leaching of contaminants from the waste
.into gr01U1dwater.
'!be cap will be designed to meet or exceed the performaTlrP requiremems set forth
in 40 CFR Sections 264.111, 40 CFR 264.310, and the technical guidance document
Design and Construction of RCRA/CERCLA Final Covers (EPA/625/4-91/025, May
1991 b) or in a manner that achieves performance equivalent to that required by 40
. CFR Sections 264.111,264.310, and the technical guidance. Site-specific conditions
will be considered in determining the most effective cap design. Alternative cap
designs will be evaluated to expedite cap construction, minimi7~ settlement, ;and
minimize tbe use of nonrenewable resources (e.g., a hydraulic barrier design using
a bentonite mat technology instead of a 24-inch layer of recompacted natural low-
permeability so~ a drainage layer design using geosynthetics or geogrids instead of
all-inch soil layer).
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As a party to the FF A, MEDEP has reviewed the various alternatives and bas
indicated its suppon for the selected remedy. MEDEP concurs with the selected
remedy. for NAS Brunswick Sites 1 and 3. A copy of the letter of concurrence is
presented in Appendix F of tbis ROD.
InstallatiOn Restoration Program.
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ACRONnJ,1S
1 . ARAR Applicable or Relevant and Appropriate Requirement
1. ATSDR Agency for Toxic Substance and Disease Regis1Iy
AWQC Ambient Water Quality Criteria
l BACSE Brunswick Area Citizens for a Safe EnvironiDent
bgs below groUJ1d SlJn~t¥
I CERCLA Comprehensive Environmental Resp~ Compensation, and liability
A~ of 1980 (the Superfund statute)
CSF cancer slope factor
I em/see centimeters per second
CWA Oean Water Act
C! cubic yards
l DCA dichloroetbane
DCE dichloroethylene
I DDT dichlorodiphenyltrichloroethane
FFA Federal Facility Agreement
r FFS Focused Feasibility Study
FS Feasibility Study
I gpm gallons per minute
m Hazard Index
f HA hydrogen peroxide
HQ Hazard Quotient
r !AS Initial Assessment Study
IRP Installation Restoration Program
[ MCL Maximum Contamina.nt Level
MCLG. .Maximum Contaminant Level Goal
[ MEDEp . Maine Department of Environmental Protection
MEG Maximum Exposure Guidelines
mgd million gallons per day
r mg/kg milligrams per kilogram
mg/L milligrams per liter
r Installation Aestoration . Program
I WOO29246.080 6834~
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1 MSL mean sea level
t NAS Naval Air Station
NCP National Contingency Plan
NPDES National Pollutant Discharge EJimintttion.System
t .NPL Natin"aJ Prinritif'S.List
.f OSHA OcCUPational Safety and Health Administration
03 ozone
I PAR polynuclear aromatic hydrocarbons
PCB polychlorinated biphenyl
POTW publicly owned treatment works
L PVC polyvinyl chloride
RCRA Resource Conservation and Recovery Act
I RID risk reference dose
RI Remedial Investigation
ROD Record of Decision
r SDWA Safe Drinking Water ACt
SVOC semivolatiJe organic compound
I TAG Technical Assistance Gram
TBC to be considered
r TCA tricbIoroetbane
TCE trichloroethylene
TCLP Toxicity Characteristic Leachate Procedure
I 'IRC Technical Review Committee
[ Ilg/L micrograms per liter
USEPA U.S. Environmental Protection Agency
UV ". -ultraviolet
[ VOC .vo1a.tile organic compound
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REFERENCES
E.C. Jordan Co., 1990a. "Draft Final Remedial Investigation Report N.AS
Brunswick"; Portland, Maine; August.
E.C. Jordan Co., 1990b. "Draft Final Phase I Feasibility Study Development ~Lnd
Screening of Al1e~ves NAS Brunswick"; Portland, Maine; August.
E.c. Jordan Co., 1991a. "Draft Final Supplemental Remedial Investigation Report
NAS Brunswick"; Portland, lhirw>: ,aA.ugJw
E.C. Jordan Co., 1991b. "Draft Final Supplemental Feasibility Study Sites 5, 6, ~Lnd
12 NAS Brunswick"; Portland, Maine; July.
E.C. Jordan Co., 1991c. "Focused Feasibility Study Sites 1 and 3 NAS Brunswi(:k";
Portland, Maine; October. .
E.C. Jordan Co., 1991d. "'Draft Fma1 Focused F~asibility Study Site 8 NAS
Brunswick"; Portland, Maine; October.
E.C. Jordan Co., 1991e. "Draft Final Feasibility Study NAS BrunSwick"; Portland,
Maine; November.
r
Theis, C.V., 1935. "The Relation Between tbe Lowering 'of tbe Piezometric Surface
and the Rate and Duration of Discharge of a WeD Using Groundwater
Storage"; Transactions, American Geophysica1 Union, Vol. 16, pp. 519-524.
U.S. Environmenta1 Protection Agency (USEPA), 1990. "StreamHnine the RI/FS for
CERCLA Municipal uT1rlfm Sites"; OSWER Directive 9355.3-11JFS;
September. . .
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U.S. Environmenta1 Protection Agency (USEPA), 1991a. "Drinking Water
Regulations and Health Advisories"; Office of Water, Washington, D.C.;
. November.
U.S. Environmental Protection Agency (USEPA), 1991b. "Design and Construction
of RCRA/CERCLA Final Covers-. Office of Research and Development;
Washington, D.C.; EPA/625/4-91/025. May.
Instanatlon Restoration Program
WOO29246.080
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W0Q292A6.CMIO
APPENDIX A
MEDIA-SPECIFIC DATA SUMMARY TABlES
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", ....',"', ". .
. ... .. .
. ........ ....
. . . ....
.. '
.....
Fluoranthene
Pyrene
1,4-Dictllorobenzene
2-Methytnaphthalene
Total PAHs
Bis(2-Elhylhexyl)Phthalate
4,4'-00D
4,4'-00T
'Arochlor 1242
1254
Aroddor 1.2SD
Naphthalene
Xylenes
Ac~tone
Dieldrin
Tetrachloroethene
Alpha-Chlordane
Gamma BHA
Gamma Chlordane
Heptachlor
Chrysene
Vinyl Ch10ride
1,2-DichJoroelhene
Endrin
1,1-0ichloroethane
NOTES:
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All concentrations In pglkg
J: Estimate concentration
ANALYTICAL SUMMARY
SITES 1 AND 3
SOILS
,.,': ,"~GE OF CONCENTRATIONS DETECTEO
,,'.,.,,',' ',:,,:TEST PITS" 'SOIL BORIN(3S '
,:SURFACE, <;SUBSURFACESUBSURFACE'
NO ND-3SO ND
NO ND-460 NO
NO ND-1100 ND
NO ND-480 NO
ND-16690 ND-23770 NO
NO NO-1700 N0-4600
NO NO-28 NO
NO NO-150 ND-71
N0-470 ND-440 NO
NO
ND-'720
ND-810
NO-33
NO-11J
N0-48
ND-6
ND-800
ND-15
ND-11 00
NO-78
ND-470
D
ND
ND
NO
NO
NO
ND
NO
NO
ND
NO
NO
NO
Nt)
ND
Nt)
ND
Nt)
ND
NO-7
ND
NO
NO
NO
ND
NO
NO
NO
NO-16
ND-27
ND-33
ND-7
NO
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.... ..
. . . ... . ... .
Aluminum
Arsenic
Barium
Cadmium
Calcium
Chromium
Cobalt
Cyanide
jron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
SITES 1 AND 3
GROUNDWATER
. .... "'~ANGEOF
'C~~~;;T~ONS DETecTED .
ND-5200
ND-107
ND-327
ND-13
ND-128000
ND-11
ND-6O
ND-34
~6"OOJ
ND-60
ND-221 00
21-5400
ND-o.22J
ND-78
ND-24000
ND-S40000
ND-8O
NO-297
8.1-590
2.4-190
ND-24
ND-180
ND-25
ND-460D
ND-38
ND-60
ND-6
ND-13
ND-210
ND-32
ND-200
ND-660E
ND-20
ND-21J
ND-27J
ND-95
ND-230
ND-410D
ND-86
Vanadium
Zmc
Bicarbonate
Chloride
Sulfate
Vinyl Chloride
. ChJoroethane
Methylene Chloride
1,1-Dichloroethane
1,2-Dichloroethene (total)
Benzene
4-Methyl-2-Pentanone
Toluene
CNorobenzene
Ethylbenzene
Xylenes(total)
Bis(2-Ethylhexyl)phthalate
Naphthalene
1,4-Dichlorobenzene
4-Methylphenol
Phenol
2-Methylphenol
BenzoIC AcId
NOTES:
All concentrations In pg/L
(1) Standard Is under review.
(2) Standard goes into effect January 1, 1993.
(3) Standard goes into effect December 7, 1992-
(4) MCLI are separate for cis- and trans- 1,2-DCE. Standard listed is for
cis, the lower of the two standards.
(5) Standard gHS into eff.ect July 30. 1992.
J: Estimate concentration
D:-Concentration obtained via dilution.
~ Anatyte concentration exceeded catibration range of GC/MS
A-2
.. .,~ . ......
. ".:Mdl' ././
50(1 )
2000(2)
5
at tap:1 5(3)
2
2
. ,..
MEG
1430
30
1000
5
5
154
20
2
150
0.15
5
70(4) 70
5 5
1000(5) 2000
100(5)
700(5) 700
10000(5) 6'00
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I SJTES 1 AND 3
SURFACE SOILS, SURFACE WA1ER. ~£NTS.1.EACHA1ES
I . . RANGE OF CONCENTRATIONS Dc I c~ I t:LJ
..:SURFACE. q>$URFACE ... .. . ..LEACHATE
...... ..SOILS . ..'WATER .:.SEEPS
I Aluminum NO ND-605OD 97-199000
Antimony ND NO. 122 ND-384
Arsenic ND No.70.9 No.387OJ
I Barium ND No.1380 No-.1 30
Beryllium ND ND-9.S 0.99.5
Cadmium NO Nt)-12.' NO. 180
l Calcium ND No.78200 20-144000
fill) 7 11-1180
Cobalt NO No.223 ND-232 ND-1240
Copper NO ND-326 ND-58 ND-914
[ Cyanide ND ND-20.8 ND No.392
Iron NO 2140.1910000 7()()()-42OOOOJ 10700-251
Lead NO N0-415 ND-123J ND-1740
E Magnesium NO ND ND No.243000
Manganese ND-6S ND-6B80 ND-21000J ND-50000
:La '.1 7 9.3
NicteI ND 0 lID U)SO
'E. Potassium NO ND-5420 ND HI)- 112000
Silver ND ND ND ND-11.6
Sodium ND ND-24600 NO ND-S4400
b Vanadium ND ND ND No.2600
Zinc ND No.676OJ No.266J 26-2770
Vinyl Chloride ND ND ND ND-11
Methylene Chloride NO NO ND-52J ND
r Acetone NO NO ND-6OJ ND
1 ,1-Dic:hloroettlane . ND ND ND No.24
r,2-0Ichloroethene ND NO ND No.140
E 1,2-Dichloroethane NO ND ND-78 ND
1 " , , -Trichloroethane NO ND-SQ ND-76 ND
Trichloroethene ND No.31 ND-10 ND-20
n ','.2- Trtchloto8th8n8 Nt) ND HO ND
etrachloraethene NO ND-30 NO Nt)
1,1.2,2- Tetrachloroethane ND-100 ND-12 NO-3700 ND-nOO
Toluene NO ND NO ND-S
'0 Ethylbenzene ND ND No.nO ND-9J
XylenlS(total) NO ND ND ND-17J
BiS(2-Ethylhexyl)phthaiate ND ND NO ND-23
[ 1,4-DIchlorobenzene NO ND NO-6800 ND-36J
DiChlorobenzene ND ND ND ND-1.7J
4-Methylphenol ND NO ND-4920 ND-57
Benzoic Acid ND ND ND ND-64
r ,4'-OOE NO NO ND ND-O.400
,'" -DOT ND 12.22
4,4'-DOD ND 0 NO ND-o.360
I Total PAHa ND ND ND-18910 NO
NOTES:
All concentrations In ppb
I . J: 1:st1m8t8 "",.It...IbMtlorl
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APPENDIX B
RISK CALCUlATIONS: BASElINE RISK ASSESSMENT
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INGES110N OF AND DERMALCONTACTWI1H SURFACE SOIL
sm::s 1 AND 3
ADULT AND auLD
... H. HAduJt
.:.::::::.:::.~:,,::::.:::t.
~
CIIdmium
0IrciD0F1Uc PABs
CIromium III
CIromium VI
Copper
Qui*
4,f"-mr
Lad
Mupncse
illercui)'
Nietel
NoacarciDopDic PAHs
PCBI
VIIIIdium
%iDe
U 0.183 1.8E-4B 4.'73E-4M ~-05 J.'Z!&-GS ~1E-Q6
U 0.06'2 1.DOE-Q3 3.10£-04 1.3SE-05 3.52E..Q5 1.!3E-06
'7.65 0,4296 4.00E-03 UI8E-03 6.0SE-05 1.87E-04 LOSE-OS
13.68 6.732 1.00E+OO 2.83E-06 1.39E-06 3.21E..07 I.58E-07
1.52 0.74 5.ooE-03 3.43E-05 1.69E-05 4.16E..06 1.QSE-06
25.4 '.98 3.'70£-02 7.'74E-05 1.82E-05 UO£..06 1.21£-06
1.2 0.Q522 2.OQE-02 3.38E-05 1A7E-06 ..'70£..06 2.OIE-07
0.052 0.1IM41 '.IXIE-04 s.86E-05 1.f5E-e6 t.ozE.-05 l.ue-.
15.3 15.4 1AQE-04 1.01E-Ol 1.D7E-02 1.16E.-OZ 137E-m
256 111 2.00E-Ol 1.44E-04 6.26E-05 1.75E-05 7.60E-06
3.3 0.38 3.00E-04 I.24E-03 I.43E-04 1.51£,-04 1.14E-05
16.8 3.93 2.00E-02 1.74E-04 4.06E-05 1.97E.-05 4.61E-06
4.36' 0.33 4.00E-03 6.15E-04 4.65E-05 1.D7E.-04 8.07E-06
Q.4'7 0.0482 1.ooE-06 3. '78E-QZ 3.88£-03 6.57E.-G3 6.'74£-04
37.7 1'" 7.ooE-03 6.07E-04 2.5OE-04 7.38E-05 3.mE-QS
159 43.6 2.00E-Ol I.64E-04 4..51E-05 1.87E-05 5.12E-06
1.44E-Ol 2.53E-02 1.88E-02 3.14E-03
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H..: ....'u......... .:'.)~.:<':j~~.i
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. :. :. ... '... :.':<:ompound
H.
Lc8d
75.3
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1.40E-04
8.40E-Ol
a.4OE-01
1.72£-01
1.12£-01
.. ...
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',''''. '...,'.'.,'.'.',.',"'.',
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. ,,:-,:/:; \:::~;'~,.. .~~":'.,,::
.:?:/:: <.:.j:;.':::~: .:;::;:::::.
Anc1Iic
o..JuoF...;c PAIS
4,4'-DDT
PCBa
1,1.1.2- Tcuw:bloroetbane
4.2
"1.15
o.os2
0.4'7.
0.1
Q.113
G.G6
G.OO441
0.0482
0.G0619
l.'75E+OO
1J!&+01
JAOE-Ol .
7.70E+00
2.OOE-Ol
i.2BE-07
.u6E-CIS
9.96E-09
1.04E-06
5.64E-09
5.2SE-c)s
1.15E-09
U3E-01
5J7E-11
USE-08
2.4%E-11
2.10£-0'7
16tE-OS
2.78E-G6
U'E-I0
1.09E-0'7
3.49E-I0
. 3.03E-06
4.IBE-OS
lMl:.-06
6.nE-I0
UZl~-0'7
3.!I11~-10
3.63]~-06
B-1
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1'ABLE2
INGES110N OF ANI) m:R1IA1..t:ONT.ACTWI'J1f l.EA0IA1E SURFACE'WA"I'ER
sm::s 1 AND 3-
CHILD
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AneDic
BeryWIIIII
Cldmilllll
OInImium
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4,4'-DDD
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4,4'-DDT
1,4- DictA.. ~....
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MaDJIDCIC
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V8ll8dium
VmyI OIIoride
X)'IeDcs
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1.1- Dicbloroethane
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3870
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180
321
26.9
0.36
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110
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2.OOE-02
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2.00E-02
1.00£-01
1.040£-04
2.00£-01
3.0DE-IM
2.00E-02
J.O(JE-ID
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6-ODE-OS
2.ooE+OO
2.GOE-01
1.00E-01
9.73E-03
33J2E-m
L13E-04
3.6$E-03
6.51E-04
1.36E-QS
7.30E-QS
1.UE-Q5
3.45£-m
4.(1$-05
!.58£-05
'.11£-06
1.26£-01
2.53E-03
6.52E-04
4.46E-04
2.2!E-04
3.77£-03
IJ16E-03
8.61£-07
LDm-CI3
2.43E-06
L90E-Q!
1.33E-03
"'6E-03
1.21£-05
6.18E-04
I.30E-04
2.57£-06
3.47£-06
.3.S5E-06
1.64E-t15
2ME-t15
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6.99E~07
3.77£-02
5.63E-04
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1.21E-DC
1.40E-05
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0.69
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1.24
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1.38
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4.!'7£-m
1.40E-04
4-'3E-03
S.Q8E-04
1.6'E-05
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1.01E-04
4.28E-OS
5.03E-~
6.91£-~
I.13E-OS
I.56E-01
3.15£-03
8.10£-04
U4E-04
2.BOE-04
.U8E-03
2.31E-03
1.07£-06
1.33E-QJ
3.D2E-06
2.36E-Ol
1.66E-03
'6.HE-4B
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7JiBE-04
1.6IE-04
3.19E-06
4.30E-06
4.78E-06
2.04E-O&
3.59E-06
629£-06
8.69£-07
4.68£-02
6.99E-04
1.48E-04
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L73£-OS
8.02£-04
UOE-04
8.69£-08
U4E-04
5AJE-0'7
5.77E-02
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3906
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0.078
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211m
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0.44
0.01
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Clramium VI
CDpper
1.4- DicblorobemeDe
1.2- DicblOtOeIbyleDc
lad
Nupll~
Mercury
Nickel
IJJ- TricbIaroetbaDe
Tricbloroc1hyleae
VUldium
ZiDc
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1:7'7
9.18
1.02
14,4
0348
0.00361
1U
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0.509
6.98
0.0142
0.000323
1.69
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1.28E-01
1.18£-05
1.S1£-04
4.2.$...04
UJ2E-04
5.28£-06
~
1ZE-G'Z
3.29£-03
6.26E-04
1.49E-04
1.50E-06
1.73£-03
3.07E-04
1.84E-01
~1OE-QJ
5.:Z7E-CM
1.14E-06
433E-05
I.26E-O'
'.23E-06
2..44E-07
3.33E-DZ
9A2E-cM
3060£-04
1.04E-04
4.80E-06
...8'E-08
1.33E-04
9.39E-Q5
3.84E-02
1.!SE-m
1.19E-a2
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U2E:-04
431E:-04
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6.46E-06
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2.2N::-m
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1.82E:-04
I.84E:-06
1.78E-03
2.8SEt-04
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4.1OE-cM
2.54E-06
4.46E-05
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6.4OE-06
2..99E-01
3.S-m
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3.71E-04
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594E-08
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l.00E-G3
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5.ooE-03
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2.OOE-02
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UQE-01
3mE-04
l.00E-02
4.ooE-03
9.ooE-03
1.DQE-03
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11 12.7 1.15£+00 l.11E-06 3.78E-07 1.11Et-06 3.88E-07
6.8 0348 1.4OE-02 1.77E-08 9.D4E-I0 1.16E-08 1.11E-09
3.7 0.137 2.OOE-Ol a.olE-08 l.97E-09 t.80Et-08 3.63E-09
Q.44 Q.0142 5.1OE-02 2.11E-09 1.76E-ll 332Et-09 l.07E-10
0.01 0.000323 1.10E-02 1.19E-ll 3.I5E-13 1.46E-11 4.11E-13
2.21E-06 3.81E-07 1.29Et-06 3.93E-07
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INGFS110N OF AND DERMAL CONTACT wrnlSU1lFACl:WA'JER
SI'IES J .AND.3
QUlD
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:;','DaIe,.""
IJ.371
337
39.3
1AQE-04
2JJOE-01
2.00E-Ol
J.D5E-m
2.22E-m
2.86£-04
I.30E-OZ
04.1IE-OC
2.99£-04
6.1SE-05
8.39E-04
~-QJ
LI(E-Q3
2.11£-04
l.06E-OZ
3ME-Gt
2.43E-M
4.68E-05
6.78E-04
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1.1,2,2- TeU8CbJoroethanc
20
1.1
2.00E-Ol
1.74E-07
1.74E-07
9-'$-09
9-'$-09
UIE-07
UIE-07
l.05E-08
l.05E-08
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I'NGES'I1ON OF AND DaMALCONTACTwrm samIEMT
sm:s 1 AND 3
aDLD
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. . . . . . . . . . . . . . . .. . . . . .
.. . . .. . . . ... "..
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,('-N...~jooi , ':":, :,::::,:,:,~,::,
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" '
Amalie 2B 11.5
1JEHP 2a2 o.m
Cldmiam 3 03"
CuoaIium m 23.4 9.09
CuoaIium VI 2.6 1.01
Copper 31 9.1
Can:iDoFDic PAIls 8.59 0.59'
lad DO . 19.11
...~.,..- !940 "181
Merc:my 0.19 0.015
NICkel 22 3.94
Naac:ariDoseDic PAIls 11.72 1.(X)9
VUlldium 38 7.91
ZiDc 179 663
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4.00E-Q3
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2.00E-Ol
3.00E-04
2.OOE-02
4.DOE-Q3
7.DOE-Q3
2.OOE-Ol
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2JIIIE-OII 3.D2E-D5 3.M~-04 1SE-C15
8.94E-OC 1.06E-G4 8.311~-04 9.84E-05
6.97E-Q6 2.71E-06 6.48E-Q6 2.52E-Q6
1.10E-OC 4.29E-Q5 1.14J~-04 4.41E-05
l.78E-OC '.22E-OS U3J~-04 '.37E-05
'.81E-Q3 4.D2E-OC 7.11E-03 4.93E-04
2QE-01 J.fi£-GZ 2Mi5-01 1"776-C
U3E-G3 ,U7E-G4 3DE-D3 nzE-04
1.34E-04 Il16E-D5 1381~-G4 tJ»E-as
3.28E-OC '.87E-OS 3.os.~-OC '.
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APPENDIX C
RISK CALCULATIONS: FUTURE USE SCENARIO
,
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INOBSTION OP OROUNDWATER
ADULTS -Aven. Cdaceatnuoat
SIfe8 "nd 3
HAS 8rulllWlct, Bnlll8Wlc:k M..
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EXPoSURE PARAM8TI!RS
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CONCI!N11tA TION. WA'r1!II cw "./llIer CANCI!R IIsIC -IMrAKB (1III"c-da,) a CANd!R SLoPB PACfOR ("''''-da').~1
DfOI!S11oH ItATa IR 2 1l1e"'., USI!PA
IIAlARD QUOttI!NT .. INTAKE (1II1"c-da" I RI!PI!RI!NCU bOSH (..Iit-da,)
BODY MllaHT aW 70 " USerA
.
I!XPOSUuI PlmQUl!NC'f !lt '50 -lltear USI!PA INTAIII-INOI!S11ON - CW a fR al!Ap al!P U!D
I!XPOSUItB D1IRA11ON I!D 30 JUn USBPA BW a AT a 36S daM'
A Vl!lAOINO""1I 30
CAHCI!It AT 70 JUn
tfONCANCI!It AT 30 JUri
NoCt:
PM ""'"n:IDClpaIc circe..: AT-tn
I!QUATJONS
. .
ADD Ellvironmell181 Services, 'nc.
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INGEStION OP OROUNDWATER
ADU~TS -Avera&e CodctatntIoaI
Sits I and 3
HAS Btllnnrlct: IlnIIII*lck UIIIII
CARCINOGENIC BPFt!CTS
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MdII,Ic8a aIorWD o.oln I 1.I1!-04
'r.,I a.JoricIe 0.0112 I I.OI!-04
1,I-DIc"CIIVCdoue 0.004"" I S.II!-GS
I.c84I 0.001 I '.4I!-o'
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ADD Environmenlnl Services, Ine.
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:' .:',':'. .~.:c:.::..:.; C:~::~A.I
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1.9
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j,:~UMMARY CANC~R RISK.."
,.....
CANCI!R RI!l1t
IHOI'.STloN
...
2.21!-CN
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HIHN
fiE-Ot
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IN0BS110N 081 GROUNDWATBIT
ADULTS -AYeI8p ~~,A;o
SIte8 I and :I
NAS BrvlllWlck& B,....1tt MdftI
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IDRINK
I.-p~b-.zl
NONCARCINOOBNIC EFFECTS
l'i1:J,~~iE::i~ii~~S"~:~;'ii""'k;:";;":Q{f.;AY.. .... :~:
----
IIA2ARD
QUOTII!Hf
INOP.snOtf '.
l'OTAI.
IIA2AI(I)
QUOTIENT
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0...... O.OM 1 t.91!-G4 . 1 9.911-G4 O.OEtOO 9.91!-G4
~ 0.008 I 2.2B-G4 "A
X,... 0.106 I 2.91!-oJ 2 1.511<0) O.DetOO I.5I!-GJ
"lctel 0.04 1 1.12-oJ 0.002 S. ,I!-GI O.DetOO Be-GI
~ 0.0022 I ..oe-G5 O.OZ S.Dt!-GJ O.OE'on J.OI!-OJ
? 1.2-~ 0.007 I 1.91!-eN 0.01 1.9H-02 o.oetOO I.9c-Gz
~- 0.021 I UI!-G4 0.1 UE-oJ o.oetOO uc-GJ
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.
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SUMMARY II AZA.m INOEX
6H-0I
o~=- 6~~CH I
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AnD Envlronmenlal SetVlc:c~. Inc.
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m~NOPOROUNDWATBR
ADULTS -AYCh&e CancaItnIIcMt
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HAS BrauwIcl: Dru_1et MII8e.
CARcmOOENIC EPPBCTS
J~~~:;2twi5~i;~;::i;iv~=::;li!t:'~~;;"""i'i""""'" .j.;c2:.~:n
Ane8Io 0.107 I 1.32-03
.....,.. 0I0rWI 0.46 I 1.42-0]
YI8JI a.8arWo 0.14 I 1.6e-o]
','-Dle" --..... 0.0)5 I ".le-04
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1N0l!STlON OP OROUNDW A'I'IIA
ADULTS -AYCdIO CcI8ce8Indoa
Slee I .... 3
NAS Bruuwlc1a 8rauw1ck M""
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NONCARCINOOBNIC 8PF1!C1'8
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I.aII 0.2OJ I S.61!-ctJ
X,... 0.66 I 1.81!-01
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a.Iot J' . t.., o.on I 1.11!-cN
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2 9.011-4)3
0.002 1.511.01
0.02 .""II-GZ
0.01 1.<41!-01
0.1 S.SI!-GZ
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ADD ~nvironmenllli Servlcel, Inc:.
01; t()O
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IIAZARD
qUOTJEHr
UI!-62
9.01!-4IJ
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4.4e-412
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APPENDIX D
APPUCABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
-
WDam46J8O
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TAlLE D-t
CHEMICAl-SPtCIFIC ARARs. CIUttRIA. AOVlSORlES. ANO OtllUAffct
ROD: SittS 1 AND 3
NASBRUNSWtCK
MaAA
GROUNDWATERI
SURFACE WATER
f:ederal
~
......
Federal Guidance and
Cllterla To Be
Considered
W0029248.T2BO/1
REGUllEMEIfT
SDWA . Melt (40 CFR
t41.11 . 141.16)
SDWA. MClGs (40 CFR
141.50 - 141.81)
ReM - Subp~rt F
Groundwater Protection
Standard., Nlemata
Concentration Umlts
(40 CFR 284.94)
Federal AWOC
. USEPA Fhk ~ference
Doses (RIDs)
STAtus
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Appllcabll
To Be Consldertd
REGUlllEMENT SYft0P811
MCLa have been promulgated for levera' common
organic and Inorganic contaminants. these levels
regulate the eoncentratlon of eontamlnan" In public
drinking water supplies, but may also b. considered
relevant and appropriate for groundwater aqullers used
for drinking water.
MClGs are health.based criteria. As promulll~ed under
SARA. MClGs are to be considered for drlhldng water
sources. MClGs are avallabte for seve,al brtlanlc and
Inorganic contaminants.
This requirement OUtlines standard', In addition to
bachground concentrations and MCLe, tcJ be used In
establishing clean-up levels for remedlatlng groundwater
contamination. .
Federal AWOC Incfude (1) health-baMd criteria
developed for 95 carcinogenic and nont*Clnogenlc
compounds and (2) water quality param.ler'. AWOC for
the protection of human health provide levels for
exposure from drlnhlng water and oonsurtllftg aquatic
organisms, and from consuming fish aton.. Remedlat
. actions Involving contaminated surfaof water or
groundwater must consider the uses of the *ater and the .
circumstances of the release or threatened I&lease; this
determines whether AWQC are relevant and appropriate.
RIbs are the levels considered unllktly to cause
slgnmcant adverse health effects aSloclated with a
threshold mechanilltn of action In huma" '''posure for a
IIfellme. .
COHIIJEMT1OIt .. THE REM£bIAL PtloC£88
Groundwattr at NAS BfUnswlcfc Is not . current souret
of drinking water; therefore, MCLa .re not apptlcable,
but may b. relevant and appropriate. To assess the
potential risks to human health due to consumption of
groundwat8t, conlamlnant concentrations wer.
compared ftJ their Meu.
The 1990 "tlonal Contingency Plan atates that non-
ze,o MClOs are to be used at goals. Becaus'
groundwater at NAS Brunswick Is not a currenl lOurce
of drinking water, MClGs are not applicable, but may
be relevllht and appropriate. Contaminant
. concentratIOns In groundwater were compared to their
MClGs.
Most of thl MCLe promulgated under RCRA are th.
same as SbwA MCls. The standards set forth undet
RCM do not reflect recent changes and additions ...
SDWA MCU. Becaule groundwater Is not. current
lOurce of drtnklng water; RORA MCls .re not
appllcabl., but ma, be relevant .nd appropriate.
AWOC wi. be applicable If treated groundwater II
discharged to surface water. The Navy's preferred
discharge option II to the Brunswick POTW, although
the Navy has not yet received approval from the
POTW. AWQC. tnay be considered during
developmtnt of pretreatment standards because the
POTW discharges Ita effluent tei the Androscoggin
RIver.
Because there ." only. hmlted number of
promulgattd standards for contaminants In lOll and
water. USEPA RIDs wer. used to characterize risks due
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TAlLE D.'
CHEM1CAL-8P(CIFIC ARARa. CftfTERIA. A~VI8ORlEa, AND GUIDANCE
ROD: SfT£a' AND 3
NAS BRUN8W1Ct(
-
q
MEIM
CutI88DrRA 110tf .. tHE RdotEOIAl PRocl:88
State
~
N
State Criteria and
Guidance To Be
Considered
am
Federal
w0029248.T280/2
..~
USEPA Hurttan Health
Assessment Group Cancer
Slope Factors (CSFs)
MaIne DrInking Water f'lles
(t~144A CMR Chapters
231.233) .
MaIne Algulatlona Relating
to Water Quality CriterIa for
foxlc Pollutants (MEDEP
Regs, Ct.apter 584)
"-'I.. ~atlng to TestIng'
of PrIvate Water Systems
for Potentially Hazardous
Contam/nents (1~144A
CMR ettapter 233,
Appendl. C)
O==n Nr k1 .. fd~t!on!!!
f'rlmary and Secondary
Ambient Nr Quality
Standards (40 CFR 50)
STATU8
To Be Conslde"-
Relevant and
Appropriate
Applicable
To Be Consld8f8d
~.ppl!C!!b!e
RtOUIftEMENT SVNOI'8I8
CarcinogenIc effects present the mott up.foodate
Information on cancer risk potency derived tram USEPA's
Human Health Assessment Group.
Maine's Primary Drinking Water Standards are equivalent
to federal MCLs. When state levels ar. rnpre stringent
than federal levels, the state levels mav be used.
. This rule limIts the concentrations of certain materials
allowed In MaIne waters to prevent the occurrence of
pollutants In toxlo amounts as requlr.d by state and
federal law. Except" naturally occurring, Imblent levels
of toxic pollutant. .hall not exceed the CI8*, Water Act
AWac. Where AWac do not elllst, the Board of
Envlronmentat Protection shall adopt alte.speclflc
numerical crllerla.
Appendl. C outlines Maximum Exposl.lr8 Guidelines
(MEGs) for organlo and Inorganic compounds. MEGs
Include health advisories, which are maxlrfttJm allowable
concentrations 01 specific contaminants In drinking water.
Prima'}' .mblen' IIr quality standards dettn. levels of air
quality to protect public health. Second." ambient air
quality standards protect public welfere trom known or.
. antlclpeted adver.. effects from pollutants.
Becaus. there ar. only. limited number 0'
promulgated standards for contaminants In soli and
water, USEPA CSFI were tlsed to compute the
Individual Increm."'at cancer risk resulting trorn
exposure to certain oompounda.
Groundwlter at NA9 Brunswick III not a current source
of drinking water; therefore, State Drinking Water
Standard. are relevant and appropriate. Contaminant
concentrations In groundwater were compared to State
standard. to assess the potenllel risks to human heallh
due to COhaumpllon of groundwater.
ThIs rul. wi" be applicable If treated groundwatet la
discharged to surfate water. The Navy's preferred
dlscharg' opllon I, fo the Brunswick POTW, although
the Navy has not yet receilled approval from "'e
POTW. AWQC win be considered during development
of pretreatment Itllndards.' Thl. rule Is potentially
appllcab..ln development of pretreatment standard. If
AwrJC dO not exlat for eny contaminants present In
groundwater.
MEGs "I" been OOhsldered for chemical compounds
for which there a" no promulgated standards.
MEGs ~'V be considered If treated groundwater Is
discharged baclc to groundwetar. The Navy', pref.rred
dlschar~ option Is to the Brunswick POTW; however,
the Navy has not yet received approval from the
POTW. MEGa may potentlallv be considered durtng
development of discharge limits for reinjection of
treated groundwater.
Particulate standard for mattar I... than 10 mIcron. I'
150 119/ml, 24-hour average concentration. this
requirement la applicable to ellcavatlon and
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TAlLE D.1
CHEMICAL-SPECIFIC ARARa. CflITBIIA. AbVl8OREa. AM) OUIJAt8c£
ROD: 8ITU t AM) 3
NAS 81\U1f8W1C1(
-
-
State
MEbIA
ftCCItMBIEHT
MaIne Ambient Air Quality
Siandarde C38 MRSA.
S8ctIon ~I MEDEP Rega,
Otapter ttO)
SfATUI
Appllcabl.
RblUlREMbtT SYNOPSIS
Thl" Chapter establishes ambient air quality standards
that are maximum levels of a particular pollutant
permitted In the ambient air.
CoII8IotM11Oft IN tHI: RtMtblAl PRoc.
Th. standard for particulate matter Is 150 pg/rW.
24-hour everag. coocentratlon. This standard ..
appllcabl. to excavallon and oonstructlon activities. .
Notee:
ARAR ..
AWac .
em
CMR
CSF
t:S
MCL
tf MCLG
\AI MEG .
. MEDEP ..
MRSA .
NAS .
'" .
"CRA .
AID
SARA
SDWA .
USEPA
pg/m' '"
Ym29248.T280/3
.
AppIl08ble or Allevant and Appropriate Requirement
Ambient Wat., Quality ertterla
Code 01 Federal Regulation,
Code of Maine Rule,
cancer slope fltotor
feasibility study
Maximum Contaminant level
Maximum Contaminant level Goal
Maximum EJcpoaure Quldellne,
Main. Department of t:nvlronmental Protection
Main. RevlB8d Statu.. Annotated
Naval Air Station
remedial Inveatlgatlort
Resource Conservatloh and Recovery Ad
reference d088
Superfund Amendmentt Ind Reauthorization Ad
Safe Drinking Water ADt
U.S. Environmental ProtectIon Agency
micrograms per cublo meter
..
.
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t.'lE 0-1
LOCA11ON-SPECtFIC ARARs. CRITERIA. ADVISORIES. AND OUIDANt!
ROD: SM8 1 AND 3
NA88RUN8WfC1t
-
MBMA
WETlANDS/FLOODPlAIM8
State
'f MERE BROOK
.
~
WOO29248.T280/4
REoUlllBlENf
Maine Natural
Resources Protection
Aut (38 MRSA, SectIon
480-A through 5)
Natural Resources
'rotectlon Act, Perm"
by Rule Standards
(MEDEP Regs, Chapter
bit
""Ine Standards lor
ttasslflcatlon of Minor
bralnages (38 MRSA,
8ectlon 468)
Maine Natural
Resources Protection
Act (38 MRSA. Section
480-A through S)
STAtUS
Appllcabll
Applicable
Applicable
Appllcabl.
ItEQUlMMENT 8YNO""
This act outtlnes requirements for Mrtaln activities
adjacent to any freshwater wetland greater than 10
acres or with an associated stream, brOOk,. or Pond or
adjacent to a ooastal _tland. Ttle activities must not
unreasonably Interfere with certain n."'ral features,
such as natural flow or quality of an1 waters, nor harm
significant aquatic habitat, freshwat.r. fisheries, or
other aquatic 11f..
This rule outlines prescribed standards for specific
activities that may take place 11\ Of adjacent to
wetlands af'Jd water bodies.
Mer. Brook II classified as a al.. b water under the
stat. water quality standards. aa.. B waters are
defined as suitable for drinking water (Ifter treatment),
fishing, reefeatlon In and on the water, ind as habitat
for fish and other aquatic life.
A perm" application must be aubmlttfd and approved
by the Main. Bureau of Land aul"" Control Ind
Section 480-D performance stand.rds met when
conducting a~tles adjacent to any freshwater
wetland greater than 10 acres or with an associated
atream, brook, or pond.
COI88IDfMTIOfII .. THE REMtDIAL "'DCE88
Because oanstructlon of the alurry wallis within 100
feet of "'e,. Brook, this regulation Is applicable.
Remedl" activities will need to meet the substantive
requirements of this Act.
This regulation Is appllcabl. to construction of me
elurry wall. Activities Involving disturbance of 1011
material within 100 feet of the normal high water line.
will bet designed to Incorporate all applicable
standards.
Thes. tegulatlons apply to 8ctIvitles conducted
adjacent to Mere Brook. Remedial. construction
.hould not result In the degradation of water quality
classification.
Thesa tegulaUon8 may also potentially apply If
treated groundwater Is discharged 10 surface wattr.
The NltIIy'8 preferred discharge option Is to tf1.
Brunswlc:k POM; however, the Navy has not yet
received approval from the POTW. The d..lgnated
usas of the waterl receiving either direct dlscharg. or
POM tffIuent m\J8t be conlldered and protected In
developing either discharge "mlts or pretreatm.nt
standards.
Substantive requirements of thll regulation apply to
aetlvlU.. conducted adjacent to Mere Brook.
Howevtr, a perm" Is not required for the seleated
remed~ llnee administrative permit requirement. .re
waived far r;rr.od!al :etlvl!!e: conducted on.~It. It
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T A8LE D-2
LOCAl101t-8p£ctFIC ARARa. CRfTUM. ADVISORIES, AND dUIbAtfcr
ROO: SITO 1 ANO 3
NAS BRUNSWICK
-
-
MEtJIA
OTHER NATURAl..
RESouRcES
State
~
""
RrQUlRlMEN1'
ATAtUs
REQumM9ft SYHOI'88
Thlt law requires the classlflcatl"" of the state',
groundwater to protect, conserve, and maintain
groundwater resources In the Interett of the heallh,
safety, and general welfare of the '*!PIe of the stale.
Under the Malna standards, grourtm-ater Is classified
as GW-A.
this act and associated regul.tlOf$ govem new
developments, Including those th.t h8hdle hazardous
waste, New developments canrtol adverselv affect
existing uses, scenic character, 0' n.""al resources In
the municipality or neighboring murtlolpalltV.
CONIIDEM11OfI II THE REMEDIAL PAoCf88
Thl. rfgul.tlon will applv If treated groundwatltt I.
discharged back to groundwater. The Na'ly'.
pr.flrrtd discharge option Is to the Brunswick POfWi
howtYIr, the Navy has not yet received approval fforn
thl POTW. "discharge to groundwater Is 'mployed,
the olasslflcatlon and uses of groundwater ..III
lYaluated during development of dlscharQe limits,
Tholl regulations conctrnlng No Adverse
Environmental Impact 0.'., Chapter 375) are
appllctble to Implementation of the selected rem.dv.
In particular standards for prolectlon of groundwater
would applv to construction and groundwater
tr.a,,",nt actlvltlls. However, anv licenses required.
bV reference, will not need to be obtained since
perm'" are not required for actions conducted o".sile
at fedlral Superlund sites.
Not..:
MAR
MRSA
MEDEP .
HAS .
POTW .
RIfFS .
w0029246. T280/5
Maine Standards for
Ctassilication of .
Groundwater (38
MRSA. SectIon 470)
Applicable
Maine SIte Locallon
l:Jevelopment law and
Regulations (38 MRSA
Sections 48t-490:
MEDEP Rega, Chapters
37t-377)
Applicable
Applicable or Relevtnl and Appropriate Requirements
Maine RevIsed StatuteS Annotated
Malrte Department of Blvlronmental Protection
Naval AIr Station
Publicly Otmed Treatment Wofl(s
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G
TA8LE D-S
AC11ON-SPECIFIC AI'ftJeABLE Oil RnEVANT ANO APPROPRIATt R£1lUIIItM9fTa
ROD: 8ma 1 ANO 3
NAS BRUNSWICK.
C0fI8I0EM11Oft II 1M: REM£OIAl PR0CE88
. REOUIREM£Nf BYN0PS&8
8TA1\I8
ftrClUlllEMEN1'
Federal
The wast. matert" .t Sit.. f and 3 h.. not been formally
defined as a RCRA-regulated waste: therefore, only seotlons
of the facility standards are relevant and appropriate.
Because of NaVV ..curlly concerns, 9Itel 1 and 3 are
fenced and aCC8d to the waate Is effectively restricted.
Genaral facility requirements outlln. general waste analyals,
security measures, Inspectlonl, and training requirements.
ReM . Gtneral FaclHty Standard.
(40 CFR 264.1()'264.18)
Relevant and
Appropriate
All other relevant ..neral requirements will be Incorporated
Into the construotlon. and operation of the groundwater
treatment plant.
Because toJllc constHuenta are presenl at Sites 1 and 3,
preparedness and prevention requirements are relevant and
appropriate to th. Implementation of the selected remedy.
During the remedial construcllon safely and communication
equipment Will be Installed at the site, and local authorltle'
Will be familiarized With sll. operation'.
this rsgulallon outlines requIrements for safety equipment
and spill-control for hazardous waste facilities. Part of the
regulation Includes a requIrement that facllitle' be
deslgnad, maintained, constructed, and operated to
minimize the possibility of an unplanned release thai OIJuld
threaten human health or the environment.
Relevant and
Appropriate
ReM . Preparedn... and Prevent/on
(40 CFR 264.30.2M.31)
I
Relevant and
Appropriate
Because toldc cotIstituenla are present at SItes 1 and 3,
contingency plant and emergency procedures are releYa'"
and appropriate 10 the Implementation of the setected
remedy. Plan. win be developed and Implemented durlnll
site wort! Including Installallon of eJltractlon wells, and
Implementation of IHe remedies. Copl.. of the plans will
be kept on-sit..
Because loxlc constituents are present In the wastes at
SItes 1 and ~, and since those wastes will be left In place,
groundwater mllflltorlng requirements are relevant and
appropriate to Ihe seltoted remedy. long-term
groundwater monitoring Is Included a8 part of the selected
remedy proposed action.
Because the waste material. at SIte. 1 and 3 will be left In
place, those p.'" of thl. regulation OORcemlng long-term
monitoring and malntenanoe of the site .re relevant and
appropriate to the selected remedy.
Thl. regulation outllnel the requirements for emergency
procedu.,es 10 be used following explosions, tires, 110.
ReM . Contfngency Ptan and Emergency
Procedures (40 C~ 264.50-264.56)
Relevant and
Appropriate
"". regulation details groundwater monitorIng
requlremenls for hazardous waste treatment faolllll... The
regulation but/lne. general groundwater monltortng
standards, .s well al standards for detection monltotlng,
compliance monitoring, and corrective action monllorlng.
ReRA . Releases from SolId Waite Mattagement
Units (40 cm 264.90-264.109)
Thl. regulation details gen"al requIrements for cfo8U18 and
post-closure of hazardous waste facilities, InchIdlng
Installation of . groundwater monltorlnliJ program.
Relevant and
Appropriate
ReM . Closure and Poat-dosure
(40 CFR 264.11()'264.120'
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OOt'Itlnued
TAlLE 0.3
AC11ON-8P£CFIC APPlICABLE Oft RREVANT AND APPROPfIIAn REGt...MboTa
ROD: 8nts 1 AND 3
NASBRUlUWlCK
REGUIIIEMtNT
REGUilEMEffT 8YNOI'8I8
Thes. standards are applicable to miscellaneous unit. not
previously defined under elllsting RGRA regulations.
Subpart X outlines performance requirement. thet
mlscelleneous units be dlligned, constructed, operated,
and maintained to prevent releases to the subsurface,
groundwater, surface water, and wetlands that may have
aelver.. effects on human health and the envlronme'!'.
C0fIIIIDdA11OIiI .. 1I4E REMmtAl PRoCOl
STATUS
".
ReRA - Mscellaneous Unitt (40 CAt
264.600-264.999)
Because the ..ltcted remedy Includes a groundwatet
treatment plant, the general design, performance. and
operating requirements of Subpart" X Ire relevant and
appropriate. Howtver, a permit I. not required for remedial
Ictlons conducted on-site at federal Superfund sites.
Relevant and
Appropriate
ReRA Land Disposal Resttlctlons (.to em 268)
laM disposal of RCM hazardous wastes Is restrtcted
without specified treatment. II must be determined thltt the
waite, beyond a reasonable doubt, meets the definition of
one of the IpIcifled restrlated wastes and the remedial
aetton must constitute "placement" for the land disposal
restrfctlons to be consldefed applicable. Ft:Ir .ach
hazardous waste, the LORs IpICIfy that the wast. mt18t be
treated either by . treatment technology Or to .
conoentratlon level prior to disposal In a RCM Subtitle C
permitted facility.
The.e regulation. specify the 8-hour time-weighted evtrage
concentration for various organic compounds. fr.lnlng
requirements for workers at hazardous waste. opetatlons
are specified In 29 CFR 1910.120.
During treatment of groundwater, lIudge containing
hazardous constituents will be generated. The selected
remedy Includ.. provision. for analysis of this sludge,
Including Toxicity Characteristic Leachate Procedure (TCLp)
testing. LORs ar. potentially applicable If'he sludge falls
TCLP. The uleoted remedy does address handling and
disposal of the sludge as I hazardou. wlste, If necessary.
To be
determined
~
.....
OSHA. Oener.llndustry Standardl
(29 CFR Part 19101
Because toxic odnstltuents are present at Sites 1 and :I,
OSHA regulations are applicable. "roper respiratory
equipment will bt worn " It Is Impossible to maintain the
work atmo.ph'" below designated concentration..
Worke,. performing actlvltl.. would be required to have
completed apecIIIo training requirements.
Because toxic constituents .re prestnt It Sltll 1 and 3.
OSHA regulations are applicable. All appropriate safety
equipment will be on-sltl. In addition, lafely prooeduret
would be followltd during on-site activities.
Applicable
OSHA. Safety and Health Standard.
(29 CFR Part 1926)
This regulatlpn specifies the type of safety equipment and
J'rOCldures to be followed during site remediation.
Applicable
Thl. regulation outlines the recordkeeplng and reportlrig
requirements for an employer under OSHA.
OSHA. hecordkefplng, Reporting. and Related
Regulations (29 ct=R 19(4)
Applicable
Because toxic constltuenlt are present at Sites 1 Ind 3,
OSHA regulatlona are applicable. Th..e requirements wl~
apply to all site tantraetor. and subcontractors, and must
be followed during all site *"rk.
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TA8LE D-3
AC11ON-SP£CtFIO APf'UCA81£ OR RElEVANt AND A",""OPRIATE flEo\lMUlbIT8
ROO: Sms 1 AND S
NASBRUNSWICIt
-
Q
REOuiBHNT
CWA - NPDES Regulation'
(40 CFR Parts 122, 125)
UndergfC)und inJection Control Program
ty (40 CFR 144, 146, t47, 1dOO)
aD
CWA. Pretreatment Standards for POTW
Dlsc:harl88 (40 CFR Part 403)
~
Maine landfill Disposal Aegulatlont
(MEDEP Regs, Chapter 401)
w0029248.T280/8
STATue
Applicable
Applicable
Applicable
. REOUlRt'MbIT SYNOP8I8
Thll requirement Implements the NPDES P"'Ora'" that
apeolfJes the applicable effluent standards, monitoring
requirements, and .tandard and special conditIo'" 'or
direct discharge.
Thl.. regulations outline minimum progrllm and
performance standards for underground InJection programs.
Technical criteria and standards for siting, operatIOn Ind
maintenance, and raportlng and recordkeeplng as required
for permitting are set forth In PaI1148.
Thl. regul8tlon specifies pretreatment Itandard, for
dlecharges to I POTW. "treated grou.." II
dlsoharged to I POTW, ttie P01W mUlt have m8Chanlsml
available to meet the requirements of the NatIonal
. ""'''.alment Progrlm - introduction of Pollut8nt1 which
08"" pall through or Interference are prdhlblted.
Dlac:hargel mUlt 1110 comply with any local roTW
regulatlonl. "hazardous wllte II discharged to "" PaTW,
the PaTW mey be lubJect to RCM permlt-bY-NIe.
Relevant and - 1M.. regulliiKInt outline th. piim;lltliiy ;aqul;~T~ for
Appropriate wa'te disposal by landfill. Chapter 401 speclf\8s cIoaure
and poat-clolure maintenance requirements.
C0ftSlDlM1ioN It TttE REMEDIAL PIIOC£88
NPDES requlr8ments will be applicable If treated
groundwater I. discharged to surfaC8 water. The Navy"
preferred dlsc:harge option II to the Brunswick P01Wj
however, the Na~ hal not yet recelv.d approval from the
POTW. Both on. .nd oft.slte dlsc:harge. ffC)m CERCLA lite.
to lurface wate,. 're required to mell' the lubstantlve CWA
NPDES requirements, Including discharge limitation.,
monitoring requirements, and best management practice..
Brunswick P01W hal a current NPDES permit. A permit
would be required" treated groundwater II discharged on-
alte.
This regulation wtli be applicable" treated groundwater I,
discharged back to groundwater. 'the Navy's preferred
dlsc:harge option 18 to the Brunswick POTW; however, the
Navy has not yet received approval from the POTW.
Discharge of treated groundwater, by well InJection, mUlt
be In accordance *"" all the criteria .and atandards I" theSe
federal regulatlOltl, al well 8S meet .11 state Underoround
injection ConlfOl Program requirements. Treated
groundwater mutt meat all SDWA Itandards prfor to wetl
InJection.
this regulation .. applicable since thl Navy's preferred
discharge optl~ II to the brunswick POTW; howaver, the
Navy ha. not.ytt received approval from the potw. "
treated groundwater Is dltcharged to a PaTW, the treated
wate, must meet III dlac:harge limitation. Imposed by the
POTW.
9:x::ut:: SItes t !.'1d 3 enoomp!~ ~ former !!nd!!~. the..
requirements a" relevant and appropriate. Design of .
cover system wfll have to meet minimum standardl and
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TA8lE D-'
AC11ON-SP£CFIC AMlCA8LE Of! RElEVANT AND APPftOPRlAT£ RE0UIfttMENT8
ROD: Inti 1 AND 3
NASBRUNSWICK
~!"EQUIREMBft
Maine Ruin to Control the Subsurfeoe DIscharge
of Pollutants by Well injection (MEDEl' Regs,
Chapter 543)
STATUI
Applicable
R£GUIItMtJn SYNOP8l8
CONIIOIMTION 1M 'tHE REIIUDtAL PltOC£88
this regulation prohibits the Injection o. hazardOUI WIIste
Into or above water-bearing formations via a new CIa.. IV
w.II, The subsurface discharge Into or through a CI... IV
well that would cause or allow the movement o. fluid "'to
an underground source of drinking water thaf may 'e"'l1 In
a violation o' any Maine Primary Drinking Watet Standard,
or which may otherwise adversely affect public hlalth, Is
prohibited.
The rules provide a comprehensive program 'or handling,
slOrage, and recordkeeplng at hazardous waste 'acllltles.
The, .upplement the RCM regulations.
Regulatea the discharge of any pollutants. Speclfl.. that
the dlacharge, either by Itself or combined With other
discharges, Will riot lower the quality of any classified bcJdy
of water below such clalSlfioallon. The dlscharg. wllf be
subject to effluent limitations that require application at the
belt practicable treatment.
These regulation' Will be applicable If treated groundwater
Is discharged bacft to groundwater. Th. Navy', preferred
discharge option II to the brunswick POTW; howeve,. the
Navy has not yet 'ecelved approval from the POTW. For
discharge to the MlbsurfllC8, groundwater must be treated
to a target clean-up levels I88S than or equal to the Maine
MEGs to bi reoh_ged to the aquifer.
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Maine Hazardous Wast. Manlgement Rulea
(MEDEP Regs,'Chapters 800-802, 8!10, 851.853-
851)
Maine Wlter Pollution Control Law: Conditions 0'
f Ucenses (38 MRSA, Section 414-A)
\0
Relevant and
Appropriate
BeeIU.. these requirements supplem.nt RCM hazardous
wiste regulation., they are relevant and approprIate.
Applicable
The lubstanllve rtqulremenh of thl.. regulation will apply "
treated groundwater Is discharged to surface water, Th.
Navy's preferred discharge option ,. to the Brunswfck
POTW; however, the Navy has not yet received approva'
from the POTW. . If treated water Is discharged dlrectfy to
surface water the effluent must receive thl best practlcabl.
treatment before discharge.
this regulation Will apply If treated groundwater ,.
discharged to surface water, The Navy" preferred dlsoharg.
option Is to the IJrunswlck POTW; howevlr, the Navy hat
not yet receIved Ipproval from the POTW. If dlscha'ge to
surface water.ls Imployed, Best Manag.mlnt Practlctls win
be used when handling wastes.
Maine Water Pollution Control Law: Cettaln .
Deposits and Dlschargea Prohibited. (38 MRSA.
Section 420)
Applicable
No person, firm. corporation, or other legal tntlty Ihall
pia, deposit, discharge, or spill mercury or t01i1o or
hatardaus substances, eIther directly or Indlrectl)', Into the
Inland groundwater or surface waters, tidal waters, on the
Ice, or on the banks thereof, 80 that the same may ftow or
b8 washed Into such watetl, or In such manne, that the
drainage therefrom may flow Into such waters.
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TABU 0-3
AC11ON-SPtctFIC APPlICA8LE OR RElEVANT A* APPIIOPRIATE REQ"oI.AUn'8
ROD: sma 1 AND 3
NAB BIlUN8W8Ck
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StAM
. "tQUIIIBIBff
ate Guidance and
o Be Considered
ert
MEDEP, Bureau of W8ter 0u8l1ty ContraI. Policy
tNmber 10, "The DIscharge of Hazardoul
Substances 10 Groundwatcn of the State-
To Be
Considered
REOuiRtWI£NT 8YN0P88
The bureau will deny applications for waste dlsch8rlle
llcen..s for the discharge to groundwaters of subata,*s
designated by the Soard to be hazardous when such
substances are present In concentrations exceeding
groundwater levels which occUr naturally In the _a.
exemption may be granted If the groundwater Is treated to
reduce the concentrations of pollutants discharged to bfldw
the IIVII considered safe for drinking water,
CoIIsIMMttoN II nc hEMmtA\. h0CE88
Thtl pollCV will fleed to be considered It treated
groundwater II discharged back to groundwater. The Nalty'.
preferred dlscharg' option II to the Brunswick POTW;
however, the Navy has not yet received approval from the
POTW. "treated Wlter Is discharged to the lubsurface. the
minImum level of groundwater treatment would be reql.llred
to provide adequate protection II no other mean. of
disposal II feaslbte. this policy would only be considered
after application of federal and state underground InJeotIon
control regulation.. .
. 'P .tHl
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CFR ..
fjNA -
LbRs -
MEDEP -
MEG
MRSA
NAS
NPOES -
OSHA-
PaTW -
ReM -
SOWA -
tCLP -
Code 08 Federal Regutatlon.
Clean Water Act
Land DIsposal RntrlctloM
Maine Department of EnvIronmental Protection
Maximum Exposure Gulde"ne.
MaIne Revtsed Statute. Annotated
Naval AIr Station
National Potlutant Dlsoh... elimination System
Occupational Safety and Health Administration
publicly own8d treatment works
Resource Coneervatlon and Recovery Act
Safe Drtnklng Water fd
TOlllolty Charaoterlstlo Ltaohate Procedure
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"8:
APPENDIX F
MEDEP Lbl lbR OF CONCURRENCE
i
WCX!29246.OIO
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I . .' :. "~\"'f\~hlft.t~ STATE OF MAINE
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I\:\~~J Departm~~~~~~~ental Protection
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.10"" R. IIIIcII:DINAN. A
GOI/ERNOA
June", 1.992
DEAN Co """"on
COIoIM!SSIONER
Thomas A. nam,:ll$
Captain, CEC, u.s. Navy
Commanding Officer
Department of the Navy, Northern Division
Naval Facilities Enqineering Command
Building 77-L
Philadelphia Naval Shipyard
Philadelphia, FA ~9112-5094
RE:
Naval Air Station Brunswick Superfund Site, Bruns'",ick,
Maine
Dear Captain Dames:
The Maine Department of Environmental Protection (MEDEP) has
reviewed the June 1992 Draft Record of Decision (ROD)
regarding Sites 1 & 3 for the Naval Air Station Brunswick
Superfund Site located in Brunswick, Maine.
Based on that draft the MEDEP concurs with the selected
remedial action. This action consists of a mUlti-compoJ'1ent
approach for the containment of waste and remediation c:>f
groundwater as outlined in the following: .
I.
Slurry Wall
A. The soil/bentonite slurry wall will be placed ilround
the landfill.
B. The wall will be keyed into natural clay format:ions.
C. Due to interference from the weapons compound, the
wall will not be continuous around the landfill
site.
n.
cap
A. A l~ermeability. cap will be Constructed ove:~ 'the
landfill"area.
B. The cap will extend over the slurry wall.
C. The cap will not extend into the Weapons Compo\.1lnd
Area.
D. Future closure of the Weapons Compound will result
in a reevaluation of the cap construction.
.';
prilllnl Oil rrtydU ptIp~,
. PcrtJ.and .
REGIONAL OFFICES
-a.n;or.
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III. Groundwater Extraction Wells
IV.
v.
A. Grcundwater eX'tracti~ wells vill be installed which
will remove contaminated qroundwater beneath the cap
and within. the 'slurry wall. .
B. The number and placement of extraction wells wil~ be
determined during the design phase.
c. Pump tests will be conducted to determine pumping
rates. .'
Groundwater Treatment
A. Extracted groundwater will be pumped to a central
treatment plant.
B. Groundwater will be pretreated to remove inorganic
co~po~~~nds.. .
c. Groundwater vi11 be treated to reduce or eliminate
volatile organic compounds through the use of
UV/oxidation technology.
D. Treatment levels will be based on the Public
Operated Treatment Work's (POTW) National Pollution
Discharge Elimination system permit and/or MCLs.
E. Treatability studies will be conducted prior to
full-scale design. . .
Discharge of Treated Water
A. Discharge of treated water will be to the base
sanitary sewer system which connects to the
Brunswick Sewer Dis1:rict, Public Operated Treatment
Works (POTW). POTW approval will be. required.
B. Flow from the NABS treat1nent facility will not cause
the POTW to exceed its capacity.
VI. . Clean-up levels
A. Groundwater clean-up levels for contaminants have
been set at the MCL.
B. No soil clean-up leveJ.s were established.
c. Ecological 'ta1; get clean-up J.eveJ.s ~= leachate seeps
and surface water have been' set a't the Ambient Water
Q~ty criteria or risk based levels.
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VII. Institutional controls
A. Land use restrictions will .be placed en future use
c~ the landfill and groundwater a££ected by 'the
landfill. These restrictions will pro~ibit
disturbance of landfilled materials. and.extraction
cf groundwater for any use besides remediation.
B. Warninq siqns will be placed in appropriate
locations.
VIII. Environmental monitoring
A. Groundwater flow and quality will be monitored.
B. Surface water, sediments, and leachate seeps will
be monitored.
c. Dispersiop and degradation of contamination al:t'eady
mnanated frcm 'the larnl£ill will be 1!\Onitored. .
D. At a minimmn, environmental monitoring will
continue for 30 years. .
E. Five year reviews will be conducted.
F. A risk assessment will be part of the 5 year
review.
G. The need for future remedial action will be
assessed.
This concurrence is based apon "the State's understanding
that:
A. The MEDEP.will continue to participate in the
Federal Facilities Aqreement dated October 19,
and in 'the review and approval o£ cperational
desiqns and monitoring plans.
B. Groundwater extraction wells established within the
slurry wall enclosure will be maintained.
Groundwater elevation levels will be monitored
within the landfill to determine the effectiveness
of the slurry wall/cap. If groundwater levels rise,
resulting in contact between contained waste and the
groundwater, the extraction wells will be
reactivated to maintain appropriate qroundwater
levels. Discharge water from any 'future pumpin,q,.
beyond that anticipated in this ROD, will requi.re
treatment.
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'c. At.. the coinpletion cf the remedy, any residual %'isk
at the site will fall within the risk ranqe
specified under the Federal National.Continqenc~
Plan (NCP). The MEDEP remains concerned that tbe
qroundwater clean-up standard for vinyl chloride is
not consistent with the risk ranqe specified in the
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NCP. In particular, if vinyl chloride is reduced no
lower than 2.0 ppb groundwater clean-up level
specified in this ROD, the residual risk £rom this
co~pound alone will exceed the worst case 10-4 cu~
off speci:.:ied in the NCP. The MEDEP finds the
specified groundwater clean-up goal for vinyl
chloride, may not provide sufficient protection of
public health. The state, however I anticipates that
in reducing most compounds at the Site to their
respective groundwater clean-up goals, vinyl
chloride will be reduced to protective levels
well below the clean-up goals stated in the ROD.
Therefore our concurrence is based upon the
understanding that the decision as to completion of
the remedy for groundwater will be based on the
total residual groundwater risk from the Site and
that further remedial action wi3l be required if the
total sit4 risk exceeds the 10- cuto£f specified in
-the NCP.
D. Institutional controls must remain in place as part
of the remedial. alternative,. if the calcul!~ed total
excess cancer r1sk for the s1te exceeds 10
E. The site conditions shall be reviewed within five(S)
years from the conclusion ef the remedial action to
ensure that public health and the environment are
not significantly impacted by the remedial
contaminants~ Of particular concern to the MEDEP is
the potential for increased concentrations of vinyl
chloride due to anaerobic degradation of residual
chlorinated compounds in groundwater.
The MEDEP looks £orward to working with the Department of
the Navy and the USEPA ~o resel ve the environmental problems
posed' by this site. If you need additional information, do
not hesitate to contact myself or members of my staff.
rs;:~
Dean C. Harriott
commissioner
cc: Alan, Prys\1Dk~, Director, BHMSWC
Micha~l -Barden,.. Director, DSIR
~~~iBylanaf~DirectbT7-FFU
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