United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01-92/066
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 ~ been removed at the request of
the issuing agency. They contain material which supplement. but adds no fur1her applicable information to
the content' of the document. All supplemental material is, hoWeVer, contained In the administrative record
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50272-101
REPORT DOCUMENTATION 11. REPORT NO. I ~ 3. Recipient'a Acceaeion No.
PAGE EPA/ROD/ROl-92/066
4. T1t1e and Subtitle S. Report Date
SUPERFUND RECORD OF DECISION 06/16/92
Brunswick Naval Air Station (Operable Unit 2), ME
6.
Second Remedial Action - Interim
7. Author(a) a. Performing Organization Rept. No.
8. Pltrformlng OrgaJnlzation Name and Addreaa 10. ProjecVTuk!Wo,k Unit No.
11. Contract{C) 0' G,ant(G) No.
(C)
(G)
12. Sponao,ing Organization Name and Addreaa 13. Type 01 Report & Pe,lod CovenKI
U.S. Environmental Protection Agency 800/000
401 M Street, S.w.
washington, D.C. 20460 14..
1S. Supple....ntary Notaa
PB93-963706
16. AbetraCl (Umit: 200 worda)
The 3,094-acre Brunswick Naval Air Station site (NAS Brunswick) 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.5. Navy's antisubmarine warfare operations in 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 currently
NAS Brunswick 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 past disposal of hazardous materials. Investigations were conducted by the U.S.
Navy and EPA beginning in 1983 to determine the contaminated site areas including, Site
4, an acid/caustic pit used from 1969 to 1974 for disposal of liquid wastes; Site 11, a
former fire-training area, used over a 30-year period until 1990, where fuels, oils,
(See Attached Page)
17. Document Analysia L Desc,lptora
ReCord of Decision - Brunswick Naval Air Station Operable Unit 1), ME
Second Remedial Action - Interim
Contaminated Medium: gw
Key Contaminants: VOCs (PCE, TCE)
b. IdentilieralOpen.Ended Terme
c. COSA 11 Field/Group
18. Availability Statement 19. Secu,ity Clua (This Report) 21. No. 01 pagea
None 72
20. Security Clasa (Thia Page) 22. Price
None
272 (4-77)
(Sea ANSI-Z39.18)
See Instructions on Reverse
(Formerly KTlS-35)
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EPA/ROD/ROl-92/066
Brunswick Naval Air Station (Operable Unit 2), ME
Second Remedial Action - Interim
Abstract (Continued)
and degreasing solvents were used in the fire-training exercises; and Site 13, the
Defense Reutilization and Marketing Office (DRMO) area, consisting of three underground
storage tanks containing oils, waste fuels, and solvents which were removed in the late
1980's. Extensive hydrogeological data from a 1990 study delineated a plume of
VOC-contaminated ground water extending north to south along the eastern boundary of the
site, known as the Eastern Plume. This ROD addresses an interim remedy for Site 2, the
Eastern Plume, the source of which has been traced to Sites 4, 11, and 13. An additional
1992 ROD specified containment of onsite buried wastes and ground water plume management.
A future ROD will address a final remedy for the ground water at NAS Brunswick. The
primary contaminants of concern affecting the ground water are VOCs, including PCE and
TCE.
The selected remedial action for this site includes extracting and treating contaminated
ground water onsite using precipitation and filtration processes to remove metals such as
iron and manganese, and UV/oxidation to remove VOCs, with offsite discharge of the
treated water to a local POTW for final treatment; conducting treatability tests prior to
design of the treatment system; and implementing a Navy monitoring program to ensure that
the system is effective. Extracted ground water for this OU will be combined with ground
water from OU1, the subject of a previous ROD, and treated concurrently in a single
system. The estimated present worth cost for this remedial action is $4,223,000, which
includes an O&M cost of $1,845,000 over 5 years.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific ground water clean-up goals for this site were based on SDWA ~ICLs and
health-based standards and include 1,1,1-TCA 200 ug/l; TCE 5 ug/l; PCE 5 ug/l;
trans-1,2-DCE 100 ug/l; cis-1,2-DCE 70 ug/l; 1,1-DCA 3,500 ug/l; and l,l-DCE 7 ug/l. The
interim action is intended to contain the Eastern Plume and prevent further migration to
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RECORD OF DECISION.
FOR AN
INTERIM REMEDIAL ACTION
AT THE
EASTERN PLUME GROUNDWATER
OPERABLE UNIT
NAVAL AIR STATION BRUNSWICK, MAINE
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RECORD OF DECISION.
FOR AN
INTERIM REMEDIAL ACTION
AT THE
EASTERN PLUME GROUNDWATER
OPERABLE UNIT
NAVAL AIR STATION BRUNSWICK, MAINE
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NAVAL AIR STATION BRUNSWICK .
INTERIM RECORD OF DECISION
TABLE OF CONTENTS
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Contents
Page No.
DECLARATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . 1
DEOSION SUMMARY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
I. SITE NAME, LOCATION, AND DESCRIPTION. . . . . . . . . . . 6
n. SITE mSTORY AND ENFORCEMENT ACTIVITIES. . . . . . . 9
A LAND USE AND REsPONSE HISTORY. . . . . . . . . . . . . . . 9
B. ENFORCEMENT HISTORY. . . .. . . . .. . . . . . .. . . . .. 11
COMMUNITY PARTICIPATION. . . . . . . . . . . . . . . . . . . .. 14
SCOPE AND ROLE OF OPERABLE UNIT ............. 15
SUMMARY OF SITE CHARAcrERISTICS ............. .16
A GROUNDWATER FLow AND SUBSURFACE GEOLOGY. 16
B. GROUNDWATER QUALITY. . . . . . . . . . . . . . . . . . . .. 17
C. KNOWN OR POTENTIAL ROUTES OF MIGRATION OF
CONTANITNATION ............................ 22
VI. SUMMARY OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . .. 24
VII. DE VEL 0 P MEN TAN D S eRE E N IN G 0 F
AL1'ERNA TIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 26
A STATUTORY REQUIREMENTS/RESPONSE
OBJECI1VES ................................ 26
TECHNOLOGY AND ALTERNATIVE DEVELOPMENT
AND SCREENING. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 26
vm. DESCRIPTION OF AL1'ERNATIVE . . . . . . . . . . . . . . . . . .. 28
IX. SUMMARY OF TIlE COMPARATIVE ANALYSIS OF
AL1'ERNATIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 29
A OVERALL PROTECTION OF HUMAN HEAL'IH AND '!HE
ENVIRONMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 29
. COMPUANCE WITH APPUCABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS. . . . .. . . . . . . . . . . .. 29
C. LoNQ.TERM EFFECl'lVENESS AND PERMANENCE. . .. 30
D. . ,.REDUcnON OF TOXICITY, MOBD..ITY, OR VOLUME .
THROUGH TREATMENT. . . . . . . . . . . . . . . . . . . . . .. 30
SHORT-TERM EFFECl'lVENESS . . . . . . . . . . . . . . . . . .. 30
DMPLEMENTABD..ITY .......................... 31
COST. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 31
STATE ACCEPTANCE.. . .. .. ... ... .. .. . .. . . . ; .. 31
m.
IV.
V.
B.
B.
E.
F.
G.
H.
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NAVAL AIR STATION BRUNSWICK
INTERIM RECORD OF DECISION
TABLE OF CONTENTS
( continued)
Contents
Page No.
I. COMMUNITY ACCEPTANCE. . . . . . . . . . . . . . . . . . . .. 31
TIlE SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . . . . .. 33
A D..EANuP I..EVELS . . ... . ~ . . . . . . . . . . . . . . . . . . . . .. 33
B. DESCRIPTION OF REMEDIAL COMPONENTS. . . . . . . .. 33
XI. STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . . . .. 39
, A THE SELECTED INTERIM REMEDy IS PROTECI1VE OF,
HUMAN HEALTH AND THE ENVIRONMENT. . . . . . . .. 39
THE SELECI'ED INTERIM REMEDY ATTAINS ARARs . 39
THE SELECIED INTERIM REMEDIAL AcnON IS COsr-
EFFECTIVE. . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . . . .. 45
THE SELECTED INTERIM REMEDY UTILIZES
PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT OR RESOURCE RECOVERY
TECHNOLOGIES TO THE MAXIMUM EXTENT
PRACTICABLE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 46
THE SELECI'ED INTERIM REMEDY SATISFIES THE
PREFERENCE FOR TREATMENT WHICH
PERMANENTLY AND SIGNIFICANTLY REDUCES THE
TOXICITY, MOBILITY, OR VOLUME OF THE
HAZARDOUS SUBSTANCES AS A PRINCIPAL
ELEMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 46
XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES. . . .. 47
xm. STATE ROLE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 48
x.
B.
C.
D.
E.
APPENDICES
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
Applicable or Relevant and Appropriate Requirements
Responsiveness Summary
MEDEP Letter of Concurrence
Admini~trative Record Index and Guidance Documents
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Figure
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2
3
4
5
6
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WOO292S1.080
NAVAL AIR STATION BRUNSWICK
INTERIM RECORD OF DECISION
LIST OF FIGURES
Page No.
Site L.ocation Map. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 7
Limits of the Eastern Plume. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
10
Shallow Groundwater Flow-Eastern Plume Area. . . . . . . . . . . . . . . .
18
Deep Groundwater Flow-Eastern Plume Area. . . . . . . . . . . . . . . . . .
19
Schematic East-West Cross Section of Geology of Eastern Plume. . .. 20
Schematic North-South Cross Section of Geology of Eastern Plume.. 21
Extraction Wells Water Treatment Plant L.ocation and Process. . . . .. 35
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Table
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3
WOO292S1.080
NAVAL AIR STATION BRUNSWICK
INfERIM RECORD OF DECISION
LIST OF TABLES
Page No.
VOC Contaminant Concentrations. . . . . . . . . . . . . . . . . . . . . . . . . .. 23
List of Contaminants of Concern. . . . . . . . . . . . . . . . . . . . . . . . . . .. 25
Target Cleanup Levels. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 34.
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DECLARATION
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SITE NAME AND WCATION
Naval Air Station (NAS) Brunswick, Eastern Plume
Brunswick, Maine
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected interim remedial action for the
hydraulic containment of cont~min~ted groundwater referred to as the Eastern Plume
at 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
and, to the extent practicable, the National Contingency Plan. Through this
document, the Navy plans to remedy, on a interim basis, by hydraulic containment,
recovery, and treatment, the threat to human health and the environment posed by
contaminated groundwater. This decision is based on the Administrative Record for
the site. The Administrative Record for the site is located at the Public Worko;
Office at NAS Brunswick.
The State of Maine Department of Environmental Protection (MEDEP) and the U.S.
Environmental Protection Agency (USEP A) concur with the selected interim
remedial action.
A final remedy for the site including both groundwater and source operable units is
being developed through the Remedial Investigation/Feasibility Study process and
a subsequent Record of Decision (ROD) will be issued to address the final site
remedy.
ASSESSMENT OF THE SITE
Actual'or threatened releases of hazardous substances from the Eastern Plume, if not
...addressed by implementing the interim response action selected in this ROD, may
present an imminent and substantial endangerment to public health, welfare, or the
environment
1~:... . ~ -. -or.'
DESCRIPTION OF THE REMEDY
The interim remedial action will contain the Eastern Plume, preventing further
migration of the plume and discharge of the plume to the Harpswell Cove estuary.
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The interim remedial action consists of groundwater extraction, treatment, and
discharge of treated groundwater. Wells will be positioned to hydraulically contain
the Eastern Plume. Extracted groundwater will be combined with extracted
groundwater from Sites 1 and 3 and treated together. Remediation of Sites 1 and
3 is addressed in a separate ROD. Iron and manganese will be removed from the
extracted groundwater by precipitation and filtration processes to reduce their
interference with treatment of the volatile organic compounds (VOCS). The VOCs
will be removed from the water using the ultraviolet/oxidation treatment technology.
The proposed discharge method is to the Brunswick publicly owned treatment works
(POTW), however, another option may be used if approval for discharge to the
POTW cannot be obtained. Ultimate discharge is to the Androscoggin River via a
National Pollutant Discharge Elimination System Permit. Before designing the
treatment system, treatability tests will be conducted to provide information on the
compounds and concentrations likely to be present in the effluent.
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Before startup of the extraction well network, the Navy will submit a monitoring
program for approval by the MEDEP and the USEP A, "to confirm that the
containment system is effective. "
The interim remedial action will address the principal threat of discharge of
contaminated water to Harpswell Cove by containing the Eastern Plume before it
reaches Harpswell Cove. The potential threat to human health is not an immediate
threat because water from the contaminated plume is not currently used as a
drinking water supply. The final site remedy to address both the source and
groundwater operable units along with future threats to human health and the
environment will be addressed in a subsequent ROD. This interim remedial action
is expected to be consistent with the final remedy.
STATUTORY DETERMINATIONS
The selected interim remedial action is protective of human health and the
environment, complies with federal and state applicable or relevant and appropriate
requirements for this limited scope, and is cost-effective. Because this action does
not constitute the final remedy for the Eastern Plume, the statutory preference for
":remedies that employ treatment tbatreduces toxicity, mobility, or volume as a
principal element, although partially addressed in this remedy, will be addressed"in
the final response action. This remedy uses permanent solutions and alternative
~--treatment technologies to the maximum extent practicable for this site. Because this
remedy may result in hazardous substances remaining in on-site groundwater above'
health-based cleanup levels, a review will be conducted by the Navy, the USEP A, and
the MEDEP within five years after startup of the groundwater containment to ensure
that the interim remedy continues to provide adequate protection of human health
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and the environment. This review will be conducted at least every five years as long
as hazardous substances remain in on-site groundwater above health-based cleanup
levels or until the ROD for the final site remedy is signed and supersedes this ROD.
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The foregoing represents the selection of an interim remedial action by the
Department of the Navy and the U.S. Environmental Protection Agency, Region I,
with concurrence of the Maine partment of Environmental Protection.
Concur and Recommend for' ediate implementation:
By: - \ ~ 7 A " e: \L- :J~~ ~ 1-.
Thomas A Dames
Title: Captain, CEC, U.S. Navy
Commanding Officer
Northern Division
Naval Facilities Engineering Command
By:M~
H.M. Wilson
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 an interim 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.
By:
Date: ~ 1'1 IJf2-
Title: Regional Administrator, USEP A
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DECISION SUMMARY
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I. SITE NAME, WCATION, 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 that are under
investigation. This interim Record of Decision (ROD) relates to the groundwater
plume, known as the Eastern Plume, which is the result of past or current
contamination at Sites 4, 11, and 13.
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 the base is characterized by low, undulating bills with
deeply incised brooks; ground surface elevations range from mean sea level (MSL)
in lowland drainage areas and the Harpswell Cove estuary, to over 110 feet above
MSL west and southeast of the southern end of the runways. Topography in the
base's developed areas has been modified by construction, and ground surfa~e
elevations generally range from 50 to 75 feet above MSL. .
NAS Brunswick is an active facility supporting the U.S. Navy's antisubmarine warfare
operations in the Atlantic Ocean and Mediterranean Sea. The primary mission of
the base is to operate and maintain P-3 Orion aircraft. NAS Brunswick first became
active in the 1940s during .World War n, and underwent major expansion in the
1950s.
NAS Brunswick is located on 3,094 acres. Tbe operations area (138 acres), east of
the two parallel runways, 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 percent), grasslands (approximately 28 percent), and paved areas (approximately
12 percent) comprise most of the base property. Paved areas are mostly flight ramps
and runways.' Tbe 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 Harpswell Cove.
PropertY usage -mrounding ''NAS -Brunswick is ,mmarily '$Uburban -.nd -rural .
residential, with some commercial and light industrial uses along Routes 1, 24, and
123. An elementary school, college, and a hospital are located within 1 mile of the
western base boundary.
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POOR QUAU1'Y
ORiGiNAL
FIGURE 1
SITE LOCATION MAP
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The Eastern Plume, the groundwater operable unit being addr"essed in this interim
ROD, is the result of contamination at Sites 4, 11, and 13. Groundwater in the area
of the plume is not currently used for drinking water or other purposes; therefore,
there are no human receptors. The plume is predicted to discharge to Harpswell
Cove in five years, potentially affecting many ecological receptors. The
contamination of groundwater in the Eastern Plume has not affected the current use
of natural resources. Use of groundwater and surface water in this area is very
limited; however, the presence of contaminated groundwater does prevent the use
of this natural resource in the future.
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II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. LAND USE AND RESPONSE HISTORY
Extensive hydrogeological and analytical data collected during the 1990 field program
delineated a plume of volatile organic compound (VOC)-contaminated groundwater
extending north to south along the eastern boundary of NAS Brunswick. This VOC
plume, the result of contamination at Sites 4 (the Acid/Caustic Pit), 11 (the former
Fire Training Area), and 13 (the Defense Reutilization and Marketing Office
[DRMO] Area), is known as the Eastern Plume (Figure 2). Groundwater in this
plume flows south toward Harpswell Cove. The contaminated groundwater is not:
flowing toward residential areas east of the base, and it is currently not discharging
to or impacting any surface water bodies. The southern limit of the plume is'
believed to be in the vicinity of New Gumet Road. The predicted discharge zone
for the Eastern Plume, the tidal area where Mere Brook flows into Harpswell Cove,
is approximately 750 feet away from the southern extent of the Eastern Plume (E.c.
Jordan Co., 1991b). Based on groundwater modeling, the plume is predicted to
reach the discharge zone in about five years; however, this interim remedial action
is intended to contain the plume and prevent it from reaching Harpswell Cove.
Surface water contamination has been detected in Mere Brook both above the
southern part of the Eastern Plume and east of Site 11 in the Picnic Pond Area. The
Eastern Plume flows beneath both of these surface waters; however, the presence of
contaminants in these surface waters are related to other source areas (e.g., Sites 1
and 3 and surface runoff). Contaminants detected in the surface water differ from
the contaminants detected in the Eastern Plume and the Eastern Plume is not
believed to be hydraulically connected to these surface waters.
Off-base drinking water wells were tested for some residences on Coombs Road in
Brunswick to determine if contaminated groundwater from the base had affected
these wells. Contamination from the Eastern Plume was not expected to impact
these wells and this was confirmed by the testing.
Sites 4, 11, and 13 at NAS Brunswick are believed to be current or past contributors
to groundwater contamination in the Eastern Plume. .Site 4, the Acid/Caustic Pit,
.' ~as used from 1969 to 1974 for the disposal of liquid -wastes. .IDle wastes were
poured into the pit, which was approximately -4.feet '5qUare '1IJld 3 feet ~eep.
Investigations showed that subsurface soils around Site 4 were not contaminated and
groundwater was only contaminated with low levels of trichloroethylene (TCE).
Based on these results, it is believed that Site 4 no longer contributes to groundwater
contamination in the Eastern Plume. .
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i ... .. LIMITS OF EASTERN PLUME
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Site 13, the DRMO Area, consisted of three underground storage tanks located south
of Site 4. One tank was uSed for diesel fuel. The other tanks reportedly were used
for storage of waste fuels, oils, and degreasing solvents (R.F. Weston, Inc., 1983). All
three tanks were removed during the late 1980s and a new fiberglass diesel
underground storage tank was installed. Groundwater sampling downgradient of
Site 13 has shown decreasing VOC contamination since removal of the tanks. The
most recent groundwater samples from this area contained only low levels of
contamination, indicating that Site 13 is no longer acting as a source of
contamination for the Eastern Plume.
Site 11 is a former Fire Training Area that was used regularly over a 3D-year period
until it was closed in the fall of 1990. Waste liquids including fuels, oils, and
degreasing solvents were used as fuel for the fire training exercises. The most
prevalent contaminants in groundwater (Le., 1,1,1-trichloroethane [TCA] and TCE)
are consistent with the wastes used at the Fire Training Area and the soil
contamination at the Fire Training Area. Site 11 is believed to be the primary
continuing source of groundwater contamination in the Eastern PI\?lIle. The Fire
Training Area is no longer in use.
A more. detailed description of the history of Sites 4, 11, and 13 can be found in the
Remedial Investigation Report in Subsections 8.1, 12.1, and 13.1 (E.C. Jordan Co.,
1990a). .
B. ENFORCEMENT HISTORY
Tbe Navy's cleanup of hazardous wastes at NAS Brunswick falls under the Navy's
Installation Restoration Program (IRP) and meets the requirements of the
Comprehensive Environmental Response, Compensation and liability Act and the
Superfund Amendments and Reauthorization Act (CERCLA). The program was
conducted in several stages:
.
In 1983, an Initial Assessment Study (!AS) detailed historical
hazardous material usage and waste disposal practices af NAS
Brunswick.
.
In 1984, a Pollution Abatement Confirmation Study was conducted.
These studies recommended further investigation of seven of the nine
hazardous waste sites originally identified.
In 1987, NAS Brunswick 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 began
in 1987 for seven sites. .
.
In February 1988, the first Technical Review Committee (TRC)
meeting was held. The TRC meetings have been held quarterly since
that initial meeting.
.
Two sites were added to the RI/FS program in 1989, as well as the
two additional sites originally identified in the IAS.
.
Two other sites were added to the program in 1990. Currently, the
Navy is studying 13 sites under the IRP.
.
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
contamination at NAS Brunswick. Tbe FF A sets forth the roles and
responsibilities of each agency, contains deadlines for the investigation
and cleanup of hazardous waste sites, and establishes a mechanism to
resolve disputes among the agencies.
.
In August 1990, the Navy completed Draft Final RI and Phase I FS
Reports (E.C. Jordan Co., 1990a and 1990b). The RI described field
sampling investigations, geology, and hydrogeology, and presented
contamination and risk assessments. The Phase I FS identified
remedial action objectives, and developed and screened remedial
alternatives for the nine original sites studied in the Draft Final RI.
.
The Navy submitted Draft Final Supplemental RI and FS reports for
an additional four sites in August and July of 1991, respectively. Tbe
Draft Final Supplemental RI also contained additional field sampling
results for Site 11 and the Eastern Plume.
Each of the stages and documents listed above pertain to Sites 4, 11, and 13 and the
Eastern Plume. Information on many of the other sites at NAS Brunswick is also
included in these reports.
Because the Navy is committed to providing a timely response to environmental
contamination at NAS Brunswick, a strategy was developed to expedite the RI/FS .
process. This strategy involves identifying the sites for which enough information
currently 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
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these sites. Tbe Navy has identified Sites 1 and 3, and the groundwater associated
with Sites 4, 11, and 13 (i.e., the Eastern Plume) as distinct areas of contamination
and believes the remedial process can be initiated. Focused Feasibility Studies 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 submltted to the regulatory agencies for review (E.c. Jordan Co..,
1991b, 1992a, and 1992b).
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III. COMMUNI1Y PARTICIPATION
Throughout the site's history, the community has been active and involved. The Navy
has kept the community and other ~1}terested parties abreast of site activities through
informational meetings, 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 placed the Proposed Plan for the Eastern Plume in the
information repository at the Curtis Memorial Library. The Administrative Record
for the Eastern Plume 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 is made up of Navy, USEP A, MEDEP, and various
community representatives. 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 TRC also has representatives
from the Brunswick-Topsham Water District. The TRC 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 outlining a .
program to address community 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, Maine, to discuss the results of the
RI.
On December 12, 1991, the Navy held an informational meeting to discuss the results
of the RI and the Navy's Proposed Plan for the interim remedial action for the
Eastern Plume. During this meeting, the Navy, its consultants, and regulatory
representatives answered questions from the public and accepted formal comments.
From December 6, 1991, through January 24, 1992, a public comment period was
held to accept public comments regarding the proposed interim action for the
.Eastern Plume, and on any other documents previously made public. The public
comments and the responses to the comments. are included in Appendix B,
Responsiveness Snmmary. .
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IV. SCOPE AND ROLE OF OPERABLE UNIT
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An interim remedial action for the groundwater operable unit for Sites 4, 11, and 13,
referred to as the Eastern Plume, was developed to control and prevent further
migration of contaminated groundwater off the NAS Brunswick property and into
Harpswell Cove and to begin to reduce the concentration of contaminants in the
groundwater until a final remedy can be chosen. The interim remedial action is not
intended to be a final remedy but should be consistent with the final remedy that is
chosen. This management of migration option is also part of the remedial
alternatives being evaluated in the FS, and will be consistent with the final remedy
chosen for the Eastern Plume and Sites 4, 11, and 13. Tbe final ROD, which
includes the Eastern Plume, may be based in part on the data collected during the
design, operation, and monitoring of the interim remedy. Additional interim
remedial action(s) may be proposed if data collected before the final ROD warrants
such actions.
The interim remedy manages migration of the Eastern Plume by extracting, treating,
and discharging contaminated groundwater from the Eastern Plume. Extraction wells
will be installed to pump contaminated groundwater from the subsurface where it will
be piped to a treatment plant. Tbe water will be treated using oxidation/filtration
and ultraviolet (UV) light/oxidation and discharged to the public sewer system for
. conveyance to the local publicly owned treatment works (p01W). Discharge to the
POTW is the preferred discharge option but has not yet been approved. This
remedial action will hydraulically contain the Eastern Plume and prevent future
discharge of contaminated groundwater to Harpswell Cove. It is also anticipated that
groundwater from Sites 1 and 3 will be treated together with groundwater from the
Eastern Plume. Sites 1 and 3 are being addressed in a separate ROD.
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V. SUMMARY OF SITE CHARACI'ERISTICS
A focused field investigation of groundwater contamination associated with Sites 4,
11, and 13 (i.e., the Eastern Plume) was conducted as part of the Post-Screening
Work Plan between August and November of 1990. This program was developed to
supplement existing information at these sites and presented in the Draft Final RI
Report (E.C. Jordan Co., 1990a). The Post-Screening Field Program consisted of a
piezometric cone penetrometer sUlVey, installation of monitoring wells, aquifer
permeability testing, and groundwater sampling and analysis. The results of the field
investigation are presented in the Draft Final Supplemental RI Report (E.C. Jordan
Co., 1991a). The specific objectives of the Eastern Plume field program include:
.
characterize the hydrogeologic regime, including the geologic deposits
underlying the study area, the direction arid rate of groundwater flow,
and possible discharge to Mere Brook, and Harpswell Cove;
.
assess the nature, distribution, and migration of contaminants in
shallow and bedrock aquifers; .
.
assess the degree to which future migration of contamiml11ts may pose
a threat to public health, welfare, and the environment; and
.
obtain groundwater quality data to assess the applicability of
groundwater treatment technologies for the FS.
The information obtained from the field investigation is summarized in the following
sections.
A. GROUNDWATER FLow AND SUBSURFACE GEOLOGY
Groundwater in the Eastern Plume occurs in the overburden. soil and bedrock
formations. The overburden soil at NAS Brunswick is a stratified formation
consisting of a sand layer, a transition layer, and a clay layer. The transition layer
is made up of interbedded silt, sand, and a clay layer. The sand, transition, and clay
soil layers are all part of the Presumpscot Formation, which was deposited during the
late glacial marine submergence of southern Maine. The variability of soil types in
-~the Presumpscot Formation was caused by the glacial retreat and sea level changes
that occurred when the soils were depOsited. Tbe saturated thickness of the
Presumpscot Formation, or thickness of the overburden saturated with groundwater,
varies from 10 to 90 feet across the Eastern Plume area, and generally spans the sand
and transition layers.
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RI data (E.C Jordan Co., 1991a) indicate tbat groundwater flows radially from
Site 11 to the northeast, east, and southeast, and flows southeast from Sites 4 and 13
(Figures 3 and 4). Sballow groundwater from Sites 4, 11, and 13 flows toward and
discbarges to Mere Brook and its tributaries (see Figure 3). The deep groundwater
. flows in a more soutberly direction (see Figure 4), and is largely constraind by the
presence of sand lenses at deptb and tbe eastern limb of the clay trough. The clay
trougb observed at tbe site is influenced by an observed bedrock trougb also
interpreted to exist at tbe site. Figure 5 sbows a scbematiC representation of a
typical west-to-east cross section of the trough south of New Gurnet Road. Bedrock
along tbe eastern boundary of the base forms tbe eastern limb of a trough. The
bedrock trougb is also bounded by a bedrock higb to tbe west (see Figure 5). The
clay layer of the Presumpscot Formation lies on top of the bedrock and a deep sand
layer occurs below tbe transition sediments and above tbe clay.
Figure 6 sbows a scbematic nortb-to-soutb profile illustrating bow the geologic
formation influences deep groundwater flow. The deep sand layer within the trough
acts to channel groundwater (and contaminant) flow to the south, because the sandy
zones are more permeable than tbe more silty layers of tbe formation above and
below tbe deep sand layer, whicb may act as a preferred path for groundwater and
contaminant movement witbin tbe aquifer (see Figure 6). Groundwater does not
flow througb the clay layer on top of bedrock due to the clay's low permeability;
bowever, groundwater does flow in tbe fractures and joints of the bedrock (E.C
Jordan Co., 1991a).
The groundwater flow system located within tbe Eastern Plume area is interpreted
to discbarge to the upper portions of tbe Harpswell Cove watersbed area, based on
data presented in the Draft Final Supplemental RI Report (E.C Jordan Co., 1991a),
and sbown in Figures 8-14 and 8-18 of that report. Based on groundwater surface
contour maps, bydraulic conductivity data, current groundwater cbemical data, and
bydraulic gradients, the soutbern edge of tbe Eastern Plume is interpreted to
discbarge to the Harpswell Cove area in approximately five years.
B. GROUNDWATER QUALm'
. -Groundwater contamination is encountered in deep, sand-rich zones above the cl~y
layer, and in shallow groundwater near the source areas. Shallow groundwater away
--::from the source area where it discharges to Mere Brook is not a>ntamin~ted.
Groundwater contamin~tion has not been detected east of the eastern boundary of
the base, or in water samples collected from monitoring wells in the bedrock aquife.r
(E.C. Jordan Co., 1991b). .
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FIGURE 3
SHALLOW GROUNDWATER FLOW.
EASTERN PLUME AREA
18
POOR QUALITY
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-....... ME_TIVE -- II!:..:...=., ':::1 ~r ~ V ~ --
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FlOW o.I£CTIOII f. 1-,,"'" (. /'\ - -
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K~ < r« DEEP GROUNDWATER FLOW -
. i .ie ... EASTERN PLUME AREA
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INTERPRETIVE GROUNDWATER FLOW DIRECTION
INTERPRETIVE GROUNDWATER LEVEL
SAND
TRANSITION
BEDROCK
FIGURE 5
SCHEMATIC EAST-WEST CROSS SECTION OF
GEOLOGY OF EASTERN PLUME
ClAY
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INTERPRETIVE GROUNDWATER FLOW DIRECTION
INTERPRETIVE GROUNDWATER LEVEL
SAND
TRANSITION
CLAY
FIGURE 6
SCHEMATIC NORTH-SOUTH CROSS SECTION OF
GEOLOGY OF EASTERN PLUME
BEDROCK
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Data indicate tbat TCA is tbe most prevalent contaminant in tbe Eastern Plume,
although other VOCs (i.e., tetrachloroethylene, TCE, l,l-dichloroethylene [l,l-DCE],
1,2-dichloroetbylene [1,2-DCE], and l,l-dicbloroetbane [1, I-DCA]) were also
detected (E.c. Jordan Co., 1991a). Tbe highest concentrations of several compounds
detected in tbe Eastern Plume exceed tbe Maximum Contaminant Levels (MCLs)
establisbed by the USEPA under the 1986 Federal Safe Drinking Water Act and the
Maximum Exposure Guidelines (MEGs) outlined in tbe Maine Drinking Water
Rules. A summary of tbese groundwater data are presented in Table 1.
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A complete discussion of site cbaracteristics can be found in tbe Draft Final
Supplemental RI Report in Section 8.0 (E.C. Jordan Co., 1991a).
C. KNOWN OR POTENTIAL ROUTES OF MIGRATION OF CONTAMINATION
Sballow groundwater contamination is present in tbe vicinity of tbe source areas of
Sites 4, 11, and 13 and downgradient of Sites 4 and 13. Altbougb tbe higbest levels
of groundwater contamination generally occur in tbe nortbwestern portions of tbe
Eastern Plume, contamination observed in the remaining portions of tbe Eastern
Plume area occurs witb a deep, sand-ricb layer located within tbe transition zone.
Therefore, contaminated groundwater flowing from the source areas initially flows
southeast, and wben it becomes entrained in tbe deeper portions of the aquifer, a
more southerly flow occurs. The ultimate entrainment of groundwater contaminants
in tbe deep groundwater (located within sand-ricb strata) is further empbasized by
the lack of sballow groundwater contamination in tbe downgradient portion of the
plume. The contaminant migration pathway for groundwater contamination at the
Eastern Plume site is generally within a deep sand-rich strata and it is within this unit
tbat VOCs will migrate to tbe Harpswell Cove watershed.
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TABLE 1
VOC CONTAMINANT CONCENTRATIONS
ROD: EASTERN PLUME
NAS BRUNSWICK
CONSTITUENT
TCA
TCE
PCE
1,1.DCE
1,2-DCE
1,1-DCA
RANGE OF CONCENTRATIONS DETECTED
SHALLOW OFF-
WELLS DEEP WELLS . SITE
MCL MEG (NEAR SoURCE) (DOWNGRADIENT) WELLS
200 200 13 - 1200 11 - 2300 ND
5 5 5.770 6.-1200 ND
5 5 ND - 42 ND-9 ND
7 7 ND-6 ND - 110 ND
70/100(1) 70/100(1) 63 - 680(2) ND . 98(2) ND
NA NA ND - 130 ND - 170 ND
No_:
(1)
(2)
ND
MCL
MEG
TCA
TCE
PCE
DCE
DCA
NA
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Total 1,2-DCE
Not Detected
Maximum Contaminant Level (Federal Safe Drinking Water Act)
Maximum Exposure Guideline (State of Maine Drinking Water Rules)
trichloroethane
trichloroethytene
tetrachloroethytene
dichloroethytene
dichloroethane
not available
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VI. SUMMARY OF SITE RISKS
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A risk evaluation estimated the potential for adverse human health effects from
exposure to contaminants associated with the Eastern Plume. The potential risks
were quali.'itively evaluated and determined based on a comparison of the
concentration of each contaminant detected at least once in groundwater to federal
MCL and Maine MEG concentrations. MCLs and MEGs represent contaminant
concentrations in water considered to be acceptable to human exposure. Therefore,
those contaminants detected above their respective standard and criteria values were
considered to present a potential risk to human health.
The risk evaluation identified several contaminants in the Eastern Plume at
concentrations exceeding their respective MCLs. The MCLs are promulgated federal
drinking water standards and the Maine MEGs are established guidance levels. The
federal MCL and state MEG values are the same for the contaminants of concern
in the Eastern Plume (Table 2). There is currently no risk of exposure to the
Eastern Plume groundwater; it is not currently used as a water supply on base, and
the plume has not been found to affect off-base private drinking water wells. If, in
the future, residents were to use the groundwater within the Eastern Plume as a
drinking water supply, that usage could pose long-term risks to human health. The
Eastern Plume is not currently discharging to Harpswell Cove; however, if
contaminated groundwater were allowed to flow into Harpswell Cove, there would
be potential for adverse ecological effects.
Actual or threatened releases of hazardous substances from the Eastern Plume, if not
addressed by implementing the response action selected in this ROD, may present
an imminent and substantial endangerment to human health, welfare, or the
environment. The interim action for hydraulic containment and recovery of
groundwater will prevent future migration and reduce contamin:mt concentrations in
groundwater from the Eastern Plume.
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TABLE 2
LIST OF CONTAMINANTS OF CONCERN
ROD: EASTERN PLUME
HAS BRUNSWICK
MAXIMUM MCL MEG
CONTAMINANT CONCENTRATION CP9/L) .
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VII. DEVEWPMENT AND SCREENING OF ALTERNATIVES
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A. STATUTORY REQUIREMENTS/RESPONSE OBJECI1VES
The primary goal at NPL and similar sites is to undertake remedial actions that are
protective of human health and the environment. Sections 120 and 121 of CERCIA
establish several statutory requirements and preferences, including: a requirement
that the remedial action, when' complete, must comply with all federal and more
stringent state environmental standards, requirements, criteria or limitations, unless
a waiver is invoked; a requirement that the remedial action is cost-effective and 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 toxicity, mobility, or
volume of hazardous substances as a principal element over remedies not involving
such treatment. Response alternatives were developed to be consistent with these
congressional mandates.
Based on types of contaminants, environmental media of concern, and potential
exposure pathways, remedial action objectives were developed to mitigate existing
and future potential threats to human health and the environment. These response
objectives were:
3.
To minim;7.e further migration of the Eastern Plume.
To m;n;m;7.e any future negative impact to the Harpswell Cove estuary
resulting from discharge of contaminated groundwater.
To reduce the potential risk associated with ingestion of contaminated
groundwater to acceptable levels.
To reduce the time required for restoration of the aquifer.
1.
2.
4.
B. TECHNOLOGY AND ALTERNATIVE DEVELOPMENT AND SCREENING
Because the actions described in this ROD are for an interim remedial action,
development and screening of remedial action alternatives was not conducted. A
single alternative to address the Eastern Plume on an interim basis was developed.
The Navy's selection of the interim remedial action is the result of a comprehensive
. ~uation of djfferent groundwater treatment options. The Draft FS for the site was
conducted to identify and analyze the alternatives. considered for addressing both
source and groundwater contamination. The FS report describes and evaluates five
alternatives: an alternative that offers no action; an alternative that only considers
groundwater extraction and treatment; and three alternatives that each evafuate a
different source control option in conjunction with groundwater treatment For each
treatment alternative, the groundwater extraction and treatment strategy is the same.
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The interim remedial action is consistent with the alternatives developed and
screened in the FS for the final site remedy, and it provides a timely response to
contamination in the Eastern Plume until a final remedy can be chosen.
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VIII. DESCRIPTION OF ALTERNATIVE
This section summarizes the interim remedial action developed and evaluated for the
. Eastern Plume. The proposed interim remedial action COL.,ists of extraction,
treatment, and discharge of treated groundwater. The extraction system will consist
of groundwater extraction wells that will hydraulically contain the plume and reduce
contamination throughout the plume. A monitoring program will be developed to
ensure that the interim remedial action obtains hydraulic capture of the Eastern
Plume. Changes to the interim remedial action would be made if the monitoring
results determine that the interim remedial action does not achieve hydraulic capture
of the plume.
Extracted groundwater will first be treated to remove iron and manganese. H iron
and manganese are not removed, they will interfere with the VOC treatment
processes. The VOC treatment technology proposed for the interim action is
UV / oxidation. The effluent will be sampled to ensure that the water meets
appropriate discharge requirements.
Discharge of the treated water will be through a new sewer connection from the on-
site treatment building to the public sewer system for conveyance to the local POTW.
Final treatment and disposal will occur at the POTW. A discharge permit will be
required from the Brunswick POTW that will outline specific discharge limitations.
The Brunswick POTW has not yet agreed to accept treated groundwater from the
Eastern Plume. H they do not accept the treated groundwater, an alternative
discharge option (e.g., surface water, groundwater, or the storm sewer system) will
be used.
Estimated Time For Design and Construction: 2 years 5 months
Estimated Time for Operation: 5 years
Estimated Capital Cost: $1,223,000
Estimated Operation and Maintenance Cost (net present worth):
Estimated Total Cost (net present worth): $4,223,000.
$1,845,000.
*Net present.worth costs ar~ based on a 10 percent discount factor and five years of
-()peration.
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IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 121(b)(1) of CERCLA presents several factors that at a minimum must be
considered in the assessment of alternatives. Building upon these specific s.atutory
mandates the National Contingency Plan articulates nine evaluation criteria to be
used in assessing the individual remedial alternatives.
For a final remedy, several alternatives are usually developed and evaluated for a site
or operable unit. Because this ROD is for an interim remedial action, only one
alternative was developed and its evaluation with respect to the nine criteria is
presented below. A full range of alternatives for Sites 4, 11, and 13 which contribute
to the Eastern Plume was developed in the FS and will be presented in the final
ROD for the final remedy.
A. OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Overall Protection of Human Health and the Environment addresses how an
alternative as a whole will protect human health and the environment This includes
an assessment of how human health and environmental risks are properly eliminated, .
reduced, or controlled through treatment, engineering controls; or institutional
controls.
Tbe interim remedial action for addressing groundwater contamination will provide
overall protection of human health and the environment. Protection is provided by
containment of the plume to prevent the migration of contaminated groundwater to
currently uncontaminated areas, and by permanent reduction of contaminant
concentrations in the water through treatment and off-site disposal of the sludge
produced by metals pretreatment.
B. COMPLIANCE WITH APPUCABLE OR RELEvANT AND APPROPRIATE REQUIREMENTS
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
addresses whether or not a remedy complies with all state and federal environmental
and public health laws and/or provides grounds for invoking a waiver. For interim ::..
.-actions, it is appropriate to analyze compliance with only those Jaws and regulatio~:.?
that are applicable or relevant and appropriate to the limited scope of the~. .
.action. However, the interim remedial action proposed for the Eastern Plume Wlll.
be designed to meet action- and chemical-specific ARARs for the discharge ot
treated groundwater and disposal of sludge resulting from the pretreatment process.
All location-specific ARARs will also be met In addition, the interim remedial
action proposed for the Eastern Plume will be designed to treat the water to MCLs
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so that this interim action will be consistent with the groundwater component of the
final site remedy.
c. LoNG-TERM EFFECl'IVENESS AND PERMANENCE
Long-term Effectiveness and Permanence refers to the ability of an alternative to
maintain reliable protection of human health and the enviroriment over time once
cleanup goals are met.
The interim remedial action is expected to meet the cleanup objectives by preventing
migration of the plume and by removing and treating the water. Residual risk will
remain because the source of contamination would not be remediated by the interim
remedial action. The final remedy for the site may contain a source control
component to expedite groundwater treatment.
D. REDUcnON OF TOXlCI1Y, MOBILI1Y, OR VOLUME THROUGH TREATMENT
Reduction of Toxicity, Mobility, or Volume Through Treatment are three principal
measures of the overall performance of an alternative. The 1986 amendments to the-
Superfund statute emphasize that, whenever possible, the USEPA should select a
remedy that uses a treatment process to permanently reduce the level of toxicity of
contaminants at a site, the spread of contaminants away from the source of
contamination, and the volume or amount of contamination at a site.
The purpose of the interim groundwater extraction and treatment for the Eastern
Plume is to prevent the funher migration of contaminants. Preventing the spread of
contaminants by pumping to contain the plume may reduce the volume of
contaminated groundwater. The plume will be contained by controlling migration
with extraction wells. Extraction wells will also be placed in the northern portion of
the plume to reduce groundwater contaminant levels. These wells are included to
help make the interim action consistent with the final remedy for the site and begin
to reduce the overall level of contamination of the Eastern Plume. These wells will
be located at the deepest points of the Eastern Plume. Groundwater from the
extraction wells will be treated using UV /oxidation. Treating the extracted water will
..permanently and significantly reduce the toxicity and mobility of contaminants in the
-extracted water.
E. SHO~~RM EFFEc11VENESS
Short-term Effectiveness refers to the likelihood of adverse impacts on human health
or the environment that may be posed during the construction and implementation
of an alternative until cleanup goals are achieved.
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The community and the environment are not expected to be adversely affected
during implementation of this action. Workers installing the groundwater extraction
system and treatment plant operators will wear protective. clothing, follow
appropriate safety procedures to minimize the chance of exposure to contaminants
as outlined in a site-specific health and safety plan, and meet Occupational Safety
and Health Act (OSHA) training requirements.
F. IMPLEMENTABILI1Y
Implementability refers to the technical and administrative feasibility of an
alternative, including the availability of materials and services needed to implement
the alternative. The extraction and treatment technologies proposed for the interim
action are implementable and have been successfully demonstrated at other sites.
The preferred option of discharging treated water to the POTW must be approved
by the Brunswick Sewer District before it can be implemented. H the application for
discharge to the POTW is not approved, another discharge option would be required.
Other discharge options include recycling the water back into the aquifer by
upgradient recharge or discharge to surface water on base.
G. COST
Cost includes the capital (up-front) cost of implementing an alternative as well as the
cost of operating and maintaining the alternative over a five-year period, and net
present worth of both capital and operation and maintenance costs. The capital,
operation and maintenance, and total cost of the interim action are presented in
Section VIII of this ROD.
H. STATE ACCEYfANCE
State Acceptance addresses whether, based on its review of the RIfFS and Proposed
Plan, the state concurs with, opposes, or has no comment on the alternative the Navy
proposes for the interim action.
As a party to the FF A, the State of Maine has provided comments on the proposed
plan and has doannented its concurrence with the interim remedial action as stated
in Section xm of this ROD. A copy of the letter of concurrence is presented in
-; Appendix C of this ROD. .
I. COMMUNm' ACCEYfANCE
Community Acceptance addresses whether the' public concurs with the Navy's
Proposed Plan. Community acceptance of the Proposed Plan was evaluated based
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on comments received at the public meetings and during the public comment period.
This is documented in the Responsiveness Summary presented in Appendix B of this
ROD.
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x. THE SELEcrED REMEDY
The interim action for the Eastern Plume addresses only the management of
migration of contaminants in groundwater. The action does not address the source
of contamination, and a final remedy for groundwater that will be presented upon
completion of the FS.
A. CLEANUP LEVELS
Cleanup levels have been established for contaminants of concern identified in the
risk evaluation. Oeanup levels have been set equivalent to the appropriate ARARs
(e.g., drinking water Maximum Contaminant Levels Goals and MCLs) if available.
In the absence of a chemical-specific ARAR, or other suitable criteria to be
considered, a concentration corresponding to a 10-6 excess cancer risk level for
carcinogenic effects or a Hazard Quotient of 1.0 for noncarcinogenic effects was used
to set cleanup levels. Periodic assessments of the protection afforded by remedial
actions will be made as the remedy is being implemented and until a final remedy
is chosen to replace the interim action.
Table 3 summarizes the cleanup levels derived based on carcinogenic and
noncarcinogenic effects for the contaminants of concern identified in groundwater.
These cleanup levels are consistent with ARARs for groundwater and attain
USEP A's risk management goal for remedial actions (carcinogenic risk level between
10-4 and 10-6).
B. DESCRIPTION OF REMEDIAL COMPONENTS
The interim remedial action consists of extraction, treatment, and discharge of
treated groundwater with groundwater and effiuent monitoring. Tbe extraction
system would be constructed within the plume to maximize the collection of
contaminated groundwater. Groundwater extraction wells will contain the southern
end of the plume and collect contaminated water from the northern part of the
plume (Figure 7). A minimum of one well would be placed at the southern end of
the plume to prevent cont~min~ted groundwater from migrating further. Additional
..extraction wells would be placed in the deepest parts of the aquifer to ensure that
. cont~mination in the deep sands is collected. The actual number of wells, pumping
rates, and configuration of the extraction well network will be determined during the
remedial design. Monitoring wells will be sampled during the interim remedial
action to confirm the capture of contaminated groundwater. Additional monitoring
wells may be installed to supplement the existing monitoring well network.
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TABLE 3
TARGET CLEANUP lEVELS
ROD: EASTERN PLUME
NAS BRUNSWICK
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TARGET
MAXIMUM CLEANUP
CONCENTRATION MCL MEG lEvEL RESIDUAL
CONTAMINANT (pg/L) (pg/L) (pg/L) (pg/L) RISK(31
1,1-DCE 110 7 7 7 5X10.s(c)
1,1-DCA 170 N/A N/A 3,SOOC2} 0.9 (nc)
cis-1,2-DCE 680C1} 70 70 70 0.2 (nc)
trans-1,2-DCE C1} 0.1 (nc)
100 100 100
1,1,1-TCA 2,300 200 200 200 0.06 (nc)
PCE 42 5 5 5 3x1 O~(c)
TCE 1,200 5 5 5 6x10'7(C)
Notes:
MCL
MEG
N/A
I19/L
DCA
DCE
PCE
TCA
TCE
(1)
(2)
(3)
Maximum Contaminant Level (Federal Safe Drinking Water Act)
Maximum Exposure Guideline (State of Maine Drinking Water Rules)
Not Available
micrograms per liter
dichloroethane
dichloroethylene
tetrachloroethylene
'trichloroethane
trichloroethylene
1,2-DCE was reported by the laboratory as total Q.e., there was no distinction between the cis- and
trans-isomer).
The Target Cleanup Level for 1,1-DCA is based on attaining the Reference Dose (RfD) of
0.1 mg/kg-day and assumes a 70 kg adult ingests 2 liters 01 water per day.
(c) indicates carcinogenic compound (nc) indicates noncarcinogenic compound
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LEGEND
LOCATION QF
... PI=IOPOSED
EXTRACTION
WEU.
~ EXTENT OF VOC
IJ CONTAMINATION
~
WATER TREATMENT PROCESS
ULTIIA'IIOUTI
_DATION
&II .A'IIR
DI$I;IWIGi
TO SIW5A
SCALE IN FEET
I ,
o 400
1136-43/9107005D
FIGURE 7
EXTRACTION WELLS
WATER TREATMENT PLANT
LOCATION AND PROCESS
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A monitoring program will be developed during the design of the interim remedial
action and submitted for regulatory approval. This monitoring program will specify
the number and location of wells to be sampled, the frequency of sampling, and the
compounds to be analyzed. The monitoring program will be developed to ensure
that the interim remedial acuon is obtaining hydraulic containment of the Eastern
Plume. Changes to the interim remedial actions would be made if indicated by the
monitoring results.
Contaminated groundwater from base landfills (Sites 1 and 3) will be pumped to the
groundwater treatment system for the Eastern Plume and treated concurrently for
VOC contamination (see Figure 7). A separate proposed remedial action program
has been prepared for Sites 1 and 3. 1bis scenario is considered feasible because of
the similar contaminants, the low flow "rate of groundwater from Sites 1 and 3, and
the short duration (estimated to be 370 days based on the containment alternative
proposed as the preferred alternative) required to pump and treat the groundwater
from Sites 1 and 3. A groundwater flow model will be developed to address the
potential effects {)f pumping groundwater at both Sites 1 and 3 and the Eastern
Plume. This modeling effort will be conducted to support the design of the remedial
actions selected for both the Eastern Plume interim action and the Sites 1 and 3
remedial action.
Several groundwater treatment options to reduce VOC con~mination in the Eastern
Plume were considered. The greatest consideration was given to air stripping with
vapor phase carbon (VPC) off-gas treatment and UV joxidation. Both technologies
are effective in treating VOCs. However, because the groundwater from Sites 1 and
3 contains components that are not effectively removed using air stripping and VPC
(i.e., methylene chloride and vinyl chloride), UV joxidation is the preferred
groundwater treatment option for this interim remedial action. A schematic flow
diagram for water treatment is presented in Figure 7.
The proposed treatment process includes removal of metals and VOCS from the
water. Before VOC treatment, dissolved metals in the groundwater (i.e., iron and
manganese) would be removed using a filtration process. The pretreatment process
is conducted to remove metals from the groundwater that may interfere with the
VOC treatment. In this process, a chemical would be. added to precipitate the
groundwater by passing the w;iter through sand filters.. The. filters would. be
backwashed periodically to prevent clogging. The solid material cleaned from the .
filters would be pressed to remove excess water and then shipped to a hazardous
waste disposal facility if determined to be hazardous, or to an off-site waste landfill
if determined to be nonhazardous. The water extracted from the solids would be
cycled ~ough the on-site groundwater treatment system.
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UV /oxidation destroys organic compounds in water by exposing them to a chemical
oxidant. (e.g., hydrogen peroxide) in the presence of UV light. Tbe contaminated
groundwater would be mixed with the oxidant and pumped into a reactor (or series
of reactors) where water would be exposed to UV light. The combined effects of
UV light and the oxidant promote rapid breakdown of organic molecules. In the
oxidation process, organic contamimmts are broken down into simpler, nonhazardous
substances such "as carbon dioxide, water, salts, acetone, sulfates, nitrates, and organic
and inorganic acids. Some of these by-products have discharge requirements (e.g.,
acetone, sulfates, nitrates) that would need to be met. The effluent would be
sampled to ensure that the water meets appropriate discharge requirements.
A treatability study would be conducted before the final design of the VOC
treatment system to determine the appropriate oxidant and concentration necessary
to destroy the VOCs. In addition, this study would provide information on the
compounds and concentrations likely to be present as by-products in the efflueut.
The treatability study would also evaluate metals pretreatment and sludge
characteristics so that suitable disposal options can be evaluated in the design phase.
Several options were evaluated for discharge of treated water:
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surface water (e.g., Mere Brook)
groundwater (e.g., infiltration)
Brunswick Sewer District's POTW
Town of Brunswick 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 would need to obtain
permission from the Brunswick Sewer District to di~charge treated effluent to the
system. The POTW's NPDES permit does not currently have pretreatment standards
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 s.tandards then become
effluent limits on the user, in this case NAS Brunswick. These standards would be
developed by the POTW to ensure that the POTW remains in compliance with its
NPDES permit and sludge use and disposal practices. Regulations .for land
~;~lic:ation of sludge have been set for the metals cadmium, chromium, copper, lead,
mercury, nickel, and zinc for both maximum permissible concentrations and
m~Yimum loading limits (on a kilogram/hectare basis). A JTI~Yim11m permissible
concentration level has also been set for PCBs.
The additional flow from the treatment plant would not" cause the POTW to exceed
its capacity. The design flow rate for the POTW is 3.85 million gallons per day
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(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
currently metered, and there would be a fee for the increased flow.
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Some variations to the components described may be necessary during the design and
as a result of groundwater flow modeling, treatability studies, and discharge
requirements. The purpose of the interim remedial action is to initiate an early
response action for the Eastern Plume. The Navy, the USEP A, and the MEDEP will
review the collected monitoring data and reevaluate the effectiveness of the interim
action. If the interim action is deemed effective and meets the requirements of the
final ROD for Sites 4, 11, and 13, the interim action could become part of the overall
remedy. If modifications need to be made to the collection or treatment systems to
meet the requirements of the final ROD, those modifications would be incorporated
into the final ROD for Sites 4, 11, and 13.
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XI. STATUTORY DETERMINATIONS
The interim remedial action selected for implementation at NAS Brunswick for the
Eastern Plume is consistent with CERCLA and, to the extent practicable, the
National Contingency Plan. The selected interim remedy is prut,ective of human
health and the environment, attains ARARs for the limited scope of the action, and
is cost-effective. The selected interim 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
interim remedy uses alternate treatment technologies or resource recovery
technologies to the maximum extent practicable.
A.
THE SELECl'ED INTERIM REMEDY IS PROTECI1VE OF HUMAN HEALTH AND
THE ENVIRONMENT
The interim remedy at this site will permanently reduce the risks posed to human
health and the environment by eliminating, reducing, or controlling exposures to
human and environmental receptors through treatment; more specifically, protection
is provided by containment of the plume to prevent the migration of contaminated
groundwater to currently uncontaminated areas, and by permanent reduction of
contaminant concentrations in the water through treatment and off-site disposal of
the sludge produced by metals pretreatment. The selected remedy will treat
extracted groundwater to levels that are protective of human health, posing human
health risks that are witlrin the lQ-4 to l~ incremental cancer risk range and that are
within the Hazard Quotient of 1.0 for noncarcinogens. Finally, implementation of
the interim action will not pose unacceptable short-term risks or cross-media impacts;
there will be little danger to workers or the community during treatment and the
contaminants removed will be destroyed.
B. THE SELECl'ED INTERIM REMEDY ATIAINS ARARS
This remedy will attain all applicable or relevant and appropriate federal and state
requirements that apply to this limited scope interim action. Generally, ARARs for
the selected interim remedial action are a subset of those found in Tables 2-1, 2-2,
and 2-4 of Section 2.0 of the FS (E.e. Jordan Co., 1992a). Because the FS
-considered permanent remedial alternatives and the remedy selected is an interim
,remedy~ some of the ARARs outlined in the FS do not apply to this interim action.
ARARs that do apply to this interim action are listed in Appendix A and are
discussed below.
When considering interim remedies, it is appropriate to analyze compliance only with
those laws and regulations that are applicable, or relevant and appropriate, to the
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limited scope of this interim action. The selected interim remedy would meet the
following federal and state ARARs for the treatment of groundwater, discharge of
the treated water, and disposal of treatment process sludges:
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Chemical-specific ARARs
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Safe Drinking Water Act (SDWA) - MCLs and non-zero MCLGs
.
Resource Conservation and Recovery Act (RCRA) - MCLs
.
Maine Drinking Water Rules
.
Clean Water Act (CWA) - Ambient Water Quality Criteria (AWQC)
.
Maine Regulations Relating to Water Quality Criteria for Toxic
Pollutants
The following chemical-specific policies, criteria, and guidelines were also considered:
.
Maine Department of Human Services Rule lO-144A, CMR
Chapter 233 - Maximum Exposure Guidelines (MEGs)
USEP A Risk Reference Doses (RIDs)
.
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USEP A Human Health Assessment Group Cancer Slope Factors
(CSFs)
Location-specific ARARs
.
Maine Natural Resources Protection Act
.
Natural Resources Protection Act
.
Maine Standards for Oassification of Minor Drainages
.
Maine Standards for Oassification of Groundwater
.
., Maine Site Location Development L8.w and Regulations
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Resource Conservation and Recovery Act (RCRA) - General Facility
Standards
.
RCRA - Preparedness and Prevention
.
RCRA - Contingency Plan and Emergency Procedures
.
RCRA - Miscellaneous Units
.
Maine Hazardous Waste Management Rules
.
Occupational Safety and Health Administration (OSHA) - General
Industry Standards
.
OSHA - Safety and Health Regulations
.
OSHA - Recordkeeping, Reporting, and Related Regulations
.
Clean Water Act (CWA) - Pretreatment Standards for POTW
Discharge
.
CW A - National Pollutant Discharge Elimination System (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
The following policies, aiteria, and guidelines (Le., TBCs) will also be considered
during the implementation of the remedial action: .
.
.
MEDEP, Bureau of Water Quality Control, Policy NUIIiber 10: "The
Discharge of Hazardous Substances to Groundwater of the State"
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Federal and State Drinking Water Regulations. Tbe chemical-specific ARARs
identified for the Eastern Plume can be applied to the interim remedy in two
manners. In the instance of drinking water standards, MCls and other guidance and
criteria to be considered (TBCs) were used in the development of target cJeanup
levels for the remediation of groundwater at the site. Drinking water standards 1!lay
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. Tbe
quality and safety of drinking water sources is regulated by the SDW A 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 appropriate because, while the
groundwater on and off site is not currently used as a drinking water source, the
groundwater underlying NAS Brunswick potentially could be used as a drinking water
source in the future. .
Target cleanup levels for groundwater within the Eastern Plume were developed
based on results of the baseline risk assessment. Federal and state MCLs were the
first order of standards used in establishing cleanup levels. For those contaminants
for which no MCLs were available, other criteria and guidelines (Le., TBCs) were
used. TBCs used during the risk assessment and in establishing cleanup levels
included Maine MEGs, USEP A RIDs, and USEP A CSFs.
The objective of the interim remedial action is to prevent further migration of the
Eastern Plume. As an interim action, not all ARARs will be attained. Attainment
of groundwater standards and risk-based target cleanup levels will be addressed as
part of the ROD for the final site remedy.
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 interim remedy depending on the
choice of discharge option. The interim remedy considers three options for discharge
of treated groundwater. The Navy's preferred option is discharge of treated water
to the Brunswick POTW. Under this option, discharge limits would be based on
factors regulated by the P01W's NPDES permit, pretreatment regulations, and water
pollution control laws, which will be discussed under action-specific ARARs.
Because final discharge from .the P01W would be to the Androscoggin River, federal
A WQC and Maine Water Quality Criteria are ultimately applicable to this discharge
option.
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Pretreatment standards are being developed with the Brunswick POTW. Both the
Pretreatment Standards and CW A NPDES will be attained upon successful
establishment of pretreatment standards for discharge from the groundwater
treatment plant.
Another option for the discharge of treated groundwater would be groundwater
reinjection. As required by Underground Injection Control Programs, to be discussed
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.
However, these regulations would require 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 effluent.
State LOcation-specific Regulations. All the location-specific ARARs that apply to
the interim remedy are related to piping that will need to cross Mere Brook. The
State of Maine location-specific ARARs relate to work conducted within 100 feet of
a stream or wetland. While no significant invasive work will be conducted close to
Mere Brook, construction activities to run piping over the brook are an element of
the interim remedy.
Tbe Maine Natural Resources Protection Act provides that activities adjacent to
streams must not cause unreasonable soil erosion, cause unreasonable harm to
significant wildlife habitats, unreasonably interfere with natural water flow, lower
water quality, or unreasonably cause or increase flooding. Chapter 305 of the
MEDEP regulations provides further standards for erosion control and soil
excavation. Implementation of the selected interim remedy would not impact the
drainage or natural flow of Mere Brook. Because the pipeline will cross Mere Brook
at an existing roadway bridge, minimal effects are expected. However, soil erosion
controls will be employed during excavation along the pipeline.
Portions of the Maine Site Location Development Law, and associated regu1ation~,
apply to this site. The law and regulations provide that new development, which
handles hazardous waste, cannot have an adverse effect on the natural environment
or pose an unreasonable risk of discharge to a significant groundwater aquifer.
Applicable portions of Chapter 375, which set forth the no adverse environmental
effect standards regulation of natural drainageways, runoff, erosion, sedimentation
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control, and groundwater quality, will be attained by the interim remedy. As
mentioned, implementation of the selected interim remedy would not impact the
drainage or natural flow of Mere Brook. Soil erosion controls will be employed
during excavation along the pipeline to roinimi7e soil entering Mere. Brook.
Groundwater extraction will remediate groundwater and prevent further impact to
the environment.
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Federal and State Hazardous Waste Regulations. The applicability of RCRA and
Maine Hazardous Waste Regulations depends on whether the wastes are RCRA-
hazardous wastes as defined under these regulations. To date, there is no
information available (i.e., manifests) to indicate that RCRA-regulated materials
were disposed of at Sites 4, 11, and 13. However, because toxic constituents are
present in the source materials and groundwater in the Eastern Plume, many portions
of the federal and state hazardous waste regulations are relevant and appropriate to
the interim remedy.
RCRA General Facility Standards, Preparedness and Prevention, and Contingency
Plan and Emergency Procedures will be attained during construction and operation
of the groundwater treatment plant. The treatment plant, which will be secured to
prevent access by unauthorized personnel. The facility will be designed, maintained,
constructed, and operated to minimi7.e the possibility of an unplanned release that
could threaten human health or the environment. During remedial construction,
safety and communication equipment will be installed at the site, and local
authorities will be familiarized with site operations. Contingency plans will be
developed and implemented during site work and treatment plant operation. A
program will be developed for handling, storage, and recordkeeping, in accordance
with Maine Hazardous Waste Management Rules.
During treatment of contaminated groundwater, sludges containing some toxic
constituents will be produced. A component of groundwater treatment includes
laboratory analysis of this sludge, including Toxicity Characteristic Leachate
Procedure (TCLP) testing. H 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 facility.
. .
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 interim remedy. Site workers will have completed
training and will have approprlate health and safety equipment on site. Contractors
and 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 interim remedy include:
(1) Brunswick POTW, (2) reinjection to groundwater, and (3) direct discharge to
surface water. Discharge of treated groundwater to the Brunswick POTW is the
Navy's preferred option; however, final approval has not been obtained from the
POTW. 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.
H discharge to the POTW is not acceptable, a second alternative is to reinject treated
water back to groundwater. The federal Underground Injection Control Program
and Maine Rules to Control the Subsurface 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 and Maine Water
Pollution Control Laws would apply to this method of discharge. Under this option,
an 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 tbe development of final
discharge limits.
C. THE SELECl'ED INTERIM REMEDIAL AcnON IS COST-EFFECJ'IVE
The selected interim remedy is cost-effective; that is, the remedy affords' overall
effectiveness proponional to its costs. The Navy evaluated the overall effectiveness
of the interim action by assessing the relevant three aiteria: long-term effectiveness
and permanence; reduction in toxicity, mobility, and volume through treatment; and
short-term effectiveness, in combination. The relationship of the overall effectiveness
of this remedial alternative was determined to be proportional to its costs. The costs
of this remedial alternative are:
-Estimated Ctlpital Cosr:S1,223,000
Estimated Operatkm and Maintenance Costs (net presenJ worth):
Estimated Total Cost (net present worth): $4,223,000.
, $1,845,000.
.Net present worth OO5ts are based on a 10 percent discount factor and five years of
operation.
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D.
THE SELECTED INTERIM REMEDY UTILIZES PERMANENT SOLUTIONS AND
ALTERNATIVE TREATMENT OR REsOURCE RECOVERY TECHNOLOGIES TO TIlE
MAxIMUM EXTENT PRACI1CABLE
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The selected interim remedy uses permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable.
The interim action was evaluated for the balance of trade-offs in terms of: (1) long-
term effectiveness 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 interim remedial
action provides the best balance of trade-offs among these criteria prior to
determination of a final remedy.
E.
THE SELECTED INTERIM REMEDY SATISFIES THE PREFERENCE FOR
TREATMENT WHICH PERMANENTLY AND SIGNIFICANTLY REDUCES THE
TOXICI1Y, MOBILI1Y, OR VOLUME OF THE HAzARDous SUBSTANCES AS A
PRINCIPAL ELEMENT
. The principal element of the selected interim remedy is the extraction of
groundwater and treatment with UV joxidation. This element addresses the primary
threat of the Eastern Plume--discharge of contaminated water to Harpswell Cove.
The interim remedial action satisfies the statutory preference for treatment as a
principal element by destroying contaminants in the extracted groundwater with
UV j oxidation.
This interim ROD will be followed by a final ROD that will determine what further
actions, if any, will be necessary to meet the preference for treatment which will
permanently and significantly reduce toxicity, mobility, or volume of hazardous
substances.
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XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES
The Navy presented a Proposed Plan (preferred alternative) for the interim remedial
action for the Eastern Plume on December 12, 1991. The interim remedial action
consisted of the same components described in this ROD. No significant changes
have been made to the interim action described in the proposed plan and presente,d
to the public.
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MEDEP has reviewed the interim remedial action and indicated its support for the
selected remedy. As party to the FFA, the state has also reviewed the RI, Remedial
Acti~n, FS, and Proposed Plan to determine if the selected remedy is in compliance
with ARARs. MEDEP concurs with the selected remedy for the Eastern Plume at
NAS Brunswick. A copy of the letter of concurrence is presented in Appendix C of
this ROD. .
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ACRONYMS
ARAR Applicable or Relevant and Appropriate Requirement
L ATSDR Agency for Toxic Substances and Disease Registry
AWQC Ambient Water Quality Criteria
I BACSE Brunswick Area Citizens for a Safe Environment
CERCLA Comprehensive Environmental Response, Compensation, and Liability
l. Act
CSF cancer slope factor
CWA Oean Water Act
1 DCA dichloroethane
DCE dichloroethylene
l DNAPL dense nonaqueous phase liquid
DRMO Defense Reutilization and Marketing Office
I .FFA Federal Facility Agreement
FS Feasibility Study
I gpm gallons per minute
I. !AS Initial Assessment Study
IRP Installation Restoration Program
I MCL Maximum Contaminant Level
MEDEP Maine Department of Environmental Protection
MEG Maximum Expos~re Guideline
r mgd million gallons per day
MSL mean sea level
[ NAS Naval Air Station
NPDES National Pollutant Discharge F.1imination System
NPL National Priorities list
r OSHA Occupational Safety and Health Act
r POTW publicly owned treatment works
ppb parts per billion
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ACRONYMS
RCRA Resource Conservation and Recovery Act
L RID reference dose
RI Remedial Investigation
ROD Record of Decision
L SDWA Safe Drinking Water Act
t TBC to be considered
TCA trichloroethane
TCE trichloroethylene
1 TCLP Toxicity Characteristic Leachate Procedure
TRC Technical Review Committee
L- USEPA U.S. Environmental Protection Agency
UV ultraviolet
[ VOC volatile organic compound
VPC vapor phase carbon
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REFERENCES
E.C. Jordan Co., 1990a. "Draft Final Remedial Investigation Report NA.S
Brunswick"; Portland, Maine; August.
E.C. Jordan Co., 1990b. "Phase I Feasibility Study Development and Screening of
Alternatives NAS Brunswick"; Portland, Maine; August.
E.C. Jordan Co., 1991a. "Draft Final Supplemental Remedial Investigation Report
NAS Brunswick"; Portland, Maine; August.
E.C. Jordan Co., 1991b. "Focused Feasibility Study Sites 1 and 3 NAS Brunswick";
Portland, Maine; October.
E.C. Jordan Co., 1992a. "Feasibility Study NAS Brunswick"; Portland, Maine; March.
E.C. Jordan Co., 199~b. "Focused Feasibility Study Site 8 NAS Brunswick"; Portland,
Maine; March.
R.F. Weston, Inc., 1983. "Initial Assessment Study of Naval Air Station, Brunswick,
Maine"; Westchester, Pennsylvania; June.
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APPENDIX A
APPliCABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
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TABLE A-1
CHEMICAl-SP£CFIC ARARs, CRlTUlIA, ADVISORIES, AM) GUIDANCE
ROD: EASTBIN PLUME
NAS BRUNSWICK
MEDIA
REQUIII!IISft '.:.,
CONSIOERA TlON IN THE REMEDIAL PROCESS
STATUS
REQUlRtMENT SYNOPSIS
GROUNDWATER/
SURFACE WATER
Federal
SDWA . MC1.8 (40 CFR
141.11-141.16)
SDWA. MCLGs (40 CFR
141.50. 141.51)
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Groundwater ProtectIon
Standards, Alternate
Concentratfon Umlta
(40 CFR 264.94)
Federal AWOC
WOO292S1.T80\6
Relevant and
Appropriate
Relevan1 and
Appropriate
Relevant and
Appropriate
Applicable
MCLs have been promulgated for several common
organic and inorganic contaminants. These levels
regulate the concentration of contaminants In public
drinking water supplies, but may also be considered
relevant and appropriate for groundwater aquifers used
for drinking water.
MClGs are health-based criteria. As promulgated under
SARA, MClGs are to be considered for drinking water
sources. MCLGs are available for several organic and
Inorganic contaminants.
This requirement outlines standards, In addition to
background concentrations and MCLs, to be used In
establishing clean-up levels for remedlatlng groundwater
contamination.
Federal AWaC Include (1) health-based criteria
developed for 95 carcinogenic and noncarcinogenic
compounds and (2) water quality parameters. AWac lor
the protection 01 human health provide levels lor
eKposure Irom drinking water and consuming aquatic
organisms, and Irom consuming fish alone. Remedial
actions Involving contaminated surface water or
groundwater must consider the uses of the water and the
circumstances 01 the release or threatened release; this
determines whether AWaC are relevant and appropriate.
Groundwater at NAS Brunswick Is not a current source
of drinking water; therefore, MCls are not applicable,
but may be relevant and appropriate. To assess the
potential risks to human health due to consumption of
groundwater, contaminant concentrations were
compared to their MCls.
The 1990 National Contingency Plan states that non-
zero MClGs are to be used as goals. Because
groundwater at NAS Brunswick Is not a current source
01 drinking water, MClGs are not applicable, but may
be relevant and appropriate. Contaminant
concentrations In groundwater were compared to their
MClGs.
Most 01 the MCLs promulgated under RCM are the
same as SDWA MCLs. The standards set forth under
RCM do not rellect recent changes and additions to
SDWA MCLs. Because groundwater Is not a current
source of drinking water; RCM MCls are not
applicable, but may be relevant and appropriate.
AWaC will be applicable II treated groundwater Is
discharged to surface water. The Navy's prelerred
discharge option Is to the Brunswick POTW, although
the Navy has not yet received approval from the
POTW. AWaC may be considered during
development of pretreatment standards because the
POTW discharges Its effluent to the Androscoggin
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TABLE A-'
CHEMICAL-SPECIFIC ARARs. CRITBIIA. ADVISORIES, AND GUIDANCE
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HAS BRUNSWICK
MEDIA
. COHSIOERATION IN THE REMEDIAL PROCESS
Federal Guidance and
Criteria To Be
Considered
RtatJMEillBrt .... ... .....
USEPA Risk Reference
Doses (RfDs)
USEPA Human Health
Assellment Group Cancer
Slope Factors (CSFe)
State
Maine DrInking W~ "'Ie,
(1o-144A CMR Chapters
231-233)
tr
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Maine Regulation. Relating
to Water Qu,llty Crtterla for
TOlllo Pollutants (MEDEP
Regs, Chapter 684)
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STAtUs
To Be Considered
To Be Considered
Relevant and
Appropriate
Applicable
REQUIIIEMENT SYNOPSIS
RfDs are the levels considered unlikely to cause
significant adverse health effects associated with a
threshold mechanism of action In human ellposure for a
lifetime.
Carcinogenic effects present. the most up-to-date
Information on cancer risk potency derived from USEPA's
Human Health Assessment Group.
Maine', Primary Drinking Water Standards are equivalent
to federal MCls. When atate levels are more stringent
than federal levels, the state levels may be used.
This rule limits the concentrations of certain materials
allowed In Maine waters to prevent the occurrence of
pollutants In tOKlc amounts as required by state and
'ederallaw. Except If naturally occurring, ambient levels
of tOKlc pollutants shall not eKceed the Clean Water Act
AWaC. Where AWaC do not eKlst, the Board of
Environmental Protection shall adopt. site-specific
numerical criteria.
Because there are only a limited number of
promulgated standards for contaminants in soil and
water, USEPA RIDs were used to characterize risks due
to noncarclnogens In various media.
Because there are only a limited number 0'
promulgated standards for contaminants In soil and
water, USEPA CSFs were used to compute the
Individual Incremental cancer risk resulting from
eKposure to certain compounds.
Groundwater at NAS Brunswick Is not a current source
of drinking water; therefore, State Drinking Water
Standards are relevant and appropriate. Contaminant
concentrations In groundwater were compared to State
standards to assess the potential risks to human health
due to consumption of groundwater.
This rule will be applicable If treated groundwater Is
discharged to surface water. The Navy's preferred
discharge option Is to the Brunswick POTW, although
the Navy has not yet received approval from the
POTW. Awac will be considered during development
0' pretreatment. standards. This rule Is potentially
applicable In development 0' pretreatment standards If
AWQC do not ellist for any contaminants present In
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TABLE A-'
CHEMICAL-SPECIFIC ARARa. CRnBUA. ADVI80R\E8. AND GUIDANCE
ROD: EASTalN PLUME
NAS BRUNSWICK
MEOI4 .
.Raa~:
.. .
STAtUS
REQUllttMEHT SYNOPSIS
CONSIDERATION IN THE REMEDIAL PROCESS
State Criteria and
Guidance To Be
Considered
Rules Relating to Testing
of Private Watar Systems
for Potentially Hazardous
Contamlnante (1()'144A
CMR Chapter 233,
Appendix C)
To Be Considered
Appendix C outlines Maximum Exposure Guidelines
(MEGs) for organic and Inorganic compounds. MEGs
Include health advisories. which are maximum allowable
concentrations of specific contaminants In drinking water.
MEGs have been considered for chemical compounds
for which there are no promulgated standards.
MEGs may be considered If treated groundwater Is
discharged back to groundwater. The Navy's preferred
discharge option Is to the Brunswick POTW; however,
the Navy has not yet received approval from the
POTW. MEGs may potentially be considered during
development of discharge limits for reinjection of
treated groundwater.
Not..:
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..... AWaC
CEACLA ..
CFA
CMR
CPF
FS
MCL
MCLG
MEG
MEDEP ..
MASA
NAS
OSWEA ..
AI
ACRA
RfD
SARA
SDWA
USEPA
Applicable or Relevant and Appropriate Requirement
Ambient Water Quality CrIteria
Comprehensive environmental Response, Compensation. and Uabillty fv;t
Code of Federal Regulations
Code of Maine Rules
carclnogenlo potenoy factor .
feasibility study
Maximum Contaminant Level
Maximum Contaminant Level Goal
Maximum Exposure Guldellnll .
Maine Department of EnvIronmental Protection
Maine RevIsed Statues Annotated
Naval Air Station
Office of Solid Waste and Emergency Response
remedial Investigation
Resource Consarvatlon and Reoov8ry fv;t
reference dose
Superfund Amendmente and Reauthorization fv;t
Sale Drinking Water fv:fI
U.S. Environmental Protection I\genoy
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TA8LE A-2
LOCATION-SPECFIC ARARs. CIUTBIIA. AovISORlES. AM) GUIDANCE
ROD: EASTERN PLUME
NAS BRUNSWICK
MmlA
. RtQ~EHT
STATUS
REQUIREMENT SYNOPSIS
CONSIDERATION IN THE REMEDIAL PROCESS
State
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MaIne Natural
Resource. Protection
Act (38 MRSA, Section
480-A through 5)
Natural Resources
Protection Act, Permit
by Rule Standards
(MI;DEP Rag., Chapter
305)
MaIne Standards for
Classification of Minor
Dralnagn (38 MRSA.
SectIon 488)
...v.
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Maine Natural
Resou"," Protection
Act (38 MRSA. Section
480-A through 5)
Applicable
Applicable
Applicable
Applicable
This act outlines requlremenls for certain activities
adjacent to any freshwater wetland greater than 10
acres or with an associated stream, brook, or pond or
adjacent to a coastal wetland. The activities must not
unreasonably Interfere with certain natural features,
such as natural flow or quality of any waters, nor harm
significant aquatic habitat, freshwater fisheries, or
other aquatic life.
This rule outlines prescribed standards for specific
activities that may take place In or adjacent to
wetlands and water bodies.
Mere Brook Is classified as a Class B water under the
state water quality standards. Class B waters are
defined as suitable for drinking water (after treatment),
fishing, recreation In and on the water, and as habitat
for fish and other aquatlo life.
A permit application must be submitted and approved
by the Maine Bureau of land Quality Control and
Section 48G-D performance standards met when
conducting activities adJaeent to any freshwater
wetland greater than 10 acres or with an associated
stream, brook, or pond.
Because piping will need to be extended across Mere
Brook, this regulation Is applicable. Remedial
activities will need to meel the substantive
requirements of this Act.
Because piping will need to be extended across Mere
Brook, Ihls regulation'. applicable. Activities
Involving disturbance of soil material within 100 feet
of the normal high water line, will be designed to
Incorporate all applicable standards.
These regulations apply to activities conducted
adjacent to Mere Brook. Remedial construction
should not result In the degradation of water quality
classification.
These regulations may also potentially apply If
treated groundwater Is discharged to surface water.
The Navy's preferred discharge option Is to the
Brunswick POTW; however, the Navy has not yet
received approval from the POTW. The designated
uses of the waters receiving either direct discharge or
POTW eHluent must be considered and protected in
developing either discharge limits or pretreatment
standards.
Substantive requirements of this regulation apply to
activities conducted adjacent to Mere Brook.
However, a permit is not required for the selected
remedy since the administrative permit requirement
are waived for remedial activities conducted on-site at
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TAeLE A-2
LOCATlON-SPECFlC ARARa, CRITERIA. ADVISORIES. AND GUIDANCE
ROD: EASTBIN PLUME
NAS BRUNSWICK
MEDIA
. R~tiMMsrt
STATUS
REQUIIIEMM SYNoPSIs
CONSIDERATION IN mE REMEDIAL PROCESS
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Maine Standards 'or
Classification of
Groundwater (38
MRSA, SectIon 470)
Maine SIte location
Development law and
Regulations (38 MRSA
Sections 481-490;
MEDEP Regs, Chapte,.
371..;J77)
Applicable
This law requires the classification 0' the state's
groundwater to protect, conserve, and maintain
groundwater resources In the Interest 0' the health,
safety, and general welfare of the people 0' the state.
Under the Maine standards. groundwater Is classified
as GW-A.
This regulation will apply I' treated groundwater Is
discharged back to groundwater. The Navy's
preferred discharge option Is to the Brunswick POlW;
however, the Navy has not yet received approval 'rom
the POlW. "discharge to groundwater is employed,
the classification and uses 01 groundwater will
evaluated during development of discharge limits.
Those regulations concerning No Adverse
Environmental Impact Q.e., Chapter 375) are
applicable to Implementation 0' the interim remedy.
.In particular, standards for protection 0' groundwater
would apply to construction and groundwater
treatment activities. However, any licenses required,
by reference, will not need to be obtained since
permits are not required f<:. actions conducted on-site
at lederal Superfund sites.
NotH:
ARAR
CERCLA a
CFR
CWA
MRSA
MEDEP a
NAS
RifFS
RCRA
Applicable
This act and associated regulations govern new
developments, Including those that handle hazardous
waste. New developments cannot adversely affect
existing uses, scenic character, or natural resources In
the municipality or neighboring municipality.
Applicable or Relevant and ApprGprl8te Requirements
Comprehensive Environmental Response. Compensation, and Uablllty Act
Code 0' Federal Regulations
Clean Water Act .
Maine Revised Statutes Annotated
. Maine Department of environmental Protection
Naval Air Station
Remedlallnvestlgation/Fe88lblllty Study
Resource Conservation and ReOCMlry Act
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TABLE A-3
ACTION-SPECIFIC APPlICABLE OR RElEVANT AND APPROPRIATE REQUIIEMENT8
ROD: EASTERN PLUME
NAS BRUNSWICK'
REQUIREMENT
CONsmERATION IN THE REMEDIAL PROCESS
0.,'...;..
STA'f\J8
REQUIREMENT SVNOP818
Federal
RCM . General Facility Standards
(40 CFR 264.10-264.18)
RCM - Preparedness and Prevention
(40 CFR 264.30-264.37)
:r
0\
RCM . Contingency Plan and Emergency
Procedures (40 CFR 264.50-264.56) .
RCM . Miscellaneous Units (40 CFR
264.600-264.999)
WOO292St.T80\ 11
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Oeneral facility requirements outline general waste analysis,
security measures, Inspections, and training requirements.
This regulation outlines requirements for safety equipment
and spill-control for hazardous waste facilities. Part of the
regulation Includes a requirement that facilities be
designed, maintained, constructed, and operated to
minimize the possibility of an unplanned release that could
threaten human health or the environment.
This regulation outlines the requirements for emergency
procedures to be used following explosions, fires, etc.
These standards are applicable to miscellaneous units not
previously defined under existing RCM regulations.
Subpart X outlines performance requirements that
miscellaneous units be designed, constructed, operated,
and maintained to prevent releases to the subsurface,
. groundwater, surface water, and wetlands that may have
adverse effects on human health and the environment.
The waste material at Sites 4, II, and 13 have not been
formally defined as a RCM-regulated waste; therefore, only
sections of the facility standards are relevant and
appropriate. All other relevant general requirements will be
Incorporated Into the construction and operation of the
groundwater treatment plant.
Because toxic constituents are present within the Eastern
Plume groundwater, preparedness and prevention
requirements are relevant and appropriate to the
Implementation of the selected remedy. During remedial
construction, safety and communication equipment will be
installed at the site, and local authorities will be familiarized
with site operations.
Because toxic constituents are present In Eastern Plume
groundwater, contingency plans and emergency procedures
are relevant and appropriate to the implementation of the
selected remedy. Plans will be developed and
Implemented during site work Including installation of
extraction wells, and Implementation of site remedies.
Copies of the plans will be kept on-site.
Because the selected remedy includes a groundwater
treatment plant, the general des'lIn, performance, and
operating requirements of Subpart X are relevant and
appropriate. . However, a permit Is not required for remedial
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TABLE A-3
ACTION-SPECIFIC APPlICABLE OR REl£VANT AND APPROPRIATE REQUIREMENTS'
ROD: EASTERN PLUME
NAS BRUNSWICK
CONSIDERATION IN THE REMEDIAL PROCE88
REQUIREMENT SYNOPSIS
STATUS
REQUIROIIENT
During treatment of groundwater, sludge containing
hazardous constituents will be generated. The selected
remedy Includes provisions for analysis of this sludge,
Including Toxicity Characteristic Leachate Procedure (TCLP)
testing. LDRs are potentially applicable If the sludge falls
TCLP. The selected remedy does address handling and
disposal of the sludge as a hazardous waste, If necessary.
land disposal of RCRA hazardous wastes Is restricted
without specified treatment. It must be determined that the
waste, beyond a reasonable doubt, meets the definition of
one of the specified restricted wastes and the remedial
action must constitute .placement. for the land disposal
restrictions to be considered applicable. For each
hazardous waste, the LDAs specify that the waste must be
treated either by a treatment technology or to a
concentration level prior to disposal In a RCRA Subtitle C
permitted facility.
These regulations specify the 8-hour time-weighted average
concentration for various organic compounds. Training
requirements for workers at hazardous wastes operations
are specified In 29 CFR 1910.120.
RCRA land Disposal Restrictions (40 CFR 268)
To be
determined
Because toxic constituents are present In Eastern Plume
groundwater, OSHA regulations are applicable. Proper
respiratory equipment will be worn If It Is impossible to
maintain the work atmosphere below designated
concentrations. Workers performing ectlvltles would be
required to have completed specific training requirements.
Because toxic constituents are present In Eastern Plume,
groundwater. OSHA regulations are applicable. All
appropriate safety equipment will be on-site. In addition,
safety procedures would be followed during on-site
act!vltles.
Applicable
OSHA - General Industry Standards
(29 CFR Part 1910)
=r
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t
This regulation specifies the type of safety equipment and
procedures to be followed during site remediation.
Applicable
OSHA - Safety and Health Standards
(29 CFR Part 1926)
Because toxic constituents are present in Eastern Plume
groundwater. OSHA regulations are applicable. These
requirements will apply to all site contractors and
subcontractors. and must be followed during all site work.
This regulation outlines the recordkeeplng and' reporting
requirements for an employer under OSHA.
OSHA - Recordkeeplng, Reporting, and Related
Regulations (29 CFR 19(4)
Applicable
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TA8LE A-3
ACTION-SPECIFIC APl'UCA8LE OR RB.£VANT AND APPROPRIATt REQUIREMENTS
ROD: EAST£RN PLUME
NAS BRUNSWICK
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
CONSIDERATION IN THE REMIDIAL PROCESS
CWA - NPDES Regulations
(40 CFR Parts 122, 125)
Applicable
This requirement Implements the NPDES program that
specifies the applicable effluent standards, monitoring
requirements, and standard and special conditions for
direct discharge.
NPDES requirements will be applicable If treated
groundwater Is discharged to surface water. The Navy's
preferred discharge option Is to the Brunswick POTW;
however, the Navy has not yet received approval from the
POTW. Both on. and off-site discharges from CERCLA sites
to surface waters are required to meet the substantive CWA
NPDES requirements, Including discharge limitations,
monitoring requirements, and best management practices.
Brunswick POTW has a current NPDES permit. A permit
would be required If treated groundwater is discharged on-
site.
Underground Injection Control Program
:I> (40 CFR 144, 146, 147, 1000)
I
00
Applicable
These regulations outline minimum program and
performance standards for underground Injection programs.
Technical criteria and standards for siting, operation and
maintenance, and reporting and record keeping as required
for permitting are set forth In Part 146.
This regulation will be applicable If treated groundwater Is
discharged back to groundwater. The Navy's preferred
discharge option Is to the Brunswick POTW; however, the
Navy has not yet received approval from the POTW.
Discharge of treated groundwater, by well injection, must
be In accordance with all the criteria and standards in these
federal regulations, as well as meet all state Underground
Injection Control Program requirements. Treated
groundwater must meet all SDWA standards prior to well
Injection.
This regulation Is applicable since the Navy's preferred
discharge option Is to the Brunswick POTW; however, the
Navy has not yet received approval from the POTW. If
treated groundwater Is discharged to a POTW, the treated
water must meet all discharge limitations Imposed by the
POTW.
CWA . Pretreatment Standards for POTW
Discharge (40 CFR Part 4(3)
Applicable
This regulation specifies pretreatment standards for
discharges to a POTW. If treated groundwater Is
discharged to a POTW, the POTW must have mechanisms
available to meet the requirements of the National
Pretreatment Program. introduction of Pollutants which
cause pass through or Interference are prohibited.
Discharges must aiao comply with any local POTW
regulations. "hazardous waste Is discharged to the POTW,
the POTW may be subject to RCRA permlt-by-rule.
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TAILE A-3
AcnON-SP£CFIC APPliCABlE OR RB.EVAHT AND APPROPRIATt REQUIREMENTS
ROD: EA8T£RN PLUME
NAS BRUNSWICK
" ,""
CONSIDERAOON IN 'OE REMEOIAL PROCESS
REQUIREMENT
'.
..
State
Maine Rules to Control the Subsurface Discharge
of Pollutants by Well Injection (MEDEP Regs.
Chapter 543)
Maine Hazardous Waste Management RuIH
(MEDEP Regs, Chapters 800-802. 850, 851, 8!53-
857)
:r Maine Water Pollution Controt Law: Conditions at
\D Ucenses (38 MRSA, Section 414-A)
Maine Water Pollution Control Law: Certain
Deposits and Discharges Prohibited (38 MRSA,
Section 420)
WOO292S1.T80\14
STATU8
Applicable
Relevant and
Appropriate
Applicable
Applicable
REQUIREMENT SYNOPSIS
this regulation prohibits the Injection of hazardous waste
Into or above water-bearing ftlrmatlons via a new Class IV
well. The subsurfacs discharge Into or through a Class IV
well that would cause or allow the movement of fluid Into
an underground source of drinking water that may result In
a violation of any Maine Primary Drinking Water Standard,
or which may otherwise adversely affect public health, Is
prohibited.
The rules provide a comprehensive program for handling,
storage, and record keeping at hazardous waste facilities.
They supplement the RCRA regulations.
Regulates the discharge of any pollutants. Specifies that
the discharge, either by Itself or combined with other
discharges, will not lower the quality of any classified body
of water below such classification. The discharge will be
subject to effluent limitations that require application of the
best practicable treatment.
No person, firm, corporation, or other legal entity shall
place, deposit, discharge, or spill mercury or tOKlc or
hazardous substances, either directly or indirectly, Into the
Inland groundwater or surface waters, tidal waters, on the
Ice, or on the banks thereof, so that the same may flow or
be. washed Into such waters, or In such manner that the
drainage therefrom may flow Into such waters.
These regulations will be applicable If treated groundwater
Is discharged back to groundwater. The Navy's preferred
discharge option Is to the Brunswick POTW; however, the
Navy has not yet received approval from the POTW. For
discharge to the subsurface, groundwater must be treated
to a target clean-up level less than or equal to the Maine
MEGs to be recharged to the aquifer.
Because these requirements supplement RCRA hazardous
waste regulations, they are relevant and appropriate.
The substantive requirements of this regulation will apply If
treated groundwater Is discharged to surface water. The
Navy's preferred discharge option Is to the Brunswick
POTW; however, the Navy has not yet received approval
from the POTW. "treated water Is discharged dlreclly to
surface water the effluent must receive the best practicable
treatment before discharge.
this regulation will apply If treated groundwater Is
discharged to surface water. The Navy's preferred discharge
option Is to the Brunswick POTW; however, the Navy has
not yet received approval from the POTW. "discharge to
surface water Is employed, Best Management Practices will
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TABLE A-3
ACTION-SPECFIC APPlICABLE OR RElEVANT AM) APPROPRIATE REQUIREMENTS
REQUIREMENT
CONSIDERATION" THE REMEDIAL PROCESS
STATUS
ROD: EASTERN PLUME
NAS BRUNSWICK
REQUIIEMENT SYNOPSIS
. ...
.. ..
State Guidance and Crlterta
To Be Considered
MEDEP. Bureau of Water Quality Control, Policy
Number 10, 'The Discharge of Hazardous
Substances to Groundwater8 of the Stat,'
To Be
Considered
The Bureau will deny applications for waste discharge
licenses for the discharge to groundwaters of substances
designated by the Board to be hazardous when such
substances are present In concentrations exceeding
groundwater levels which occur naturally in the area.
Exemption may be granted If the groundwater Is treated to
reduce the concentrations of pollutants discharged to below
the level considered safe for drinking water.
This policy will need to be considered If treated
groundwater Is discharged back to groundwater. The Navy's
preferred discharge option Is to the. Brunswick POTW;
however, the Navy has not yet received approval from the
POTW. "treated water Is discharged to the subsurface, the
minimum level of groundwater treatment would be required
to provide adequate protection If no other means of
disposal Is feasible. This policy would only be considered
after application of federal and state underground injection
control regulations.
Not..:
>
,!. AHERA
o CM
CERCLA =
CFR
CMR
CWA
DOT
LDAs
FS
MEDEP .
MEG
MRSA
NAS
NESHAP .
NPDES
OSHA
POTW
RACT
RI
RCRA
SDWA
TCLP
pg/mJ
VOC
Asbestos Hazard Emergency Rnpon.. kI
Clean Air kI
Comprehensive Environmental Response, Compensation, and Uability Act
Code of Federal Regulatfons
Code of Maine Regulations
Clean Water Act .
Department of Transportatfon (U.S.)
Land Disposal Restrictions
feasibility study
Maine Department of EnvIronmental Protection
M8I!Imum Exposure Guideline.
Maine Revised StaMes Annotated
Naval Air Station
National Emission Standards for Huardous Air Pollutants
National Pollutant Discharge Ellmlnatfon System
Occupational Safety and Health Administration
publicly owned treatment work.
Reasonably Available Control Technology
remedial Investigation
Resource Conservation and Recovery Act
Safe Drinking Water Act
Toxicity Characteristic LAtacha.. Procedure
micrograms per cubic meter
volatile organic compound
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l APPENDIX C
[ MEDEP LETTER OF CONCURRENCE
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. .. E OF IA~
STATE OF MAINE
Department of Envir.onmental P.rotection
MAIN OFFICE: RAY BUILDING. HOS;:>ITAL STREET. AUGUSTA
MAIL ACDRESS: $.at8 House SWlon 17. Augusla. ~3
2.7,289-7688
.~ ~..:..- "..
JOHN R. McKERNAN. JR.
GOVERNOR
DEAN C. MARRIOTT
COMMISSIONER
June 4, 1992
Thomas A. Dames
Captain, CEC, U.S. Navy
Commanding Officer
Department of the Navy, Northern Division
Naval Facilities Engineering Command
Building 77-L
Philadelphia Naval Shipyard
Philadelphia, PA 19112-5094
RE:
Naval Air station Brunswick Superfund Site, Brunswick,
Maine
Dear captain Dames:
The Maine Department of Environmental Protection (MEDEP) has
reviewed the June 1992 Draft Record of Decision (ROD)
regarding the Interim Remedial Action for the Eastern Plume
for the Naval Air Station Brunswick Superfund Site located
in Brunswick, Maine. .
Based on that draft the MEDEP concurs with the selected
. interim remedial action. This action seeks to control and
prevent further migration of the contaminant plume emanating
from sites 4, 11, and 13 until a final remedy for these
sites and the Eastern Plume is chosen. This interim remedy
will operate in conjunction with the remedial action
selected for Sites 1 and 3. The interim remedial action
involves the extraction, treatment and discharge of
groundwater £rom the Eastern Plume area as ~utlinedinthe
followinq: .
I. Groundwater Extraction Wells
.'
A. Groundwater extraction wells will be installed to
remove contaminated groundwater from the designated
plume ..are~ and to limit further migration of the
p~ume towards Harpswell Cove. .
B. The number of wells, pumping rates, and location of
the wells will be determined during ~he design
phase.
T
prillled 011 ncyckd paper
I
1
. P::Jrtland .
REGIONAL OFFICES
. Bangor.
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Groundwater Treatment
, A. Extracted groundwater will be pumped to a central
treatment plant.
B. Groundwater will be pretreated to remove inorganic
compounds.
C. Groundwater will 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.
III. Discharge of Treated Water
IV.
to
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be to the
to the
Treatment
A. Discharge of treated water is expected to
base sanitary sewer system which connects
Brunswick Sewer District, Public Operated
Works (POTW).
B. Flow from the NABS treatment facility will not cause
the POTW to exceed its capacity.
Clean-up levels
A. Groundwater clean-up levels for contaminants have
been set at the MCL.
B. In the absence of an MCL" groundwater clean-up
levels have been based on a excess cancer risk level
of 10-6 to 10-4 as set by USEPA policy or at a '
Hazard Ind~x of 1.0 for non carcinogenic compounds.
V.
Environmental monitoring
A. Monitoring wells will be sampled to confirm the
-.effectiveness of the Interim action.
"B. A monitoring 'Program will ,be developed .cluring-the
design phase and will require regulatory approval.
,;
VI.
other remedial actions
A. ChangeS in the interim remedial action will be '
. developed if necessary.
B. This interim action may be incorporated into or
superseded by a comprehensive remedial action'of
the site 4, 11, and 13 source areas.
.;"
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This concurrence is based upon the state's understanding
that:
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A. The MEDEP will continue to participate in the
Federal Facilities Agreement dated October 19,
and in the review and approval of oper~tional
designs and monitoring plans.
B. Groundwater extraction wells established within the
plume area will be maintained and sampled on a
regular basis.
1990
c. Selection and development of a final remedial action
for the Eastern Plume source areas will continue.
The MEDEP looks forward to working with the Department of
the Navy and the USEPA to resolve the environmental problems
posed by this site. If you need additional information, do
not hesitate to contact myself or members of my staff.
.5::~
Dean C. Marriott
Commissioner
cc: Alan Prysunka, Director, BHMSWC
Michael Barden, Director, DSIR
~~~rK';-,.HYJ.~pd~:::
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