PB94-963721
EPA/ROD/R01-93/095
December 1994
EPA Superfund
Record of Decision:
Brunswick Naval Air Station
Sites 5 and 6, Brunswick, ME
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RE~ORD OF DECISION
FOR A REMEDIAL ACTION
. AT SITES 5 AND 6
NAVAL AIR STATION BRUNSWICK
BRUNSWICK, MAINE
Ii
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Contents
NAVAL AIR STATION BRUNSWICK
RECORD OF DECISION
TABLE OF CONTENTS
Page No.
DECLARATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
DECISION SUMMARY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... 5
I.
II.
m.
IV.
v,
VI.
SITE NAME, LOCATION, AND DESCRIPTION. . . . . . . . . , . 5
SITE mSTORY AND ENFORCEMENT ACTIVITIES. ... ., 10
A LAND USE AND REsPONSE HISTORY. . . . . . . . . . . .. 10
B. ENFORCEMENT HISTORY. . . . . . . . . . . . . . . . . . . . .. 11
COMMUNITY PARTICIPATION..................... 14
SCOPE AND ROLE OF ~SPONSE ACTION. . . . . . . . . .. 15
SUMMARY OF SITE CHARACfERISTICS ............. 16 .
SUMMARY OF SITE RISKS . ~ . . . . . . . . . . . . . . . . . . . . . .. 19
VII. DEVELOPMENT AND SCREENING OF
ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 20
A STATUTORY REQUIREMENTS/REsPONSE
.. OBJECTIVES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 20
TECHNOLOGY Am> ALTERNATIVE DEVELOPMENT
AND ScREENING. . . . .. . . . . . . . . . . . . . . . . . ; . . . ., 20
\,
"
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B.
vrn. DESCRIPTION OF ALTERNATIVES. . . . . . : . . . . . . . . . .. 23
IX.
SUMMARY OF TIlE COMPARATIVE ANALYSIS OF .
ALTERNATIVES. . . . . . . . . . . . . . . . . . . '. . . . . . . . . . . . . .. 30
x.
TIlE SELECfED REMEDY. . . . . . . . . . . . . . . . . . . . . . . .. 38
.A CLEANuPLEVELS............................38
B. DESCRIPTION OF REMEDIAL COMPONENTS. . . . . . . ., 39
XI.
STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . . . .. 47
1
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Contents
A
B.
C.
D.
E.
NA VAL AIR STATION BRUNSWICK
RECORD OF DECISION
TABLE OF CONTENTS
continued
Page No.
THE SELECI'ED REMEDY IS PROTECTIVE OF
HUMAN HEALTH AND THE ENVIRONMENT..... "" 47
THE SELECI'ED REMEDVAITAINS ARARs ........ 48.
THE SELECI'ED REMEDIAL ACTION IS COST-
EFFECTIVE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 51
THE SELECI'ED REMEDY UTILIZES PERMANENT
SOLUTIONS AND ALTERNATIVE TREATMENT OR
REsOURCE RECOVERY TECHNOLOGIES TO THE
MAxIMuM EXTENT PRAcrICABLE ............... 52
THE SELECI'ED REMEDY DOES NOT SATISFY THE
PREFERENCE FOR TREATMENT WHICH
PERMANENTLY AND SIGNIFICANTLY REDUCES THE
TOXICITY, MOBILITY, OR VOLUME OF THE .
HAzARDous SUBSTANCES AS A PRINCIPAL
ELEMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 52
XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES. .. 54
xm. STATEROLE .................................... 55
. REFERENCES
GWSSARY OF ACRONYMS AND ABBREVIATIONS
APPENDICES
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
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RESPONSIVENESS SUMMARY
MEDEPLETTEROFCONCURRENCE
APPUCABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS
ADMINISTRATIVE RECORD INDEX AND
GUIDANCE DOCUMENTS
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.Figure
v
1
2
3
4.'
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NAVAL AIR STATION BRUNSWICK
RECORD OF DECISION
LIST OF FIGURES
Page No.
Site Location Map. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 6
Site 5 ................................:................ 7
Site 6 ....................:........................ .... ' 9
Transportation'Route . '.' . . . . . . . . . . . . . . . . . .'. . . . . . . . . . . . . . .. 43
ill
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Table
1
2
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NAVAL AIR STATION BRUNSWICK
RECORD OF DECISION
LIST OF TABLES
Page No.
Summary of Remedial Alternatives. . . . . . . . . . . . . . . . . . . . . . . . .. 22
Alternatives 5,6-F: Excavate and Use as Subgrade Material at
Sites 1 and 3 ............................'............... 45
iv
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DECLARATION
SITE NAME AND LOCATION
Naval Air Station (NAS) Brunswick
. Orion Street Asbestos Disposal Site: Site 5; and
Sandy Road Rubble and Asbestos Disposal Site: Site 6
Brunswick, Maine
STATEMENT OF BASIS AND PURPOSE
This decisj( , document presents a selected remedial action that will remove
asbestos-covered pipes from Site 5, the Orion Street Asbestos Disposal Site, and
remove construction rubble and asbestos-containing material from Site 6, the Sandy
Road Rubble and Asbestos Disposal Site. This decision document was developed
in accordance with the Comprehensive Environmental Response, Compensation, and
liability Act (C;:ERCLA) of 1980 as amended by the Superfund Amendments and
Reauthorization Act of 1986, and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan. 1brough this document, the Navy
plans to remedy the threat to human health, welfare, or the environment posed by
asbeStos-containing material associated with Sites 5 and 6. This decision is based on
infoImation contained in the Administrative Record for the site. The Admini"trative
. Record for this site is located at the Public Works Office at NAS Brunswick and the
Curtis Memorial library, 23 Pleasant Street, Brunswick, Maine.
The State of Maine Department of Environmental Protection and the U.S.
Environmental Protection Agency concur with the selected remedy.
ASSESSMENT OF THE SITE
. Actual or threatened releases of hazardous substances from Sites 5 and 6, if' not
addressed by implementing the response action selected in this Record of Decision
(ROD), may present an imminent and substantial endangerment to public health,
welfare, or the environment. .
DESCRIPTION OF THE SELECTED REMEDY
'V
This action addresses' the principal threat posed by Sites 5 and 6 by preventing
endangerment of public health, welfare, or the environment by implementing this
ROD. This. ROD describes the removal of construction rubble and asbestos.
"
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containing material and disposal of this material.as necessary subgrade fill for the
proposed cover system at the landfill at Sites 1 and 3.
The selected remedy includes the development of a health and safety plan to address
the specific hazards associated with handling asbestos-containing material; site
preparation; excavation of construction debris and asbestos-containing material; and
containerization of the material and transport to the Sites 1 and 3 landfill for use as
subgrade fill prior to the placement of a low-permeability cap. After excavating,. soil
samples will be collected and analyzed to confirm that waste removal is complete.
The sampling results will be submitted to the regulatory agencies and the Technical
Review Committee for review. Sites 5 and 6 will be graded to minimize erosion and
seeded to reestablish vegetation. The landfill at Sites 1 and 3, where the material
will be placed, i~ the subject of a separate ROD (NAVY, 1992a) and will be closed
in accordance with all applicable federal and state requirements, and long-term
monitoring will be implemented at these sites. .
v
STATUTORY DETERMINATIONS
The selected remedy meets the mandates of CERCLA Section 121. It protects
human health and the environment, complies with federal and state requirements
that are legally applicable or relevant and appropriate to the remedial action, and
is cost-effective. This remedy does not meet the statutory preference for treatment.
Treatment of asbestos-containing material was not found to be practicable or proven.
Because asbestos is a relatively insoluble material composed of minerals, many
conventional treatment technologies ordinarily considered for contaminated soils are
not applicable to asbestos waste. Vitrification, the only treatment demonstrated to
destroy asbestos, was eliminated because no commercially operating vitrification
plants currently exist for ex-situ vitrification and the presence of metallic objects
buried at the site would not allow effective in-situ vitrification.
Because this remedy will remove contaminated soils and nonhazardous debris from
the site, no long-term controls will be necessary and the five-year review will not
apply.
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The foregoing represents the selection of a remedial action by the Department of the
Navy, and the U.S. Environmental Protection Agency, Region 1, with concurrence of
the Maine Department of Environmental Protection.
By:
~I./ II- ~
obert L Rachar, Jr.
~/.
Date:
31J.~
Title: Captain, U.S. Navy
Commanding Officer
Naval Air Station
Brunswick, Maine
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The foregoing represents the selection of a remedial action by the Department of the
Navy, and the U.S. Environmental Protection Agency, Region 1, with concurrence of
the Maine Department of Environmental Protection.
By:
f~.~t
Date: QuL. > I, I f f!7
, .
Title: Acting Regional Administrator, USEPA
~estoratlon Program
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DECISION SUMMARY
I. SITE NAME, WCATION, AND DESCRIPTION
The U.S. Naval Air Station (NAS) Brunswick is located in Brunswick, Maine. In
1987, NAS Brunswick was placed on the National Priorities List (NPL). There are
currently 13 areas (Sites) within NAS Brunswick under investigation. This Record
of Decision (ROD) relates to the contamination at Sites 5 and 6.
NAS Brunswick is located south of the Androscoggin River between Brunswick .and
Bath, Maine, south of .Route 1 and between Routes 24 and 123 (Figure 1).
Undisturbed topography at NAS Brunswick is characterized by low, undulating hills
with deeply .incised brooks; ground surface elevations range from mean sea level
(MSL) in lowland drainage areas and the Harpswell Cove estuary, to over 110 feet
MSL west and southeast of the southern end of the runways. Topography in the
developed areas of the base has been modified by construction, with ground surface
elevationS generally ranging from 50 to 75 f~et above MSL.
NAS Brunswick is located on 3,094 acres. The operations area (138 acres) lies east
of the two parallel runways and consists of numerous office buildings, a steam plant,
fuel farm, barracks, recreational facilities, base housing, hangars, repair shops, and
other facilities to support NAS Brunswick aircraft. Forested areas (approximately
48 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. The remaining 12 percent of the base includes the operations area
(approximately 5 percent) and miscellaneous shrubland, marsh, and open water. The
southern edge of the base borders the estuary of Harpswell Cove. .
Property uses surrounding NAS Brunswick are primarily subUrban and rural
residential, with some commercial and light industrial uses along Routes 1, 24, and
123. An elemental)' schoo~ a college, and a hospital.are located within 1. mile of the
western base boundary.
Sites 5 and 6. are being considered together based on their shared geologic and
hydrogeologic conditions and historical use as disposal sites for asbestos.
Site 5, located off Merriconeag Road south of the main runway, apparently was used
briefly in 1979 to dispose of asbestos-covered pipe from a building being demolished
on base (Figure 2). . The site was inspected in. 1980 by a facility engineer who
described the site as consisting of two trenches. One of the trenches (measuring 3
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" '.
p
SOUJ:iCE: USGS QUADRANGLE. BRUNSWICK. AND ORRS ISLAND. ME, DATED 1980, 1978. 7.5 MINUTE SERIES.
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CUADIWCGLE IJ)CA~
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o
SCALE IN 'FEET
,
2,000
I
4,000
FIGURE 1
NAS BRUNSWICK
'SITES 5 AND 6 LOCATION
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3BO,250
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380 000
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0 0
0 0
! 10
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LOCATION Of ASBESTOS -
CONTAMINATED MATERIAL
HARDWOOD
HARDWOOD
LEGEND
60
I
-C,L.L.-
CLEARING UMIT UNE
-.5.-
SILTATION FENCE
ASBESTOS tiANDUNG AND
CONTAINMENT/STAGING
AND STORAC£ MfA
FIQlJE 2
REMEDIATION SITE PLAN
srt'E 5
SCALE: 1"=60'
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by 20 by 7 feet deep) contained six I-inch diameter asbestos pipes ranging in length
from 4 to 12 feet. A second parallel trench measuring 15 by 30 by 10 feet deep was
found to contain up to eight pieces of corrugated pipe of varying lengths that had
smaller asbestos pipe inside. The asbestos material was left in the trenches and
covered with soil (Roy F. Weston, Inc., 1983). .
The site is currently covered with soil, seeded, and marked with signs as an asbestos
disposal area. The soil and signs are believed to have been added in 1980. Site 5
is approximately one-quarter acre and is covered mostly with grass. The surrounding
area is tree-covered. The site is level except for a bank that drops off several feet
just southeast of the site. .
"
,
Site 6, the Sandy Road Rubble and Asbestos Disposal Site, is bordered by Sandy
Road to the southeast and by a stream behind Building 516 to the north (Figure 3).
It reportedly was used for general dumping of construction debris until the late
19705. It appears the site was originally a small depression that was later filled with
construction debris and other nonputrescible wastes. Aircraft parts reportedly were
dispQsed of at this site and asbestos-covered pipes were seen protruding from the
surface (Roy F. Weston, Inc., 1983). The site is nearly level except for a large soil
stockpile approximately 15 feet at its highest elevation on the eastern side. Empty
pipes, concrete, asphalt, and other debris ate visible at the site surface. In addition,
steel dumpsters are stored on the southwest comer of the site. Site 6 is
approximately 1 acre.
Groundwater associated with the sites is not used for potable or any other purposes.
. The base is connected to a public water supply administered by the Brunswick-
Topsham Water District.
A more complete description of the sites can be found in the Sections 4.0 and 5.0 of
the Draft Final Supplemental Remedial Investigation (RI) Report (E.C. Jordan Co.,
1991a).
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~
.700
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SCALE: 1" =80'
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LEGEND
-.S'- SILTATION FENCE
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ASBESTOS HANDUNG AND
CONTAINMENT/STAGING
AND STORAGt AREA
FIGURE 3
EXCAVA110N SITE PLAN
SITE 6
38&,760
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II. SITE HISTORY AND ENFORCEMENT ACflVlTIES
A. LAND USE AND REsPONSE HISTORY
NAS Brunswick is an active facility supporting the U.S. Navy's antisubmarine warfare
operations in the Atlantic Ocean and Mediterranean. Sea. The base's primary
mission is to operate and maintain P:-3 Orion aircraft. NAS Brunswick first became
active in the 1940s during World War II, and underwent major expansion in the
1950s.
Site 5 was apparently used once, in 1979, as a disposal area for asbestos-covered
pipes. A f(lf':;; engineer inspecting the site in 1980 described two trenches, one
measuring 3 by 20 by 7 feet deep and the second, alongside the first, measuring 15
by 30 by 10 feet deep. One trench contained six asbestos pipes from 4 to 12 feet
long and the second contained six to eight corrugated pipes with smaller asbestos
pipe inside. Nothing is known about the manner or care with which these pipes were
disposed. The trenches were covered with soiL There is no evidence or record that
this site was used for disposal of any other material.
Site 6 was reportedly used for general dumping of construction debris until the late
. 19705. A site inspection in 1980 reported asbestos-covered pipes protruding from the
surface. Aircraft parts were also reportedly disposed of at Site 6; At the current
time, pipes, concrete, asphalt and other debris are visible af the soil surface.
. .
Geophysical surveys, including magnetometer and ground-penetrating radar (GPR)
surveys, were conducted to confirm tbe presence of reported debris at these sites.
The magnetometer survey identified the presence of buried ferrous (i.e., iron-
containing) material at both sites. GPR profiling was conducted in the vicinity of
magnetic anomalies to correlate with and supplement the magnetic data. While
magnetometry and GPR techniques can indicate the presence of material.below the
ground surface, they do not provide positive identification of asbestos. .
The GPR and magnetometer surveys at Site 5 were conducted to locate the two
trenches where the asbestos-covered pipes were buried. . The magnetometer located
a single primary magnetic anomaly and a second minor anomaly. The primary
anomaly indicates a definite presence of subsurface metallic materials, but the second
minor anomaly is believed to be caused by the presence of surface debris (e.g., old
tin cans). It is possible that the single primary anomaly indicates both trenches and,
because they are directly adjacent, the survey could not distinguish between them.
The GPR smvey did not reveal additional findings but did support the results of the
magnetometer survey.
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GPR and magnetometer surveys were used to assess the areal extent of Site 6.
Unlike Site 5, no single primary magnetic anomaly was found. However, readings
forming a semicircular shape were found across the site. This suggests that the
semicircular region is probably where asbestos and rubble were disposed of at Site 6.
The GPR survey supported these findings. Another anomaly detected at Site 6 was
attributed to dumpsters stored along the southwest edge of the site and is not
considered part of the disposal site.
~
No asbestos was detected in surface soil samples collected from Sites 5 and 6.
Groundwater at Site 6 was monitored to determine if the site was contributing to
organic cont~min~tion detected in groundwater along the eastern boundary of NASB
Brunswick (Le., the. Eastern Plume). No volatile organic or semivolatile organic
compounds (VOCS or SVOCs) were detected in groundwater samples collected from
Site 6. Inorganic analytes detected in the groundwater samples were reported at
concentrations consistent with background concentrations. Groundwater
cont~min~tion resulting from asbestos (the contaminant of concern at Sites 5 and 6)
was. not of concern, because asbestos fibers are very stable in the subsurface
environment and are not likely to migrate (Gilbert, et al., 1981). Therefore,
groundwater at Sites 5 and 6 was not monitored for asbestos.
B. ENFORCEMENT HISTORY
The enforcement history at NAS Brunswick, including Sites 5 and 6, is summarized
as follows: .
.
In 1983, an Initial Assessment Study (IAS) was completed detailing
historical hazardous material usage and waste disposal practices at
NAS Brunswick. Ten sites were identified and ranked according to
potential hazard. . .
.
In 1984, a Pollution Abatement Confirmation Study was conducted.
This study recommended further investigation of seven of the 10
hazardous waste sites originally identified (i.e., Sites 1 through 4 and
7 through 9).
. .
In 1987, NAS Brunswick was placed on the U.S. Environmental
Protection Agency's (USEPA's) NPL
The Remedial IDvestigation/Feasibility Study (RI/FS) process was
initiated in 1987 fQr the seven sites.
.
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.
In February 1988, the first Technical Review Committee (mC)
meeting was held. mc meetings have been held quarterly since that
initial meeting.
.
Four sites were added to the RI/FS program in 1989 (i.e., Sites 11, 12,
13, and 14), as well as the two additional sites originally identified in
the lAS (i.e., Sites 5 and 6). Site 10, originally ~dentified in the lAS,
was no longer under the jurisdiction of NAS Brunswick and is. not
included in the Installation Restoration Program (IRP).
.
In 1990, the Navy entered into a Federal Facility Agreement (FFA)
with the USEP A and the Maine Department of Envi;onmental
Protection (MEDEP) regarding the cleanup of environmental
contamination at NAS Brunswick. The 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 Draft Final RI
Report described field sampling investigations, geology, and
hydrogeology, and presented contamination and risk assessments. The
Draft Final Phase I FS identified remedial action objectives, and
developed and screened remedial alternatives for the nine original sites
studied in the Draft Final RI. The l'iavy prepared Focused Feasibility
Study (FFS) Reports for Sites 1 and 3 and Site 8 in 1991 and 1992,
respectively (E.c. Jordan Co., 1991c and 1992b). The Navy submitted
a Draft Final Supplemental RI Report for the Eastern Plume and
Sites 5, 6, 8, 12, and 14, an FFS Report for Sites 5, 6, and 12, and an
FS for Sites 2,.4, 7, 9, 11, and 13 in August and July of 1991, and
March 1992, respectively (E.C. Jordan Co., 1991a, 1991b, and 1992a)~
.
Currently, the Navy is studying 13 sites under the IRP.
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
exists to proceed to the ROD and design phases of the - remediation process.
Separate timetables have been established for completing the Final FS reports and
RODs for these. sites. The Navy has identified Sites 5 arid 6 as a distinct area of
contamination and believes the remediai process can be initiated. FFSs for Sit~s 1
and 3~ Sites 5 and 6, and Site 8 and an FS for nine other sites (Sites 2, 4, 5, 6, 7, 9,
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11, 12, and 13) have been submitted to the regulatory agencies for review (E.C.
Jordan Co., 1991c, 1991b, 1992a and 1992b). Final RODs for Sites 1 and 3, and
Site 8 have been signed (NAVY, 1992a and 1993c). In addition, an Interim ROD
for the Eastern Plume has also been signed (NAVY, 1992b).
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III. COMMUNITY PARTICIPATION
Throughout the sites' investigative and remediation history, the community has been
active and involved in the IRP at NAS Brunswick. Community members and other
interested parties have been informed of site activities through informational
meetings, fact sheets, press releases, public meetings, and TRC meetings.
"
c
In August 1987, the Navy established an information repository for public review of
site-related documents at the Curtis Memorial Library in Brunswick. On March 22,
1993, the Navy placed the Proposed Plan and Technical Memorandum detailing the
Preferred Alternative for Sites 5 and 6 in the information repository at the Curtis
Memorial Li~rary, (ABB-ES,1993b and 1993a). The Administrative Record for
Sites 5 and 6 is available for public review at NAS Brunswick in the Public Works
office and at the Curtis Memorial Library. A n9tice and brief analysis of the
Proposed Plan was published in the local newspaper, The Times Record, on March 18,
1993.
On April 8, 1993, the Navy held an informational meeting and public hearing to
discuss the Proposed Plan for Sites 5 and 6. During this meeting, the Navy, its
consultants, and regulatory representatives answered questions from the public and
accepted formal comments. During a public comment period from March 29 to
April 27, 1993; the Navy accepted comments on the alternatives presented in the
Proposed Plan for Sites 5 and 6. The corresponding responses to comments are
included in Appendix A, Responsiveness Summary, of this ROD.
The mc has been an important vehicle for community participation. The"IRC was
established in early 1988 and comprises the 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, who became active. participants subsequent
to 1988. The TRC also has representatives from the Brunswick-Topsham Water
District. The mc meets quarterly, t:eviews 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 public concerns and keep citizens informed about and involved
in remedial activities. On August 16, 1990, the Navy held an informational meeting
at the Jordan Acres School in Brunswick to discuss the results of the RI.
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IV. SCOPE AND ROLE OF RESPONSE ACTION
The selected remedy for Sites 5 and 6 was developed in response to citizen concerns
that all debris and asbestos-containing material be removed from the site so that no
restrictions would be placed on future site use. The proposed alternative will be the
final action for Sites 5 and 6. This remedy involves excavating nonhazardous
construction rubble and debris from Site 6, excavating and containerizing asbestos-
contaminated material from Sites 5 ,and 6, and placing this material as subgrade fill
beneath the approved landfill cap at Sites 1 and 3. Fill material is needed to meet
regulatory design criteria for cover system slopes and promote positive drainage away
from the cap at Sites 1 and 3. The landfill cap exceeds MEDEP regulations for
closure ,of asbestos waste disposal sites and RCRA Subtitle D requirements for
closure, of solid waste landfills, and is an approved modification to \ffiDEP
regulations for the closure of solid waste disposal sites. Although human health risks
are not a concern under current land use, this alternative prevents future potential
exposure to asbestos. In addition, because no waste or debris would remain at either
site, there would be no need for land-use restrictions, institutional controls, or five-
year site reviews.
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v. SUMMARY OF SITE CHARACTERISTICS
The nature and extent of contamination at Sites 5 and 6 are summarized by medium
in the following paragraphs. A complete discussion of the site characteristics can be
found in Sections 4.0 and 5.0 of the Draft Final Supplemental RI (E.C. Jordan Co.,
1991a). Additional fieldwork was conducted at Site 6 during the spring of 1993 to
support design activities. The results of this field effort are also summarized below.
RI field activities included a geophysical survey consisting of GPR profiling and a
magnetometer survey, sampling of surface soils, and a detailed surface inspection at
both sites; as well as monitoring well installations, groundwater sampling and
an,alysis, and aquifer permeability testing at Site 6.
SOIL/WASTE AREA
The magnetometer survey identified the presence of buried ferrous material at both
. sites. GPR profiling was conducted in the vicinity of magnetic anomalies to correlate
with and supplement the magnetic data. The GPR and magnetometer surveys at
Site 5 were conducted to locate the two trenches where the asbestos-covered pipes
were buried. The magnetometer located a single primary magnetic anomaly and a
second minor anomaly. The primary anomaly indicates a definite presence of
subsurface metallic materials, but the second minor anomaly is believed to be caused
by the presence of surface debris (e.g., old tin cans). It is possible that the single
. primary anomaly indicates both trenches and, because they are directly adjacent, the
survey could not distinguish between them. The GPR survey did not reveal
additional findings but did support the results of the magnetometer survey.
GPR and magnetometer surveys were used to assess the areal extent of fill at Site 6.
Unlike Site 5, no single primary magnetic anomaly was found. However, readings
forming a semicircular shape were found across the site. This. suggests the
. semicircular region is probably where asbestos and rubble were disposed of at Site 6.
The GPR survey supported these findings.
A detailed visual surface inspection was made to identify any exposed asbestos
materials. Although asbestos-covered pipe was seen protruding from the surface at
Site 6 in the .past(Roy F. Weston, Inc., 1983), no evidence of exposed asbestos
materials currently exists at either Site 5 or 6.. Site 5 is marked as an asbestos
disposal site with two wanring signs; surface debris (e.g., metal buckets, tin cans, and
bottles) is scattered about the site. Four surface soil samples were collected from
Site 5 and analyzed for asbestos. The locations of the surface soil samples were based
on the geophysical survey and surface inspection. Asbestos was not detected in any
samples. .
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Six surface soil samples were collected at Site 6. The sampling locations were
established within the semicircular region identified by the magnetometer survey.
One of the six samples, collected just south of the magnetic anomaly, was of material
resembling pipe covering. The samples were 'analyzed for the presence of asbestos
material; asbestos was not detected in any of the samples.
Seven test pits/trenches were excavated in the Site 6 area in March 1993 to better
delineate the area of rubble and debris disposal. Fill material was encountered
beyond the semicircular magnetic anomaly at depths ranging from 2 to 16 feet below
ground surface (bgs). Soil samples were collected from these test pits and analyzed
for asbestos, Target Compound List (TCL), VOCS, SVOCs, Target Analyte List
(TAL) inorganics, and subjected to the Toxicity Characteristic Leachate Procedure
(TCLP). N( , ~1:>estos was detected in any samples. No unanticipated contamination
was detected in the soil samples collected from the test pits. Low levels of pesticides
(e.g., less than 150 micrograms per kilogram [lLg/kgD and VOCs (e.g., less than 30
p.g/kg) were detected in these soil samples, and SVOCs were detected in soils at
concentrations ranging from below detection limits to 19 milligrams per kilogram.
No samples failed the TCLP.
Asbestos is. a common rock-forming mineral of the amphibole mineral group.
Asbestos minerals have very low to negligible water solubility, and therefore are very
.stable in the near-surface environment (Gilbert. et al, 1981). . Because of the low
water solubility of asbestos, the. only significant migration pathways are as solid
asbestos particles in air and surface water. Because the asbestos is currently
underground and above the water table, these two means of transport are unavailable
. to asbestos at Sites 5 and 6.
GROUNDWATER
An interpretation of groundwater flow at Site 5 is based OD: the observed regional
hydrogeologic conditions hi this portion of the base. Specifically, groundwater
. fufmmation generated for Sites 1 and 3 and the southern portions of the Eastern
Plume area provide hydrogeologic data that should be generally consistent withiri the
Site 5 area. Groundwater at this site is expected to flow within the stratjfied
sand/silty sand/clay soils that overlie the Presumpscot clay unit throughout the base.
Groundwater at this site is expected to flow southeast and ultimately discharge to
Mere Brook. Mere Brook is located approximately 1,000 feet southeast of Site 5.
Estimates of the depth to groundwater based on regional hydrogeology suggest that
groundwater is approximately 25 to 30 feet below ground surface (bgs). Based on
the 1980 mspection report, this would indicate that asbestos-:-conta1ning materials are
buried above the groundwater table at Site 5. Since aSbestos fibers do not migrate
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in the subsurface environment (Gilbert et aI., 1981), groundwater at Site 5 was not
monitored. .
Shallow groundwater generally flows southeast and is located approximately 15 to
20 feet bgs at Site 6. Asbestos at Site 6 is also above the groundwater table, and
therefore the groundwater was not monitored for asbestos. However, four
monitoring wells were installed at Site 6 as part of the screening program conducted
to establish the sources and extent of contamination for the Eastern Plume. Samples
were analyzed for TCL organics and TAL inorganic compounds. The only SVOC
detected, bis(2-ethylhexyl)phthalate, was determined to be related to laboratory
contamination, not site contamination. No VOCs, pesticides, or polychlorinated
biphenyls were detected. . Inorganic compounds were detected at concentrations
consistent with background values. .
Groundwater at Site 6 was found to contain calcium, sodium, manganese,
bicarbonate, chloride, and sulfate, which are inorganics normally found in
groundwater.. These inorganics were detected at concentrations consistent with
background concentrations for NAS Brunswick and are not considered to pose a
health hazard (E.C. Jordan Co., 1991a). Background samples were collected from
uncontaminated wells upgradient of several. $ites at NAS Brunswick (E.C. Jordan Co.,
1990a).
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VI. SUMMARY OF SITE RISKS
A baseline risk assessment was performed to estimate the potential risks to human
health and the environment from exposure to contaminants associated with Sites 5
and 6 (E.C. Jordan Co., 1991a). The human health risk assessment followed a f()ur-
step process: (1) contaminant identification, which identified those hazardous
substances that, given the specifics of the site, were of significant concern;
. (2) exposure assessment, which identified actual or potential exposure pathways,
characterized the potentially exposed populations, and estimated the extent of
possible exposure; (3) toxicity assessment, which considered the types and m~jtude
of adverse health effects associated with exposure to hazardous substances; and
(4) risk characterization, which integrated the three earlier steps to summarize the
potential and actual risks posed by hazardous substances at the site, including
carcinogenic and noncarcinogenic risks. The results of the baseline risk assessment
are summarized in the following paragraphs: .
The contaminant of concern identified for the Sites 5 and 6 human health risk
assessment is asbestos, which is a carcinogen by the inhalation route of exposure.
Asbestos was not detected in any soil samples collected at Site 5 or Site 6. It is
known that asbestos pipe is buried at Site 5 and presumed to be buried at Site 6;
aowever, no data exist to quantify potential exposure to this material and subsequent
~~. .
Site 5 is' not located near any recreational areas and is remote from base housing.
Site 6 is more centrally located. Neither site is fenced, although Site 5 is posted with
signs as an asbestos disposal area. Potential current use of the sites is by older
children trespassing on site to play. Any asbestos present at depth is considered to
be stable and not likely to migrate. While there is a human health risk associated
with future potential exposure to asbestos during construction or excavation-related
activities, quantitative risks cannot be estimated because no subsurface samples were
colle~ed. The potential for increased future risks. remains if any asbestos is
uncovered by activities at. either site.
The potential for harmful impacts associated with exposure to .site-related
contamination by environmental receptors was evaluated in the Ecological Risk
Assessment (E.C. Jordan Co., 1990). The various types of ecological habitats at NAS .
Brunswick and the environmental receptors associated with these. habitats are
described in detail in the Ecological Risk Assessment. Additional data gathered
during the October 1990 and March 1993 sampling rounds are consistent with the
conclusions of this assessment. The concentration of contaminants in surface soils
at Sit~ 5 and 6 were within background concentrations (E.C. Jordan Co., 1990) and
are not expected to adversely affect environmental receptors. .
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VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A. STATUTORY REQUIREMENTS/RESPONSE OBJECTIVES
Under its legal authorities, the lead agency's (i.e., Navy's) primary responsibility at
NPL and similar sites is to undertake remedial actions that are protective of human
health and the environment. In addition, Section 121 of CERClA establishes several
other statutory requirements and preferences, including a requirement that the Navy's
remedial action, when complete, must comply with all federal and more stringent
state environmental standards, requirements, criteria or limitations, unless a waiver
is invoked; a requirement that the Navy select a remedial action that is cost-effective
and that uses permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable; and a preference for
remedies in which treatment that permanently and significantly reduces the toxicity,
mobility, or volume of the hazardous substances is a principal element over remedies
not involving such treatment. Remedial alternatives were developed to be consistent
with these congressional mandates.
,
o
Based on preliminary information relating to the types of contaminants,
environmental media of concern, and potential exposure pathways, remedial actien
objectives were established to aid in the development and screening of alternatives.
The remedial action objectives for Sites 5 and 6 were established to. mitigate existing
and future potential threats to public health and the environment, comply with state
requirements, and address community concerns, and include:
.
preventing future potential risks from exposure to airborne asbestos;
.
complying with Maine solid waste landfill closure requirements; and
.
complying with the community's desire for less restrictive land use on
base property.'. . .
B. TECHNOLOGY AND ALTERNATIVE DEVELOPMENT AND SCREENING
The Comprehensive Environmental Response, Compensation, and liability Act
(CERCI.A) and the National Contingency Plan (NCP) set forth the process by which
remedial actions are evaluated and selected. In accordance with these requirements,
a range of alternativf;s was developed for the site.
Remedial. action alternatives for NAS Brunswick were developed to meet the
following requirements: (1) the alternative adequately protects public health and the
. environment; (2) the alternative can attain chemical-specific Applicable or Relevant
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and Appropriate Requirements (ARARs) and can be implemented in a manner
consistent with locatlon- and action-specific ARARs; (3) the alternative uses
permanent treatment technologies to the maximum extent practicable; (4) the
alternatives developed are capable of achieving a remedy in a cost-effective manner,
considering short- and long-term costs; and (5) alternatives that permanently and
significantly reduce the toxicity, mobility, or volume of hazardous substances will be
selected, to the maximum extent practicable.
The Supplemental FS for Sites 5, 6, and 12 screened technologies based on site- and
waste-limiting characteristics (E.C. Jordan Co., 1991b). Of 16 technologies screened;
10 were retained and combined into remedial action alternatives. Section 5.0 of the
Supplemental FS presented the remedial alternatives developed by. combining the
technologies identified in the. screening process in the categories denoted in.
Section 300.430(e)(3) of the NCP. The purpose of the initial screening was to
narrow the number .of potential remedial actions for further detailed analysis while
preserving a range of options. Each alternative was then evaluated and screened
according to its implementability, effectiveness, and cost.
Of the six remedial. action alternatives screened in the Supplemental FS, the
following three alternatives were retained for the detailed evaluation in the FS:
.
Minimal Action
Low-permeability Cover
Excavation/Off-Site Disposal
.
.
A No Action Alternative was. added and is used as the baseline alternative. In
addition, two alternatives were evaluated after completion of the FS. A
Consolidation/Low-permeability Cover System Alternative and an Excavation/Use
of Subgrade Fill at Sites 1 and 3 Alternative are presented in the Draft Final
Proposed Plan for Sites 5 and 6 (ABB-ES, 1993b). The ExcavationjUse as Subgrade
.Material at Sites 1 and 3 is also diScussed in a Technical Memorandum (ABB-ES,.
1993a). The six alternatives evaluated are listed in Table 1 and discussed in the
following section.
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TABLE 1
SUMMARY OF REMEDIAL ALTERNATIVES
ROD: SITES 5 AND 6
NAS BRUNSWICK
ALTERNATIVE COMPONENTS
5,6-A: No Action No remedial action
5,6-8: Minimal Action Fencing and sign posting
Land-use restrictions
Annual inspections/maintenance
Five-year reviews
5.6-C: Low-permeability .Cover Site preparations
Low-permeability cover system
Fencing and sign posting
Land-use restrictions
Annual inspections/maintenance
Five-year reviews
5,6-D: Excavation/Otf-Site Disposal Site preparations
Excavation/containerization/transport
Confirmation sampling
Backfill/grade/seed .
5,6-E: Consolidation/Low-permeability Cover Site preparation
Excavation/containerization/transportation of
Site 5 materials to Site 6
Low-permeability cover system Site 6
Backfill/grade/seed
Land-use restrictions
Annual inspections/maintenance
Five-year reviews
5,6-F: Excavation/Use as Subgrade Material at Site preparation
Sites 1 and 3 Excavation
Containerization
Transportation
Confirmatory sampling
. Backfill/grade/seed
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VIII. DESCRIPTION OF ALTERNATIVES
This section summarizes eacb of tbe remedial alternatives developed and evaluated
in the FS (E.C. Jordan Co., 1992a). Because the alternatives evaluated for Sites 5
and 6 were the same, the descriptions are combined herein. Each alternative is
briefly described below and discussed in more detail in Sections 5.0 and 6.0 of the
FS Repon (E.C. Jordan Co., 1992a). The' Excavation/Off-site Disposal Alternative
for Site 6 is slightly different from the alternative presented in the FS, because it
considers complete removal of all debris and asbestos-containing material rather than
excavating only asbestos-containing material. Two other alternatives that were not
evaluated in the FS, Consolidation/Low-penneability Cover System, and Excavation/
Use as Subgrade Material at Sites 1 and 3 are presented here as Alternative 5,6-E
and 5,6-F, respectively. A Technical Memorandum for Sites 5 and 6 was prepared
which presented a detailed evaluation of the Alternative 5,6-F (but was incorrectly
referenced as 5,6-E). This evaluation describes the Excavation and Use as Subgrade
Material at Sites 1 and 3 Alternative and presents the detailed evaluation of this
alternative against the nine evaluation criteria specified in the National Oil and
Hazardous Substances Pollution Contingency Plan. It is similar in content and
format to the detailed evaluation of the other alternatives developed for these sites
and presented in the FS. These alternatives are described in the Proposed Plan for
Sites 5 and 6 (ABB-ES, 1993b).
, ALTERNATIVE 5,6-A: NO AcrION
The No Action Alternative does not include any remedial actions and provides a
baseline for comparing alternatives. Under the No Action Alternative, the sites
would remain undisturbed. Because no remedial actions would be implemented, no
costs would be incurred and long-term human health risks for the site would
essentially be the same, as those identified in the baseline risk assessment No
current risks are present at either site because asbestos materials are cgvered with
,soil. Site 5 is currently marked by warning signs. . .
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ALTERNATIVE 5,6-8: MINIMAL ACTION
This alternative would consist of the following components:
.
land-use restrictions
fencing/sign posting
environmental monitoring
five-year reviews
.
.
.
The Minimal Action Alternative for both Site 5 and Site 6 would use institutional
controls to limit future activity at the sites. Annual inspections and five-year site.
reviews would be conducted. . .
Land-use restrictions would be used to restrict fut~re site use, thereby limiting the
potential for human exposure to asbestos. The legal implications of instituting land-
use restrictions would be coordinated with appropriate Navy officials and state and
local governments. If NAS Brunswick closes, land-use restrictions would be
completed in accordance with requirements stated in National Emissions Standards
for Hazardous Air Pollutants (NESHAPS) (40 CFR 61.151[e]). Fencing and warning
signs would. be placed. around each site to reduce public access and potential
exposure to soil contaminants. The fence was assumed to be a 6-foot-high chain-link
fence for cost-estimating purposes. Warning signs would be posted along the fence
at 50-foot intervals and there would be one access gate at each site. For cost-
estimating purposes, it was assumed that environmental monitoring would be
conducted annually for 30 years.
Site 5:
Estimated Time for Design and Construction: 2 months
Estimated Time of Operation: 30 years
Estimated Capital Cost: $14,000. .
Estimated Operations and Maintenance Costs (net present worth at a 10%
discount rate): $55,000
Estimated Total Cost (net present worth at a 10% discount rate): $83,000
Site 6:
Estimated Time for Design and Construction: 2 months
Estimated Time of Operation: 30 years
Estimated Capital Cost: $28,000
Estimated Operations and Maintenance CostS (net present worth at a 10%
discount rate): $84,000
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Estimated Total Cost (net present worth at a 10% discount rate): $134,000
ALTERNATIVE S,6-C: LOW-PERMEABILITY COVER
This alternative would consist of the following components:
.
site preparation
cover construction
fencing/sign posting
institutional controls
site inspections and maintenance
environmental monitoring
five-year reviews.
land-use restrictions
.
.
.
.
..
..
.
The Low-permeability Cover Alternative was evaluated separately for each site. The
. cover system would be designed to meet current Maine regulations for closure of
asbestos waste disposal sites because these requirements are more stringent than the
cover system requirements outlined in NESHAPS. The cover system would contain
asbestos, eliminate the possibility of future contact and inhalation, and prevent
generation of asbestos dust. Closure of the sites would also require land-use
restrictions, fencing, and warning signs as described for the Minimal Action
Alternative. Annual inspections would occur and repairs would be conducted as
appropriate to confirm the integrity of the fence and cover system Five-year reviews
wquld be required under CERClA. For cost-estimating purposes, it was assumed
that environmental monitoring and five-year reviews would be conducted for 30.
years.
Site 5:
Estimated Time for Design and Construction: 6 months
Estimated Time of Operation: 30 years
Estimated Capital Cost: $58,000
Estimated Operations .and Maintenance Costs (net present worth at a 10%
discountrare):$8~000
Estimaied Total Cost (net present worth at a 10% discount rate): $170,000
Site 6:
Estimated Time for Design and Construction.' 7 months
Estimated Time' of Operation: 30 years
Estimated Capital Cost: $133,000
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Estimated Operations and Maintenance Costs (net present worth at a 10%
discount rate): $84,000
Estimated Total Cost (net present worth at a 10% discount rate): $260,000
ALTERNATIVE 5,6-D: EXCAVATION/OFF-SITE DISPOSAL
This alternative would consist of the following components:
.
site preparation
excavation and transport of material
containerization of asbestos material
confirmation sampling
grading and seeding of excavated area
"
.
.
.
.
The Excavation/Off-site Disposal Alternative for Site 5 involves removing all
materials containing asbestos from the site, approximately 12 cubic yards, and
disposing of them in an off-base landfill permitted to receive asbestos wastes. The
Excavation/Off-site Disposal Alternative for Site 6 involves excavating all debris from
Site 6 and disposing of it in a proper off-site facility. Initial estimates assumed
approximately 8,800 cy of material which included approximately 250 cy of asbestos-
containing material and approximately 8,550 cy of construction debris and rubble
would be excavated at this site. Additional field investigations determined a larger
areal extent of material; the debris at Site 6 consists of approximately 18,700 cy
which includes approximately 250 cy of asbestos-containing material and
approximately 18,450 cubic yards of construction rubble and debris. However, the
cost for this alternative is based upon 8,800 cy of material. Proper health and safety
procedures would be followed during the removal and transportation of "asbestos-
containing material. The sites would not need to be closed as asbestos disposal sites,
as the Low-permeability Cover Alternative would require. Remedial activities after
excavation at Sites 5 and 6 under this alternative would require filling of the
excayations, and restoring the sites to a natural condition.
A confirmation sampling program would be developed and submitted for regulatory
review. The sampling plan would identify the sampling frequency for collecting soil
samples from the side walls and bottom of the excavation at both Sites 5 and 6. Soil
samples would be analyzed for asbestos at Site 5, and TCL and TAL constituents and "
asbestos at Site 6. All analytical results would be available for regulatory and mc
review. Because asbestos material would be remov~d from the sites, no long-term
monitoring or five-year reviews would be required. "In addition, no land-use
"restrictions would be applied to these sites.
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Site 5:
Site 6:
Estimated Time for Design and Construction: 6 months
Estimated Time of Operation: not applicable
Estimated Capital Cost: $90,000
Estimated Operations and Maintenance Costs (net present worth at a 10%
discount rate): not applicable
Estimated Total Cost (net present worth at a 10% discount rate): $108,000
Estimated Time for Design and Construction: 9 months
Estimated Time of Operation: not applicable
Estimated Capital Cost: $3,065,000
Estimated Operations and Maintenance Costs (net present worth at a 10%
d~countrat~:notapplicabk
Estimated Total Cost (net present worth at a 10% discount rate): $3,678,000
Costs for confirmatory sampling during excavation are not included.
. ALTERNATIVE S,6-E: CONSOLIDATION/LOW-PERMEABILI1Y COVER
This alternative would consist of the following components:
.
site preparation
excavation and transport of material from Site 5
containerization of asbestos material at Site 5 .
placement of excavated material at Site 6
cover construction at Site 6
grading and seeding
institutional controls
site ~pections and maintenance
environmental monitoring
five-year reviews
land-use restrictions
.
.
.
.
.
.
.
.
.
.
This alternative includes excavating asbestos-cov~red pipes from Site 5, transporting
them to Site 6, and constructing a low-permeability soil cover that would be designed
and constructed to meet the performance requirements of the MEDEP regulations
for tbe closure of construction debris landfills. Tbe state Tequirements are more
stringent than tbose requirements outlined in NESHAPS. . Proper health ci.nd safetY
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pracedures wauld be fallawed during the remaval 'af asbestas at Site 5 and transpart
ta Site 6.
The cast estimate assumes the use .of 18 inches .of clay and 6 inches .of vegetative
caver ta camply with the Maine Salid Waste Management Regulatians far the
clasure .of canstructian debris landfills. The Salid Waste Management Regulatians
are applicable far this alternative because the site wauld still cantain salid waste.
These salid waste requirements are mare stringent than the state .or federal
requirements far asbestas dispasal sites as well as the. federal salid waste
requirements. Annual inspectians, five-year reviews, and land-use restrictians at Site
6 wauld be required as part .of this alternative.
Sites 5 and 6:
Estimated Time for Design and Construction: 7 months
Estimated Time of Operation: Minimum of 30 years of cover maintenance
Estimated Capital Cost: $249,000
Estimated Operations and Maintenance Costs (net present wonh at a 10%
discount rate): $84,000
Estimated Total Cost (net present wonh at a 10% discount rate): $400,000
ALTERNATIVE 5,6-F:
EXCAVATION/USE AS SUBGRADE MATERIAL AT
SITES 1 AND 3
This alternative wauld cansist .of the fallawing campanents:.
8
site preparatian
excavation and transpart .of material
cantainerizatian .of asbestas material
grading and seeding .of excavated areas
.8
8
8
This alternative' invalves excavating nanhazardaus constructian rubble and debris
from Site 6, excavating and containerizing asbestos-containing material from Sites 5
and 6, and transparting these materials, as well' as the stackpiled sail at Site 6, far
use as subgrade fill beneath the landfill cap ta be constructed at Sites 1 and 3. It has
been estimated that approximately 12 cy and 250 cy .of asbestas-containing material
will be excavated from Sites 5 and 6, respectively. The Sites 1 and 3 landfill cap,
which was selected as the remedy in a ROD (NAVY, 1992a) for these sites, exceeds .
MEDEP regulations for the closure of asbestos waste diSposal sites and RCRA
Subtitle D requirements for clasure of solid waste landfills, and is an approved
madificatian to. MEDEP regulatians far the closure .of salid waste dispasal sites.
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Although human health risks are not a current concern, this alternative would
prevent future contact with asbestos.
Q
Q
A confirmation sampling program would be developed and submitted for regulatory
review. The sampling plan would identify the sampling frequency for collecting soil
samples from the side walls and bottom of the excavation at both Sites 5 and 6. Soil
. samples would be analyzed for asbestos at Site 5, for TCL and TAL constituents and
asbestos at Site 6. All analytical results would be available for regulatory and TRC
review.
As stated, initial estimates assumed approximately 8,800 cy of material to be
excavated at Site 6. Additional field investigations determined a larger areal extent
of material and larger volume of materiai to be excavated (approximately 18,700 cy).
However, the cost for this alternative is based upon excavation of 8,800 cy of
material to be excavated at Site 6. No long-term monitoring, five-year reviews, or
land-use restrictions would apply at either Site 5 or 6. The cost and time estimates
for this alternative are: . .
Estimated Time for Design and Construction: 4 months
Estimated Time of Operation: not applicable.
Estimateq Capital Cost: $568,000
Estimated Operations and Maintenance Costs (net present worth at a 10%
discount rate): not applicable.
Estimated Total Cost (net present worth at a 10% discount rate): $681,000
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IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 121(1))(1) of CERClA presents several factors that, at a minimum, the Navy
is required to consider in its assessment of alternatives. Building upon these specific
statutory mandates, the NCP lists nine evaluation criteria to be used in assessing the
individual remedial alternatives.
A detailed analysis was performed on the alternatives using the nine evaluation
criteria to select a site remedy. The following is a summary of the comparison of
each alternative's strengths and weaknesses with respect to the nine evaluation
criteria. These criteria and their definitions are as follows:
Threshold Criteria
. Tbe two threshold criteria described below must be met for the alternatives
to be eligible for selection in accordance with the NCP.
1.
Overall protection of human health and the environment
addresses whether or not a remedy provides adequate
protection and describes how risks posed by each pathway are
eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls; . .
2.
Compliance with ARARs describes how the alternative complies
with chemical-, location-, and action-specific ARARs, or other
criteria, advisories, and guidance.
Primary Balancin~ Criteria
The following five criteria are used to compare and evalUate the elements of
one alternative to another that meet the threshold criteria.
3.
4.
Long-term effectiveness and permanence evaluates the
effectiveness of alternatives in protecting human health and the
environment after response objectives have been met; in terms
of the magnitude of residual risk and the adequacy and
reliability of controls.
Reduction of toxicity, mobility, or volume through treatmeD~
evaluates the treatment technologies by the degree of expected
reduction in toxicity, mobility, or volume of hazardous material.
This criterion also evaluates the irreversibility of the treatment
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process and the type and quantity of residuals remaining after
treatment.
5.
Short-term effectiveness addresses the period needed to achieve
protection and any adverse impacts on human health and the
environment that may be posed during the construction and.
implementation period, until the remedial action objectives are
achieved.
6.
Implementability assesses the ability to construct and. operate
the technology; the reliability of the technology; the ease of
undertaking additional remedial actions; and the ability to
monitor the effectiveness of the remedy. Adm1tistrative
feasibility is addressed in terms of the Cibility to obtain
. approvals from other agencies. This criterion also evaluates the
availability of required resources, such as equipment, facilities,
specialists, and capacity.
7.
Cost evaluates the capital and operation and maintenance costs
of each alternative, and provides an estimate of the total
present worth cost of each alternative.
Modifyine Criteria
The modifying criteria are used in the final evl.luation of remedial alternatives
generally after public comment on the RI/FS and Proposed Plan has been
received.
8.
State acceptance addresses whether, based on its review of the
RI/FS and Proposed Plan, the state concurs With, opposes, or
has no comment on the alternative the Navy proposes for the
remedial action. .. .
The State of Maine has commented on the proposed plan and
has documented its concurrence with the remedial action in the
letter of concurrence presented in Appendix B of this ROD.
9.
Community acceptance addresses .whether the public concurs
with the' Navy's Proposed Plan. Community acceptance of the
Proposed Plan was .evaluated based on comments received at
. the public hearings and during the public comment period.
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This is documented in the Responsiveness Summary presented
in Appendix A of this ROD.
The state acceptance criterion has been addressed by incorporating comments
received from the state on the Proposed Plan. The state is a party to the FF A and
has had the opportunity to review and comment on all documents. Community
acceptance criterion is addressed as part of the Responsiveness Summary in
Appendix A of this ROD.
Following the detailed analysis of each individual alternative, a comparative analysis,
focusing on the relative performance of each alternative against seven of the nine
criteria, was conducted. The comparative analysis of four alternatives. for Sites 5 and
6 can be found in Taples ,5-4 and 6-4 of the FS, respectively (E.C. Jordan Co.,
1992a). Two additional alternatives were presented in the Proposed Plan:
Consolidation/Low":permeability Cover and Excavation and Use as Subgrade
Material at Sites 1 and 3. The comparative analysis of all six alternatives can be
found in Section 8 of the Proposed Plan (ABB-ES, 1993b).
The section below presents the nine criteria and a brief summary of each alternative
and its strengths and weaknesses according to the detailed and comparative analyses.
Overall. Protection of .Human Health and the Environment
The Selected Alternative, Excavation and Use as Subgrade Material at Sites 1 and
3, would prevent future potential exposure to asbestos by removing these
contaminants from Sites 5 and 6 and placing them in the Sites 1 and 3 landfill
subgrade for the proposed cover system. The Excavation/Off-site Disposal and
Consolidation/Low-permeability Cover alternatives for Sites 5 and 6 would also
prevent future potential exposure to asbestos.. Engineering controls would be
~equired to minimize exposure to airborne asbestos during any excavation activities
.conducted as part of these alternatives. .. .
The Minimal Action and Low-permeability Cover alternatives for both Sites 5 arid
6 reduce potential risk through land-use restrictio~ The No Action Alternative for
Sites 5 and 6 does not include land-use restrictions and, therefore, would not be
protective of human health if the sites were developed for residential use. Under
current conditions, all of the alternatives provide adequate protection to human
health and the environment, because there is no cun:ent exposure to asbestos at
either Site 5 or 6. .
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Compliance with Applicable or Relevant and Appropriate Requirements
, '
The cover system component of the Selected Alternative at Sites 1 and 3, which
meets RCRA Subtitle C requirements, meets or exceeds the performance
requirements of the Maine Landfill Disposal Regulations for the Management,'
Testing, and Disposal of Special Wastes (38 MRSA Section 1304, Chapter 405.4)
governing disposal of asbestos, and is an approved modification to the most stringent
ARAR, the State of Maine Solid W8$te Management Regulations (Chapter 401.7)
governing the closure of solid waste landfills. The State of Maine requirements
pertaining to the storage, transport and disposal of asbestos wastes (MEDEP
Regulations, Chapter 405.4) will also be met. It should be noted that although the
cover system at Sites 1 and 3 meets or exceeds state and federal requirements for
asbestos ane . '~~truction debris, the landfill at Sites 1 and 3 is an unlicensed facility
with regard to the asbestos disposal requirements of these regulations. However, the
Maine Division of Solid Waste Facility Licensing has stated that a license is not
required since disposal of the material at Sites 1 and 3 would be part of a remedial
action at a CERCLA site (MEDEP, 1993). The Low-permeability Cover and the
Consolidation/LOw-permeability Cover alternatives for Sites 5 and 6 would also
comply with these ARARs. . ,
The' Excavation/Off-site Disposal and Consolidation/Low-permeability Cover
alternatives for Sites 5 and 6 and the Excavation ~d Use as Subgrade Material at
Sites 1 and 3 (the Selected Alternative) would be conducted in accordance with
NESHAPS and Occupational Safety and Health Administration (OSHA)
requirements. Fugitive dusts from clearing, grading, and excavation activities would
be controlled (e.g., by using water sprays) to meet the requirements of NESHAPS.
Respiratory protection used during remedial activities would comply with OSHA (29
CPR 1926.58).
Location-specific ARARs require that erosion control measures suCh as revegetation
, and' erosion control fencing be used during excavation and grading to prevent
sediment transport off site. The No Action and Minimal Action alternatives for both
, Sites 5 and 6 would not meet the Maine reqUirements for closure of asbestos waste
disposal sites (38 MRSA Section 1304, Chapter 405.4).
Refer to Appendix C-l for additional information on ARARs.
Transport of material from Sites 5 and 6 to Sites 1 and 3 requires consideration of
additional ARARs for Sites 1 and 3 than those specified in the ROD for Sites 1 and
3. These ARARs are summarized in Table C-4 in Appendix C of this ROD and will
be discussed further in an Explanation of Significant Difference (ESD). ,The ESD
\
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WOO2937S.mIO
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will be incorporated in the Administrative Record for Sites 1 and 3. The movement
of material from Sites 5 and 6 will not occur until after the ESD is issued. .
Long-term Effectiveness and Permanence
Excavation of asbestos-containing materials under the Selected Alternative,
Excavation and Use as Subgrade Material at Sites 1 and 3 and the Consolidation/
Low-permeability Cover and Excavation/Off-site Disposal alternatives would be
effective in eliminating long-term risks at Site 5 and would allow for nnHmited use
of the area following remedial action. The Excavation/Off-site Disposal Alternative
and Excavation and Use as Subgrade Material at Sites 1 and 3 (the Selected
Alternative) would 'also allow for unlimited use and eliminate potential risks at
Site 6. The Low-pemieability Cover Alternative for Sites 5 and 6 would effectively
cover the sites and limit site access, but would require long-term inspection and
maintenance. The Minimal Action Alternative for Sites 5 and 6 would limit access
and future land use as long as the restrictions were enforced. No unacceptable risk
currently exists at either site. However, there is a risk associated with uncontrolled
exposure to asbestos in the future, so the No Action alternative for both Sites 5 and
6 might not protect human health over the long-term. .
Reduction of Toxicity, Mobility, or Volume through Treatment
The selected remedy meets the mandates of CERCLA Section 121. It protects
. numan health and the environment, complies with federal and state requirements
. that are legally applicable or relevant and appropriate to the remedial action, and
is cost-effective. This remedy does not meet the statutory preference. for treatment.
Treatment of asbestos-containine material was not found to be practicable or proven.
Because asbestos is a relatively insoluble material composed of minerals, many
conventional treatment technologies ordinarily considered for cont~minated soils are
not applicable to asbestos waste. Vitrifi~ation, the only treatment demonstrated to
. destroy asbestos, was eliminated because no commercially operating vitrification
plants currently exist for ex-situ vitrification and the presence of. metallic objects .
buried at the site would not allow effective in-situ vitrification.
Because this remedy will remove contaminated soils and nonhazardous debris from
the site, no long-term controls will be necessary and the five-year review will not
apply..
Short-term Effectiveness
During excavation under the Selected Alternative, the Excavation/Off-site Disposal
Alternative, or the Consolidation/Low-permeability Cover Alternative, engineering
ffiitallation ResiOiiiilOiiProgram
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controls and personal protective equipment would be employed to protect site
workers. Soils would be kept damp, preventing the generation of dust that could
contain asbestos. Workers would also wear protective clothing and respirators to
prevent inhalation of asbestos and follow a site health and safety plan.. The
Consolidation/Low-permeability Cover Alternative, which includes consolidation of
. waste from Site 5 with. Site 6, and Excavation and Use as Subgrade at Sites 1 and 3,
the Selected Alternative, minimize potential hazards associated with transporting
excavated asbestos materials over long hauling distances. There would be no adverse'
effects on the community during implementation of the No Action or Minima) Action
alternatives for Sites 5 and 6. .
Environmental impacts for the remedial alternatives are associated with removal of
trees and brush and surface water runoff. . The No Action and Minimal Action,
alternatives for Sites 5 and 6 would have no adverse effects, becaUse they do not
include invasive activities. All other alternatives that include a cover or an
.excavation component would require minor clearing of brush and some engineering
controls to handle surface water runoff and erosion control. .
Implementability
The Selected Alternative, Excavation and Use as Subgrade Material at Sites 1 and
3, and the Excavation/Off-site Disposal and Consolidation/Low-permeability Cover
alternatives would be most difficult to implement. because they require special
asbestos-handling procedures for removal and transportation of the material. The
Low-permeability Cover Alternatives for Sites 5 and 6 and the Consolidation/Low-
permeability Cover Alternative. for Site 6 would require identification of a suitable
borrow source and land-use restrictions. Locating the asbestos-containing material
at Site 6. may be difficult and require significant exploration. Alternatives foJ;' both
Sites 5 and 6 would be easy to implement. The Minima) Action Alternative for both
sites would require land-use restrict~ons. .
Cost
The capital, operation' and maintenance, and total cost for each alternative is
provided in S~ction vn, Description of Alternatives. Over half the estimated cost
of the Selected Alternative, Excavation. Use as Subgrade Material at Sites 1 and
3, is attributed to the excavation and batkfilling cost at Site 6, which is based upon
initial estimates of 8,800 cy of material to be excavated. Other benefits of this
alternative are tha.t with the material placed beneath the proposed cap at Sites 1 and
3, there would be nQ off-base hauling of material as there would be for the
Excavati~n/Off-site Disposal Alternative and there would be no long-=-term
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WOO2937S.080
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monitoring cost as there would be for the Consolidation/Low-permeability Cover
Alternative.
The No Action Alternative for Sites 5 and 6 would cost nothing. The major cost
component in the Minimal Action Alternative for Sites 5 and 6 is long-term site
inspection and five-year review costs. The cost estimates assume that inspections and
reviews would continue for 30 years. The Low-permeability Cover Alternative for
Sites 5 and 6 is more expensive, because in addition to site inspections, five-year
reviews, and institutional controls, the cost estimates include material and
construction costs for the cover systems, engineering design costs, and long-term
maintenance costs.
The Site 5 Excavation/Off-site Disposal Alternative cost was of the same order of
IJUignitude as the Low-permeability Cover Alternative for Site 5. because of high
excavation costs; however, the Excavation/Off-site Disposal Alternative for Site 5
does not include long-term maintenance and five-year review costs. The
Excavation/Off-site Disposal Alternative for Site 6 assumed that all .material
disposed of at Site 6 would be excavated and transported to an off-base landfill for
final disposal. More than half the total cost of this alternative is estimated to be for
transporting and disposing of the soil and debris, making this alternative proln"bitively
expensive. The cost of the Consolidation/Low-permeability Cover Alternative was
estimated by combining the Excavation/Off-Site Disposal Alternative costs for Site 5
and the Low-permeability Cover Alternative costs for Site 6. Transportation and
disposal costs for Site 5 were eliminated, but construction costs for Site 6 were
increased to account for the burial of Site 5 pipes using soil from the Site 6 soil.pile.
State Acceptance
As party to the FF A, the State of Maine has commented on the RI, FS, Technical
. Memorandum, and Proposed Plan. The state has documented its concurrence with
. the remedial action as stated in Section XIll of this ROD. A copy of the state's
letter of concurrence is presented in Appendix B of this ROD.
Community ~cceptance
The Excavation and Use as Subgrade Material at Sites 1 and 3 Alternative was
developed as a direct resUlt of public comments received on the Site 8 Proposed
Plan. Public comments specifically requested the evaluation of alternatives that do
not result in land-use restrictions. The Navy's Selected Alternative for Sites 5 and
6 was developed to nieet this objective.
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Community acceptance of the Proposed Plan was evaluated based on comments
received at the public meetings and during tbe public comment period. This is
doaunented in the Responsiveness Summary presented in Appendix A of this ROD.
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X. THE SELECTED REMEDY
The selected remedial alternative chosen for Sites 5 and 6 (i.e., Alternative 5,6-F)
is a comprehensive remedy that includes excavation of asbestos-containing material
and construction debris. It is designed to remove the buried waste and place it
beneath a permanent, low-permeability cap at Sites 1 and 3.
A. CLEANUP LEVELS
Based on data presented in the RI and results of the baseline risk assessment, there
is no current risk to human health from exposure to asbestos. Therefore, target
clean-up levels for asbestos were not calculated. However, the remedial. action
objectives include the removal of asbestos-containing material from Sites 5 and 6 to
eliminate the potential future risks associated with exposure to subsurface asbestos
material.
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B. DESCRImON OF REMEDIAL COMPONENTS
The Navy's Selected Alternative involves excavating nonhazardous construction
rubble and debris from Site 6, excavating and containerizing asbestos-containing
material from Sites 5 and 6, and transporting these materials, as well as the
stockpiled soil at Site 6, for use as subgrade fill beneath the landfill cap at Sites 1
and 3. This material will provide necessary subgrade fill to meet the design criteria
for the Sites 1 and 3 landfill cap. This cap exceeds MEDEP regulations for the
closure of asbestos waste disposal sites. Although human health risks are not a
current concern, this alternative would prevent future contact with asbestos.
This alternative includes. the following components:
.
development of a health and safety plan
site preparation .
excavation and confirmation sampling
containerization of the asbestos-containing material
transportation of materials
disposal
site restoration
.
.
.
.
.
.
Components of this remedial alternative are described in the foll()wing paragraphs.
. Development of a Health and Safety Plan
Because of potential health hazards associated with asbestos exposure, a detailed
health and safety plan would be developed prior to any remedial actions at Sites 5
and 6. This plan would comply with OSHA and other state and federal regulations,
as appropriate.
. The Safety, Health, and Emergency Response Plan (SHERP) will address the
handling of contaminated soils, groundwater, asbestos-containing material, and
construction debris that are encountered during excavation, removal, and disposal
activities and will describe some of the resultant procedures. and equipment required
to protect workers and the general public from hazards associated with contamin~ted
materials. Should any unforeseen or site-specific safety factors, health hazards, or
con
-------
During all invasive activities, a radiological survey, will be conducted to identify the
potential for radiological hazards. Soil surfaces will be scanned periodically with a'
NA (Tl) scintillator (5x5 em detector size) and pancake Geiger Mueller detector.
The former instrument is very sensitive to gamma radiation and the latter measures
alpha, beta, and gamma radiation. The instruments will be used for qualitative
measurements only. H radiation is detected at levels greater than twice the
background leve~ work will stop and the Contracting Officer and the Site Safety and
Health Officer will be notified to evaluate the situation. '
Site Preparation
Site preparation involves all the activities associated with the alternative that must
be conducted before the actual &ite remediation can begin. Important components
include clearing and grubbing of vegetation, construc.ting an access road, mobilization
of equipment, and erosion control at each site.
Site preparation at Sites 5 and 6 would include clearing trees, brush, and other
v~getation from the sites and nearby work areas. The sites are relatively flat and
free of heavy vegetation, but some of the surrounding area contains small trees and
brush that would require clearing to provide site access.
An access road, and small staging area would be constructed at Sites 5 and 6 outside
the limits of waste for storage of equipment during excavation, decontamination
areas, and access for trucks to remove soil and debris. Possible staging areas for
Sites 5 and 6 are shown on Figures 2 and 3, respectively. These areas would be used
to store excavation equipment, supplies for containerizing asbestos-containiIig
materials, equipment to break up construction rubble (Site 6), and any temporary
facilities. Because the sites are small and only a relatively short time would be .
required to implement the alternative, only minimal improvements would be made
to prepare the access roads and staging areas. The existing access road at Site 6
would be improved to support heavy' equipment. Equipmept would then be
mobilized to the sites.
To minimize erosion and sedimentation to downgradient areas during the
excavations, erosion controls (e.g., a silt fence or,hay bales) would be placed around
the, perimeter of the work area along the downgradient edges. Site 6 is adjacent to
an unnamed tributary. The Maine Natural Resources Protection Act provides that
removal of soils or other activities conducted adjacent to streams must not cause
unreasonable soil erosion, cause unreasonable harm to significant wildlife ,habita~
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. Portions of the work at Site 6 are
~oration Program
WOO2937S.080
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located within 100 feet of the tributary; therefore, all Standards of Permit By Rule,
Section 2, Disturbance of Soil Adjacent to a Wetland or Water, must be met.
Implementation ot the selected remedy would not impact the drainage or natural
flow of this tributary. Erosion control measures will be employed during construction
to minimize soil/sediment from entering the surface water.
Excavation and Confirmation Sampling
Site 5 would be excavated to remove all materials containing asbestos. The
overburden soils in the area of the primary anomaly from the magnetometer survey
would be excavated and stockpiled for use as backfill, and the asbestos-covered pipes
removed. The pipes are estimated to be between 7 and 10 feet deep. For cost-
estimating purposes, it was assumed that a I-foot-thick circumference of soil
surrounding the pipes would be handled. as asbestos waste. The soil surrounding the
pipes would be cleared using a vacuum device that contains soils automatically, and
then the pipes would be removed from the trench. The total quantity of asbestos-
co~taining soil and pipes at Site 5 was estimated to be 12 cy. Volume calculations
are presented in. the FS. The actual volume to be excavated would be established
in the field by experienced asbestos abatement professionals and analytical sampling.
Site 6 would be excavated to remove all construction rubble and debris, including an
assuined volume of 250 cy of asbestos-containing materials. For cost-estimating.
. purposes, it was assumed that an area of 18,700 square feet would be excavated to
a depth of 10 feet, plus the 1,900-<.yon-site soil pile for a total of 8,800 cy of material
(see Figure 3). Volume calculations are presented in the FS. The amount of
material to be excavated was estimated from historical information, geophysical
surveys, soil sampling, and monitoring well installation logs presented in the Draft
Final Supplemental RI Report. Subsequent field investigations determined that there
was a larger areal extent of material and the revised volume of material to be
excavated is approximately 18,700 cy consisting of 250 cy of asbestos and 18,450 cy
. of construction rubble and debris. However, the cost estimate is based upon the
initial quantity estimate. .. .
During excavation at Sites 5 and 6, engineering controls. and personal protective
equipment would be employed to protect worker safety. Soils would be kept damp,
preventing the generation of dust that could contain asbestos at Site 6. As stated,
a detailed health and safety plan would be developed and followed during all
remedial actions. Aft~r excavation is completed, soil samples would be collected at
Sites 5 and 6. to confirm that no site-related cont::lmitlants are left in place. The
presence of debris or rubble at Site 6 would be evaluated visually. The sampling and
analysis plan would be developed by the remedial construction contractor before
work .begins and submitted for regulatoi)' review and comment. At a minimum, three
Installation ~rogram
W0Q2937S.080
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soil samples would be collected and analyzed for asbestos at Site 5 and analyzed for
TCL and TAL constituents and asbestos at Site 6. The sample locations would be
selected by a NavY representative from areas where staining is apparent (if any).
Excavation would proceed if these contaminants are detected above background
concentrations. H contamination is detected, and cannot be physically removed by
excavation, long-term monitoring of groundwater may be implemented to evaluate
the impacts on groundwater downgradient of the site. Long-term monitoring is not
.a component of the remedial action because contamination is not expected, based
on results of the RI and pre-design field programs. However, if necessary, Sites 5
and 6 could be included in the long-term monitoring program to be developed for
NAS Brunswick.
Contained, .utJn of Asbestos-containing Material
The asbestos-containing material excavated from Sites 5 and 6 would be
containerized in two layers of polyethylene, each with a minimum thickness of 6 mils
in accordance with the Maine Landfill Disposal Regulations for the Management,
Testing, and Disposal of Special Wastes (38 MRSA Section 1304, Chapter 405.4), and
labeled in accordance with OSHA regulations (29 CFR 1910.1001 or 1926.58).
Transportation of Materials
Transportation of the material from Sites 5 and.6 to Sites 1 and. 3 would be
accomplished using 12-cy dump trucks. The material would be placed at Sites 1 and
3 for use as subgrade fill beneath the landfill cap in accordance with Maine Solid
Waste Management Regulatio.ns (Chapters 401.7 and 405.4). Chapter 401.7 covers
closure of solid waste landfills and 405.4 regulates disposal.of asbestos. The
transport distance from Site 5 to Sites 1 and 3 is approximately 1.3. miles and from
Site 6 to Sites 1 and 3 is approximately 0.65 mile. For cost-estimating purposes, the
round-trip transport distance from these sites to Sites 1 and 3 is . assumed to be 2
miles. The transportation route would not pass through residential or developed
areas of the base. Figure 4 depicts the proposed transportation routes. .
At Site 5, it is anticipated that excavation, containerization, and transport activities
would take two to three days, and that one dump truck would be required for . one
day only. At'Site 6, it is estimated that approximately 250 cy of material would be
excavated and loaded for transport each day, and that three to four trucks would be
required to keep pace. with the rates of excavation, containerization, and breaking of
construction debris. Site 6 activities are estimated to last a total of eight weeks (for
excavation of 8,800 cy), including site preparation and restoration.
IiiiiiIlation Restoration Program
WOO2937S.080
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- .'} ..
. ;/\1 ..,....~ ~ ~
. ~' . . R8d ~.' .......'..
. - -
. ". -
.,
..:.. l'
. -
I ~...-
,
i ". ~;.~.~.
; ,c...,:.
rr~' i
l,A::' ~
. ~~'.: ;:.~. .
I
p
SOURCE: USGS QUADRANGLE. BRUNSWIC1C. AND ORRS IS&.AHD.IIE. DAmD 1""'878. 7.5 MINUTE SERIES.
G
LEGEND
.& SITE LOCATION
..... PROPOSED TRUCK ROUTE .
- DlRECT10N OF TRUCK TRAveL
~....~....... LDCA1IOI8
/
.1
o
SCALE IN FEET .
.
2.GaO
I
4,000
FIGURE 4
PROPOSED TRUCK ROUTE
SITES 5 AND 6
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Disposal
Sites 1 and 3 at NAs Brunswick are existing hazardous waste disposal sites that have
been inactive since the 1970s. A ROD for these sites has been signed. The cap for
these sites has been designed as an approved modification to the Maine Solid Waste
Management Regulations, and in accordance with RCRA Subtitle C guidelines for
closure of hazardous waste landfills, which are more stringent than NESHAPS or the
Maine regulations for closure of asbestos disposal sites. Using the material from
Sites 5 and 6 as subgrade fill at Sites 1 and 3 will help provide the proposed cap with
the requisite slopes to promote long-term positive drainage of stormwater off the cap.
Site Restoration
After excavation is completed at Sites 5 and 6, the areas would be backfilled as
necessary with clean soil and regraded to promote positive drainage, and all denuded
areas would then be seeded and mulched to reestablish vegetation. The sites will be
inspected on a regular basis during the turf establishment period to ensure promotion
of growth until a stand of turf is established; the turf establishment period will be in .
. effect until the turf has been mowed three. times. The areas will be mowed, weeded,
watered, fertilized and overseeded as necessary to promote turf growth. There' would
be no need for warning signs, institutional controls, or five-year site reviews because
. no waste. would remain at either site.
Table 2 presents the estimated cost of this altern'itive. This estimate assumes a
. project duration of one week at Site 5 and eight weeks at Site 6, based on the
assumed volumes of material of 8,800 cy at Site 6 and 12 cy at Site 5. The total cost
of this alternative is $681,000.
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WOO2937S.080
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TABLE 2
ALTERNATIVE 5,~F:
ExCAVA~ AND USE AS SUBGRADE MATERIAL AT Srrcs 1 AND 3
ROD: SITES 5 AND 6
HAS BRUNSWICK
, ,
'ExcAVATE12:cyATSrrESiAND
'::::ExcAVATE8,aOOCYAT SITE. &,
I
COST
I
'PRESENT -
WOR11f '
CaDItal Costs
Site ,Preparation
, Temp. Road, Decon Pad
Mobilization
Survey'
excavation/Backfilling.
Equipment and Labor
FBI Material - Place and Compact
Protective Clothing
20,500
12,300 .
1,600
Remove Temporary Pavement
Dispose of Temporary Pavement and Road Base
Grade
Seed, FertUlze and Mulch
214,400
91,200
7,800
3,100
27,100
44,100
5,900
5,500
700
2,200
436,400
87.300
, $523,700 $523,700
PackagingjTransport
Containerize Asbestos
Transport to Landfill
Place and Compact at Landfill
Site Restoration
Subtotal
Contingency (@ 20%)
T ota! Capital Costs:
WOO1!J'575r.fm/2
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continued
TABLE 2
AI. TERNATIVE 5,6-F:
exCAVATE AND USE AS SUBGRADE MATERIAL AT SITES 1 AND 3
ROD: SITES 5 AND 8
NAS BRUNSWICK
. exCAVATE. 12. cy AT SI1E 5 AND.
. ExcAVATE 8;800cy AT SITE 6 .
Indirect Costs
Health and Safety (@ 5% of Capital Cost)
PRESENT.
COST WORTH
26,200
26,200
52,300
52.300
$157,000 $157,000
N/A N/A
N/A N/A
N/A N/A
N/A N/A
$680,700
Legal, Administrative, and Permitting
(@ 5% of Capital Cost)
Engineering (@ 10% of Capital Cost)
Services During Construction (@ 10% of Capital Cost)
Total Indirect Costs:
Annual DDeratina Costs
Total Capital Costs:
Five-Year Review
SUBTOTAL:
Total Cost:
No..:
cy
=
cubic yards
w002fH1SrJJ8IJ/3
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XI. STATUTORY DETERMINATIONS
The remedial action selected for implementation at NAS Brunswick Sites 5 and 6 is
consistent with CERCLA and, to the extent practicable, the NCP. The selected
remedy is protective of human health and the environment, attains ARARs, ~d is
cost-effective.
A.
THE SELECTED REMEDY IS PROTECI'IVE OF HUMAN HEALTH AND THE
ENVIRONMENT
, The remedy at Sites 5 and 6 will permanently reduce the risks posed to human health
and the environment by eliminating, reducing, or controlling exposures to asbestos
by human and environmental receptors through' engineering controls.
Human health risks from exposure to asbestos are currently not a concern at Sites 5
ane! 6; however, this alternative would prevent any future contact with asbestos if
these sites are developed in the future. Asbestos minerals are very stable in the
subsurface environment and are unlikely to migrate. Groundwater is considered an
unlikely transport mechanism; the depth to groundwater at Site 5 is 25 to 30 feet and
at Site 6 is 15 to 20 feet, minimizing the possibility of asbestos migrating through
groundwater flow. .
During removal of the asbestos-containing materials at Sites 5 and 6, exposure to
airborne asbestos could occur. This exposure would be reduced by wetting the
material prior to excavation to minimize any airborne migration of asbestos and
, thereby minimizing any risk to ,human health and the environment In addition, the
asbestos-containing material would be containerized to reduce the risk of any further
exposure.
Removal of the rubble and debris from Site 6 would eliminate the physical hazards
(i.e., chance of injury) associated with exposed reinforced concrete, pipes, and other
debris at the site. Placement of this material at Sites 1 and 3 for use as subgrad~ fill
beneath the proposed landfill cap would reduce accessibility to the debris during
construction and eliminate the physical hazards associated with the material once. cap
construction is complete.
Removal of the material from Sites 5 and 6 would be beneficial to environmental
receptors because once the material is removed, the sites would be regraded and
revegetated to restore the natural physical condition of each site. This site
restoration may potentially provide a more, suitable environment for establishment
of the natural ecosystem at Sites 5 and 6. Removal of Waste from these sites would
allow for unrestricted development of these sites in the future.
Installation Restoration Program
WOO2937S.080
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Placement of the material at Sites 1 and 3 could increase risks to environmental
receptors at the landfills; however, these risks will be minimi7.ed by the remedial
design at Sites 1 and 3.
B. THE SELECl'ED REMEDY AITAINS ARARs
This remedy will attain all applicable or relevant and appropriate federal and state
requirements that apply to Sites 5 and 6. ARARs for Sites 5 and 6 were identified
during both the RI and FS. Section 2.0 of the RI and Section 3.0 of the FS reports
present tabular summaries of all ARARs identified, including the regulatOIY citation
and a brief summary of the regulatory requirement and its consideration in the
remedial process. The ARARs are also included as Appendix C to tbis ROD. The
following narrative summarizes key ARARs and their applicability to the selected
remedy.
The selected remedy would meet the following federal and state ARARs:
Chemical-specific ARARs
.
Oean Air Act - National Ambient Air Quality Standards
.
Maine Ambient Air Quality Standards
.
OSHA - Construction Standards
.
Oean Air Act - National Emission Standards for Hazardous Pollutants
.
Maine Landfill Disposal Regulations
.Location-specific ARARs
.
Maine Natura! Resources Protection Act-
.
Maine Standards for Classification of Minor Drainages
.
Maine Site Location Development Law and Regulations
.
Maine Solid Waste Management Rilles: Land Disposal Facilities
Natural Resources Protection Act, Permit by Rille Standards
.
WOO2937S.080
Installation Restoration Program
48. .
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Action-specific ARARs
.
RCRA - Subtitle D Landfill Regulations
.
Occupational Safety and Health Administration (OSHA) - General
Industry Standards
.
OSHA - Safety and Health Regulations
.
Asbestos Hazardous Emergency Response Act
.
National Emission Standards for Hazardous Air Pollutants - Asbestos
.
OSHA - Recordkeeping, Reporting, and Related Regulations
.
Maine Asbestos Abatement Regulations
.0
Mam~ Landfill Disposal Regulations
Federal and State Air Quality Regulations. The excavation of soil, asbestos'
contaminated material and construction debris and rubble proposed in the selected
remedy will not create any new sources of air emissions. Theref~re, many federal
and state regulations governing air quality do not apply to the selected remedy. The.
applicable air quality standards are particulate standards promulgated under the
Oean Air Act and Maine Ambient Air Quality Standards and the asbestos standards
promulgated under NESHAPS (40 CFR, Part 61, Subpart M), OSHA (29 CFR
Part 1926), and the Maine Landfill Disposal Regulations (Chapter 405.4). The
particulate standard would apply to remedial construction activities associated with
excavation. These standards would be attained through monitoring and, if necessary,
use of dust suppression techniques or engineering controls. .
The asbestos standards would apply to any action causing asbestos fibers to be
emitted to the air. The state standard is the most stringent, at 0.1 fibers per cubic
centimeter in air, which is half of the OSHA permissible expgsure limit. .NESHAPS
require that there be no visible emissions or that emission controls be' used.
State Location-specific Regulations. All of the location-specific ARARs that apply
to the selected remedy are based on the close proximity of Site 6 to the nnnamed
tributary. The Maine Natural Resources Protection Act provides that removal of
soils or other activities conducted adjacent to streams must not cause unreasonable
soil erosion, cause unreasonable harm to significant wildlife habitats, unreasonably
interfere with natural water. flow, lower water quality, or unreasonably cause or
Installation Restoration Program
WOO2937S.080
49
-------
increase flooding. Chapter 305 of the MEDEP regulations provides further standards
for erosion control and soil excavation. Portions of the work at Site 6 are located
within 100 feet of the tributary; therefore, all Standards of Permit By Rule, Section 2,
Disturbance of Soil Adjacent to a Wetland or Water, must be met Implementation
of the selected remedy would not impact the drainage or natural flow of this
tributary. Erosion control measures will be employed during construction to
minimize soil/sediment from entering the surface water.
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. Asbestos is not a hazardous
waste regulated under RCRA. To date, there is no information available (i.e.,
manifests) to indicate that RCRA-regulated materials were disposed of at. Sites 5 or .
6. ..Two samples from Site 6 analyzed in March 1993 by TCLP passed (did not leach
. hazardous constituents in toxic quantities); therefore, the soil is not a characteristic
waste. However, because no RCRA-regulated materials were documented at Sites 5
and 6, Land Disposal Restrictions were not established to be an ARAR for the sites
or final remedy.
OSHA regulations protecting worker health and safety at hazardous waste sites
pertain to the implementation and long-term operation of the selected remedy. Site
workers will have completed training requirements and will have appropriate health
and safety equipment on site. Contractors and subcontractors working. on site will
follow health and safety procedures.
Federal and State Solid Waste Regulations
The cover system component of the Selected Alternative at Sites 1 and 3, which
meets RCRA Subtitle C requirements, meets or exceeds the performance
requirements of the Maine Landfill Disposal Regulations for the Management,
Testing, and Disposal of Special Wastes (38 MRSA Section' 1304, Chapter 405.4)
'governing disposal of asbestos, and is an approv~d modification to the most .stringent
ARAR, the State of Maine Solid Waste Management RegulationS (Chapter 401.7)
governing the closure of solid waste landfills. The State of Maine requirements
pertaining to the storage, transport and disposal of asbestos wastes (MEDEP
Regulations, Chet.pter 405.4) will also be met. It should be noted that although the
cover system at Sites 1 and 3 meets or exceeds state and federal requirements for
asbestos and construction debris, the landfill at Sites 1 and 3 is an, unlicensed facility
with regard to the asbestos disposal requirements of these regulations.. However, the
Maine DiVision of Solid .Waste Facility Licensing has stated that a license is not
required since dispos~ of the material at Sites 1 and 3 would be p~ of a remedial
action at a CERCIA site (MEDEP, 1993). .
~oratlon Program
50
WOO2937S.080
-------
Transport of material from Sites 5 and 6 to Sites 1 and 3 requires consideration of
additional ARARs for Sites 1 and 3 than those specified in the ROD for Sites 1 and
3. These ARARs are summarized in Table C-4 in Appendix C of this ROD and will
be discussed further in an Explanation of Significant Difference' (ESD). The ESD
will be incOIporated in the Administrative Record for Sites 1 and 3. The movement
of material from Sites 5 and 6 will not occur until after the ESD is issued. .
c. THE SELECTED REMEDIAL ArnON IS COST-EFFECTIVE
The selected remedy is cost-effective; that is, the remedy affords overall effectiveness
proportional to its costs. In selecting this remedy, the Navy identified alternatives
that were protective of human health and the environment and that attained ARARs,
and then evaluated .the overall. effectiveness of each alternative by assessing the
relevant three criteria: (1) long-term effectiveness and permanence; (2) reduction in
toxicity, mobility, and volume through treatment; and (3) short-term effectiveness, in
combination. The relationship of the overall effectiveness of the selected remedial
alteI.1l3.tive was determined to be proportional to its costs. The costs of this remedial
alternative are: .'
Estimated Capital Cost: $568,000
Estimated Operation and Maintenance Cost (net preSent worth at a 10%
discount rate): not applicable
Estimated Total Cost (net present worth at a 10% discount rate):
$681,000
The least expensive alternative is clearly the No Action Alternative with no cost.
The Mjnjrna] Action Alternative is expected to cost approximately $217,000 for both
sites. The Low-permeability Cover Alternative cost combined for the two sites is
$430,000. Excavation and Off-site Disposal for the two sites would total $3,786,000.
The Consolidation/Low-permeability Cover Alternative would cost $400,000.
While the selected remedy does not have the lowest estimated capital cost of the' six
treatment alternatives, over half the cost is directly related to excavation and backfill.
H the actual volume excavated is less than the estimate, the' cost of this remediation
would be significantly reduced and be comparable to the other alternatives
considered. The Navy also believes that the benefit in providing the opportunity for
future development of Sites 5 and 6 offsets the increased costs.
Installation Restoration Program'
WOO2937S.080
51
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D.
THE SELECTED REMEDY UmlZES PERMANENT SOLUTIONS AND ALTERNA11VE
TREATMENT OR REsOURCE RECOVERY TECHNOLOGIES TO THE MAxIMUM
EXTENT PRACTICABLE
The Navy identified those alternatives that attain ARARs and that are protective of
huIrian health and the environment The Navy also identified which alternative uses
permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. This determination was made by
deciding which one of the identified alternatives provides the best balance of factors
among alternatives 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 perman~nce and the reduction of toxicity, mobility, and
volume through treatment; and considered the preference for. treatment as a
principal element, the. bias against off-site land disposal of untreated waste, and
community and state acceptance. The selected remedy provides the best balance of
trade-offs among the alternatives.
The Navy's Selected Alternative for cleanup at Sites 5 and 6 involves excavating,
transporting, and placing asbestos-containing material and construction rubble and
debris as subgrade fill beneath the proposed landfill cap at Sites 1 and 3. This is a
new alternative that was developed during the remedial design phase of Sites 1 and
3, when it was determined that fill requirements for subgrade material beneath the
cap could incorporate the material from Sites 5 and 6. In addition, this alt~mative
addresses the concerns raised during the public hearing for Site ~ (October 15, 1992).
Excavating material from Sites 5 and 6 will eliminate the need for long-term land-use
restrictions at these sites. Hauling material to Sites 1 and 3 will also minimi7.e the
hazards .associated with transporting asbestos over long distances (e.g., to an off-base
location) and eliminate the need for a low-permeability cap at Site 6 and the
resultant long-term monitoring and land-use restrictions. Completely removing waste
from Sites 5 and 6 allows these areas to be developed for future use and eliminates
the need for long-term management. .
E.
THE SELECTED REMEDY DOES NOT SATISFY THE PREFERENCE FOR
TREATMENT WHicH PERMANENTLY AND SIGNIFICANTLY REDUCES THE
TOXICITY, MOBILITY, OR VOLUME OF THE HAzARDOUS SUBSTANCES AS A
PRINCIPAL ELEMENT
This remedy does not meet the statutory preference for. treatment. Treatment of
asbestos-containing material was not found to be practicable or proven. Because
asbestos isa relatively insoluble material composed of minerals, many c~nventiona1
treatment technologies ordinarily considered for contaminated soils are not
Installation Restoration Program
WOO2937S.080
52
-------
applicable to asbestos waste. Vitrification, the amy treatment demonstrated to
destroy asbestos, was eliminated because no commercially operating vitrification
plants currently exist for ex-situ vitrification and the presence of metallic objects
buried at the site would not allow effective in-situ vitrification.
Because this remedy will remove contaminated soils and nonhazardous debris from
the site, no long-term controls will be necessary and the five-year review will not
apply. Physical hazards associated with the disturbed material would be eliminated
once the cap is constructed at Sites 1 and 3.
WOO2937S.080
~rogram
53
-------
XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES
The Navy presented a Proposed Plan (Preferred Alternative) for remediation of
Sites 5 and 6 in March 1993. The Preferred Alternative included excavating
asbestos-containing material from Sites 5 and 6 as well as non-hazardous ~nstruction
rubble from Site 6, and using this material as subgrade fill beneath the proposed
Sites 1 and 3 landfill cap. No significant changes have been made to the alternative
described in the Proposed Plan and presented to the public.
fiiSiiiIitiOii1oration Program
WOO2937S.080
54
-------
XIII. STATE ROLE
As a party to the FF A, MEDEP has reviewed the various alternatives and has
indicated its support for the selected remedy. MEDEP concurs with the selected
remedy for NAS Brunswick Sites 5 and 6. A copy of the letter of concurrence is
presented in Appendix B of this ROD.
Instal'iiiiOiiFiestoration Program
WOO2937S.080
55
-------
REFERENCES
ABB Environmental Services, Inc. (ABB-ES) 1993a. "Draft Final Technical
Memorandum: Detailed Evaluation of Alternative 5,6-E: Excavation and
Use as Subgrade Material at Sites 1 and 3"; Portland, Mame; March.
ABB Environmental Services, Inc. (ABB-ES) 1993b. ''Proposed Plan Sites.S and 6";
Portland, Maine; March.
E.e. Jordan Co., 1990a. "Draft Final Remedial Investigation Report NAS
Brunswick"; Portland, Maine; August.
E.C. Jordan Co., 1990b. "Draft Final 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.e. Jordan Co., 1991b. "Draft Final Supplemental Feasibility Study Sites 5, 6, and
12 NAS Brunswick"; Portland, Maine.
E.C. Jordan Co., 1991c. "Focused Feasibility Study Sites 1 and 3 NAS Brunswick";
, Portland, Maine; October. ' ,
E.e. Jordan Co., 1992a. "Feasibility Study NAS Brunswick"; Portland, Maine; March.
E.e. Jordan Co., 1mb. "Focused Feasibility Study Site 8 NAS Brunswick"; Portland,
Maine; April.
Gilbert. et al., 1981. Experimental Studies of Amphibole Stability; Reviews in
. Mineralo - Am hiboles and Other H drous iboles; VoL 9B, pp. 129-'21,7.
Maine Department of Environmental Protection (MEDEP), 1993. Letter from Mark
R. Hyland, Director, Federal Facilities Remediation to James Shafer, Prpject
Manager, Department of the Navy, Northern Division; January, 25.
Northern Division, Naval Facilities Engineering Command (NAVY), 1992a. ''Record
, of Decision for a Remedial' Action at Sites 1 and 3 Naval Air Station
Brunswick, Maine"; Portland, Maine; June.
Installation Restoration Program
WOO2937S.080
-------
REFERENCES
Northern Division, Naval Facilities Engineering Comm~nd (NAVY), 1992b. ''Record
of Decision for an Interim Remedial Action at the Eastern Plume Operable
Unit Naval Air Station Brunswick, Maine"; Portland, Maine; June.
Northern Division, Naval Facilities Engineering Command (NAVY), 1993. "Record
of Decision for a Remedial Action at Site 8 Naval Air Station Brunswick,
Brunswick, Maine"; Portland, Maine; August.
Roy F. Weston, Inc., 1983. "Initial Assessment Study of Naval Air Station,
Brunswick, Maine"; West Chester, Pennsylvania; June.
~on Program
WOO2937S.080
-------
GLOSSARY OF ACRONYMS AND ABBREVIATIONS
ARAR
BACSE
bgs
CERClA
cy.
FFA
FFS
FS
GPR
!AS
IRP
MEDEP
MSL
NAS
NCP
NPL
NESHAPS
. OSHA
PCB
RCRA
RI
ROD
SARA
SHERP
SVOC
WOO2937S.080
Applicable or Relevant and Appropriate Requirement
Brunswick Area Citizens for a Safe Environment
below ground surface
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (the Superfund statute)
~ubic yards
Federal Facility Agreement
Focused Feasibility Study
Feasibility Study
Ground-penetrating radar
Initial Assessment Study
Installation Restoration Program.
Maine Department of Environmental Protection
mean sea level .
Naval Air Station
National Contingency Plan
National Priorities List
National Emissions Standards for Hazardous Air Pollutants
Occupational Safety and Health Administration
c
polychlorinated biphenyl
Resource Conservation and. Recovery Act
Remedial Investigation
Record of Decision
Superfund Amendments and Reauthorization Act of 1986
. Safety, Health, and Emergency Response Plan
semivolatile organic compound
.
Installation Restoration Program
-------
GLOSSARY OF ACRONYMS AND ABBREVIATIONS
TAL
TRC
TCL
. TCLP
",gjkg
USEPA
VOC
Target Analyte List
Technical Review Committee
Target Compound List
Toxicity Characteristic Leachate Procedure
micrograms per kilogram
U.S. Environmental Protection Agency
volatile organic compound
WOO2937S.080
IiiSiii1iiiO'i1Restoration Program
-------
---
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APPENDIX B
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,
I.
STATE OF MAINE
DEPARTMENT OF ENVIRONMENTAL PROTECTION
JOHN A. McKERNAN. JR.
GOVERNOR
DEAl! C. IIAJIAIOTT
COMMISSIONER
DEIIRAH RICHARD
OEPIJrf COMMISSIONER
Auqust 30, 1993
W.A. Waters
Captain, CEC, u.s. Navy
Commanding Officer
Department of the Navy, Northern Division
Naval Facilities Engineering Command
Buildinq 77-L .
Philadelphia. Naval Shipyard
Philadelphia, PA 10112-5094
RE: Naval Air station Brunswick. Superfund site, Brunswick,
Maine
Dear Captain Waters:
'The Maine Department of Environmental Protection (MEDEP) has
reviewed the Auqust 1993 Record of Decision (ROD)
for a remedial action at sites 5 and 6 for the Naval Air
Station Brunswick Superfund site located in Brunswick,
. Maine. '
On the basis of this ROD .the MEDEP concurs with the selected
remedial action. This action includes excavating
nonhazardous construction rubble and debris from site 6,
excavating and containerizing aSbestos-containing material
from sites 5 and 6, and transporting these materials, as
well as the stockpiled soil at Site 6, for use as subqrade
fill beneath the landfill cap at Sites 1 and 3. This
material will provide some of the necessary subqrade fill to
meet the design criteria for the sites 1 and 3 landfill cap.
This alternative includes the following components:
I.
Development of a Health and Safety Plan
A. A detailed Health and Safety Plan will be developed
prior to any remedial actions at Sites. 5 and'6. This'
plan will comply with .OSHA and other state and federal
regulations, as ~ppropriate.
B. During all invasive activities, a radioloqical
survey will be conducted to identify the potential for
radiological hazards. . .
AUGUSTA ,
STAT1I ~ STA1ION 17
AuGuSTA. .... CM3:J3.Q017
(207) 2117-'" .FAX:. (207) 2117.7828
GWICf LClCArm AT: RAy ~ HOSPn'AL STREET
POATI.AND
312 CMCO RoAD
PoImANO. ME 0.1013
(2117) Il7'II-83OO FAX:. (207) I7M303
BANGOR
101 HOGAN RoAD
BMaoR. ME 00W01
(207) "1~ FAX: (2117) ..1-45&6
PRESQUE ISLE
1235 CEIfTRAL DIWI. Sl(YwAY P-
PIIUauIISL!. WE 0&181 ,
(207) 784>0177 FAX: lam 7&4-1507
-------
II.
III.
Site Preparation
A. An access road and small staging area will be "
constructed at sites 5 and 6 outside the limits of the
waste for storage of equipment during excavation,
decontamination areas, and access for trucks to remove
soil and debris. " .
B. Erosion control measures will be employed during
construction to minimize soil/sediment from entering
the tributary adjacent to Site 6, in accordance with
the Natural Resources Protection Act, Permit By Rule
Standards, "Chapter 305. "
Excavation and Confirmation sampling
A. site 5 will be excavated to remove all materials"
.containing asbestos. The asbestos-covered pipes and a
l-foot-thick circumference of soil surrounding the
pipes will be handled as asbestos waste.
B. The soil surrounding the pipes will either be
cleared using a vacuum device that contains soils
automatically or will be adequately wetted", then the
pipes will be removed from the trench.
c. site 6 will be excavated to remove all construction
rubble and debris, including an assumed volume of 250
cy of aSbestos-containing material.
D. Soils at site 6 will be kept damp, preventing the
generation of dust that could contain asbestos.
" E. After excavation is compieted, soil samples will be
collected at Sites 5 and 6 to confirm that no site-
related contaminants are left in place.
F. The sampling and analysis plan will be developed by
the "remedial construction contractor before work begins
and submitted for regulatory review and comment.
G. Ata minimum, three soil samples. will be collected
and analyzed for TCL and TAL constituents and asbestos
at site 6! ."
H. If contamination is detected, and cannot be
physically removed by excavation, long term monitoring
of groundwater may be implemented to evaluate the
-------
IV.
containerization of Asbestos-Containing Material
<>
A. The aSbestos-containing material excavated from
sites 5 and 6 will be containerized in two layers of
polyethylene, each with a minimum thi~kness of 6 mils.
Transportation of Materials
v.
A. Transportation of the material from sites 5 and 6 to
sites 1 and 3 will be accomplished using 12-cy dump
trucks and will not pass through residential or
developed areas of the base.
B. Erosion control measures will be employed during
construction to minimize soil/sediment from entering
the surface water in accordance with the Natural
Resources Protection Act Permit By Rule Standards,
Chapter 305.
C. The material will be placed at Sites 1 and 3 for use
as subqrade fill beneath the landfill cap in accordance
with Maine Solid Waste Management Regulations (Chapter
401.7 and 405.4).
D. Material from Sites 5 and 6 that is placed at Sites
1 and 3 will be covered daily with at least six inches
of compacted non-asbestos cover for the duration of the
disposal period.
E. Final cover procedures will be followed according to
Maine Solid Waste Regulations Chapter 405.4 (B)(5) (0)
if the cap for Sites 1 and 3 i$ not substantially under
construction within 30 days of the.last placement of' .
asbestos waste materials.
This concurrence is based upon the state's understanding
that:
o .
A. The MEDEP will continue to participate in the
Federal Facilities Agreement dated October 19, 1990 and
in the review and approval of operational designs and
-------
Th~ MEDEP looks forward to workinq with the Department of
the Navy and the USEPA to resolve the environmental problems
posed by this site. If you need any addit~onal information,
do not hesitate to contact me or members of my staff.
{;
Sincerely,
j{ilk C:-/, ~~t21i /7.
f~
Dean C. Marriott'
Commissioner
pc:
Captain Robert Rachor,
Robert MCGirr, ABB-ES
Meqhan Cassidy, USEPA
Mark Hyland, MEDEP
BNAS
-------
..:
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<}
APPENDIX C
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
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c
. TAB~ C-1
CHEMICAL-SPECIFIC MARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR SITES 5 AND 8
ROD: SITES 5 AND 8
NAS BRUNSWICK
b
...
..
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AIR
State
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. . .
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~E~UI~~E~ $.yNQP~'~.. ..
This Chapter establishes ambient air quality standards that
are maximum levels 01 a particular pollutant permitted In the
ambient air.
.... .
The standard for particulate
matter Is 150 pg/m3, 24-hour
average concentration, which
applies to excavation
activities.
Not..:
n
I
.- ARAR
CM
CFR
CMR
CSF
MCL
MCLG
.....
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STAro~
Maine Ambient Air Quality
Standards (38 MRSA, Section
584; MEDEP Regulations,
Chapter 110)
Applicable
..
Applicable or Relevant and Approprlat~ PAqulrement
Clean Air Act
Cod. of F.d.ral Regulations
Cod. of MaIn. Rul.s
Cancer Slope Factor
Maximum Contaminant Level
Maximum Contaminant Level Goal
I:
WOO1.937SfJJ80/4
MEDEP
MRSA
AtD
SDWA
USEPA
pg/m3
Maine Department of Environmental Protection
Maine Revised Statues Annotated
reference dose
Saf. Drinking Water Act
U.S. Environmental Protection Agency
micrograms per cubic meter
=
-------
.TABLE C-2
lOCATION-SPECIFIC ARARS, CRITERIAj ADVISORIES, AND GUIDANCE FOR SITES 5 AND 8
ROD: SITES 5 AND 8
NAS BRUNSWICK
.. .. ."..
. '" .
. ... .
.M~I~..
SURFACE WATER
Federal
... .. . . . . .. . .
. ............
. .. .
. . ... . . . .
. R~9.ijIR~~ H
Section 404 (b)(1 ) Guidelines
for Specifications of Disposal
Sites for Dredged or Fill
Material (40 CFR Part 230)
WETlANDs/FLOODPLAINS
n State Maine Natural Resources
I-
N Protection Act (38 MRSA,
Section 480-A through S)
WOO29375T.08O/S
Natural Resources Protection
Act, Permit by Rule
Standards (Maine
Department of Environmental
Protection (MEDEP)
Regulations, Chapter 305)
STATUS
Relevant and
Appropriate
Applicable
Applicable
REQUIREMENT $VNQP$IS
. No discharge of dredged or fill material Is
permitted If there Is a practicable alternative to the
proposed discharge which would have less
adverse Impact on the aquatic ecosystem so long
as the alternative does not have other significant
adverse environmental consequences.
This act outlines requirements for certain activities
adjacent to any freshwater wetland greater than
10 acres or with an associated stream, brook, or
pond 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 prescribes standards for specific
activities that may take place In or adjacent to
wetlands and water bodies. The standards are
designed to ensure that the disturbed soli material
. Is stabilized to prevent erosion and siltation of the
water.
. ..... "".' .." '. .. ... ,,". . ... .
... . " . . "'," '. ",.' "..". .,' . ",
. . . . .. .. .
... AcriO" TQ.~ TAKEtf'1'() A".AI"ARA~S
The remedial action does not Involve a
discharge of material to water or wet-
lands, and construction activities will be
designed to ensure that there will be no
adverse Impacts to aquatic ecosystems.
Remedial activities regulated under this
act will meet activity standards.
Substantive requirements of these
regulations must be met by any action
taken within 100 feet of a wetland or
stream. .
Proposed activities Involving disturbance
of soli material within 100 feet of the
normal high water line will be designed
to Incorporate aU applicable standards.
-------
conUnued
~
CO>
TABLE C-2 .
.LocATION-SPECIFIC ARARS, CRITERIA, ADVISORIES, AND GUIDANCE FOR SITES 5 AND 8
ROD: SITES 5 AND 8
NAS BRUNSWICK
. . ..... ..
. . .. .
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.. .. .
. . . .
.. .. . .
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. R~QU'''-=M.ENT $~NOP~I$
State
OTHER NATURAL RESOURCES
?
w
Maine Site Location
Development law and
-Regulations (38 MRSA
Sections 481-490; MEDEP
Regulations, Chapter 375)
Relevant and
Appropriate
This act and regulations govern development and
Include hazardous activities that consume,
generate, or handle hazardous wastes and 011.
Activities cannot adversely affect existing uses,
scenic character, or natural resources /n the
municipality or neighboring municipality. The
regulations provide that there be no unreasonable
adverse effects on specified Items (Including air
quality, runoff/Infiltration relationships, surface
water quality), no unreasonable alteration of
climate or natural drainage ways, and provisions
for erosion and sed/mentation control and noise
control.
Remedial alternatives will be developed
considering these. regulations. A permit .
Is not required for on-site activity.
Not..:
ARAR .
. CERCLA .
CFR .
CWA .
EO .
MRSA .
MEDEP .
Applicable or Relevant and Appropriate Requirements
Comprehensive ~vlronmental Response, Compensation, and Uablllty Act
Code of Federal Regulations . .
Clean Water Act .
Executive Order
MaIne Revl..d Statutes Mnotated
MaIne Department of Environmental Protection
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TABLE C-3
ACTION-SPECIFIC ARARs, CRITERIA, AND GUIDANCE FOR SITES 5 AND 8 .
ROD: SITES 5 AND 8
NAS BRUNSWICK
. .. .... . . .. . .
. '" . ....
" .
.. .....
.., A~qU."EMEtff '
Federal
Occupational Safety and Health
Act (OSHA) - General Industry
Standards'
(29 CFR Part 1910)
OSHA - Safety. and Health
Standards
(29 CFR Part 1926)
CM - National Emission
? Standards for Hazardous
.po Pollutants (NESHAPs) (40 CFR
Part 61)
..
WOO2937fiJJ80/7
, .
, ST~TVS
Applicable
Applicable
Relevant and
Appropriate
REQUIREMENT SYNOPSIS
These regulations specify the 8-hour tlme-
weighted averag~ concentration for various
organic compounds. Training requirements
for workers at hazardous wastes, Including
asbestos, operations are specified In 29 CFR
Part 1910.120.
This regulation specifies the type of safety
equipment and procedures for handling
asbestos.
NESHAPs are promulgated for emissions of
particular air pollutants, Including asbestos.
Emissions of asbestos fibers are regulated
under Subpart M of 40 CFR Part 61. This
regulation Includes requirements for Inactive
waste disposal sites for asbestos mills and
manufacturing and fabricating operations, for
active wa~te disposal sites, and for waste
disposal for demolition and renovation
operations. It does not Include requirements
for Inactive waste disposal sites like Sites 5
and 6 which were for demolition and renova-
tion operations. Therefore, the NESHAP will
not be .appllcable. to cleanup of Siles 5 and
6. HOwever, the regulation Is .relevant and
appropriate. to the control of asbestos fiber
emissions at an Inactive waste disposal slle
for demolition and renovation operations
because the situation Is sufficiently similar.
. ... ." ',", ","," . .. ," '" ," ',"'" .", .
. . . .. . .
. .. '. .
ACTlq~ TC) ~~ J~TQ ATTA.ij A~R4
Proper respiratory equipment will be worn If II
Is Impossible to maintain the work
atmosphere below the concentration.
Workers performing activities would be
required to have completed specific training
requirements.
All appropriate safety equipment will be on
site. In addition, safety procedures will be
followed during on-site activities.
The NESHAP requirements for emission
limits, and personnel training for the handling
and disposal of asbestos (Subpart M) are
relevant and appropriate to activities
conducted at Sites 5 and 6. The actions
taken under the remedial action will meet
these requirements.
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contlnUg"
"
c'
TABLE C-3
ACTION-SPECIFIC ARARs, CRITERIA, AND GUIDANCE FOR SITES 6 AND 8
ROD: SITES 6 AND 8
HAS BRUNSWICK
. . . . . .... . . . . . . . .
... ... . . n..." .
. .... ... .... . .
.. .' .....--
:"~9.Yi~~:(. .
State
. .
'. . . .
J~EQ~I~~M~ S'a'NOPSIS
.:Acn()ijf9"W'M<~~Af,),..~AMR!H1.
. .' .. ..... .
.. . .. -. .
. .....
. .. . ". . . . . .
:.: ..:':':::::::...:::::ti~t9.:~
.. . .
Maine Solid Waste Management
Rules Including Regulations for
Construction/Demolition Debris,
Inert FUI, Land Clearing Debris,
and Woodwaste (MEDEP
Regulations, Chapters 400-4(4)
Maine Solid Waste Management
Rules: Management, Testing, and
Disposal of Special Wastes
? (MEDEP Regulations, Chapter
\II 405) .
Maine Asbestos Abatement
Regulations (MEDEP Regulations,
Chapter .136) .
Applicable
These regulations outline requirements for
closure of landfills to be used for the disposal
of construction/demolition debris.
Sites 5 and 6 can be classified as a
constructlonl demolition debris I~ndflll;
therefore, the closure of the waste disposal
area must meet the minimum specifications
outlined In Chapter 404.
Applicable
Section 405.4 sets forth requIrements that
apply to the storage, ,ran sport and disposal
of asbestos wastes.
These requirements will pertain to activities
conducted at Sites 5 and 6.
Applicable
These regulations specify the minimum work These requirements will apply to remedial
practice requirements for asbestos abatement activities at Sites 5 and 6.
contractors.
No...:
CFR
CMR
CWA'
DOT
FlFRA
MEDEP
MRSA
. Code of Federal Regulations
. Code of MaIne Regulation.
. . Clean Water Act
. Department of Transportation (U.S.)
. Federal Inl8Ctlclde, Fungicide, and Rodenticide Act
. MaIne Department of environmental Protection
. MaIn. Fllvl88d Statut.. Annotated
NAS = Naval Air Station .
NPDES = National PoUutant Discharge EUmlnatlon System
OSHA = Occupational Safety and Health Administration
POTW publicly owned treatment works
RCRA = Resource Conservation and Recovery Act
pg/m3 = micrograms per cubic meter
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TABLE C-4
ADDITIONAL ACTION-SPECIFIC ARARs, CRITERIA, AND GUIDANCE FOR SITES 1 AND 3
NECESSARY DUE TO ADDITION OF MATERIAL FROM SITES 5 AND 8
ROD: SITES 5 AND 8
HAS BRUNSWICK
. . . .
" "
".. Rr;Q~ifi~~ " "
Federal
CM - National" Emission
Standards for Hazardous
Pollutants (NESHAPs) (40 CFR
Part 61)
Occupational Safety and Health
Act (OSHA) - General Industry
n Standards (29 CFR Part' 1910)
I
0\
" OSHA - Safety and Health
Standards (29 CFR Part 1926)
State
Maine Solid Waste Management,
Testing, and Disposal of Special
Wastes (MEDEP Regulations,
Chapter 405)
WOO2931ST.08O/9
" $T~11JS
Relevant and
Appropriate
Applicable
Applicable
Applicable
REQUIREMENT SYNOPSIS
NESHAPs are promulgated for emissions of
particular air pollutants, Including asbestos.
These regulations specify the a-hour tlme-
weighted average concentration for various
organic compounds. Training requirements
for workers at hazardous waste, Including
asbestos, operations are specified In 29 CFR
Part 1910.120.
This regulation specifies the type of safety
equipment and procedures for handling
asbestos.
Section 405.4 sets forth requirements that
apply to the storage, transport and disposal
of asbestos wastes.
. ....... . .
. '. . . .' . . ..~. '.
ACTION TOm; T~~ .,qATtAIN ARAR.~
" The NESHAP requirements for emission
limits, and personnel training for the handling'
and disposal of asbestos (Subpart M) are
relevant and appropriate to activities
regarding the movement of asbestos material
to Sites 1 and 3. Actions taken at Sites 1
and 3 will meet these requirements.
Proper respiratory equipment will be worn If It
Is Impossible to maintain the work
atmosphere below the concentration.
Workers performing activities will be required
to have completed specific training
requirements.
All appropriate safety equipment will be on
site. In addition, safety procedures will be
followed during on-site activities.
These requirements will pertain to activities
Involving disposal of asbestos materials at
Sites 1 and 3. .
,'.
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c
conUnued
TABLE C-4
ADDITIONAL ACTION-SPECIFIC ARARs, CRITERIA, AND GUIDANCE FOR SITES 1 AND 3
NECESSARY DUE TO ADDITION OF MATERIAL FROM SITES 5 AND 8
ROD: SITES 5 AND 8
NAS BRUNSWICK
. .
., . .
:. flr;Q~IREM~. .'
Maine Asbestos Abatement.
Regulations (MEDEP Regulations,
Chapter 136)
. . .. .... .. .
...' ". ..... . ....
. .. ..
.. . ...
STATUS
Applicable
REQUIREMENT SYNOPSIS
ACTION 19' ~!;"~N tc)AT1'~N.A~R~ .
These regulations specify the minimum work These requirements will apply to remedial
practice requirements for asbestos abatement activities at Sites 1 and 3.
contractors.
Notu:
CFR =. Code of Federal Regulations
CMR ':' Code of Maine Regulations
CWA .. Clean Water Act .
DOT.. Department of Transportation (U.S.)
FIFRA .. Federal Insecticide, Fungicide, and Rodenticide Act
n MEDEP = Maine Department of Environmental Protection
.!., MRSA . MaIne Revised Statutes Annotated
NAS Naval Air Station
NPDES = National Pollutant Discharge Elimination System
OSHA = Occupational Safety and Health Administration
POTW = publicly owned treatment works
RCRA Resource Conservation and Recovery Act
JI9/m3 =. micrograms per cubic meter
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