PB94-963715
EPA/ROD/R01-94/089
November 1994
EPA Superfund
Record of Decision:
Brunswick Naval Air Station, Groundwater
Operable Unit Site 9, Brunswick, ME,
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INTERIM RECORD OF DECISION
FOR THE GROUNDWATER OPERABLE UNIT
AT SITE 9
NAVAL AIR STATION, BRUNSWICK
BRUNSWICK, MAINE
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NAVAL AIR STATION BRUNSWICK
INTERIM RECORD OF DECISION
TABLE OF CONTENTS
Contents
Paee No.
DECLARATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
DECISION SUMMARY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
I.
II.
SITE NAME, LOCATION, AND DESCRIPTION. . . . . . . . . . . 5
SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . 9
A. LAND USE AND RESPONSE HISTORY. . . . . . . . . .. . . . . 9
B. ENFORCEMENT HISTORY. . . . . . . . . . . . . . . . . . . . .. 10
COMMUNITY PARTICIPATION. . . . . . . . . . . . . . . . . . . .. 12
SCOPE AND ROLE OF RESPONSE ACTION. . . . . . . . . .. 13
SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . . . .. 13
A. RESULTS OF THE 1988 AND 1990 REMEDIAL
INVESTIGATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 13
B. RESULTS OF 1993 INVESTIGATIONS. . . . . . . . . . . . . .. 17
C. SUMMARY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 19
VI. SUMMAR Y OF SITE RISKS. . . . . . . . . . . . . . . . . . . . . . . " 20
A. STATUTORY REOUIREMENTS/RESPONSE
OBJECTIVES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 24
TECHNOLOG" AND A;LTERNATIVE DEVELOPMENT
AND SCREENING. . . . . . . . . . . . . . . . . . . . . . . . . . . " 26
VIII. DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . . . . . . .. 27
IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF
ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " 30
THE SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . . . . .. 36
A. CLEANUP CONCENTRATIONS. . . . . . . . . . . . . . . . . . .. 36
B. DESCRIPTION OF REMEDIAL COMPONENTS. . . . . . . .. 36
XI. STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . . . .. 39
A. THE SELECTED REMEDY IS PROTECTIVE OF HUMAN
HEALTH AND THE ENVIRONMENT. . . . . . . . " . . . .. 39
THE SELECTED REMEDY ATTAINS ARARs ........ 39
THE SELECTED REMEDIAL ACTION IS
COST-EFFECTIVE. . . . . . . . . . . . . . . . . . . . . . . . . . .. 41
THE SELECTED REMEDY USES PERMANENT
SOLUTIONS AND ALTERNATIVE TREATMENT OR
III.
IV.
Y.
B.
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B.
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D.
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NAVAL AIR STATION BRUNSWICK
INTERIM RECORD OF DECISION
TABLE OF CONTENTS
( continued)
Contents
Page No.
RESOURCE RECOVERY TECHNOLOGIES TO THE
MAxIMUM EXTENT PRACTICABLE. . . . . . . . . . . . . .. 41
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
ELEMEJl.il . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " 42
XII. DOCUMENTATION OF SIGNIFICANT CHANGES. . . . . " 42
XIII. STA1E ROLE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " 42
E.
REFERENCES
GLOSSARY OF ACRONYMS AND ABBREVIATIONS
APPENDICES
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
RESPOI\l';IVENE.SS SUMMARY
GROUNDWATER DATA SUMMARY TABLES
MEDEP LETTER OF CONCURRENCE
APPUCABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS
ADMINISTRATIVE RECORD INDEX: SITE 9
APPENDIX E
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NAVAL AIR STATION BRUNSWICK
INTERIM RECORD OF DECISION
LIST OF FIGURES
Page No.
Site Location Map: Site 9 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 6
Area of Potential Contamination: Site 9 ....................... 8
Site Location Exploration Map: Site 9 . . . . . . . . . . . . . . . . . . . . . . .. 14
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NAVAL AIR STATION BRUNSWICK
INTERIM RECORD OF DECISION
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LIST OF TABLES
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Table
Pag:e No.
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Groundwater Contaminants and Regulatory Criteria. . . . . . . . . . . . .. 22
Summary of Risk Estimates: Ingestion of Groundwater. . . . . . . . . " 25
Summary of Risk Estimates: Ingestion of Groundwater. . . . . . . . . .. 37
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DECLARATION
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SITE NAME AND LOCATION
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Naval Air Station (NAS) Brunswick
Neptune Drive Disposal Site: Site 9
Brunswick, Maine
STATEMENT OF BASIS AND PURPOSE
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This Interim Record of Decision (ROD) document presents the selected interim
remedial action of groundwater remediation through natural attenuation, institutional
controls, and long-tenn monitoring of the groundwater operable unit at the Neptune
Drive Disposal Site: Site 9 at NAS Brunswick in Brunswick, Maine. This decision
document was developed in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) 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.
Through this document, the Navy plans to monitor natural attenuation and prevent
exposure to contaminated groundwater which is a potential threat to human health,
welfare, or the environment at Site 9, while conducting additional source
investigations. This decision is based on information contained in the Administrative
Record for the site. Copies of this Administrative Record are located at the Public
Works Office at NAS Brunswick, and at the Curtis Memorial Library, 23 Pleasant
Street, in Brunswick, Maine.
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The State of Maine Department of Environmental Protection (MEDEP) and the U.S.
Environmental Protection Agency (USEPA) concur with the selected interim remedy.
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A final remedy and subsequent ROD for the site including both groundwater and
source operable units will be developed after conducting additional investigations.
ASSESSMENT OF TIlE SITE
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Actual or threatened releases of hazardous substances from Site 9, if not addressed
by implementing the interim respon:,~ action selected in thi~ ROD, may present an
endangerment to public health, welfare, or the environment.
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DESCRIPTION OF THE SELECTED REMEDY
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The interim remedial action consists of groundwater remediation through natural
attenuation, long-term environmental monitoring, institutional controls to prevent
exposure to contaminated groundwater, and five-year site reviews. Environmental
monitoring of groundwater, surface water, sediment, and leachate seep will be
conducted to measure the changes in contaminant concentrations due to natural
attenuation. Monitoring results will be submitted to the regulatory agencies as part
of the five-year reviews.
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By implementing this interim ROD, any threats posed by groundwater at Site 9 are
addressed by preventing endangerment to public health, welfare, or the environment.
The potential threat to human health is not immediate because groundwater at this
site is not currently used as a drinking water supply.
STATUTORY DETERMINATIONS
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The selected interim remedial action 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 interim
remedial action, and is cost-effective. This interim remedy will control risks posed
by the site, and will be consistent with a final remedy for the site. Because this
action does not constitute the final action at Site 9" the statutory preference for
remedies that employ treatment to reduc~ toxicity, mobility, or volume as a principal
element will be addressed in the final response action. Because this remedy may
result in hazardous substances being present in groundwater above health-based
cleanup concentrations, institutional -.:ontrols ~ll be necessary and a review will be
conducted by the Navy, the USEPA, and the MEDEP within five years to ensure that
the interim remedy continues to provide adequate protection of human health and
the environment. This review will be conducted at least every five years as long as
hazardous substances are present in groundwater above health-based cleanup
concentrations or until the ROD for the final site remedy is signed and supersedes
this Interim ROD.
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The foregoing represents the selection of an interim remedial action by the
Department of the Navy and the U.S. Environmental Protection Agency, New
England Regional Office, with concurrence of the Maine Department of
Environmental Protection.
By:
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Date:
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Title: Captain, U.S. Navy
Commanding Officer
Naval Air Station
Brunswick, Maine
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The foregoing represents the selection of an interim remedial action by the
Department of the Navy, and the U.S. Environmental Protection Agency, Region I,
with concurrence of the Maine Department of Environmental Protection.
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By:
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John P. DeVillars
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Title: Regional Administrator, USEP A
U.S. Environmental Protection Agency
Region I
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DECISION SUMMARY
I. SITE NAME, LOCATION, 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 Interim
Record of Decision (ROD) relates to the groundwater operable unit that is part of
the contamination at Site 9. '
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 feet 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 per'Jent of the base includes the operations area
(approximately 5 percent) and miscellaneous' shrub land, 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 elementary school, a college, and a hospital are located within 1 mile of the
western base boundary.
Site 9 was identified as a potential hazardous waste site in the Initial Assessment
Study (IAS) and was later included h. the Pollution Abatement Confirmation (PAC)
Study (R.F. Weston Inc., 1983 and E.c. Jordan Co., 1985). Based on information
gathered during those tasks, including review of aerial photographs and grading plans,
Site 9 was defined as three areas of potential contamination: (1) the former location
of an incinerator in the northeast corner of Building 220, and an inactive ash landfill/
dump area in the current location of Buildings 218 and 219 (military barracks north
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SITE LOCAT1ON MAP SITE 9
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of Neptune Drive); (2) a reported disposal area behind Building 201 (the dining
facility south of Neptune Drive); and (3) the two streams bordering the recreational
area behind Building 201. .
These areas are described in the following paragraphs and shown in Figure 2.
Former Incinerator and Ash Landfill/Dump Area
There is no precise information concerning the location of the incinerator and ash
landfill/dump area or types of wastes handled or disposed of in these areas. The
IAS identifies this area as the "first dump area used at the Air Station." The
incinerator was apparently operated during a period commencing on or after April
1943, when the air station was commissioned, until the fall of 1946, when the air
station was demobilized. Although the station was leased to various occupants from
1947 through 1951, including the University of Maine and Bowdoin College for
classrooms and student housing, and various small commercial enterprises, it is
unknown if the incinerator was used during this period. The air station was
recommissioned in 1951, but it is unknown if the incinerator resumed operation. The
incinerator could have been used as late as 1953, when the barracks that now occupy
the location of the former incinerator were built. The !AS (R.F. Weston, Inc., 1983)
states that during the period the incinerator was in operation, solid wastes were
burned and the ash was placed in the dump. Wastes disposed of at this location
reportedly included solvents which were burned on the ground, paint sludges, and
possibly wastes from the Metal Shop.
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Current land use at the former incinerator and inactive ash landfill/dump area is for
military residences. The grading plan; for the barracks (Buildings 212 through 220)
constructed at this location show an oblong~ "dump area," approximately 125 by
75 feet, located around existing Building 219. The grading plans also show an old,
42-inch-diameter drain adjacent to the dump area. The drain ran from north of
Orion Street, past the dump area, under Neptune Drive to the unnamed stream
running between Buildings 201 and 293. The drain may represent a potential
preferential pathway for contaminant migration. The drain was reportedly removed
during construction of the barracks.
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Building 201
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Historical information and aerial photographs indicate an area southeast of
Building 201 as a potential source of contamination. This area was reportedly used
as a dumping area (R.F. Weston, Inc., 1983). Building 201 was formerly the Chiefs
Club and in 1993 was converted to the Galley. The main use of this building is as
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J APPROXIMATE LOCATION
OF ASH DISPOSAL AREA
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a cafeteria. The area behind Building 201 has been used as a picnic area. A
barbecue pit is located southeast of the building.
Unnamed Streams
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Two unnamed streams border the area around Building 201; one to the north; one
to the south. These streams receive runoff from the central portion of the base
including the runways, parking lots, and paved roads. These streams flow and
discharge to the Picnic Pond located approximately 3,000 feet downstream of Site 9.
Seeps have been observed flowing into the northern unnamed stream.
Groundwater associated with the site 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.
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A more complete description of the site can be found in Section 10.0 of the Draft
Final Remedial Investigation (RI) Report (E.C. Jordan Co., 1990a); Section 6.0 of
the Draft Final Supplemental RI Report (E.c. Jordan Co., 1991); and the Technical
Memorandum for Site 9 (ABB-ES, 1994a).
II. SITE HISTORY AND ENFORCEMENT ACTMTlES
A.
LAND USE AND RESPONSE HISTORY
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NAS Brunswick is an active facility supporting the U.S. Navy's antisubmarine warfare
operations in the Atlantic Ocean and Mediterranean Sea. The base's primary
mission is to operate and maintain P-; Orion aircraft. NAS Brunswick first became
active in the 1940s during World War II, and underwent major expansion in the
1950s.
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Site 9 is located in the central portion of the base. Based on historical information,
including aerial photographs and grading plans, Site 9 was originally defined as three
areas of potential contamination: (1) the former location of an incinerator in the
northeastern corner of the current site of Building 220, and an inactive ash
landfill/dump area in the current location of Buildings 218 and 219 (military barracks
north of Neptune Drive); (2) a reported disposal area behind Building 201 (the
dining facility south of Neptune :C.ive); and (3) the two streams bordering the
recreational area behind Building 201 (R.E Weston, Inc., 1983). These areas are
described in Section I and shown on Figure 2.
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As part of the RI for Site 9, the Navy conducted field activities and environmental
sampling in 1988 and 1990 to determine the geologic and hydrologic conditions and
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the distribution of contamination at this site. The results of the RI are presented in
Section 11.0 of the Draft Final RI Report (E.c. Jordan Co., 1990a) and Section 7.0
of the Draft Final Supplemental RI Report (E.C. Jordan Co., 1991). Additional
investigations were conducted by the Navy in 1993 to better evaluate the septic
system as a source of groundwater contamination and fonner incinerator and ash
landfill/ dump area. The results of these investigations are summarized in the
Technical Memorandum. These documents are part of the Administrative Record
and are also available for review at the Curtis Memorial library in Brunswick,
Maine.
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ENFORCEMENT HISTORY
The enforcement history at Site 9 and the NAS is summarized as follows:
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In 1983, an !AS was completed detailing historical hazardous material
usage and waste disposal practices at NAS Brunswick. Ten sites were
identified and ranked according to potential hazard.
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In 1984, a PAC Study was conducted, which recommended further
investigation of seven of the 10 hazardous waste sites originally
identified (i.e., Sites 1 through 4 and 7 through 9).
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In 1987, NAS Brunswick was placed on the U.S. Environmental
Protection Agency's (USEP A) NPL.
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The RljFeasibility Study (FS) process was initiated in 1987 for the
seven sites identified in the PAC.
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In February 1988, the first Technical Review Committee (me)
meeting was held.' The mc is comprised of representatives from the
Navy, regulatory agencies, surrounding communities and concerned
citizens. mc meetings have been held quarterly since that initial
meeting.
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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 IAS (Le., Sites 5 a..d 6). Site 10, originally identified in the lAS,
was no longer under the jurisdiction of NAS Brunswick and is not
included in the Installation Restoration Program (IRP).
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In 1990, the Navy entered into a Federal Facility Agreement (FFA)
with the USEP A and the Maine Department of Environmental
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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.
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In August 1990, the Navy completed the 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 Navy prepared Focused Feasibility
Study (FFS) Reports for Sites 1 and 3 and Site 8 in 1991 and 1992,
respectively (E.C. Jordan Co., 1991a and 1992a). The Navy submitted
a Draft Final Supplemental RI Report for the Eastern Plume and
Sites 5, 6, 8, 9, 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., 1991, 1991b, and 1992). A
Technical Memorandum summarizing additional field investigations of
the septic system and former ash landfill/dump area at Site 9 was
prepared in May 1994 (ABB-ES, 1994a). RODs have been signed for
Sites 1 and 3, Sites 5 and 6, and Site 8. An Interim ROD has been
signed for the Eastern Plume.
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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 is
available to proceed to the ROD. Separate timetables have been established for
completing the Final FS reports and RODs for these sites.
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The Navy has identified the groundwater at Site 9 as a distinct area of contamination
and believes the remedial process can be initiated. An FS for Site 9 was submitted
to the regulatory agencies for review (E.C. Jordan Co., 1992). A Technical
Memorandum was prepared in May 1994 describing the results of additional field
investigations of the septic system and former ash landfill/dump area at Site 9
(ABB-ES, 1994a). This document concludes that, to date, no distinct source area of
groundwater contamination could be identified at Site 9 (ABB-ES, 1994a).
Therefore, the Navy recommended groundwater remediation through natural
attenuation. The Navy proposes that long-term monitoring of groundwater, surface
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water, sediment and leachate be initiated through this ROD, while additional source
investigations of Site 9 continues. A Proposed Plan, detailing the Navy's preferred
alternative, was issued in July 1994 and a Public Hearing was held on July 14, 1994,
to discuss and accept oral comments on the preferred alternative under consideration
for Site 9. Responses to comments received during the public comment period are
presented in Appendix A, the Responsiveness Summary.
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III. COMMUNI1Y PARTICIPATION
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Throughout the site's investigative and remediation history, the community has been
active and involved. Community members and other interested parties have been
informed of site activities through informational meetings, fact sheets, press releases,
public meetings, and 'IRC meetings.
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In August 1987, the Navy established an information repository for public review of
site-related documents at the Curtis Memorial Library in Brunswick. In 1992, the
Navy placed the RI, Supplemental RI, and FS reports for Site 9 in the Information
Repository and Administrative Record. In 1994, the Navy placed the Technical
Memorandum in the Information Repository and Administrative Record. A Public
Hearing was held in July 1994. The Administrative Record for Site 9 is available for
public review at NAS Brunswick in the Public Works office or at the Curtis
Memorial Library. A notice and brief analysis of the Proposed Plan were published
in the local newspaper, The Times Record.
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The mc has been an important vehicle for community participation. The 'IRC was
established in early 1988 and comprises the Navy, USEPA, MEDEP, and various
community representatives. The ;ommunity members of the TRC include
representatives from Brunswick, Harpswell, and Topsham, as well as the Brunswick
Area Citizens for a Safe Environment. The TRC also has representatives from the
Brunswick-Topsham Water District. The TRC has met on a quarterly basis to review
the technical aspects of the program and provide community input.
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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
to discuss the results of the RI, including field investigations at Site 9.
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On July 14, 1994, the Navy held an informational meeting and public hearing to
discuss the results of the RI, FS, and Technical Memorandum, and the Navy's
preferred alternatives as presented in the Proposed Plan for Site 9. During this
meeting, the Navy, its consultants, and regulatory representatives were available to
answer questions from the public, and accept formal comments. During the public
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comment period from July 12 to August 10, 1994, the Navy accepted comments on
the preferred alternative presented in the Proposed Plan for Site 9. These comments
and the Navy's responses to them are included in Appendix A, Responsiveness
Summary, of this Interim ROD.
IV. SCOPE AND ROLE OF RESPONSE ACTION
The selected interim remedy for Site 9 at NAS Brunswick was developed to address
the groundwater operable unit while additional source investigations are conducted.
The interim remedial action is not intended to be a final remedy, but is considered
consistent with the final remedy that will be chosen. The final ROD will be based
on the results of long-term monitoring and additional source investigations relevant
to Site 9. Additional interim remedial action(s) may be proposed if data collected
before the final ROD warrants such action(s).
V. SUMMARY OF SITE CHARACTERISTICS
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The nature and distribution of contamination at Site 9 is summarized by field
program and medium in the following paragraphs. A complete discussion of the site
characteristics can be found in Section 10.0 of the Draft Final RI Report on
pages 10-14 through 10-36 (E.c. Jordan Co., 1990a), and the Technical Memorandum
(ABB-ES, 1994a). Summary tables of groundwater contaminants and their
concentrations appear in Appendix Q-1 of the Draft Final RI Report and
Appendix B of this document.
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A.
RESULTS OF THE 1988 AND 1990 REMEDIAL INVESTIGATIONS
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The RI fieldwork conducted in 1988 and 1990 was designed to assess the areal
distribution of soil contamination at the site, monitor groundwater downgradient of
Site 9, assess the significance. of chemicals detected in the groundwater, and
determine the impact of this site on surface water and sediment quality. Most of the
RI fieldwork focused on the area south of Neptune Drive and included a soil gas
survey; test pits; soil borings; installation of monitoring wells; sampling of soils,
groundwater, surface water, sediment, and a leachate seep; and in situ aquifer
permeability tests. Sampling locations are presented in Figure 3.
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Groundwater Flow and Subsurface ':eology
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Groundwater flow at the site is to the south and southeast, discharging to the two
streams. The calculated seepage velocities range from 26 feet per year throughout
most of the site to 130 feet per year in the vicinity of the streams (E.c. Jordan Co.,
1991).
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Groundwater at Site 9 occurs in the overburden soil and varies in elevation between
10 and 14 feet below ground surface (bgs). Overburden soil at Site 9 is a stratified
formation consisting of a sand layer, a transition layer, and a clay layer overlying
bedrock. The elevation of ground surface at the site is approximately 40 to 50 feet
MSL. The top of clay has been interpreted from boring logs to occur at a depth of
about 20 feet bgs on the southern edge of the site.
Surface and Subsurface Soils
A soil gas survey was conducted to help identify potential areas of volatile organic
compound (VOC) contamination. The survey included areas both north of Neptune
Drive (two points between Buildings 218, 219, and 220, south of tbe ash
landfill/dump area), and south of Neptune Drive (18 points between Buildings 201
and 293). Two of 20 soil gas points detected low concentrations of VOCs. These
points were located near Building 293, east of the site, and do not indicate a source
of VOC contamination at Site 9. In subsequent subsurface soil sampling, one VOc,
dichloroethene (DCE), was detected at 6 micrograms per kilogram (Jlg/kg) at a
depth of 14 feet in one soil boring (i.e., MW-904) (E.e. Jordan Co., 1990a). No
contaminants were detected in subsurface soil samples collected north of Neptune
Drive.
Polynuclear aromatic hydrocarbons (P AHs) were detected in several surface soil and
test pit soil samples south of Neptune Drive at concentrations up to 30.5 milligrams
per kilogram (mg/kg). The location of the highest concentrations of PAHs near the
barbecue pit suggests that P AHs may be the result of charcoal or ash disposal or
deposits. The low levels of P AHs throughout Site 9 may also be attributable to base
operations, including motor vehicle tr; ffic and aircraft exhaust. Low levels (i.e., less
than 0.50 mg/kg) of pesticides were detecteC! in four test pit samples and three
surface soil samples (E.e. Jordan Co., 1992). These pesticides are believed to be
residues from basewide use of dichlorodiphenyltrichloroethane (DDT) in the 1960s
and early 1970s.
Leachate Seeps and Sediments
One leachate seep was identified at Site 9 and sampled twice during the RI field
program and again in 1993. The seep is located at the head of the northern stream
and at the discharge of the historical drain. It is possible that the ash disposal area
is the source of contaminants in the leachate. Pesticides were detected at low levels
in both the leachate and sediment from this location. Other organic compounds
were not detected in the leachate, but two organic compounds, butylbenzylphthalate,
and 1,I-dichloroethane (DCA) were each detected in the sediment in one of the
three sampling rounds at 820 Jlg/kg and 39 p.g/kg (52 Jlg/kg in the duplicate sample),
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respectively. Inorganic contaminants detected in leachate and sediment samples
include arsenic, lead, aluminum, manganese, and zinc.
Surface Water and Sediments
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Sixteen surface water and sediment locations in the streams near Site 9 as well as
downstream at the Picnic Area Pond (about 3,000 feet downstream of Site 9) were
sampled four times during the RI field program. The fuel-related organic
compounds benzene (6 to 18 micrograms per liter [JLg/LJ), toluene (12 to 22 JLg/L),
ethylbenzene (36 JLg/L), xylenes (34 to 74 ILg/L), naphthalene (26 JLg/L), and
methylnaphthalene (25 ILg/L) were detected in surface water samples in the stream
bordering the southern side of Site 9 (E.C. Jordan Co., 1990a). The maximum
concentration of all compounds except toluene was detected in the upstream sample
(i.e., SW-915) suggesting that nonpoint source runoff from parking lots, roadways
and/or the runways, located upstream of the site, is the source of these contaminants.
The source of toluene detected at SW-916 is not known. None of these compounds
were detected above their respective freshwater Ambient Water Quality Criteria
(A WQe). A WQC are contaminant concentrations in surface water that are
considered protective of aquatic organisms.
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Calcium, iron, magnesium, and sodium were detected in the streams bordering Site 9
at concentrations exceeding background levels of surface water samples collected in
Mere Brook. In addition, iron concentrations exceeded the chronic A WQC for this
metal in both upstream and on-site sampling locations. Concentrations of inorganics
in surface water at the Picnic Area Pond did not exceed A WQCs. These
concentrations were consistent with background values (E.c. Jordan Co., 1990a).
Site-related VOCs were not detected in sediment samples from the streams near
Site 9; however, toluene was detected in two sediment samples from the Picnic Area
Pond. Concentrations of inorganics in sediment samples were consistent with
background concentrations in sand and clay soils (E.C. Jordan Co., 1990a).
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P AHs were detected in the majority of sediment samples colleCted in most sampling
rounds from the streams in the Site 9 vicinity, at concentrations up to 383 mg/kg.
The highest concentration was detected at SD-011. Dibenzofuran was also detected
at SD-Oll at a concentration of 5.1 mgjkg. Two other organic compounds,
bis(2-ethylhexyl)phthalate (up to :,900 ILgjkg) and butylbenzylphthalate (up to
1,000 ILgjkg), were detected sporadically in sediment samples from the Site 9
streams. The highest concentrations were detected in the upstream sample at the
culvert outfall (E.C. Jordan Co., 1990a).
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Pesticides and polychlorinated biphenyls (PCBs) were not detected in surface water
or sediment.
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Groundwater
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Up to five groundwater samples were collected from the wells at Site 9 during the
RI and analyzed for Target Compounds List (TCL) VOCs, Semi Volatile Organic
Compounds (SVOCs); Pesticides, and Target Analyte list (TAL) inorganics. VOCs
were detected in three wells (i.e., MW-904, MW-906, and MW-907). These data are
summarized in Table B-1 of Appendix B. Groundwater upgradient of the septic
system and south of Neptune Drive did not contain VOCs. Vinyl chloride was
detected twice in MW-904 (12 to 27 pg/L), once in MW-906 (31 pg/L), and once in
MW-907 (18 p.g/L). The federal Maximum Contaminant Level (MCL) for vinyl
chloride is 2 p.g/L The federal Maximum Contaminant Level Goal (MCLG) is zero,
because this compound is classified as a carcinogen. The state Maximum Exposure
Guideline (MEG) for vinyl chloride is 0.15 p.g/L. DCA was detected in four of five
sampling rounds in MW-904 at concentrations ranging from 5 to 12 pg/L DCA was
detected in MW-906 at 36 pg/L in only one sampling round. DCA was also detected
in two groundwater samples (i.e., CP-902 and CP-903) collected in 1991
downgradient of the septic system at 20 and 7 p.g/L, respectively. There is neither
an MCL nor an MCLG for DCA, but the MEG is 5 p.g/L. DCE was detected in
MW-904 in two sampling rounds at 6 p.g/L, and in MW-906 at 79 p.g/L The MCL,
MCLG, and MEG for 1,2-DCE are all 70 pg/L.
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SVOCs were detected at some wells but at estimated concentration (i.e., below the
contact required quantification limit [CRQL]). Inorganics detected in Site 9
groundwater were in the normal backgound qmge, except for sodium, calcium, iron,
and magnesium (E.C. Jordan Co., 1990a). Mercury was detected in MW-904 in two
sampling rounds in 1989, but has not been detected at the site since. Mercury
concentrations were 0.22 and 0.23 p.g/L, below its MCL, MCLG, and MEG of
2 p.g/L.
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RESULTS OF 1993 INVESTIGATIONS
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In 1991, additional historical information was discovered, identifying the presence of
a septic system east of Building 201. The septic system was installed in 1952 when
Building 201 was built, and was usea until 1972 when Building 201 was connected to
the basewide sewer system (E.c. Jordan Co., 1991) It was speculated that the septic
system, located upgradient of the monitoring wells with the highest contaminant
levels, was the primary source of groundwater contamination at Site 9, prompting
further investigation of this area. In January through March of 1993, the Navy
conducted additional investigations to evaluate the Building 201 septic system as a
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potential source of contamination south at Neptune Drive and to further evaluate the
former incinerator and ash landfill/dump area north of Neptune Drive. The
investigations included the installation of soil borings, additional groundwater
monitoring wel1s, completion of a TerraProbe survey, and col1ection and analysis of
groundwater, surface water, and leachate samples.
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South of Neptune Drive - Septic System Investigation
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In January 1993, borings were dril1ed through the septic tank and four of the five
cesspools to determine if the septic system was the source of VOC contamination in
groundwater east of Building 201. VOCs, if present, would likely be attached to the
organic-rich soils within the septic tank and cesspools. Organic sediment in the
septic tank and the organic layers in the cesspools were visually identified and five
samples were collected and analyzed for contamination. ChIorobenzene was the only
site-related contaminant detected in the subsurface soils around the septic system at
a concentration of 16 ILg/kg. No VOCs, PCBs or pesticides were detected above the
CRQL While the septic system cannot be ruled out as being a past source of VOC
contamination detected in this area, results of these samples indicate that the septic
system is not a current source of contamination.
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Two monitoring we11s were insta11ed south of the southern unnamed stream (MW-909
and MW-91O), and groundwater samples were collected from these new and from the
four existing wells (MW-904, MW-906, MW-907, and MW-908) behind Building 201.
Samples were sent for analysis for TCL VOCs, SVOCs, pesticides, PCBs, and TAL
inorganics. No VOCs were detected above the CRQL. However, vinyl chloride
(non-detect to 9J ILg/L), DCA (non-detect to 21 p.gjL), and toluene (non-detect to
1J p.gjL), were observed in one Jr more samples and one SVOC (bis-2-
ethylhexyl)phthalate at 121 ILg/L in MW-906j was observed in the 1993 sampling
event.
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Only a few inorganics were observed in samples from MW-909 and MW-910 above
background concentrations. Of these, only aluminum, iron, and manganese exceeded
their respective MCLs, but these are secondary standards based on aesthetic qualities
and not on protection of human health. A summary of these data are presented in
Tables B-2 and B-3 of Appendix B.
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The groundwater sample results als:- indicate that contaminants are not migrating
beneath the southern unnamed stream. These data support the assumption that
contaminated groundwater discharges directly to the unnamed streams. To evaluate
whether or not the former drain acts as a conduit for any contaminants that may be
site-related, a leachate surface water and a sediment sample were collected on the
south side of Neptune Drive at location LT-901. These sampJes were analyzed for
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the same analytes as those tested for in the groundwater samples. Detections of
DCA, P AHs, and pesticides were noted in the sediment sample.
North of Neptune Drive. Former Incinerator and Disposal Area
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A TerraProbe investigation consisting of 33 locations, and three monitoring wells
were installed during the 1993 field investigation north of Neptune Drive. Results
of these activities identified the distribution of ash in the fonner landfill/dump area.
The ash extends on either side of Building 219. Ash, found from 6 to 16 feet below
ground surface (bgs), was sampled and found to contain P AHs at concentrations from
3.8 to 33 mg/kg. The presence of P AHs is typical with burned materials observed
in the borings. .
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Three monitoring wells were installed during this field investigation consisting of one
. upgradient well (MW-916), and two wells downgradient of the ash landfill/dump area
(MW-914 and MW-915) and one groundwater sample from each well was collected
for chemical analysis.
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Groundwater samples collected immediately downgradient of the ash disposal area
did not contain P AHs at concentrations that could be quantified. Sporadic low
concentrations of DCA, DCE, and vinyl chloride were detected in the two
downgradient monitoring wells. Except for vinyl chloride, all compounds were
detected below their respective MCLs. Vinyl chloride was detected only in one
monitoring well at a maximum concentration of 10J p.g/L, which is above its MCL
of 2 p.g/L. Elevated inorganic concentrations were detected in the downgradient
wells. Ho\yever, only two analytes, cadmium and manganese, were detected above
their respective MCLs. A summary uf these Qata are presented in Tables B-2 and
B-3 of Appendix B.
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The groundwater sampling results from the downgradient monitoring wells do not
indicate a significant source of VOC contamination that continuously impacts
groundwater quality. Overall groundwater quality in the two downgradient wells
indicate that, although the ash is below the water table, organic compounds are not
leaching from the ash or migrating through groundwater flow at concentrations of
concern to human health or the environment.
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c.
SUMMARY
The results of the 1988, 1990, and 1993 field investigations at Site 9 indicate the
presence of vinyl chloride and DCE in groundwater at concentrations in excess of
their MCLs and vinyl chloride, DCE and DCA in excess of their MEGs. The septic
system, originally thought to be the source of VOC contamination south of Neptune
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Drive, was sampled to evaluate residual contamination. Sampling results indicate
that the septic system is not currently a source of groundwater contamination. The
former ash landfill/dump area, north of Neptune Drive, was identified and
characterized. P AHs were detected in the ash material; however, these compounds
were not detected in groundwater immediately downgradient from this area. Vinyl
chloride was detected in one monitoring well downgradient from the landfill/dump
area but was not detected in ash or soil samples. Elevated concentrations of
inorganics were detected in groundwater downgradient of the ash disposal area, and
the presence of these analytes may be due to past disposal activities in this area.
Inorganics and PAHs were detected in leachate and/or sediment samples. The
presence of these contaminants may be due to the ash or to other non-point source
runoff from the roadways or parking lots.
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The Navy recommended an interim remedial action for the groundwater operable
unit at Site 9 because no definitive source area was found. Despite the inability to
detennine the source of groundwater contamination, the previous investigations have
concluded that: the former incinerator and ash landfill/dump area and the septic
system are not current sources of VOC contamination. The interim remedial action
consists of long-term monitoring of groundwater, surface water, sediment and
leachate at Site 9 to evaluate groundwater remediation by natural attenuation both
north and south of Neptune Drive. The Navy is proposing additional source
investigations at Site 9. The final Proposed Plan and ROD for Site 9 will incorporate
the results of additional and address any other remedial actions that may be
necessary to remediate the remainder of Site 9.
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VI. SUMMARY OF SITE RISKS
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A baseline risk assessment was conducted to estimate the potential risks to human
health and the environment from exposure to groundwater, surface water, sediment,
leachate, and soil contaminants associated with Site 9. The human health risk
assessment followed a four-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 established
the extent of possible exposure; (3) toxicity assessment, which considered the types
and magnitude of adverse health effects associated with exposure to hazardous
substances; and (4) risk characterizo.:;on, 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 for Site 9 are summarized in Appendix Q of the Draft Final RI Report
(E.C. Jordan Co., 1990a). However, because this section is to support the interim
groundwater ROD, only the risks associated with groundwater exposure are
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summarized in this section. A summary of site risks will be presented in the final
ROD for this site.
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The groundwater contaminants of concern (COe) identified in the Site 9 human
health risk assessment constitute a representative subset of all the contaminants
identified during the RI. The COCs were selected to represent potential site-related
hazards based on toxicity, concentration, frequency of detection, and mobility and
persistence in the environment. The COCs are summarized in Tables Q-7 and Q-14
in Appendix Q of the Draft Final RI Report (E.C. Jordan Co., 1990a). A summary
of the health effects of each COC is presented in Appendix Q, pages Q-122 through
Q-151 of the Draft Final RI Report (E.C. Jordan Co., 1990a).
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The potential risks associated with exposure to groundwater contaminants south of
Neptune Drive were qualitatively evaluated in the Draft Final RI report (E.c. Jordan
Co., 1990a) based on a comparison of contaminant concentrations to MCLs, MCLGs,
MEGs, or health-based criteria. Quantitative risk estimates were developed as part
of the Technical Memorandum (ABB-ES, 1994a) to evaluate risks associated with
potential future use of groundwater from the portion of Site 9 north of Neptune
Drive not previously evaluated. A summary of the groundwater contaminants of
concern, analytical data and regulatory standards and criteria are presented in
Table 1.
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VOCs were the contaminants detected most frequently at Site 9. VOCs were
detected in three wells (MW-904, 906 and 907) located south of Neptune Drive and
one well (MW-915) located north of Neptune Drive. Vinyl chloride was detected at
concentrations ranging from non-detect to 31 p.g/L south of Neptune Drive and from
non-detect to 101 p.g/L north of Neptune Drive. The federal MCL for vinyl chloride
is 2 p.g/L. The federal MCLG is zero because this compound is classified as a
carcinogen. The MEG for vinyl chloride is 0.15 p.g/L. In addition to vinyl chloride,
DCA and DCE were detected in groundwater at concentrations in excess of either
the MCL, MCLG, or MEG.
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Inorganics detected in groundwater at Site 9 were in the normal background range,
except for sodium, calcium, iron, mercury and magnesium (south of Neptune Drive)
and sodium, calcium, aluminum, chromium iron, and manganese (north of Neptune
Drive). Aluminum, iron, and manganese concentrations exceeded their respective
MCLs. However, the MCLs for the:::: inorganics are based on aesthetic qualities and
not on protection of human health.
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Quantitative risk estimates for ingestion of groundwater were developed as part of
the Technical Memorandum based on analytical data collected in 1993. The risk
. estimates were based on a residential exposure and assumed that a 7D-kilogram adult
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CONCENTRATION RANGE FEDERAL MCL FEDERAL MCLG MAINE MEG
COMPOUND . (pG/L) CPG/L) (pG/L) (pG/L)
Vinyl Chloride ND - 31 2 0 0.15
1,1-Dichloroethane ND - 36 - - 5
1,2-Dichloroethylene ND . 79 70 70 70
2-Butanone ND - 110 -- -- -
Toluene ND - 1 J 1,000 1,000 2,000
PAHs (total) ND - 12J - - --
Mercury ND - 0.23 2 I 2 2
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MEG
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TABLE 1
GROUNDWATER CONTAMINANTS AND REGULATORY CRITERIA
INTERIM RECORD OF DECISION: SITE 9
NAS BRUNSWICK
Maximum Contaminant Level; (USEPA. 1992)
Maximum Contaminant Level Goal; (USEPA, 1992)
Maximum Exposure Guideline; (MEDOH, 1990)
Not Detected
Estimated Concentration
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drinks 2 liters of water per day for 30 years. This scenario is considered to be
conservative because groundwater beneath the site is not currently used for potable
purposes. The quantitative risk estimates are presented in Appendix C of the
Technical Memorandum (ABB-ES, 1994a) and summarized in the following
paragraphs.
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Excess lifetime cancer risks were estimated for the groundwater exposure pathway
by multiplying the exposure level by the chemical-specific cancer slope factor (CSF).
CSFs have been developed by USEP A from epidemiological or animal studies to
reflect a conservative "upper bound" of the risks posed by potentially carcinogenic
compounds. That is, the true risk is unlikely to be greater than the predicted risk.
The resulting risk estimates are expressed in scientific notation as a probability (e.g.,
lxlO-6 for 1/1,000,000) and indicate (using this example) that an individual is not
likely to have more than a one-in-a-rnillion chance of developing cancer over 70 years
as a result of site-related exposure to the compound at the stated concentration.
Current USEP A practice considers carcinogenic risks to be additive when assessing
exposure to a mixture of hazardous substances.
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The Hazard Index (HI) was also calculated for the groundwater exposure pathway
as USEP A's measure of the potential for noncarcinogenic health effects. The HI is
the sum of Hazard Quotients (HQs), which are calculated for each chemical by
dividing the exposure level by the reference dose (RID) or other suitable benchmark
for noncarcinogenic health effects. RIDs have been developed by USEP A to protect
sensitive individuals during the course of a lifetime, and they reflect a daily exposure
level that is likely to be without an appreciable risk of an adverse health effect.
RIDs are derived from epidemiological or animal studies and incorporate uncertainty
factors to help confirm that adverse health effects will not occur. The HQ is often
expressed as a single value (e.g., 0.3) indicating the ratio of the stated exposure as
defined to the RID value (in this example, the exposure as characterized is
approximately one-third of an acceptable exposure level for the given compound).
The HQ is only considered additive for compounds that have the same or similar
toxic endpoints. Risk estimates developed as part of this baseline risk assessment
were evaluated using the USEP A criteria and target risk range to identify the need
for remedial actions at this site.
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The significance of risk estimates was evaluated by comparing risks to established
target levels. USEP A has establisheu target levels for the evaluation of carcinogenic
risks and noncarcinogenic hazards at hazardous waste sites. USEP A's guidelines
state that the total incremental carcinogenic risk for an individual resulting from
multiple-pathway exposures at a Superfund site should not exceed a range of 10-6 to
10-4. The State of Maine has established a guideline of 1xlO.5 incremental
carcinogenic risk as a target risk level for remediation at hazardous waste sites. The
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risk characterizations in this report refer to the USEP A's target risk range; and
carcinogenic risk estiInates as being "below the target range" when risks are less than
10-6; "within the target range" when risks are between 10-6 and 10-4; and "above the
target range" when risks are greater than 10"". The 'USEPA's and State of Maine's
target hazard level for noncarcinogenic effects is an HI of 1.0.
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Incremental cancer risks and HIs for the groundwater scenarios evaluated at Site 9
are summarized in Table 2. The HI is calculated to be 6.0 and 3.0 based on
exposure to the maximum and average contaminant concentrations, respectively.
Both IDs exceed the USEP A target level of 1.0, but are below the USEP A Region I
values of concern for HI of 10 (USEP A, 1989). The elevated HI is due almost
entirely to the presence of manganese. The incremental carcinogenic risk is
estimated to be 2x104 for the maximum and 1x104 for the average exposure
conditions. The cancer risk is attributable to the presence of vinyl chloride. The
estimated incremental cancer risks are at or slightly exceed the USEP A target risk
range and exceed the MEDEP's risk guideline.
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Environmental receptors are not considered to be at risk from exposure to
groundwater contaminants. Groundwater at Site 9 discharges to the tributaries
bordering the site. The ecological risks associated with exposure to surface water
and sediments were calculated and are presented in Appendix Q to the Draft Final
RI (E.c. Jordan Co., 1990a). Exposure to contaminants (i.e., DDT and PARs) from
sources other than Site 9 groundwater may be associated with potential risks to
aquatic organisms. These risk estimates will be used to determine the need for
additional remedial actions in the stream sediments and surface water at Site 9 and
will be presented in the final ROD or source operable unit ROD for this site.
Actual or threatened releases of hazardous substances from this site, if not addressed
by implementing the response action selected in this ROD, might present an
endangerment to public health, welfare, or the environment. The objective of the
selected interim remedial action is to reduce contaminant concentrations in
groundwater at Site 9 through natural attenuation.
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VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
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STA11JTORY REQUIREMENTS/RESPONSE OBJECTIVES
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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 the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA) establishes
several other statutory requirements and preferences, including a requirement that
it
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AVERAGE SCENARIO MAXIMUM SCENARIO
MAXIMUM AVERAGE HAZARD INCREMENTAL INCREMENTAL
CONCENTRATION CONCENTRATION INOEX CARCINOGENIC HAZARD INDEX CARCINOGENIC
COMPOUND (pgll) (pglll (UNITlES6: RISK (UNIT\.E8SI (UNITLESSI RISK (UNfTLESSI
Vinyl Chloride 10 6 0.00027 1.3x10" 0.00027 2.2x1 0"
1,1.Dichloroethane 1 1 0.00068 NA 0.00068 NA
Naphthalene 1 1 0.00046 NA 0.00046 NA
Acenaphthalene 1 1 0.00068 NA 0.00068 NA
Phenanthrene 1 1 0.0027 NA 0.0027 NA
Bis(2-ethyl hexyl) phthalate 2 2 - 3.3x 1 0" - 3.3)(10"
Aluminum 5,510 2,493 0.094 NA 0.17 NA
Barium 443 239 0.21 NA 0.35 NA
Cadmium 6.4 3.8 0.035 NA 0.054 NA
Chromium 9.9 6.4 2.3 NA 5.5 NA
Manganese 1,010 415 0.024 NA 0.024 NA
Vanadium 6.2 6.2 - NA - NA
Summary 4' 1x10" 6 2x 1 0"
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Notes:
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TABLE 2
SUMMARY OF RISK ESTIMATES: INGESTION OF GROUNDWATER'
INTERIM RECORD OF DECISION: SITE 9
NAS BRUNSWICK
Not calculated; no quantitative toxicity information available.
Not applicable: compound nOI considered 10 be carcinogenic.
This scenario is based on 70 kilogram adult ingesting 2 liters of water per day for 30 years.
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the Navy's remedial action, when complete, complies 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.
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Based on preliminary information relating to the types of contaminants,
environmental media of concern, and potential exposure pathways, remedial action
objectives were established to aid in the development and screening of alternatives.
These remedial action objectives were established to mitigate existing and future
potential threats to public health and the environment, to comply with state
requirements, and address community concerns, and include:
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reducing VOC contamination in groundwater to
concentrations considered protective of human health
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evaluate groundwater quality and measure contaminant concentrations
in the groundwater, surface water, sediment, and leachate through
long-term environmental monitoring
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conduct additional source investigations of possible source areas of
contamination both north and south of Neptune Drive
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TECHNOLOGY AND ALTERNATIVE DEVELOPMENT AND SCREENING
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CERCLA and the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP) set forth the process by which remedial actions are evaluated and
selected. In accordance with these requirements, a range of alternatives was
developed for the site.
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Remedial action alternatives for NAS Brunswick were developed to (1) adequately
protect public health and the environment; (2) attain chemical-specific Applicable
or Relevant and Appropriate Requi.ements (ARARs) that can be implemented in
a manner consistent with location- and action-specific ARARs; (3) use permanent
treatment technologies to the maximum extent practicable; (4) be capable of
achieving a remedy in a cost-effective manner, considering short- and long-term costs;
and (5) permanently and significantly reduce the toxicity, mobility, or volume of
hazardous substances, to the maximum extent practicable.
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The Navy's selection of the interim remedial action was the result of a
comprehensive evaluation of different alternatives and the regulatory review process.
The Draft Final FS for the site was conducted to identify remedial technologies and
develop alternatives that could address contamination at the site. The FS report was
prepared prior to the results of the 1993 field investigations summarized in the
Technical Memorandum (ABB-ES, 1994a). The FS report describes and evaluates
five alternatives: an alternative that offers no action; an alternative that offers
minimal action but includes institutional controls and long-term monitoring; an
alternative that includes a low-permeability cover over an area of concern to
minimize rainwater infiltration through a source area; an alternative to remove the
source of contamination and dispose of it at an off-site landfill; and an alternative
to remove and dispose of the source of subsurface soils that includes extraction/
treatment of groundwater.
The No Action Alternative described in the Phase 1 FS report was renamed Minimal
Action in the FS report because it included institutional controls and environmental
monitoring. A true No Action Alternative was developed for the FS that included
no remedial actions at the site. The No Action Alternative was included to comply
with the NCP and to use as a baseline to measure the effectiveness of the
alternatives.
VIII. DESCRIPTION OF ALTERNATIVES
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Source control and groundwater remedial alternatives for Site 9 were developed and
presented in the FS report (E.C. Jordan Co., 1992). However, these alternatives
were developed based on the assumption that the septic system and leachfield
associated with Building 201 were the sources of groundwater contamination.
Sampling results collected and analyzed in 19~3 indicate that the septic system and
subsurface soils around the septic system are not acting as a current source of
contamination (ABB-ES, 1994a). Therefore, remedial actions for removing,
containing, or treating the septic system or subsurface soils are not necessary at this
time.
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The Navy will be conducting additional field investigations in the vicinity of Site 9
to evaluate other potential source areas of groundwater contamination. Until these
field investigations are completed, no source control alternatives will be developed.
Therefore, this interim remedial aCi.:Jn addresses only groundwater contamination.
Other alternatives (i.e., a no action alternative and alternatives that include a source
control component) will be developed and evaluated after the completion of the
additional field investigations at Site 9. Therefore, this section summarizes only the
No-Action and Minimal Action Alternatives developed for detailed analysis and
described in Section 8.0 of the FS (E.C. Jordan Co., 1992).
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ALTERNATINE9~:NOACTION
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The No Action Alternative does not include any remedial actions and provides a
baseline for comparing alternatives. In the No Action Alternative, the site would
remain undisturbed. Because no remedial actions would be implemented, long-tenn
human health risks for the site would essentially be the same as those identified in
the baseline risk assessment.
Estimated Time for Design and Construction: Not applicable
Estimated Time of Operation: Not Applicable
Estimated Capital Cost: None
Estimated Operations and Maintenance Costs (net present worth):
Estimated Total Cost (net present worth): None
None
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ALTERNATIVE 9-B: GROUNDWATER REMEDIATION THROUGH NATURAL
ATTENUATION, INSTITUTIONAL CONTROLS AND LONG-TERM
MONITORING
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The preferred alternative for the interim remedial action at Site 9 is remediation
through natural attenuation, and long-term monitoring of the groundwater operable
unit to measure expected decreases of contaminant concentrations over time. In
addition, institutional controls will be implemented to limit exposure to groundwater
during the time required to reduce contaminant concentrations in groundwater.
Because the source has not been characterized, the site groundwater has been set as
an operable unit, and a long-term monitoring plan is being prepared. The Navy
proposes to initiate additional source investigations to develop the final remedial
action at this site.
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The preferred alternative is the same as the Minimal Action Alternative described
in the FS, except it includes monitoring of the leachate seep at the former drain
outlet location when sufficient liquid is present to collect a sample (E.c. Jordan Co.,
1992). The preferred alternative also includes groundwater, surface water, and
sediment monitoring to measure the decrease in contaminant concentrations by
natural attenuation. The time to achieve groundwater clean-up concentrations under
this alternative was estimated based on USEP A-approved groundwater models and
groundwater flow velocities at the site. Groundwater at Site 9 moves at an estimated
26 feet to 130 feet per year; therefcPf:, a water particle will move through the site
(i.e., from Neptune Drive to the southern unnamed stream) in approximately
0.70 years. The groundwater models indicate that it may require three to 22 pore
volume flushes to remediate the aquifer. Under natural flow conditions, groundwater
clean-up concentrations would be achieved over a period of two to 15 years, the
amount of time it would take for the groundwater to discharge to the streams (E.c.
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Jordan Co., 1992). Under an active groundwater remediation scenario (i.e.,
groundwater pumping and treatment), clean-up concentrations would be achieved in
approximately three years. This scenario includes pumping contaminated
groundwater from two extraction wells to a treatment plant. The treatment process
would include pretreatment of the water for metal removal and enhanced chemical
oxidation of the organic compounds in the groundwater using ultraviolet light. The
treatment process would be designed to meet MCLs for vinyl chloride and l,2-DCE.
Once treated, the water would be discharged to the sewer, one of the streams or
reinjected into the aquifer. The time to achieve clean-up concentrations is estimated
to be three years with a total cost (net present worth) of 1,300,000
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The natural attenuation alternative includes the following components:
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groundwater remediation through natural attenuation,
long-term monitoring of groundwater, surface water, sediment, and
leachate,
institutional controls, and
five-year reviews
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The Navy will also be conducting additional source investigations concurrent with
implementing this alternative.
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Components of this interim remedial alternative are described in the following
paragraphs.
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Institutional Controls. The preferred alternative requires institutional controls (i.e.,
deed and land use restrictions) to prevent .buman consumption of contaminated
groundwater until monitoring results determine that controls are no longer necessary.
These controls would be implemented to restrict future use of site groundwater for
drinking water. The legal implications of instituting land-use restrictions would be
coordinated with appropriate Navy officials and state and local governments. If NAS
Brunswick ever closes, these restrictions would be placed on future development.
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Environmental Monitoring. Groundwater and surface water quality would be
monitored as a measure of the long-term effectiveness of remediation by natural
attenuation. Monitoring groundwater would track contaminant concentrations and
groundwater movement. Surface water and sediment monitoring would also track
contaminant concentration to evaluate the impact, if any, of groundwater discharge
to the streams. The Navy will prepare a Long-Term Monitoring Plan detailing the
sampling locations, frequency of sampling events, and contaminants to be analyzed.
This plan would be submitted for regulatory agency review, comment, and approval.
Environmental monitoring would occur until groundwater clean-up concentrations are
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achieved. For cost-estimating purposes, the monitoring was assumed to occur for up
to 30 years, although the clean-up concentrations are expected to be achieved within
15 years. The costs for monitoring the groundwater have been included to assess the
progress of natural attenuation for up to 30 years. .
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Five-year Site Review. Under CERCLA 121c, a five-year site review is required for
any site where contaminants remain on the site at concentrations that do not allow
for unlimited exposure or land use. The five-year review is expected to focus on
evaluating whether the remedial alternative continues to provide adequate protection
of human health and the environment, and would focus on the data collected as part
of the long-term monitoring program. The five-year site review could recommend
additional remedial actions at the site or that no further action is necessary. The
five-year review would be conducted in cooperation with the MEDEP and USEP A
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The cost estimate for this interim remedial alternative is based on conducting
quarterly groundwater sampling at 13 locations; surface water and sediment sampling
at five locations; and leachate sampling at one lbcation for a period of five years.
After five years, the sampling frequency is assumed to occur bi-annually for 10
additional years and annually for up to 30 years. All samples will be analyzed for
VOCs and selected samples analyzed for SVOCs and inorganics. The cost estimate
also includes costs associated with conducting five-year reviews. The actual costs of
this interim remedial alternative will be determined based on the final Long-Term
Monitoring Plan and agency input during the five year reviews.
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Estimated Time for Design and Comtruction: Not applicable
Estimated Time of Operation: 30 years of monitoring
Estimated Capital Costs: $0
Estimated Operatiom and Maintenance Costs (net present worth): $434,000
Estimated Total Cost (net present worth): $434,000
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IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
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Section 121(b)(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
individual remedial alternatives.
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A detailed analysis was performed on the alternatives using the nine evaluation
criteria to select a site remedy. The following is a summary of the comparison of
each alternative's strengths and weaknesses with respect to the nine evaluation
criteria. These criteria and their definitions are as follows:
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Threshold Criteria
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The two threshold criteria described below must be met for the alternatives
to be eligible for selection in accordance with the NCP.
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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.
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Primarv Balancine Criteria
The following five criteria are used to compare and evaluate the elements of
one alternative to another that meet the threshold criteria.
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3.
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.
4.
Reduction of toxicity, mobility, or volume through treatment
evaluates the treaunent technologies by the degree of expected
reduction in toxicity, mobility, or volume of hazardous material.
This criterion also evaluates the irreversibility of the treatment
process and the type and quantity of residuals remaining after
treatment.
5.
Short-tenn 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
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monitor the effectiveness of the remedy. Administrative
feasibility is addressed in terms of the ability to obtain
approvals from other agencies. This criterion also evaluates the
availability of required resources, such as equipment, facilities,
specialists, and capacity.
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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.
Modifvin2 Criteria
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The modifying criteria are used in the final evaluation 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 ~omment on the alternative the Navy proposed for the
remedial action.
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Community acceptance addresses the public's general response
to the alternatives described in the Proposed Plan and FS
report and requires a determination of which components of the
alternatives interested persons in the community support, have
reservations about, or oppose.
The state acceptance criterion has been addressed by incorporating comments
received from the state on the Proposed Plan. The final acceptance by the state will
be evaluated after the state has had an opportunity to review comments received
during the public comment period. The state is a party to the FF A and has had the
opportunity to review and comment on all documents relating to Site 9. Following
the detailed analysis of each individual alternative, a comparative analysis, focusing
on the relative performance of the alternatives against the nine criteria, was
conducted. The comparative analysis for the original alternatives can be found in
Table 8-11 of the FS (E.c. Jordan Co., 1992). A description of the preferred
alternative can be found in the Propvsed Plan (ABB-ES, 1994b). The section below
presents the nine criteria and a brief narrative summary of the alternatives and the
strengths and weaknesses according to the detailed and comparative analysis.
9.
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Overall Protection of Human Health and the Environment
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Overall Protection of Human Health and the Environment addresses how an
alternative as a whole will protect human health and the environment. This includes
an assessment of how human health and environmental risks are properly eliminated,
reduced, or controlled through treatment, engineering controls, or institutional
controls.
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The interim remedial action developed for Site 9 will provide protection of human
health and the environment. Protection of human health is provided by reducing
exposure to site contaminants through institutional controls. Protection to the
environment would be provided, over time, as natural attenuation reduces
contaminant concentrations discharging to the unnamed streams. Clean-up
concentrations would be achieved over two to 15 years, the amount of time required
for the groundwater to discharge to the streams.
Compliance with Applicable or Relevant and Appropriate Requirements
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Compliance with ARARs addresses whether or not a remedy complies with all state
and federal environmental and public health laws and requirements that apply or are
relevant and appropriate to the conditions and clean-up options at a specific site. If
an ARAR cannot be met, the reasons must be clearly stated and a waiver may be
required. When comparing interim remedies, it is appropriate to analyze compliance
with only those laws and regulations that are applicable or relevant and appropriate
to the limited scope of the interim action.
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The interim remedial alternative will attain ARARs that apply to the limited scope
of the interim action. Because the remedy selected is an interim action that includes
no remedial action, the location- and action-specific ARARs do not apply. The
selected remedy would meet the following' chemical-specific federal and state
ARARs: Safe Drinking Water Act MCLs and non-zero MCLGs; and Maine
Drinking Water Rules.
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Long-term Effectiveness and Permanence
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Long-term Effectiveness and Permanence refers to the ability of an alternative to
maintain reliable protection of human health and the environment over time once
clean-up goals have been met.
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Site 9 risks associated with the groundwater operable unit stem largely from potential
exposure to groundwater as drinking water. Because there is no current use of
groundwater, there is no immediate threat to human health at Site 9.
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The interim remedial action depends solely on institutional controls and land use
restrictions to reduce risks, while natural attenuation will provide the long-term
effectiveness. Effective enforcement of institutional controls will be needed to
assume proper protection of human health under this alternative.
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Reduction of Toxicity, Mobility, or Volume through Treatment
Reduction of Toxicity, Mobility, or Volume through Treatment are three principal
measures of the overall performance of an alternative. The 1986 Superfund
amendments emphasize that, whenever possible, USEP A should select a remedy that
uses a treatment process to permanently reduce the level of toxicity of contaminants
at the site, the spread of contaminants away from the source of contamination (i.e.,
mobility), and the volume or amount of contamination at the site.
The interim remedial alternative relies on institutional controls and natural flushing
of the aquifer to achieve risk reduction. There is no treatment component to this
alternative. Therefore, this alternative does not meet this criterion. An active
groundwater remediation scenario (i.e., groundwater pumping and treatment) would
achieve a significant and permanent reduction of toxicity, mobility, and volume of
VOCs in groundwater.
Short-term Effectiveness
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Short-term Effectiveness refers to the likelihood of adverse effects on human health
or the environment that may result during the construction and implementation of
an alternative until clean-up goals h~ve been achieved.
There will be no impacts to the community, ~orkers, or environment above those
that currently exist at Site 9 as a result of implementing the interim remedial
alternative.
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Impacts to workers conducting long-term monitoring will be controlled by the use of
appropriate personal protective clothing and equipment during remedial activities.
All site work would be conducted in accordance with Occupational Safety and Health
Administration (OSHA) regulations.
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Implementability
Implementability refers to the technical and administrative feasibility of an
alternative, including the availability of materials and services needed to implement
the alternative.
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The interim remedial action is implementable. Long-term monitoring has been
successfully demonstrated at other Superfund sites. An active groundwater
remediation scenario would be easily implemented. Groundwater treatment methods
are we1I developed and demonstrated, although UV / oxidation has not been used
extensively. There should be little difficulty constructing extraction wells and the
treatment plant and obtaining the clean-up concentrations. Additional remedial
actions, if necessary, would not be hindered by this remediation scenario.
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Cost
Cost includes the capital (up-front) cost of implementing an alternative as well as the
cost of operating and maintaining the alternative over the long term, and net present
worth of both capital and operation and maintenance costs.
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The capital, operation and maintenance, and total cost for the interim remedial
action alternative is provided as part of the Description of Alternatives in
Section VITI. The estimated total cost (net present worth) is $434,000. The costs are
based on sampling 13 monitoring well locations, five surface water and sediment
locations and one leachate seep. Quarterly sampling is assumed for the first five
years, with bi-annual. sampling through 15 years and annual sampling up to 30 years.
The major cost component in this alternative is long-term environmental monitoring.
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The estimated total costs (net present worth) for an active groundwater remediation
scenario is $1,31-0,000. These costs include the capital costs for installing the
extraction wells and building the treatment plant, operation and maintenance costs
associated with the treatment plant and annual monitoring costs for a period of five
years.
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State Acceptance
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As a party to the FF A, the State of Maine has provided comments and
recommendations on the RI reports, FS, Technical Memorandum and Proposed Plan.
The Navy has taken the State's comments into account. The State has documented
its concurrence with the remedial action as stated in Section XIII of this ROD. A
copy of the state's letter of concurrence is presented in Appendix C of this ROD.
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Community Acceptance
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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 hearing and during the public comment period.
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This is documented in the Responsive Summary presented in Appendix B of this
ROD.
X. THE SELECTED REMEDY
The selected remedy for the Interim ROD at Site 9 is Alternative 9B. This
alternative consists of groundwater remediation through natural attenuation, long-
term environmental monitoring of groundwater, surface water, sediment and
leachate, institutional controls and five-year reviews.
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This action does not address the source of contamination, and a final remedy for the
site will be presented after additional source investigations are conducted. In
addition, the need for remedial action in sediments and smface waters in the streams
will be evaluated and addressed in the final ROD for Site 9 or in a separate operable
unit ROD.
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A.
CLEANUP CONCENTRATIONS
Cleanup concentrations have been established for the COCs identified in the risk
evaluation. Cleanup concentrations have been set equivalent to the appropriate
ARARs (e.g., MCLs) if available. In the absence of a chemical-specific ARAR, or
other suitable criteria to be considered, a concentration corresponding to a 10~
excess cancer risk level for carcinogenic effects of an HQ of 1.0 for noncarcinogenic
effects was used to set cleanup concentrations. Periodic assessment of the protection
afforded by remedial actions will be made as the remedy is being implemented and
until a final remedy is chosen to replace this interim action.
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Table 3 summarizes the cleanup concentrations derived based on carcinogenic and
noncarcinogenic effects for the COCs identified in the groundwater. These cleanup
concentrations are consistent with ARARs for groundwater.
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B.
DESCRIPTION OF REMEDIAL COMPONENTS
This interim remedial action consists of:
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groundwater remediation through natural attenuation,
long-term monitoring \Jf groundwater, surface water, sediment,
leachate,
institutional controls, and
five-year reviews.
and
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TABLE 3
TARGET CLEANUP CONCENTRATIONS
INTERIM RECORD OF DECISION: SITE 9
NAS BRUNSWICK
CONTAMINANT
MAXIMUM TARGET CLEANUP
CONCENTRATION MCL MEG CONCENTRATION
(pgfL) (pg/L) (pgfL) (pg/L)
79 70 70 70
36 N/A 5 5
31 2 0.15 2
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DCE
DCA
Vinyl Chloride
Notes:
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MEG
N/A
P9/L
DCA
DCE
Maximum Contaminant Level (Federal Safe Drinking Water Act)
Maximum Exposure Guideline (State 01 Maine Drinking Water Rules)
Not Available
micrograms per liter
dichloroethane
dichloroethylene
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Natural Attenuation
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Based on previous investigations, the Navy does not believe there to be a continuing
source of groundwater contamination at Site 9. Therefore, the time to achieve
groundwater cleanup concentrations by natural attenuation was estimated based on
USEP A-approved groundwater models and groundwater flow velocities at the site.
Groundwater at Site 9 moves at an estimated 26 to 130 feet per year; therefore, a
water particle will move through the site (i.e., from Neptune Drive to the southern
unnamed stream) in approximately 0.70 years. The groundwater models indicate that
it may require three to 22 pore volume flushes to remediate the aquifer. Under
natural flow conditions, groundwater cleanup concentrations would be achieved over
a period of two to 15 years, the amount of time it would take for the groundwater
to discharge to the streams. Active remediation (i.e., pumping and treatment) of the
groundwater was not warranted because of site specific conditions (i.e., sporadic
detections or contaminants).
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Environmental Monitoring
Groundwater and surface water quality would be monitored as a measure of the
long-term effectiveness of remediation by natural attenuation. Monitoring
groundwater would track contaminant concentrations and groundwater movement.
Surface water, sediment, and leachate monitoring would also track contaminant
concentrations to evaluate the impact, if any, of groundwater discharge to the
streams. The Navy will prepare a Long-Term Monitoring Plan detailing the sampling
locations, frequency of sampling events, and contaminants to be analyzed. This plan
will be submitted for agency review and comment. Environmental monitoring would
occur until groundwater cleanup concentratiops are achieved. For cost-estimating
purposes, the monitoring is assumed to occur for a period of 30 years.
Institutional Controls
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The selected alternative requires institutional controls to prevent human contact with
contaminated groundwater until monitoring results determine that controls are no
longer necessary. These controls would be implemented to restrict future use of site
groundwater for drinking water. The legal implications of instituting land-use
restrictions would be coordinated with appropriate Navy officials and state and local
governments. If NAS Brunswick cIo~es, these restrictions would be placed on future
development.
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Five-year Reviews
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Under CERCLA 121c, a five-year site review is required for any site where
contaminants remain on the site at concentrations that do not allow for unlimited
exposure of land use. The five-year review is expected to focus on evaluating
whether the remedial alternative continues to provide adequate protection of human
health and the environment, and would focus on the data collected as part of the
long-term monitoring program. The five-year site review would be conducted in
cooperation with the MEDEP and USEP A.
XI. STATUTORY DETERMINATIONS
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The remedial action selected for implementation at NAS Brunswick Site 9 is
consistent with CERCLA and, to the extent practicable, the NCP. The selected
remedy is protective of human health and the environment, attains ARARs, and is
cost-effective. However, the selected remedy does not satisfy the statutory preference
for treatment that permanently and significantly reduces the toxicity, mobility, or
volume of hazardous substances as a principal element. The selected remedy is an
interim action which will be consistent with the final remedy that will be selected for
Site 9.
A.
THE SELECTED REMEDY IS PROTECfIVE OF HUMAN HEALTH AND mE
ENVIRONMENT
The remedy at Site 9 will permanently reduce the risks posed to human health and
the environment by eliminating, reducing, and controlling exposures to human and
environmental receptors through natural attenuation. Human health risks will be
reduced through the use of institutiona! controls during the time required to achieve
cleanup objectives (estimated to be between two and 15 years). The implementation
of the selected remedy will not pose unacceptable short-term risks or cross-media
impacts.
B.
THE SELECTED REMEDY ATIAINS ARARs
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This remedy will attain all applicable or relevant and appropriate federal and state
requirements that apply to the limited scope of the interim action. Generally,
ARARs for the selected interim r~tnedial action are a subset of those found in
Tables 2-1,2-2 and 2-4 of Section 2.0 of the FS (E.c. Jordan Co., 1992). However,
because the FS considered permanent remedial alternatives and the remedy selected
is an interim action that includes no remedial action, the location- and action-specific
ARARs outlined in the FS do not apply. Appendix D presents tabular summaries
of the chemical-specific ARARs that apply to the remedy including the regulatory
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citation and a brief summary of the regulatory requirement and the action to be
taken to attain the ARAR.
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The selected remedy would meet the following federal and state ARARs:
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Chemical-specific ARARs
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Safe Drinking Water Act (SDWA) - MCLs and non-zero MCLGs
.
Maine Drinking Water Rules
,
The following chemical-specific policies, criteria, and guidelines were also considered:
.
Maine Department of Human Services Rule 10-144A, CMR Chapter
233 -MEGs
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USEP A Human Health Assessment Group CSFs
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Location-specific ARARs
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No remedial actions are included in this interim action; therefore, location-
specific ARARs are not triggered.
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Action-specific ARARs
No remedial actions are included as part of this interim action; therefore,
location- or action-specific ARARs are not triggered.
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Federal and State Drinking Water Regulations. The chemical-specific ARARs
identified for Site 9 were applied to the RIfFS process to determine the need for
groundwater remediation. The drinking water standards, MCLs, and other guidance
and criteria to be considered (TBCs) were used to evaluate potentia] risk to human
health from the ingestion of groundwater. In the evaluation of potential risk, the
groundwater in the aquifer underlying the site is classified by the state as GW-A, a
drinking water source. The quality ~-:d safety of drinking water sources is regulated
by the SDW A and Maine Drinking Water Rules. MCLs are enforceable standards
under the SDW A that represent the maximum level of contaminants that is
acceptable for users of public drinking water supplies. MCLs are relevant and
appropriate because, while the groundwater on- and off-site is not currently used as
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a drinking water source, the groundwater underlying NAS Brunswick potentially
could be used as a drinking water source in the future.
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In the case of DCA, because no MCL or other ARAR exists, it is appropriate to
consider the Maine MEG in setting a cleanup level. Use of the MEG of 5 ,.,.gJL will
reduce the risks to levels which are within USEPA's acceptable risk range of 1
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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 because it is implementable and provides long-term
effectiveness. The selected remedy, however, does not satisfy the statutory
preference for treatment because active groundwater. treatment is not considered to
be cost-effective or feasible at this time. The interim remedial action provides the
best balance of trade-offs among these criteria prior to determination of a final
remedy.
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E.
THE SELECTED REMEDY DOES NOT SATISFY THE PREFERENCE FOR
TREATMENT WHICH PERMANENTI..Y AND SIGNIFICANTLY REDUCES THE
TOXICITY, MOBILI1Y, OR VOLUME OF THE HAzARDOUS SUBSTANCES AS A
PRINCIPAL ELEMENT
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This remedy does not meet the statutory preference for treatment. Active
groundwater treatment was not considered to be cost-effective at this time, based on
time required to achieve response objectives.
This interim ROD will be followed by a final ROD that will determine what further
action, if any, will be necessary for a complete remedy at tbe site that will meet the
preference for treatment which will permanently and significantly reduce toxicity,
mobility, or volume of hazardous substances.
XII. DOCUMENTATION OF SIGNIFICANT CHANGES
The Navy presented a Proposed Plan for remediation of the groundwater operable
unit at Site 9 in July 1994. The prefeITed alte'rnative included long-term monitoring
of groundwater which will be remediated by natural attenuation. Institutional
controls will also be implemented. No significant changes have been made to the
alternative described in the Proposed Plan and presented to the public.
XIII. STATE ROLE
,
As a party to the FF A, MEDEP has reviewed the various alternatives and has
indicated its support for the selected interim remedy. MEDEP concurs with the
selected interim remedy for NAS Brunswick Site 9. A copy of the letter of
concurrence is presented in Appendix C of this Interim ROD.
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GLOSSARY OF ABBREVIATIONS AND ACRONYMS
ARAR
AWQC
bgs
CERCLA
CRQL
CSF
COC
DCA
DCE
DDT
FFA
FFS
FS
HI
HQ
!AS
IRP
MCL
MCLG
MEDEP
MEG
mg/kg
mg/L
MSL
NAS
NCP
NPL
OSHA
Applicable or Relevant and Appropriate Requirement
Ambient Water Quality Criteria
below ground surface
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (the Superfund statute)
contract required quantification limit
cancer slope factor
contaminant of concern
dichloroethane
dichloroethene
dichlorodiphenyltrichloroethane
Federal Facility Agreement
Focused Feasibility Study
Feasibility Study
Hazard Index
Hazard Quotient
Initial Assessment Study
Installation Restoration Prograrl1
Maximum Contaminant Level
Maximum Contaminant Level Goal
Maine Department of Environmental Protection
Maximum Exposure Guideline
milligrams per kilogram
milligrams per liter
mean sea level
Naval Air Station
National Oil and Hazardous Substances Pollution Contingency Plan
National Priorities List
Occupational Safety and Health Administration
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GLOSSARY OF ABBREVIATIONS AND ACRONYMS
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PAC Pollution Abatement Confirmation Study
I PAR polynuclear aromatic hydrocarbons
PCB polychlorinated biphenyl
.1 RID reference dose
RI Remedial Investigation
ROD Record of Decision
SDWA Safe Drinking Water Act
SVOC semivolatile organic compound
TAL target analyte list
TECs other guidance and criteria to be considered
TCL target compound list
TRC Technical Review Committee
p.gjkg micrograms per kilogram
p.gjL micrograms per liter
USEPA U.S. Environmental Protection Agency
VOC volatile organic compound
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REFERENCES
ABB-ES, 1994a. "Technical Memorandum: Site 9: Neptune Drive Disposal Site";
Portland, Maine; May.
ABB Environmental Services, Inc. (ABB-ES), 1994b. "Proposed Plan for Site 9, the
Neptune Drive Disposal Site NAS Brunswick"; Portland, Maine; July.
E.c. Jordan Co., 1985. "Pollution Abatement Confirmation Study NAS Brunswick";
Portland, Maine; July.
E.c. Jordan Co., 1990a. "Draft Final Remedial Investigation Report NAS
Brunswick"; Portland, Maine; August.
E.c. Jordan Co., 1990b. "Draft Final Phase] Feasibility Study Development and
Screening of Alternatives NAS Brunswick"; Portland, Maine; August.
E.c. Jordan Co., 1991. "Draft Final Supplemental Remedial Investigation Report
NAS Brunswick"; Portland, Maine; August.
,
E.c. Jordan Co., 1991a. "Focused Feasibility Study for Sites 1 and 3 NAS
Brunswick"; Portland, Maine; October.
E.c. Jordan Co., 1991b. "Focused Feasibility Study for Sites 5, 6, and 12 NAS
Brunswick"; Portland, Maine; July.
E.c. Jordan Co., 1992. ''Feasibility Study Sites 2, 4, 7, 9, 11 and 13 NAS Brunswick";
Portland, Maine; March. ~
E.c. Jordan Co., 1992a. "Feasibility Study for Site 8 NAS Brunswick"; Portland,
Maine; March.
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R.F. Weston Inc., 1983. "Initial Assessment Study of Naval Air Station, Brunswick,
Maine"; Westchester, Pennsylvania; June.
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U.S. Environmental Protection Agency (USEPA), 1989. "Risk Assessment Guidance:
Region I"; Boston, Massachli.~ctts; February.
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APPENDIX A
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RESPONSIVENESS SUMMARY
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SUMMARY OF COMMENTS RECEIVED
DURING THE PUBLIC COMMENT PERIOD
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During the public comment period, written comments were received from special
interest groups. At the public meeting on July 14, 1994, several questions and
comments were also raised. The following is a list of all comments and questions
and the Navy's response.
1.
Comment (written): Page 1-1. It would be helpful to have an idea of when
the interim remedial action will begin, when the Navy anticipates conducting
the additional source investigations, and approximately when the final
remedial action will be selected. This comment relates to BACSE's concerns,
as stated at the July 14, 1994 public hearing on the subject document, that the
additional source investigations, as well as the evaluation and possible
remediation of contaminated stream sediments be conducted in a timely
fashion.
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Response: The interim remedial action for Site 9 of long-term monitoring is
scheduled to begin in Fiscal Year 1995 (FY95). The fiscal year begins on
October 1, 1994. Additional source investigations are also scheduled for
FY95. Based on the results of the additional source investigations, the Navy
will either begin the final remedial action for Site 9 or collect additional
information to fill potential data gaps. Without knowing the results of the
additional source investigations, the Navy cannot commit to a date for the
final remedial action ,at this site. However, the Navy is committed to
proceeding in a timely fashion and all schedules for future work will be
prepared and submitted to the Technical Review Committee (TRC) for
review and comment.
2.
Comment (written): Page 3-4. Why is the old drain mentioned at the end of
the Former Incinerator and Ash Landfill section of concern.
Response: The old drain is mentioned in this section because it represents
a potential preferential pathway for contaminant migration. Contaminants
associated with the ash landfill may have leached from the disposal area and
migrated through the subsurface soils along the location of the old drain. As
part of the additional source investigations, the Navy has proposed sampling
the soils from this area and placing a monitoring well to better evaluate this
potential contaminant pathway.
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SUMMARY OF COMMENTS RECEIVED
DURING THE PUBLIC COMMENT PERIOD
(Continued)
Comment (written): Page 4-1. It should be clarified that the Proposed Plan
referred to in the final sentence in Section 4.0 is not the subject document,
but rather a future plan related to the additional source investigations, and
that the risks to be addressed will include the risks associated with P AHs
(polynuclear aromatic hydrocarbons) detected in stream sediments.
Response: The Proposed Plan referred to in the final sentence of Section 4.0
is the Proposed Plan for the final remediation of Site 9 and not the subject
document. The "final" Proposed Plan will provide a summary of site risks
from exposure to all media including the risks associated with exposure to
P AH contamination in stream sediments. These risk estimates will be used
to determine the need for additional remedial actions at Site 9 and be
summarized in the final Record of Decision (ROD) or operable unit ROD to
be prepared for this site.
4.
Comment (written): Page 4-5. Why is there no risk estimate for
1,2-Dichloroethylene (DCE) in Table 4-2. What are the risk estimates for
DCE.
Response: The risk estimates presented in Table 4-2 were based on analytical
data collected in 1993 from the wells (MW-914, MW-915 and MW-916) north
of Neptune Drive. 1,2-Dichloroethylene (DCE) was not detected in these
wells and therefore, a q\lantitative risk estimate could not be developed. The
quantitative risk estimates in the Proposed Plan are a summary of the risk
evaluation presented in the Technical Memorandum (May 1994).
5.
Comment (written): Page 6-1: The estimate of time (0.70 years) for a water
particle to travel through Site 9 does not appear to be correct if groundwater
moves at an estimated rate of 26 to 130 feet per year. For example,
monitoring well MW-916 is situated almost 500 feet upgradient of the nearest
identified groundwater discharge location, the northern unnamed stream (see
Figure 3-3, for example). At the estimated rates, groundwater in the vicinity
of MW -916 might be expected to discharge to the northern unnamed stream
in approximately 3.8 to 19.2 years.
Response: The estimated time of 0.70 years for a water particle to travel
through Site 9 is based on the distance from the area of contaminated
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SUMMARY OF COMMENTS RECEIVED
DURING THE PUBLIC COMMENT PERIOD
(Continued)
groundwater (i.e., MW-904, MW-906 and MW-908) to the stream. This
distance is approximately 90 feet. Assuming a seepage velocity of 130 feet per
year, a water particle would require 0.70 years to discharge to the unnamed
stream.
6.
Comment (written): Page 6-2. It is not clear how the results of the additional
source investigations will be evaluated in conjunction with the long-term
monitoring results. How does the reevaluation of the interim remedial action
mentioned in the last sentence on Page 1-1 figure into the long-term
monitoring plan.
Response: The results of the additional source investigations will be used to
support the final ROD for Site 9. For example, if these investigations indicate
a source of groundwater contamination, a final ROD or an operable unit
ROD focusing on source remediation may be appropriate. If the
investigations do not identify a source of groundwater contamination, the
interim remedial action of long-term monitoring may be appropriate as the
final action. This determination cannot be made until the results of the
source investigations become available for review and evaluation.
The data collected a&. part of the long-term monitoring program will be
evaluated at a minimum of eveI)' five years. However, the Navy has indicated
that these data will be evaluated more frequently and will be used, as
appropriate, to evaluate the effectiveness of the selected interim remedial
alternative. If the data collected as part of the long-term monitoring program
does not support groundwater remediation through natural attenuation (i.e.,
decreases in groundwater contaminant concentrations), then additional
remedial actions may be necessary. The TRC will be involved in the review
and evaluation of the data.
.
Comment (written): Page 6-3. Was the cost estimate based on conducting 15
or 30 years of annual monitoring once 5 years of quarterly monitoring and 10
years of biannual monitoring are completed. If the estimated time of
operation is 30 years, it would appear that 15 years of annual monitoring is
appropriate for the cost estimate.
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SUMMARY OF COMMENTS RECEIVED
DURING mE PUBLIC COMMENT PERIOD
(Continued)
Response: The cost estimate is based on conducting quanerly sampling for
years 0 through 5, biannual sampling for years 6 through 15, and annual
sampling for years 16 through 30.
8.
Comment (verbal): The citizens group is concerned that additional
investigations be conducted in a timely fashion.
Response: The interim remedial action of long-term monitoring and
additional source investigations at Site 9 are both scheduled to be conducted
during the fiscal year 1995 which begins on October 1, 1994. The Navy
considers this to be a timely response to community and regulatory concerns.
9.
Comment (verbal): The citizens group is concerned that the sediments in the
stream be addressed in a timely fashion.
Response: The Naval Air Station has conducted sediment sampling for P AH
contamination in the unnamed tributary adjacent to Site 9. These data will
be used in conjunction with existing data and data collected as part of the
long-term monitoring program to evaluate potential clean-up alternatives for
the stream sediments, as necessary. The remedial alternatives for the stream
sediments will be pres;nted in a Proposed Plan and documented in either an
operable unit or final ROD for Site 9. The public will have the same
opponunity to comment on these alternatives that it has had to comment on
the Interim Remedial Alternative presented in this ROD.
10.
Comment (verbal): How did the Navy determine that it would take 2 to 15
years to clean up the groundwater?
Response: The range of time estimated for contaminants in the groundwater
at Site 9 to decease to drinking water concentrations is based on three
variables; (1) the measured groundwater velocities at the site, (2) the distance
between the contaminated source area and the discharge location, and (3) the
fraction of organic carbon (f..:) which largely determines the retardation factor
which then is used to determine the number of pore volumes of groundwater
that must flush through the area.
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SUMMARY OF COMMENTS RECEIVED
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(Continued)
It was estimated to require 0.70 years for a water panicle to travel through
Site 9, from the area of contaminated groundwater identified in MW-904,
MW-906, and MW-908 to the discharge location at the southern unnamed
stream. The distance between the monitoring wells and the stream is
approximately 90 feet. Using the measured groundwater velocity of 130 feet
per year, a water particle would require 0.70 years to discharge to the
unnamed stream.
The time required to achieve cleanup concentrations is based on the
calculation of 22 pore volumes through the area of contamination. Because
the plume contains contaminants that adsorb onto the soil, the plume travels
slower than groundwater. The retardation factor assumed in this estimate was
based on a range of f.x: of 0.01 to 0.001. This range results in the 2- to 15-
year estimate presented in the Interim ROD.
Comment (ver~: Is it correct that the model used is based on static
conditions and not on trends?
Response: Yes, that is correct.
12.
Comment (verbal): \v,here do the two unnamed streams empty into?
Response: The two unnamed streams discharge into the lower portion of
Mere Brook which discharges into Harpswell Cove.
13.
Comment (verbal): Do we know how much contaminants are flowing through
those streams every year?
Response: No. However, the Navy and NAS do monitor the surface water
in these streams. The long-term monitoring program described in this ROD
will provide additional data that will allow the Navy to estimate the amount
of contamination that is discharging from the Site 9 area into the two
unnamed streams.
Comment (verbal): Are there 8 other sites that are discharging into streams
and into Mere Brook? .
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SUMMARY OF COMMENTS RECEIVED
DURING mE PUBLIC COMMENT PERIOD
(Continued)
Response: There are a total of 13 sites that are being studied as part of the
Installation Restoration Program (IRP). Of these 9 sites are within the Mere
Brook drainage area, as well as several non-IRP sites.
15.
Comment (verbal): The best and hopeful plan that you have coming out of
this monitoring will show a decrease in these contaminants over the years.
Do you hope they just go away? Is that what we're looking for?
Response: Yes. The Navy's remedial action at Site 9 is groundwater
remediation through natural attenuation. Allowing natural processes such as
degradation to reduce contaminant concentrations in groundwater. Over time,
the Navy expects to see a decrease in groundwater contamination. This will
be measured through the implementation of the long-term monitoring
program.
16.
Comment (verbal): The report said something about chromium, was that an
error?
Response: No. Chromium was detected in groundwater in two monitoring
wells north of Neptune Drive at estimated concentrations of 9.9J p.g/L
(MW-914) and 4.3J p.u./L (MW-915 duplicate sample). Chromium was not
detected in the MW-915 sample. The chromium concentration is considered
to be estimated because it was detected below the contract required detection
limit for the laboratory performing the analysis. Background concentrations
of chromium is estimated to be 6.3 p.g/L.
17.
Comment (verbal): The reason I asked is that chromium has the highest risk
estimate (hazard index) as presented in Table 4-2 of the Proposed Plan.
Could you just talk about that for a minute?
Response: The risk estimates presented in Table 4-2 of the Proposed Plan
are based on the assumption that an individual drinks 2 liters of water per day
for 300 days per year over a 3D-year exposure duration. All the water is
obtained from the area beneath Site 9. The hazard index is the ratio of the
exposure dose the individual receives divided by an "acceptable" dose (Le.,
concentration of the contaminant that is expected to be without adverse
effects). If the hazard index is greater than 1, then the assumed exposure
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SUMMARY OF COMMENTS RECEIVED
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(Continued)
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dose could result in adverse health effects. . However, this is not a certainty
because of the numerous assumptions and uncertainties made in calculating
the ratio (Le., the assumption that someone drinks the water and that the
toxicity data generally conducted on small mammals reflects the risks to
humans).
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The hazard index for chromium is the highest of all the compounds detected
in the groundwater. This indicates, that relative to all other contaminants,
chromium could potentially cause the greatest risk if water at Site 9 was used
for drinking purposes. Based on these results, chromium should be identified
as a contaminant of concern at Site 9. It should be noted that chromium was
not detected at Site 9 at concentrations in excess of its Drinking Water
Standard of 100 p.g/L.
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The long-term monitoring program includes the sampling of groundwater and
analysis of chromium (among other contaminants). As such, additional data
will become available as to the distribution of chromium contamination at Site
9.
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APPENDIX B
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GROUNDWATER DATA SUMMARY TABLES
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TABLE B-1
SUMMARY OF GROUNDWATER ORGANIC AND INORGANIC ANALYSIS (1989 - 1991)
INTERIM RECORD OF DECISION: SITE 9
NAS BRUNSWICK
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SAMPUNO ROUND 1 1 2 2 3 4 4 4 4 4 & & & & &
REPORT DATE 1/89 1/89 3/89 3/89 7/89 1/90 1/90 1/90 1/90 1/90 4/91 4/91 4/~1 4/91 4/91
SAMPlE LOCATION MW- MW.80:1 MW.804 MW.803 MW-804 MW- MW.803 MW.- MW.eo7 MW..oe MW.804 MW.- _.807 CP.eo3 CP.90Z
Vinyt Chloride 12 NO 27 NO NO NO NO NO 18 NO NA 31 NA NA NA
1,1-0lchloroethane t2 NO 12 NO 6J 5 NO 36 ND NO NA NO NA 20 20
1,2-Dlchloroethytene 6 NO 6 NO ND ND NO NO NO NO NA 79 NA NO NO
2-Butanone NO NO NO NO 68J NO 110 NO ND ND NA NO NA NA NA
Aluminum NO NO NO NO 1130 NO NO 445J NO NO NA ND NA NA NA
Calcium 18000 9700J 21100 7140 16800 18400 6650 12000 26600 18200 NA 10700 NA NA NA
Iron NO 3600J NO 3430 1950 .. NO 3700 NO NO NO NA 115 NA NA NA
Magnesium 5700 NO 5960J NO 5610 5730 NO NO 5570 NO NA NO NA NA NA
Manganese 160 240J 167 207 123 155 223 336 2500 823 NA 52.5 NA NA NA
Mercury O.22J NO 0.23 NO NO NO NO NO NO NO NA NO NA NA NA
Sodium 7500 17000J 5410 14000 8040 NO 17800 36700 16100 10800 NA 35100 NA NA NA
Zinc NO NO NO NO 25.3 NO NO No No No NA No NA NA NA
Bicarbonate NA NA NO NO NA NA NA NA NA NA 43 74 100 NA NA
Chloride NA NA NA NA NA NA NA NA NA NA 7.3 29 24 NA NA
Sulfate NA NA NA NA NA NA NA NA NA NA 4.9 8.8 6.2 NA NA
. . . . . I I
Notes:
All concentrations in pg/L eKcept bicarbonate, chloride, and sulfate which are In mg/l.
Sample locations are shown In Figure 1-2.
pg/L
mg/L
J
NO
NA
micrograms per liter
milligrams per liter
estimated concentration
not detected
not analyzed
-------
.~,...;.,,"
VOCII lua/LI
._.
,-'"
,_'
.:"."'.f"'
,~.
_.
,-,
TABLE B-2
SUMMARY OF GROUNDWATER ORGANIC ANALYSES (1993)
INTERIM RECORD OF DECISION: SITE 9
NAS BRUNSWICK
SOUTH OF NEPTUNE DRIVE
NORTH OF NEPnlNE DRIVE
MW-908/DUP
2/4/93
MW-910
2/4/93
MW-914
3/18/93
MW-91S/DUP
3/18/93
MW-916
3/18/93
Vinyl Chloride 10 NO 8J NO 9J NO/2J NO NO NO 10J/8J NO
1.1-0CA 10 NO NO NO 2J NO NO NO NO 1J/1J NO
1.2-0CE 10 NO 1J 4J 1J ND ND ND ND NO ND
Toluene 10 1J NO NO NO NO ND ND ND NO NO
SVOCII lualll
PAHs (Total)
bj
I
N
Pellt/PCB lualll
Notell:
J
IT
DUP
MW
VOC
SVOC
Pest/
PCB
/l9/l
NO
CROl
WO()(,9430.TRO\5
30J
NO
NO
NO
5J
NO
12J
NO
1J
NO
NO/ND
NO
3J/NO
NO
Estimated Value
Leachate
Duplicate Sample
Monitoring Well .
Volatile Organic Compound
Semivolatile Organic Compound
Pesticides/Polychlorinated Biphenyl
micrograms per liter
not detected
Contract Required Ouantitation limit
-------
SOUTH OF NEPTUNE DRIVE NORTH OF NEPTUNE DRIVE
ko. CONe.
HMEGS "IT.eol MW-804 MW.- MW-907 __lOOP MW-8OtI MW.810 MW"I4 MW..IGIOUP MW..I8 00
'MCl 2/4/93 2/4193 2/4193 2/4/93 2/4193 2/4/93 3/18/93 3/18/93 3/18193 _.INA68
CRDl 3/18/93
"'gill "'gill "'gIl' "'gill (Palll (Palll (POll' CllgIl' (POll' !IIg/t! !IIall' C/lalll (Pgll'
MAlVTt CIIalll
Aluminum 200 50.200 S 1,430 4,940 NO NO NO NO 241J ND 5,510 1,910/1,830 No 652
Antimony 60 6 NO NO NO NO No NO NO NO NO NO .
Arsenic 10 50 R . 9.4J NO NO NO NO NO ND ND NO ND 2.8
..
Barium 200 2,000 1,500 64.4J NO NO No NO NO No 229 443/441 46.4J 17
Berytlium 5 4 NO NO NO NO NO NO NO ND NO NO .
Cadmium 5 5 5 NO NO NO NO NO NO NO 6.4 NO NO
Calcium 5,000 16,700 18,400 14,100 40,300 24,100/25,700 2,140J 4,180J 33,800 51,300/51,300 22,000 18,000
Chromium 10 100 100 16.3 NO NO NO No ND ND 9.9J ND/4.3J ND 6.3
Cobalt 50 7.8J NO NO NO NO NO NO NO NO NO 8
Copper 25 1,300 T 23.1J NO NO NO NO NO NO NO NO NO 4
Iron 100 300S 7,I90J NO 314J NO NO 360J NO 30,IOOJ 12,oooJ/12,looJ 220J 4,430
Lead 3 15 T 20 32.8 NO ND NO NO ND NO NO NO NO 10
Ma9nesium 5.000 . 2,180J 5.520 4,310J 5,530 3,oooJ/2,990J 775J 709J 3,05OJ 4,490J/4,5OOJ 2,290J 8,300
Man9anese 15 50 S 200 219 183 56.7 6,720 609/689 22.8 27.8 230 991/1010 14.7J 570
Mercury 0.2 2 2 ND ND ND NO NO ND NO NO NO NO 0.11
Nickel 40 100 150 NO NO NO NO NO NO NO NO No NO
Potassium 5,000 3,040J NO 2,190J 2,460J 2,630J/2,470J ND NO 3,57OJ 7,430/7,430 3,920J 4,800
Selenium 5 50 10 NO NO NO NO ND NO NO NO NO NO .
Silver 10 100 S 50 NO NO NO NO NO NO NO NO NO NO
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Notes:
......lot-
..,~..
..~,,~
'1IIIIIfto-1.,
",...........,
-
~.',
'-
-
continued
TABLE B-3
SUMMARY OF GROUNDWATER INORGANIC ANALYSES (1993)
INTERIM RECORD OF DECISION: SITE 9
NAS BRUNSWICK
SOUTH OF NEPTUNE DRIVE NORTH OF NEI2TUNE DRIVE
ko. COflC.
'MCL "MEGS 'LT-IIOI MW-804 MW.- MW.eo7 MW-808IOUP MW-809 MW-810 MW-914 MW.91BIOUP MW-'" OF
CIIDL !PaIL' "'oIL' 3/1S/83 214/93 214193 214/93 214193 214193 214193 3118/93 3/18193 3118193 lNoRo./NASII
MAlVIt ",gILl !POlLl !PolL' !PolL' "'glL' "'oIL' "'oIL' "'oIL' "'OILI (PolL' (PolL' 1PoIL'
Sodium 5,000 - 711,000 6,240 35,400 16,200 15,100/16,200 4,030J 2,55OJ 4,100J 27,900/27,900 58,800 52,500
Thallium 10 2 0.4 ND ND ND ND ND ND ND ND ND ND 2.1
Vanadium 50 - 1'.0J ND ND ND ND ND ND 6.2J ND ND 9.2
Zinc 20 5,0005 . 195 8.8J 6.9J 13.8J ND/8.1J 10.4J 7.9J ND ND ND 105
Cyanide 10 154 11.6 ND ND ND ND I ND I ND I ND I ND I ND ! -
. . I I
CRDL
pg/L
MW
DUP
ND
J
LT
Con1ract Required Detection Umit
micrograms per liter
monitoring well
duplicate sample
not detected
estimated value
leachate
LT-901 Is a leachate sample and not a monitoring well sample
According to Safe Drinking Water Act (SDWA), U.S. Environmental Protection Agency (USEPA), 1992, Fact Sheet: Drinking Water Regulations and Health Advisories. Office of Water,
Washington, D.C., Dec8mb8r, t992.
Maximum Exposure Guldsllne, as established in the Maln8 Drinking Water Rules (1Q-144A CMR. Chapters 231.233).
Under Review
Secondary Drinking Water Standard
Based on Treatment Technique. Value given Is an action level.
Value not available
+
. +
R
S
T
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APPENDIX C
..
MEDEP LETI'ER OF CONCURRENCE
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Installation Restoration Program
WOO69430.0BO
7124-03
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21217 772 4762
ft207 772 4762 ABB PORTLAND ME
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12:30
J
,..'IRO",,£~
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I>-~( Dt ii;.''''~
. STATE OF MAINE
'DEPARTMENT OF ENVIRONMENTAL PROTECTION
.
.IDtIIf R. ~...... JR.
GOVERNOR
DEAN C. IIAIIIIO'IT
COu~
J
.1
- IIICiHAIIO
DB'IITY aJMMISSIONEA
September 16, 1994
W.A. Waters
Captain, CEC, tr. S. Navy .
Commano;ng Officer ; .
Depar-...ment of the Navy, Nort.hern Di;'visi6n
Naval Facilities Engineering Co~d .
Building 77-L I
Philadelphia Naval Snipyard
philadelphia, PA 10112-5094
RE: Naval Id.r Station Brunswick Superfund Site, Brunswick,
Maine i .
t
Dear Captain Waters:
The Maine Department of E..."lviroImlential Protection (MEDEP) has
reviewed the August 1.994 Draft Final Interim Record of
Decision (ROD) for the groundwater ioperable unit at Site 9
for the Naval ~~r Station Brun~~~c~ Superfund Site located
in Brunswick, Maine. .
I
on the basis of r'hi s ROD, and on the understanding that
additional source invest.igations ~ll be conducted at Site
9, the MEDEP concurs vd1:.b. the sele~ted ;-emedial action.
i
~
This inter~ remedial action consists of groundwater
remediation through na~ural attenuationi long term
enviror~ental monitoring, insti~utionalcontrols to prevent
exposure to contami~~cea groundwater, and five-year site
reviews. Environmenta~ monitoring iof groundwater, surface
water, seniment, and leachate seep ~~~ll. be conducted to
measure the changes ;-n contaminant ;concentrations due to
natural attenuation. ;
J
,
The results of field investigation~ conducted in 1988, 1990,
and 1993 indicate the presence of yinyl:chloride and DCE in
groundwater at concentrations in eXcess of their MCLs and
vinyl chloride, DCE and DCA in excess if their MEGs. The
field invescigations did not, hawever, identify any distinct
source areas for these VOCs. There!fore, the Navy
recOIIllI1eD.ded an inter:Un remedial action of the groundwater
operable unit at Site 9 because no idefinitive source area
was found.
I
I
AUGuSTA
. STAt1i - SfATCIN 17
AllGUSTA. "- DGDan7
I2D7) 287~ F/IJI.: 12117) 28T-7126
lWeI! &DC.IIID A1': RA., suu.c.. Hcx;PIrAj, smIi:IiT
PCIImAHD MiIGOR
~2 CAIIICO RoAD 10& HCIGAN RoAD
P'IJIIIUIC. ME OC1C3 IWIaioIt ME 0C0c01
111"1- FIUt C2O"J I7W3I3 IZJI') sw,~ FN(: (2D7) "'...c(,84
",- -1K,a./-
PREmuE ~
1m cemw.. DIWE. SlC'lW4'1' PIoII<
~ 1&1;. !olE 0017II& .
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tt207 772 4762 ABB PORTLAND ME
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12:31
The !i[avy ",,""ill be conductiT>g additional f~eld investigations
in the vicinity of Site 9 to evaluate other potential source
areas of groWldwater contamiIlation. i A final remedy and
subsequent ROD for the site including both groundwater and
source operable units w-:il1 be developed after conducting
adcUtional source investigations. 1 .
This coneu--rrence is based upon the s~. ate',s understanding
that.:
A. The ldEDEP rill cont i 'P'Iue to "articipate in the
Federal Facilities Agreement. daied October 19,
1.990 and in the review and: approval of operational
designs and monitoring plans. .
B. Surface ;,o,-ater mo.,.,;toriilg r~sults wi.ll be
compared to the State of Maine's ,1...mbient Water
Quali~ Criteria for the protection of human
health and aquatic life. i
. .
c. The Navy ...,-il1 conduct ~ddit:;ional source
investigations at Site 9. ;
i
i
The MEDEP looks fon.-a.rd to working with the Depart:nent of
the Navy and the USEPA to resolve envirorimental problems
posed by this site. If you Ileed any! additional info~tion,
do not hesitate to contact me .or memrersof ~ staff.
Sincerely,
/J:d, 1/ Gwdf:-
t>eborah N. Garrett
Acting Commissioner
pc:
CaDtain t>.J. Ne~soD.
Ellzabet-~ Walter, .ABB-ES
Robert Lim, tTSEPA Region 1
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APPENDIX D
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APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
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Installation Restoration Program
WOO69430.080
7124-03
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TABLE D-1
CHEMICAL-SPECIFIC ARARs, CRITERIA, ADVISORIES, AND GUIDANCE
INTERIM RECORD OF DECISION: SITE 9
NAS BRUNSWICK
MEDIA
ACTION TO BE TAKEN TO ATTAIN ARARs
REQUIREMENT
STATUS
REQUIREMENT SVNOPSIS
GROUNDWATER(
SURFACE WATER
Federal
t:1
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Federal Guidance and
Criteria To Be
Considered
WOOr.?430.T'80\8
SDWA - MCLs (40 CFR
141.11 - 141.16)
RCRA-Subpart F
Groundwater Protection
Standards, Alternate
Concentration Limits
(40 CFR 264.94)
USEPA Risk Reference
Doses (RfDs)
USEPA Human Health
Assessment Group Cancer
Slope Factors (CSFs)
Relevant and
Appropriate
Relevant and
Appropriate
To Be Considered
To Be Considered
MCLs have been promulgated for several common
organic and inorganic contaminants. These levels
regulate the concentration of contaminants in public
drinking water supplies, but may also be considered
relt!vant and appropriate for groundwater aquifers used
for drinking water.
This requirement outlines standards, in addition to
background concentrations and MCLs, to be used in
establishing clean-up levels for remediatlng groundwater
contamination.
RIDs are the levels considered unlikely to cause
significant adverse health effects associated with a
threshold mechanism of action in human exposure for a
lifetime.
Carcinogenic effects present the most up-to-date
information on cancer risk potency derived from USEPA's
Human Health Assessment Group.
Under Alternative 9B, the selected remedy, the MCLs
will be attained through natural attenuation within two
to 15 years.
Under Alternative 9B, the selected remedy, the MCLs
will be attained through natural attenuation within two
to 15 years.
Because there are only a limited number of
promulgated standards for contaminants in water,
USEPA RIDs will be used to characterize risks due to
noncarcinogens in groundwater, as necessary, during
the five-year reviews.
Because there are only a limited number of
promulgated standards for contaminants in water,
USEPA CSFs will be used to compute the individual
incremental cancer risk resulting from exposure to
certain compounds, as necessary, during the five year
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continued
..--.,
,.......
...~;.
..~.,
"J.u.,t;
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'1W
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APPENDIX E
ADMINISTRATIVE RECORD INDEX: SITE 9
.
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Installation Restoration Program
WOO69430.080
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NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
SITE 9
TABLE OF CONTENTS
Section
Title
Page No.
SECTION 1: PREUMINARY ASSESSMENTS................. "'" E-2
SECTION 2: SITE INSPECTIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . " E-2
,
SECTION 3: REMOVAL ACTIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . " E-3
SECTION 4: REMEDIAL INVESTIGATIONS. . . . . . . . . . . . . . . . . . . . .. E-3
J
SECTION 5: FEASffiILITY STUDIES.......... ............. "" E-11
SECTION 6: PROPOSED PLANS AND PUBUC HEARING
TRANSCRIPTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. £-13
~
.
.
SECTION 7: RECORDS OF DECISION. . . . . . . . . . . . . . . . . . . . . . . . .. E-14
I
SECTION 8: POST-RECORD OF DECISION. . . . . . . . . . . . . . . . . . . .. E-15
SECTION 9: COMMUNITY~LATIONS ........................ E-15
SECTION 10: PROGRAM GUIDA.l~CE .... . . . . . . . . . . . . . . . . . . . . .. E-19
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SECTION 2:
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NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
SITE 9
PRELIMINARY ASSESSMENTS
Volume 1:
Initial Assessment Study of Naval Air Station Bnmswick, Maine, prepared by
Roy F. Weston, Inc.; June 1983 (Sites 1, 2, 3, 4, 5, 6, 7, 8, 9, and 10).
Correspondence: NOT APPLICABLE TO SITE 9
SITE INSPECTIONS
Volume 1:
Pollution Abatement Confinnation Study, Step 14 - Verification, prepared by
E.C. Jordan Co. [ABB Environmental Services, Inc.]; June 1985 (Sites
1,2,3,4,7,8,9).
Correspondence:
1.
Memo to Don Smith, NUS Corporation, from Colin Young, NUS
Corporation, regarding the site inspection at the U.S. Naval Air Station;
September 22, 1983.
2.
Memo to Robert Kowalczyk, Naval Facilities Engineering Command,
Northern Division. from William Fisher, E.C. Jordan Co. [ABB
Environmental Services. Inc.], regarding the schedule of on-site exploration
and sampling activities during the Pollution Abatement ConfIrmation Study;
October 30~ 1984.
3.
Memo of conversation between Robert Kowalczyk. Naval Facilities
Engineering Command, Northern Division, and William Fisher, E.C. Jordan
Co. [ABB Environmental Services, Inc.], regarding the preliminary data from
the ConfIrmation Study at Brunswick and the status of fieldwork; December
11, 1984.
4.
Memo of conversation between Robert Kowalczyk, Naval Facilities
Engineering Command, Northern Division, and William FISher, E.C. Jordan
Co. [ABB Environmental Services, Inc.), regarding the preliminary results of
the NACIP Study at Brunswick and the expected completion of the sampling;
January 3, 1985.
5.
Memo of conversation between Robert Kowalczyk, Naval Facilities
Engineering Command, Northern Division, and William Fisher, E.C. Jordan
Co. [ABB Environmental Services, Inc.], regarding the results of the NACIP
Study at Brunswick and the expected submittal of the report; January 15, 1985.
6.
Letter to William FISher, E.C. Jordan Co. [ABB Environmental Services, Inc.],
from A. Rhoads, Department of the Navy, Northern Division Environmental
£-2
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NA V AL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
SITE 9
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SECTION 3:
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Volume 1:
Volume 2:
SECTION 4:
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Volume 1:
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Protection Section, regarding comments on the Draft Confirmation Study
Verification Step report; April 15, 1985. ~
7.
Meeting minutes of May 22, 1984{5], meeting among Department of the Nary,
Northern Division, NAS Brunswick, and E.C. Jordan Co. [ABB Environmental
Services, Inc.], regarding the NACIP Confirmation Study Verification Phase
report; May 24, 1985.
8.
Letter to William FISher, E.C. Jordan Co. [ABB Environmental Services, Inc.],
from A. Rhoads, Department of the Navy, Northern Division Environmental
Protection Section, regarding comments on the revised Confumation Study
Verification Step Report; August 2, 1985.
Letter to Robert Jackson, U.S. Environme~tal Protection Agency (USEPA),
from L.K Jones, Naval Air Station, Brunswick, regarding transmittal of the
June 1985 [Pollution Abatement Confumation Study, Step 1A - Verification]
Report; December 3, 1985.
Letter to L.K Jones. Naval ..<\iT Station, Brunswick, from Robert Jackson,
USEPA, regarding comments on the [June 1985] Pollution Abatement
Confirmation Study. Step 1A - Verification Report; January 13, 1986.
11.
Letter to L.K Jones, Naval Air Station, Brunswick, from Anthony Leavitt,
Maine Department of EnvironmentaJ Protection (DEP), regarding comments
on the [June 1985J Pollution Abatement Confumation Study, Step 1A -
Verification Report; January 13, 1986.
12.
Letter to Jim Shafer. Department of the Nary, Northern Division, from Nancy
Beardsley, MEDEP. regarding MEDEP's comments on future planned field
activities and the TRC meeting discussion for Site 9; April 1, 1993.
REMOVAL ACTIONS
NOT APPLICABLE TO SITE 9
NOT APPLICABLE TO SITE 9
REMEDIAL INVESTIGATIONS
Remedial InvestigationjFeasibility Study Worlc Plan, formerly Draft Pollution
Abatement Confumation Study Work Plan - Step 1 prepared by E.C. Jordan
Co. [ABB Environmental Services, Inc.]; April 1988 (Sites 1,2,3,4,7,8,9).
October 6, 1994
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NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
SITE 9
Addendum to RIIFS Work Plan, prepared by E.C. Jordan Co. [ABB
Environmental Services, Inc.]; July 1988 (Sites 1,2,3,4,7,8,9).
Additional Sampling Plan, prepared by E.C. Jordan Co. [ABB Environmental
Services, Inc.]; August 1989 (Sites 1,2,3,4,7;8,9).
CorrespoDdeDce:
1.
Letter to Commander L.K. Jones, Naval Air Station B~ck, from Matthew
Hoagland, USEPA, regarding comments on the September 1986 Draft
Pollution Abatement Confirmation Study Work Plan - Step IB:
Characterization; November 24, 1986.
2.
Letter to Matthew Hoagland, USEPA, from T.G. Sheckels, Naval Air Station
Brunswick, regarding responses to USEP A comments on the September 1986
Draft Pollution Abatement Confmnation Study Work Plan - Step 1B:
Characterization; March 31, 1987.
3.
Letter to Commander L.K. Jones, Naval Air Station Brunswick, from David
Webster, USEPA, regarding clarification as to the status of incorporating
USEPA's comments into the revised report, and communication of their
concerns for Site 8; April 9, 1987.
4.
Letter to Charlotte Head, USEP A, from Kenneth Finkelstein, National
Oceanic and Atmospheric Administration (NOAA), regarding comments on
the RIfFS Workplan for Phase II field activity; April 14, 1989.
5.
Letter to Charlotte Head, USEPA, from Sharon Christopherson, National
Oceanic and Atmospheric Administration (NOAA), regarding responses to
Navy comments on NOAA's work plan recommendations; May 8, 1987.
6.
Letter to David Epps and Robert Kowalczyk, Naval Facilities Engineering
Command, Northern Division, from Charlotte Head, USEPA, regarding the
[pollution Abatement Confmnation Study, Step] 1B - Characterization Work
Plan meeting, and a discussion for the Superfund program; June 29, 1987.
7.
Meeting summary of June 12, 1987, planning meeting at USEPA Region I
offices in Boston, Massachusetts, among USEPA; U.S. Navy; E.c. Jordan Co.
[ABB Environmental Services, Inc.]; Maine DEP; NOAA; Camp, Dresser &
McKee; June 30, 1987.
8.
Letter to Robert Kowalczyk, Naval Facilities Engineering Command, Northern
Division, from Jack Hoar, Camp, Dresser & McKee, regarding meeting notes
from a June 12, 1987, planning meeting at USEPA Region I offices in Boston,
Massachusetts, among USEPA; U.S. Navy; E.C. Jordan Co. [ABB
Environmental Services, Inc.]; Maine DEP; NOAA; Camp, Dresser & McKee;
July 8, 1987.
E-4
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NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
SITE 9
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9.
Letter to Charlotte Head., USEPA, from Kenneth Finkelstein, National
Oceanic and Atmospheric Administration, regarding the June 10, 1987,
Trustee Notification Form; November 10, 1987.
10.
Letter to Captain E.B. Darsey, Naval Air Station Brunswick, from Merrill
Hohman, USEPA, regarding comments on the [January 1988] Pollution
Abatement ConflJ'1I1ation Study RI and Extended SI Studies, the Site Quality
Assurance Plan, the Site Health and Safety Plan, and the Quality Assurance
Program Plan; March 15, 1988.
11.
Letter to Ronald Springfield, Naval Facilities Engineering Command.,
Northern Division, from Cynthia Kuhns, Maine DEP, regarding comments on
the January 1988 Remedial Investigation Work Plan, and the January 1988
Quality Assurance Program Plan (see Section 10 of this index); April 7, 1988.
12.
Letter to Charlotte Head., USEPA, from. Gordon Beckett, U.S. Fish and
Wlldlife Service, regarding comments on the [April 1988] RIfFS Work Plan;
May 10, 1988.
13.
Letter to Charlotte Head., USEPA, from Kenneth Finkelstein, National
Oceanic and Atmospheric Administration, regarding the [April 1988 Remedial
Investigationf Feasibility Study] Work Plan; May 13, 1988.
14.
Letter to Captain E.B. Darsey, Naval Air Station Brunswick, from Cynthia
Kuhns, Maine DEP, regarding comments on the April 1988 Remedial
Investigationf Feasibility Study Work Plan; June 6, 1988.
15.
Letter to Captain E.B. Darsey, Naval Air Station Brunswick, from David
Webster, USEPA, regarding comments on the April 1988 Remedial
Investigationf Feasibility Study] Work Plan; June 17, 1988.
16.
Memo from M. Aucoin, Naval Air Station Brunswick, regarding laboratory
analytical methods discussed in the RIfFS Work Plan; August 12, 1988.
17.
Letter to Naval Facilities Engineering command., Northern Division, from
Anthony Sturtzer, Naval Energy and Environmental Support Activiry,
regarding laboratory approval for Installation Restoration Program analyses;
August 22. 1988.
18.
Letter to Charlotte Head., USEPA, from T.G. Sheckels, Department of the
Navy, Northern Division, regarding status and completion of the first phase
of fieldwork and sampling under the RIfFS Work Plan: October 26, 1988.
Letter to Ronald Springfield, Naval Facilities Engineering Command,
Northern Division, from Denise Messier, Maine DEP, regarding comments
on the April 1989 Draft Additional Sampling Plan; May 22. 1989.
E-5
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NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
SITE 9
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I
2.
J
j
3.
i
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20.
Letter to T.G. SheckeIs, Naval Facilities Engineering Command, Northern
Division, from David Webster, USEPA, regarding comments on the April
1989 Draft Additional Sampling Plan; June 9, 1989.
21.
Letter to Ronald Springtield, Naval Facilities Engineering Command,
Northern Division, from Denise Messier, Maine DEP, regarding approval of
the Draft Additional Sampling Plan; June 15, 1989.
22.
Letter to Ronald Springfield, Naval Facilities Engineering Command,
Northern Division, from Melville Dickenson, E.C. Jordan Co. [ABB
Environmental Services, Inc.], regarding transmittal of the Additional
Sampling Plan and some outstanding issues that needed further discussion
with the regulatory agencies; August 9, 1989.
23.
Letter to Ronald Springfield, Naval Facilities Engineering Command,
Northern Division, from David Webster, USEPA, regarding comments on the
August 1989 Draft Additional Sampling Plan; September 26, 1989.
24.
Letter (0 Ronald Springfield, Naval Facilities Engineering Command,
Northern Division, from Denise Messier, Maine DEP, regarding comments
on the August 1989 Additional Sampling Plan; December 28, 1989.
Post-Screening Work Plan, prepared by E.C. Jordan Co. [ABB Environmental
Services, Inc.]; July 1990 (Sites 1,2,5,6,8,9,11,12,13, Eastern Plume; Treatability
Studies 8; 11).
Addendum - Post-Screening Work Plan, prepared by E.C. Jordan Co. [ABB
Environmental Services, Inc.]; November 1990 (Sites 1,2,5,6,8,9,11,12,13,14,
Eastern Plume; Treatability Studies 8; 11).
Correspondence:
1.
Letter to Kenneth Marriott, Department of the Navy, Northern Division, from
Ted Wolfe, Maine DEP, regarding comments on the April 1990 Draft Post-
Screening Work Plan; May 1, 1990.
Letter to Kenneth Marriott, Depanment of the Navy, Northern Division, from
Michael Jasinski for David Webster, USEPA, regarding the April 1990 Draft
Remedial Investigation Report and the April 1990 Draft Post-Sa-eeDing Work
Plan; May 17, 1990.
Letter to Kenneth Marriott, Department of the Navy, Northern Division, from
Susan Weddle, TRC community member, regarding comments on the
February 1990 Draft Phase I Feasibility Study. Development and Screening
of Alternatives, and the April 1990 Draft Remedial Investigation Report and
the April 1990 Draft Post-Screening Work Plan; May 23, 1990.
£-6
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Volume 3:
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Volume 4:
.,
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Correspondence:
I
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4.
Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the ruly 1990 Post-Screening
Work Plan; July 27, 1990.
5.
Letter to James Shafer, Department of the Navy, Northern Division, from
David Webster, USEPA, regarding comments on the July 1990 Post-Sa-eeDing
Work Plan; August 30, 1990.
Round I Data Package, Phase I - Remedial Investigation, prepared by E.C.
Jordan Co. [ABB Environmental Services, Inc.]; January 1989 (Sites
1,2,3,4,7,8,9).
Correspondence:
2.
Letter to Ronald Springfield, Department of the Navy, Northern Division,
from David Gulick, E.C. Jordan Co. [ABB-ES] regarding the transmittal of
the Round I Data Package; January 13, 1989.
3.
Letter to T.G. Sheckels, Department on the Navy, Northern Division, from
David Webster, USEPA, regarding comments on the Round I Data Package
and recommendations on future data packages; March 13, 1989.
4.
Letter to Charlotte Head, USEPA, from Kenneth Finkelstein, National
Oceanic and Atmospheric Administration. regarding comments on the
Rounds I and II Data Packages; March 13, 1989.
Round II Data PackrJge. Phase I - Remedial Investigation, prepared by E.c.
Jordan Co. [ABB Environmental Services, Inc.]; March 1989 (Sites
1,2,3,4,7,8,9).
Round III Data Package, Phase I - Remedial Investigation, prepared by E.C.
Jordan Co. [ABB Environmental Services, Inc.); July 1989 (Sites 1.2.3,4,7,8.9).
1.
Letter to Ronald Springfield, Northern Division, Naval Facilities Engineering
Command, from David Gulick, E.C. Jordan, Co. [ABB-ES], regarding
transmittal of and comments on the Round II Data Package; March 10, 1989.
2.
Letter to Ronald Springfield, Northern Division, Naval Facilities Engineering
Command, from David Gulick, E.C. Jordan, Co. [ABB-ES], regarding
transmittal of and comments on the Round ill Data Package; July 14, 1989.
3.
Letter to Jack Jojokian, USEPA, from John Walker, Camp, Dresser & McKee
Federal Programs Corporation, regarding comments on the Round ill Data
Package; August 31, 1989.
October 6, 1994
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4.
Letter to Ronald Springfield, Northern Division, Naval Facilities Engineering
Command., regarding comments on the Round III Data Package; October 4,
1989.
Remedial Invesagation Feasibility Study - Round W Data Padazge, prepared by
E.C. Jordan Co. [ABB Environmental Services, Inc.]; January 1990 (Sites
1,2,3,4,7,8,9,11,13).
Correspondence:
1.
Letter to Meghan Cruise, USEPA, from Kenneth Finkelstein. National
Oceanic and Atmospheric Administration, regarding comments on the Round
4 [IV] Data Package; August 28, 1989.
2.
Letter to Kenneth Marriott, Northern Division, Naval Facilities Engineering
Command., regarding comments on the Round IV Data Package; March 5,
1990.
Draft Final Remedial Investigation Report Volume 1, prepared by E.C. Jordan
Co. [ABB Environmental Services, Inc.]; August 1990 (Sites 1,3; 2; 4,11,13; 7;
8; 9).
Correspondence:
1.
Letter to Kenneth Marriott, Department of the Navy, Northern Division, from
Susan Weddle, TRC community member, regarding comments on the April
1990 Draft Remedial Investigation Report; May 15, 1990.
2.
Letter to Kenneth Marriott, Department of ' the Navy. Northern Division, from
Michael Jasinski for David Webster, USEPA, regarding comments on the
April 1990 Draft Remedial Investigation Report and the April 1990 Draft
Post-Screening Work Plan; May 17, 1990.
3.
Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the August 1990 Draft Final
Remedial Investigation Report; October 10, 1990.
4.
Letter to James Shafer, Department of the Navy, Northern Division, from
Mary Jane O'Donnell, USEPA, regarding comments on the August 1990 Draft
Final Remedial Investigation Report; October 17, 1990.
Draft Fzna/ Remedial Investigation RepoTt Vo/wne 2: Appendices A-I, prepared
by E.C. Jordan Co. [ABB Environmental Services, Inc.]; August 1990 (Sites
1,3; 2; 4,11,13; 7; 8; 9).
October 6, 1994
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Volume 9:
Correspondence:
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Volume 11:
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Draft Fznai Remedial Investigation Report Volume 3; Appendices K-P, prepared
by E.C. Jordan Co. [ABB Environmental Services, fnc.]; August 1990 (Sites
1,3; 2; 4,11,13; 7; 8; 9).
Draft Final Remedial Investigation Report Volume 4; Appendix Q . Risk
Assessment, prepared by E.C. Jordan Co. [ABB Environmental Services, Inc.];
August 1990 (Sites 1,3; 2; 4,11,13; 7; 8; 9).
1.
Letter to Ronald Springfield, Naval Facilities Engineering Command,
Northern Division, from Charlotte Head for David Webster, USEPA,
regarding the inclusion of the [Step] 1A Verification Study data in the risk
ass;:ssment for the air station; September 15, 1988.
2.
Letter to T.G. Sheckels, Naval Facilities Engineering Command, Northern
Division, from David Webster, USEPA, regarding review comments on the
Phase I Feasibility Study Preliminary Development of Alternatives, and the
Preliminary Risk Assessment; May 5, 1989:
3.
Letter to Kenneth Marrion, Department of the Navy, Northern Division, from
Ted Wolfe for Denise Messier, Maine DEP, regarding comments on the
February 1989 Preliminary Risk Assessment; February 8, 1990.
4.
Letter to Kenneth Marriott Department of the Navy, Northern Division, from
Ted Wolfe, Maine DEP, regarding comments on the April 1990 Draft
Remedial Investigation Report; May 17, 1990.
Remedial Investigation Feasibility Study Round V Data Package, prepared by
E.C. Jordan Co. [ABB Environmental Services, Inc.]; March 1991 (Sites
5,6,8,9.11,12,14, Eastern Plume; Treatability Study for Sites 8,11).
Draft Final Supplemental RI Report Volume 1, prepared by E.C. Jordan Co.
[ABB Environmental Services, Inc.]; August 1991 (Sites 5,6,8,9,11,12, Eastern
Plume ).
Correspondence:
1.
Letter to Meghan Cassidy, USEP A, from Kenneth Enkelstein, National
Oceanic and Atmospheric Administration, regarding comments on the [April
1991] Draft Focused Feasibility Study for Sites 1 and 3; the [April 1991] Draft
Supplemental Remedial Investigation; and the [April 1991] Draft
Supplemental Feasibility Study for Sites 5, 6, and U; May 1, 1991.
October 6, 1994
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NAVAL AIR STATION BRUNSWICK
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SITE 9
2.
Letter to Captain H.M. Wilson, Naval Air Station Brunswick, from Samuel
Butcher, regarding comments on the [April 1991J Draft Supplemental
Remedial Investigation Report; May 1, 1991.
3.
Letter to James Shafer, Department of the Nary, Northern Di\-ision, from Ted
Wolfe, Maine DEP, regarding comments on the [April 1991J Draft
Supplemental Remedial Investigation Report; May 23, 1991.
4.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding comments on the [April 1991J Draft
Supplemental Remedial Investigation Report; May 30, 1991.
5.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding additional comments on the April 1991
Draft Supplemental Remedial Investigation Report; June 19, 1991.
6.
Letter to James Shafer, Department of the Nary, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the [August 1991J Draft Final
Supplemental Remedial Investigation Report; September 4, 1991.
7.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding comments on the [August 1991J Draft
Final Supplemental Remedial Investigation Report; September 10, 1991.
Draft Ftnal Supplemental R1 Report Volume 2: Appendices A-I, prepared by
E.C. Jordan Co. [ABB Environmental Services, Inc.]; August 1991 (Sites
5,6,8,9,11,12, Eastern Plume).
Draft Final Supplemental R1 Report Volume 3: Appendices K-Q, prepared by
E.C. Jordan Co. [ABB Environmental Services, Inc.J; August 1991 (Sites
5,6,8,9,11,12, Eastern Plume).
Technical Memorandum: Site 9, prepared by ABB Environmental Services,
Inc.; May 1994 (Site 9).
Correspondence:
1.
I
f
2.
~
J
Letter to Jim Shafer, Deparment of the Navy, Northern Di\-ision, from Nancy
Beardsley, Maine DEP, regarding comments on the [June 1993J Draft
Technical Memorandum: Site 9; August 6, 1993.
Letter to Jim Shafer, Deparment of the Navy, Northern Division, from Loukie.
Lofchie, BACSE, regarding comments on the [June 1993] Draft Technical
Memorandum: Site 9; August 10, 1993.
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8.
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SECfION 5:
Volume 1:
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3.
Letter to Carolyn lePage, R. G. Gerber Inc., from Deborah Roy, President,
Safe Tech Consultants, Inc. regarding comments on t6e risk assessment in the
[June 1993] Draft Technical Memorandum: Site 9; August 10, 1993.
4.
Letter to Jim Shafer, Deparment of the Navy, Northern Division., from
Meghan Cassidy, USEPA, regarding comments on the [June 1993] Draft
Technical Memorandum: Site 9; August 11, 1993.
5.
Letter to Fred Evans, Deparment of the Navy" Northern Division, from
Loukie Lofchie, BACSE, regarding comments on the [September 1993] Draft
Final Technical Memorandum: Site 9; October 26, 1993.
6.
Letter to Fred Evans, Deparment of the Navy, Northern Division, from
Robert Lim, USEPA, regarding comments on the [September 1993] Draft
Final Technical Memorandum: Site 9; October 27, 1993.
Letter to Fred Evans, Deparment of the Navy, Northern Division, from Nancy
Beardsley, Maine DEP, regarding comments on the [September 1993] Draft
Final Technical Memorandum: Site 9; October 27, 1993.
MemorandUm from Fred Evans, Department of the Navy, Northern Division,
to the Technical Review Committee regarding the [May 1994] Fmal Technical
Memorandum: Site 9; August 29, 1994.
FEASIBILITY STUDIES
Draft Final Phase I Feasibilicy Study Development and SC1f!ening of Alternatives,
prepared by E.c. Jordan Co. (ABB Environmental Services, Inc.]; August 1990
(Sites 1,3; 2; 4.11,13: 7; 8; 9).
Correspondence:
1.
Letter to T.G. Sheckels, Department of the Navy, Northern Division, from
David Webster, USEPA, regarding comments on the February 1989 Phase I
Feasibility Study: Preliminary Development of Alternatives, and February 1989
Preliminary Risk Assessment reports; May 5, 1989.
2.
Letter to Alan Prysunka, Maine DEP, from T.G. Sheckels, Department of the
Navy, Northern Division, regarding Applicable or Relevant and Appropriate
Requirements (ARARs) for Remedial Investigationf Feasibility Study
(RIfFS); March 6, 1990.
3.
Letter to Kenneth Marriott, Department of the Navy, Northern Division., from
Ted Wolfe, Maine DEP, regarding comments on the February 1990 Draft
Phase I Feasibility Study Development and Screening of Alternatives; April
17, 1990.
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SITE 9
4.
Letter to Kenneth Marriott, Department of the Navy, Northern Division, from
David Webster, USEPA, regarding comments on the February 1990 Draft
Phase I Feasibility Study Development and Screening of Alternatives; April
23, 1990.
5.
Letter to Kenneth Marriott, Department of the Navy, Northern Division, from
Susan Weddle, TRC community member, regarding comments on the
February 1990 Draft Phase I Feasibility Study Development and Screening of
Alternatives, and the April 1990 Draft Post-Screening Work Plan; May 23,
1990.
Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on Draft Final Phase I Feasibility
Study Development and Screening of Alternatives; September 28, 1990.
NOT APPLICABLE TO SITE 9
Feasibility Study Volume 1, prepared by E.C. Jordan Co. (ABB Environmental
Services, Inc.]; March 1992 (Sites 2; 4,11,13; 5,6; 7; 9; 12; 14; Eastern Plume).
Correspondence:
1.
Letter to Meghan Cassidy, USEPA, from John Lindsay, National Oceanic and
Atmospheric Administration, regarding commentS on the [July 1991] Draft
Feasibility Study Report; August 16, 1991.
2.
Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the July 1991 Draft Feasibility
Study Report; September 20, 1991.
3.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEP A, regarding comments on the July 1991 Draft
Feasibility Study Report; September 23, 1991.
4.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding comments on the November 1991 Draft
Fmal Feasibility Study; December 26, 1991. .
Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the November 1991 Draft Final
Feasibility Study Report; January 2, 1992.
£-12
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Volume s:
SECTION 6:
Volume 1:
Volume 2:
Volume 3:
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6.
Comments from BACSE on the Feasibility Study Repon, February 18, 1992.
Feasibility Study Volume 2: Appendices A - 0, prepared by E.C. Jordan Co.
[ABB Environmental Services, Inc.]; March 1992 (Sites 2; 4,11.13; 5,6; 7; 9; 12;
14; Eastern Plume).
NOT APPLICABLE TO SITE 9
PROPOSED PLANS AND PUBLIC HEARING TRANSCRlPTS
NOT APPLICABLE TO SITE 9
NOT APPLICABLE TO SITE 9
Proposed Plan, prepared by ABB Environmental Services, Inc.; July 1994
(Site 9).
Transcript of the Public Hearing for Site 9, prepared by Mason Lockhart
Hagopian & Ramsdell; July 14, 1994 (Site 9).
Correspondence:
1.
Lener to Fred Evans, Deparment of the Nary, Northern Division, from Nancy
Beardsley, Maine DEP, regarding the Site 9 Proposed Plan/Interim
Groundwater Record of Decision; December 8, 1993.
2.
Letter to Carl Delo~ USEPA, from Gordon E. Beckett, U.S. FISh & Wildlife
Service, regarding comments on the [May 1994] Draft Proposed Plan; June 2,
1994.
3.
Letter to Fred Evans, Department of the Navy, Northern Division, from
Robert Lim, USEPA, regarding comments on the [May 1994] Draft Proposed
Plan; June 15, 1994.
4.
Letter to Fred Evans, Department of the Nary, Northern Division, from
Loukie Lofchie, BACSE, regarding comments on the [May 1994] Draft
Proposed Plan; June 15, 1994.
5.
Letter to Fred Evans, Department of the Nary, Northern Division, from
Nancy Beardsley, Maine DEP, regarding comments on the [May 1994] Draft
Proposed Plan; June 16, 1994.
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6.
Letter to Fred Evans, Department of the Navy, Northern Division, from
Nancy Beardsley, Maine DEP, regarding comments on the [June 1994] Draft
Proposed Plan; July 7, 1994.
7.
Letter to Nancy Beardsley, Maine DEP, from Fred Evans, Department of the
Navy, Northern Division, regarding the Source Investigation Work Plan Site
9 and responding to the Maine DEP letter of December 8, 1993; July 19,
1994.
RECORDS OF DECISION
NOT APPLICABLE TO SITE 9
NOT APPLICABLE TO SITE 9
Interim Record of Decision for the Groundwater Operable Unit at Site 9
prepared by ABB Environmental Services, Inc.; September 1994 (Site 9)
Correspondence:
1.
Letter to Fred Evans, Department of the Navy, Northern Division, from
Loukie Lofchie, BACSE, regarding comments on the [June 1994] Draft
Interim Record of Decision for the Groundwater Operable Unit at Site 9; July
15, 1994.
2.
Letter to Fred Evans, Department of the Navy, Northern Division, from
Robert Lim, USEPA, regarding comments on the [June 1994] Draft Interim
Record of Decision for the Groundwater Operable Unit at Site 9; July 18,
1994.
3.
Letter to Fred Evans, Department of the Navy, Northern Division, from
Nancy Beardsley, Maine DEP, regarding comments on the [June 1994] Draft
Interim Record of Decision for the Groundwater Operable Unit at Site 9; July
18, 1994.
4.
Letter to Fred Evans, Department of the Navy, Northern Division, from
Robert Lim, USEPA, regarding comments on the [June 1994] Draft Interim
Record of Decision for the Groundwater Operable Unit at Site 9; July 29,
1994.
5.
Letter to Fred Evans, Department of the Navy, Northern Division, from
Robert Lim, USEPA, regarding comments on the [August 1994] Draft Final
Interim Record of Decision for the Groundwater Operable Unit at Site 9;
September 1, 1994.
October 6, 1994
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6.
Letter to Fred Evans, Department of the Navy, Northern Division. from
Loukie Lofchie, BACSE, regarding comments on the [August 1994] Draft
rmal Interim Record of Decision for the Groundwater Operable Unit at Site
9; September 1, 1994.
7.
Letter to Fred Evans, Department of the Navy, Northern Division. from
Nancy Beardsley, Maine DEP, regarding comments on the [August 1994]
Draft Final Interim Record of Decision for the Groundwater Operable Unit
at Site 9; September 2, 1994.
POST-RECORD OF DECISION
NOT APPLICABLE TO SITE 9
COMMUNITY RELATIONS
Community Relations Plan - for NAS Brunswick NPL Sites prepared jointly by
Public Affairs Office, Navy Northern Division, and E.C Jordan Co. [ABB
Environmental Services, Inc.]; September 1988
Correspondence:
1.
Public notice for the Remedial Investigation and Feasibility Study schedule for
Brunswick Naval Air Station Superfund Site published in the Portland Press
Herald; February 24, 1988.
2.
Memo to Commanding Officer, Naval Air Station Brunswick, from T.F.
Rooney, Department of the Navy, Northern Division, regarding community
relations interviews, and comments on the Draft Community Relations Plan;
July 14, 1988.
3.
Press release regarding the USEPA and U.S. Navy announcing the signing of
the Federal Facility Agreement for the Brunswick Naval Air Station; October
6, 1989.
5.
Letter to Ken Marriott, Naval Facilities Engineering Command, Northern
Division, from Joshua Katz, Brunswick Area Citizens for a Safe Environment.
regarding Freedom of Information Act request; March 6, 1990.
6.
Press release regarding an extension of application notification deadline for
Technical Assistance Grant Application to be filed; March 26, 1990.
October 6, 1994
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U.
13.
.
J 24.
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4.
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5.
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7.
Letter to [Joshua) Katz, from TJ. Puro!, Naval Air Station Brunswick,
regarding the availability of information requested~under the Freedom of
Information Act; April 6, 1990.
8.
Letter to Kenneth Marriott, Naval Facilities Engineering Command, from
Joshua Katz, Brunswick Area Citizens for a Safe Environment, regarding the
Freedom of Information Act request; a March 22, 1990 public information
meeting; and the preliminary response to an April 8, 1990 site visit: April U,
1990.
Fact sheet for Naval Air Station Brunswick regarding question and answers
about National Priorities List Sites; August 15, 1990.
Press release announcing the public comment period for the Federal Facility
Agreement for Brunswick Naval Air Station; November 2, 1990.
Press release regarding Brunswick citizens receiving a $50,000 federal grant
for a Superfund advisor; January 3, 1991.
Public notice announcing the public meeting/hearing and public comment
period for Site 9 Proposed Plan; July 1994.
25.
Fact sheet regarding the Proposed Plan for Site 9, The Neptune Drive
Disposal Site; July 1994.
Technical Review Committee Meeting M'l1Wtes (November 19lf7 co December 10.
1992).
1.
Meeting minutes of December 3, 1987, Technical Review Committee (TRe)
meeting to get acquainted, to discuss results of completed and planned
investigations, and to establish future review procedures; undated.
2.
Meeting minutes of January 11, 1988, TRC meeting to discuss the project
schedule; January 26, 1988.
Memo to TRC members from Geoffrey Cullison, Naval Air Station.
Brunswick, regarding corrections to the January 11, 1988, meeting minutes;
February 3, 1988.
Meeting minutes of May 17, 1988. TRC meeting to discuss the draft charter
for the TRC at Brunswick and a review of the revised April 1988 RIfFS work
plan; undated.
Meeting minutes of July 8, 1988, TRC meeting to attend a site tour and to
confum proposed locations; of field investigations, undated.
E-16
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6.
Meeting minutes of November 22, 1988, TRC meeting to review analytical
data from the first round of sampling, and to establish parameters for the
second round of sampling; undated.
7.
Meeting minutes of February 22, 1988, TRC meeting to review validated
analytical data from the first round of sampling, and to present preliminary
information for the forthcoming risk analysis and alternative development
deliverables; undated. .
8.
Memo of TRC meeting minutes of March 28, 1989, to discuss the structure
of the third round of sampling; April 10, 1989.
9.
Letter to Bruce Darsey, Department of the Navy, Naval Air Station,
Brunswick, requesting copies of the March 27, 1989, TRC meeting minutes;
April 18, 1989.
10.
Lener to Senator William Cohen from E.B. Darsey, Department of the Navy,
Naval Air Station, Brunswick, regarding a copy of the requested TRC meeting
minutes, and the contact for the IRP program at the base; April 28, 1989.
11.
Meeting minutes of June 20, 1989, TRC meeting to discuss the Additional
Sampling Plan, the RIfFS program, and the schedule for its implementation;
July 11, 1989.
u.
Meeting minutes of August 10, 1989, TRC meeting to discuss the third round
of sampling; undated.
13.
Meeting minutes of February 13, 1990, TRC meeting to discuss the fourth
round of sampling: January 22. 1990.
14.
Letter to TRC members from James Shafer, Department of the Navy,
Northern Division, regarding the May 22, 1990, TRC meeting minutes in
which the Draft Initial Screening report, Draft Remedial Investigation report.
and Draft Post-Screening Plan were discussed; July 12, 1990.
15.
Memo to James Shafer, Department of the Navy, Northern Division, from
Geoffrey Cullison, Naval Air Station, Brunswick, transmitting the omitted
handout from the previous letter; July 19, 1990.
16.
Letter to TRC members from James Shafer, Department of the Navy,
Northern Division, regarding minutes from the September 13, 1990, TRC
meeting; October 31, 1990.
17.
Letter to TRC members from James Shafer, Department of the Navy,
Northern Division, regarding minutes from the January 10, 1991, TRC
meeting; January 28, 1991.
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18.
Letter to James Shafer, Department of the Navy, Northern Division, from
Melville Dickenson, ABB Environmental Services, "Inc., regarding minutes
from the October 3, 1991, TRC meeting; January 28, 1991.
19.
Meeting minutes of February 20, 1992, TRC meeting to discuss the schedule
and status of the IRP sites; undated.
20.
Meeting minutes of May 20, 1992, TRC meeting to discuss schedules for the
Sites 1 and 3 and Eastern Plume Records of Decision and Remedial Design,
the site inspection work plan for Swampy Road Debris site and Merriconeag
Extension Debris site, Site 8 Focused Feasibility Study and Proposed Plan, and
the multi-site Feasibility Study; the minutes also included a discussion of the
future actions scheduled for other sites; undated.
21.
Meeting minutes of October 1, 1992, TRC meeting to discuss schedules for
the Sites 1 and 3 and Eastern Plume Records of Decision and remedial
design, the Building 95 Removal Action, the site investigation at Swampy
Road Debris site and Merriconeag Extension Debris site, the proposed plans
for Site 8, and Sites 5 and 6; the minutes also included a discussion of the
future actions scheduled for other sites; undated.
22.
Meeting minutes of December 10, 1992, TRC meeting to discuss schedules for
the Building 95 Removal Action, the proposed plans for Sites 5 and 6, Site 8,
and Site 9, the Sites 1 and 3 and Eastern Plume Records of Decision and
remedial design, the remedial designs for Sites 5, 6, 8, 9, and Building 95, and
the site iovescigation at Swampy Road Debris site and Merriconeag ExIension
Debris site; undated.
Technical Review Committee Meeting MinUtes (MQl'Ch 1993 to September 1994)
Technical Meeting Minutes (May 1994 to August 1994)
Correspondence:
1.
Meeting minutes of March 18. 1993, TRC meeting to discuss the Building 95
Removal Action; Site 8 Proposed Plan: Sites 5 and 6 Proposed Plan; Remedial
Design for Sites 1, 3, 5, 6, 8, 9, and Eastern Plume; Site Inspections for
Swampy Road and Merriconeag Extension Debris Sites; undated.
Meeting minutes of June 10, 1993, TRC meeting to discuss the Building 95
Action Memorandum; Site 8 Record of Decision: Sites 5 and 6 Record of
Decision; Remedial Design for Sites 1, 3, and Eastern Plume; Site 9 Technical
Memorandum; Site Inspections for the Swampy Road and Merriconeag
Extension Debris Sites; undated.
Meeting minutes of September 23, 1993, TRC meeting to discuss the
Remedial Design for Sites 1, 3, 5, 6, 8. Eastern Plume, and Building 95; Sites
5 and 6 Record of Decision; Site Inspection report for the Swampy Road and
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Merricioneag Extension Debris Sites; Site 9 Technical Memorandum; buried
drums at Site 11; undated. .
4.
Meeting minutes of January 13, 1994, TRC meeting to discuss the Site 11
Technical Memorandum; Site 9 Interim Groundwater Record of Decision;
Remedial Design for Sites 1, 3, 5, 6, 8, Eastern Plume, and Building 95; and
the Site Investigation report for the Swampy Road and Merriconeag Extension
Debris Sites; undated.
5.
Meeting minutes of April 28, 1994, TRC meeting to discuss the Site 11 Time
Critical Removal Action; Site 9 Interim Groundwater Record of Decision;
Remedial Design for Sites 1, 3, 5, 6, 8, Eastern Plume, and Building 95; Long
Term Monitoring for Building 95, Sites 1 and 3 and Eastern Plume; undated.
6.
Meeting minutes of May, 19, 1994, technical meeting to discuss additional
source investigations at Site 9; undated.
7.
Meeting minutes of June 23, 1993, TRC meeting to discuss the Site 11 Time
Critical Removal Action; Site 9 Proposed Plan and Interim Groundwater
Record of Decision; Remedial Design for Sites 1, 3, 5, 6, 8, Eastern Plume,
and Building 95; confirmatory sampling at West Runway Study Area; undated.
8.
Meeting minutes of August 4, 1994, technical meeting to discuss the
construction status for Building 95 and Sites 1, 3, 5, 6, 8 and Eastern Plume;
the Site 11 Removal Action; Site 9 ROD and Work Plan; migration of the
Eastern Plume; additional sampling at Building 95; undated.
PROGRAM GUIDANCE
Quality Assurance Program Plan, prepared by E.C. Jordan Co. [ABB
Environmental Services. Inc.]; February 1988 (all sites)
Federal Facility Agreement among the U.S. Department of the Navy, USEPA,
and Maine DEP; October 10. 1990.
Correspondence:
1.
Letter to Robert Kowalczyk, Department of the Navy, Northern Division.
from Cynthia Bertocci, Maine DEP, regarding the state's interest in the
Installation Restoration Program for Brunswick Naval Air Station; February
24, 1986.
2.
Letter to L.K. Jones, Naval Air Station Brunswick, from Anthony Leavitt,
Maine DEP, regarding the state's interest in the Installation Restoration
Program fOf Brunswick Naval Air Station; February 25, 1986.
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3. Letter to Naval Facilities Engineering Command, Northern Division, from
j L.K Jones, Naval Air Station Brunswick, regarding the Nary's assessment and
control of installation pollutants (NACIP) program and guidance involving
federal and state regulatory agency oversight; March 11, 1986.
f 4. Letter to Commanding Officer, Naval Air Station Brunswick, from
Commanding Officer, Naval Facilities Engineering Command, Northern
J Division. regarding federal and state environmental agencies oversighr
authority of the NACIP program; April 7, 1986.
5. Letter to David Webster, USEPA, from KJ. Vasilik, Naval Air Station
Brunswick, regarding the defmition of the RI/FS program at the NAS
Brunswick; January 20, 1987.
6. Letter to David Epps and Robert Kowalczyk, Naval Facilities Engineering
Command, Northern Division, from Charlotte Head, USEPA, regarding the
current status and goals of the investigations; June 29, 1987.
I 7. Letter to Charlotte Head, USEPA, from R.L. Gillespie, Naval Facilities
Engineering Command, Northern Division, regarding the Navy's timetable to
complete Remedial Investigation Feasibility Study at the Naval Air Station
t Brunswick, and outlining the Navy's understanding of the responsibilities of
the various agencies involved in the RI/FS program; October 22, 1987.
t 8. Letter to Charlotte Head, USEPA, from Kenneth Finkelsrein, National
~ Oceanic and Atmospheric Administration, regarding the June 10, 1987,
Trustee :'-Iotification Form for Naval Air Station Brunswick; November 10,
1987.
I 9. Letter to Charlotte Head, USEPA, from T.G. Sheckels, Department of the
Navy, Northern Division. regarding the listing of Naval Air Station Bruns\\-ick
~ on the NFL, the establishment of the Administrative Record, and the
.
. Technical Review Committee for the base; November 16, 1987.
10. Letter to R.L. Gillespie, Naval Facilities Engineering Command. Northern
I Division, from David Webster, USEP A, regarding the schedule to be
published by February 1988. a mechanism for delineating the roles and
responsibilities of the agencies. and the USEPA's concerns over the progress
i to date; November 20, 1987.
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11. Memo to Charlotte Head, USEPA, from Joan Coyle, USEPA Water
I Monitoring Section, regarding sampling results from the Jordan Avenue Well
Field in Brunswick, Maine; December 10, 1987.
~ 12. Letter to G.D. Cullison, Naval Air Station Brunswick, and T.G. Sheckels,
i Naval Facilities Engineering Command, Northern Division, from David
Webster. USEPA, regarding the defmition of the commencement of the
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RIfFS under the Comprehensive Environmental Response, Compensation,
and Liability Act; December 17, 1987. '"
13.
Letter to Merrill Hohman, USEPA, from E.B. Darsey, Naval Air Station
Brunswick, regarding comments received at the February 10, 1988, TRC
meeting on the status of the RIfFS program; February 17, 1988.
14.
Letter to Ronald Springfield, Naval Facilities Engineering Command,
Northern Division, from David Webster for Charlotte Head, USEPA,
regarding the extent of quality assurance and quality control of validation for
samples at Naval Air Station Brunswick; April 25, 1988.
15.
Letter to Ronald Springfield, Naval Facilities Engineering Command,
Northern Division, from David Webster for Charlotte Head, USEPA,
regarding the evaluation of sites that were not incorporated into the [Hazard
Ranking System] package, especially Sites 5 and 6; April 25, 1988.
16.
Letter to Meghan Cruise, USEPA, from Alan Prysunka, Maine DEP,
regarding comments on the Federal Facility Agreement; November 8, 1989.
17.
Letter to Meghan Cruise, USEPA, from Susan Weddle, TRC community
member, regarding comments on the Federal Facility Agreement; November
16, 1989.
18.
Letter to Meghan Cruise, USEPA, from Jeanne Johnson, Town of Brunswick
Conservation Commission, regarding a request for an ex1ension for review and
comment of [tbe documents included in the Information Repository for] the
Brunswick Naval Air Station; November 17, 1989.
19.
Letter to Alan Prysunka, Maine DEP. from Merrill Hohman, USEPA.
regarding the state's comments on the [Federal Facility] Agreement;
December 18, 1989.
20.
Letter to William Adams, E.C. Jordan Co. [ABB Environmental Services,
Inc.], from R.L. Gillespie, Department of tbe Navy, Northern Division,
regarding a schedule extension for the Draft Initial Screening Report
[Feasibility Study]; February 1, 1990.
21.
Letter to T.G. Sheckels, Department of the Navy, Northern Division, from
Merrill Hohman, USEP A, regarding an amendment to the Federal Facility
Agreement; February 9, 1990.
22.
Letter to Alan Prysunka, Maine DEP, from T.G. Sheckels, Department of the
Navy, Northern Division, regarding Applicable or Relevant and Appropriate
Requirements (ARARs) for Remedial Investigation/ Feasibility Study at
Naval Air Station Brunswick; March 6, 1990.
October 6, 1994
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Letter to Ken Marriott, Naval Facilities Engineering Command, Northern
Division, from Meghan Cassidy, USEP A, regarding a request concurrence
between the agencies for an extension to the Remedial Investigation schedule;
March 12, 1990.
24.
Letter to Thomas Shecke1s, Naval Facilities Engineering Command, Northern
Division, from Alan Prysunka, Maine DEP, regarding ARARs [Applicable or
relevant and appropriate requirements] for Naval Air Station Brunswick; .
April 9, 1990.
25.
Letter to Meghan Cassidy, USEP A, from KR. Marriott, Department of the
Navy, Northern Division, regarding an extension under the FFA for preparing
the response to comments on the Draft Feasibility Study and Draft Remedial
Investigation reports; May 18, 1990.
26.
Letter to James Shafer, Naval Facilities Engineering Command, Northern
Division, from Meghan Cassidy, USEP A, regarding a notice to proceed with
the Feasibility Study activities at Naval Air Station Brunswick; June 21, 1990.
27.
Letter to Meghan Cassidy, USEPA, from James Shafer, Naval Facilities
Engineering Command, Northern Division, regarding an extension under the
FFA for preparing the response to comments on the Draft Feasibility Study
and Draft Remedial Investigation reports; June 25, 1990.
28.
Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding invertebrate tissue analysis for mercury along
the Maine coast for establishing background mercury levels; February 24,
1992.
Letter to Cmdr. Ron Terry, Naval Air Station Brunswick. from Meghan
Cassidy, USEPA, regarding sampling of Mere Brook, April 23. 1992.
Letter to James Shafer, Naval Facilities Engineering Command. Northern
Division, from Mary Sanderson, USEPA, regarding the proposed accelerated
schedules for the naval air station; January 11, 1993.
By Reference ONLY with location noted:
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U.S. Environmental Protection Agency, 1988. "Guidance for Conducting
Remedial Investigations and Feasibility Studies under CERCLA"; Office of
Solid Waste and Emergency Response; OSWER Directive 9335.3-01; Interim
Fmal; October 1988.
U.S. Environmental Protection Agency, 1988. "Engineering Evaluation/ Cost
Analysis
£-22
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