PB95-963101
EPA/ESD/R01-94/097
January 1995
EPA Superfund
Explanation of Significant Difference
for the Record of Decision:
Brunswick Naval Air Station
Sites 1 and 3, ME
9/30/1994
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EXPLANATION OP SIGNIPICANT DIPPERENCES
AT SI'l'ES 1 AND 3
NAVAL AIR STATION BRUNSWICK, MAINE
September 1994
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TABLE OF CONTENTS
Contents
DECLARATION
EXPLANATION OF SIGNIFICANT DIFFERENCES
I.
INTRODUCTION
A. SITE NAME AND LOCATION
B. LEAD AND SUPPORT AGENCIES
C. LEGAL AUTHORITY
D. SUMMARY OF THIS EXPLANATION OF SIGNIFICANT
DIFFERENCES
AVAILABILITY OF DOCUMENTS
E.
II.
SUMMARY OF SITE HISTORY, ENFORCEMENT HISTORY,
AND SELECTED REMEDY
A. SITE NAME, LOCATION, AND DESCRIPTION
B. SITE HISTORY
C. ENFORCEMENT HISTORY
D. SELECTED REMEDY
III. DESCRIPTION OF SIGNIFICANT DIFFERENCES
A. SITE 8 .
B. SITES 5 AND 6
C. APPLICABLE OR RELEVANT AND APPROPRIATE.
REQUIREMENTS
IV.
SUPPORT AGENCY COMMENTS
V.
STATUTORY DETERMINATIONS
VI.
PUBLIC PARTICIPATION
REFERENCES
GLOSSARY
APPENDICES
APPENDIX A - Response to Navy Comments
APPENDIX B Response to State of Maine Comments
APPENDIX C - MEDEP Letter of Concurrence
APPENDIX D - Administrative Record Index & Guidance
Page No.
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Documents
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FIGURE
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APPROXIMATE LOCATIONS OF SITES 1, 3, 5, 6, AND 8 .
LIST OF TABLE
1
ACTION SPECIFIC ARARS, CRITERIA, AND GUIDANCE
FOR SITES 1 AND 3
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DECLARATION FOR THE
EXPLANATION OF SIGNIFICANT DIFFERENCES
SITE NAME AND LOCATION
Sites 1 and 3
Naval Air Station Brunswick (NASB or NAS Brunswick)
Brunswick, Maine
STATEMENT OF PURPOSE
This decision document sets forth the basis for the determination
to issue the attached Explanation of Significant Differences
(ESD) for Sites 1 and 3 at the NAS Brunswick Superfund Site in
Brunswick, Maine.
STATUTORY BASIS FOR ISSUANCE OF THE ESD
Under Section 117(a) of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), if the lead agency
determines that the remedial action at a Site differs
significantly from the Record of Decision (ROD) for that Site,
the lead agency shall publish an explanation of the significant"
differences between the remedial action being undertaken and the
remedial action set forth in the ROP and the reasons such changes
are being made. Section 300.435(c) of the National Contingency
Plan (NCP) , and EPA guidance (OSWER Directive 9355.3-02),
indicate that an ESD, rather than a ROD amendment, is appropriate
where the changes in issue do not fundamentally alter the overall
remedy with respect to scope, performance, or cost. Because the
adjustments to the remedial action do not fundamentally alter the
overall remedy for the Sites 1 and 3 with respect to scope,
performance or cost, this ESD is properly being issued.
In accordance with Section 300.435(c) of the NCP, this ESD will
become part of the Administrative Record which is available for
public review at both the NASB Public Works Office and the Curtis
Memorial Library, both in Brunswick, Maine. In addition, a
notice that briefly summarizes this ESD will be published in the
Brunswick Times Record.
OVERVIEW OF THE ESD
The 1992 ROD for Sites 1 and 3 at NASB requires that the selected
remedy combine both containment of waste and recovery of
contaminated groundwater to obtain a comprehensive approach for
site remediation. In summary, the selected remedy included the
following components: construction of a cap over the landfills;
construction of a slurry wall around the waste to divert clean
water away from the landfills; extraction of contaminated
groundwater contained within the cap/slurry wall system; and
treatment of extracted groundwater by chemical oxidation,
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flocculation, clarification and filtration to remove inorganic
compounds, and ultraviolet/oxidation to destroy organic compounds
prior to discharge. The selected remedy also includes
implementation of a long-term monitoring 'program; and requires
institutional controls and land-use restrictions.
By this ESD, the Navy, as lead agency, with concurrence from EPA
and Maine Department of Environmental Protection, is including
the movement of material from Sites 5, 6, and 8 at NASB to Sites
1 and 3 in the remedial action for Sites 1 and 3. Sites 5, 6,
and 8 are additional sites at NASB undergoing remediation as part
of the CERCLA process. Sites 5 contains asbestos materials, and
Site 6 contains asbestos materials and construction debris. The
material at Site 8 includes a small volume of soil contaminated
with polYnuclear aromatic hydrocarbons, and construction
debris/rubble. The material excavated from Sites 5, 6 and 8 will
be used as necessary subgrade material in the construction of the
cap at Sites 1 and 3.
In October 1992, a Proposed Plan was issued outlining a
containment option for Site 8. Since waste was to be left in
place under this alternative, permanent land-use restrictions
were a necessary component of the remedy. During the public
comment period, the Navy received a substantial number of '
comments asking that removal of all of the material from Site 8
be considered as a new alternative. The main reason for this
request was the community's desire to avoid the need for,
permanent land-use restrictions to be placed on small parcels of
land. Since Site 8 is less than one acre in size and contains
primarily construction debris and rubble, evaluation of this new
alter-native indicated that excavation (with the use of the
material as subgrade fill for the cap to be constructed at Sites
1 and 3) was feasible and cost-effective.
In March 1993, the Navy issued a second Proposed Plan for Site 8
outlining excavation of all material and use as subgrade fill at
Sites 1 and 3 as the preferred alternative, and a second public
comment period was held. No comments were received.
Subsequent to the Navy's response to the public comments on
Site 8, the Navy evaluated alternatives for remedy selection at
Sites 5 and 6. Anticipating that the public would raise the same
issues for Sites 5 and 6 (which are only one-half acre and one
acre respectively), the Navy proposed excavation of materials
from these sites as the preferred alternative. This alternative
involves excavation of a small volume of asbestos pipes from Site
5, and excavation of aSbestos-containing material and
construction debris from Site 6 with use of the excavated
material as part of the necessary subgrade for Sites 1 and 3.
This preferred alternative was determined to be feasible and
cost-effective.
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The use of excavated material from Sites 5, 6, and 8 as subgrade
for the cap at Sites 1 and 3 does not fundamentally alter the
.overall remedy for Sites 1 and 3 with respect to scope,
performance or cost.
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DECLARATION
For the foregoing reasons,
issuance of an Explanation
and 3 at Naval Air Station
changes stated therein.
By: ~ 11
~~lson -
Title:
Captain, u.S. Navy
Commanding Officer
Naval Air Station
Brunswick, Maine
by my signature below, I approve the
of Significant Differences for Sites 1
Brunswick, in Brunswick, Maine and the
Date
i3S~ '14
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DECLARATION
For the foregoing reasons, by my signature below, I approve the
issuance of an Explanation of Significant Differences for Sites 1
and.3 at Naval Air Station Brunswick, in Brunswick, Maine and the
::ge~rtt~~ . Date ~l?o(~4-
Jo P. DeVillars
Title: Regional Administrator
u.S. Environmental Protection Agency, Region I
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EXPLANATION OF SIGNIFICANT DIFFERENCES
SITES 1 AND 3
NAVAL AIR STATION BRUNSWICK
BRUNSWICK, MAINE
I.
INTRODUCTION
A. Site Name and Location
Site Name:
Sites 1 and 3
Naval Air Station Brunswick (NASB or NAS
Brunswick)
Site Location:
Brunswick, Maine
B. Lead and Support Agencies
Lead Agency:
Support Agencies:
United States Department of the Navy (Navy)
United States Environmental Protection
Agency (EPA)
Maine Department of Environmental Protection
(MEDEP)
Pursuant to the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) ~120(e), the Navy, EPA
and MEDEP entered into a Federal Facility Agreement (FFA) , dated
October 19, 1990 regarding the cleanup of environmental
contamination of NASB. The FFA sets forth the roles and
responsibilities of each of the parties.
C. Legal Authority
Under CERCLA ~117(a), the National Contingency Plan (NCP)
~300.435(c), and EPA guidance (OSWER Directive 9355.3-02), if the
lead agency determines that differences in the remedial action
significantly change, but do not fundamentally alter the remedy
selected in the Record of Decision (ROD) with respect to scope,
performance, or cost, the lead agency shall publish an
explanation of the significant differences between the remedial
action being undertaken and the remedial action set forth in the
ROD and the reasons such changes are being made.
D. Summary of this Explanation of Significant Differences (ESD)
The 1992 ROD for Sites 1 and 3 at NASB requires that the selected
remedy combine both containment of waste, and recovery and
treatment of contaminated groundwater to obtain a comprehensive
approach for site remediation. In summary, the selected remedy
included the following components: construction of a cap over
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the landfills; construction of a slurry wall around the waste to
divert clean water away from the landfills; extraction of
contaminated groundwater contained within the cap/slurry wall
system; and treatment of extracted groundwater by chemical
oxidation, flocculation, clarification and filtration to remove
inorganic compounds, and ultraviolet/oxidation to destroy organic
compounds prior to discharge. The selected remedy also includes
implementation of a long-term monitoring program; and requires
institutional controls and land-use restrictions.
By this ESD, the Navy, as lead agency, with concurrence from EPA
and MEDEP, is including the movement of material from Sites 5, 6,
and 8 at NASB to Sites 1 and 3 in the remedial action for Sites 1.
and 3. The locations of the sites in question are shown on
Figure 1. Sites 5, 6, and 8 are additional sites at NASB
undergoing remediation as part of the CERCLA process. Site 5
contains asbestos materials, and Site 6 contains asbestos
materials and construction debris. The material at Site 8
includes a small volume of soil contaminated with polYnuclear
aromatic hydrocarbons (PARs), and construction debris/rubble.
The material excavated from Sites 5, 6 and 8 will be used as part
of the necessary subgrade material in the construction of the cap
at Sites 1 and 3.
In October 1992, a Proposed Plan was issued outlining a
containment alternative for Site 8. Since waste was to be left
in place under this alternative, permanent land-use restrictions
were a necessary component of the remedy. During the public
comment period, the Navy received a substantial number of
comments asking that removal of all of the material from Site 8
be considered as a new option. The main reason for this request
was the community's desire to avoid the need for permanent land-
use restriction to be placed on small parcels of land. Since
Site 8 is less than one acre in size and contains primarily
construction debris and rubble, evaluation of this new alter-
native indicated that excavation (with the use of the material as
subgrade fill for the cap to be constructed at Sites 1 and 3) was
feasible and cost-effective (ABB ES, Inc., 1993).
In March, 1993, the Navy issued a second Proposed Plan for Site 8
outlining excavation of all material and use of the excavated
material as part of the necessary subgrade fill at Sites 1 and 3
as the preferred alternative, and a second public comment period
was held. No comments were received.
Subsequent to the Navy's response to the public comments on
Site 8, the Navy evaluated alternatives for remedy selection at
Sites 5 and 6. Anticipating that the public would raise the same
issues for Sites 5 and 6 (which are only one-half acre and one
acre respectively) the Navy proposed excavation of materials from
these sites as the preferred alternative. This alternative
involves excavation of a small volume of asbestos pipes from Site
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5, and excavation of asbestos-containing material and
construction debris from Site 6 with use of the excavated
material as necessary subgrade for Sites 1 and 3. This preferred
alternative was determined to be feasible and cost-effective.
The use of excavated material from Sites 5, 6, and 8 as subgrade
material for the cap at Sites 1 and 3 does not fundamentally
alter the overall remedy for Sites 1 and 3 with respect to scope,
performance or cost. These adjustments will not impact the other
aspects of the original remedy: construction of a cap and slurry
wall; extraction and treatment of contaminated groundwater; long-
term monitoring; and institutional controls and land-use
restrictions.
E. Availability of Documents
This ESD shall become part of the administrative record for Sites
1 and 3. Both the ESD and the administrative record are
available to the pubiic at the following locations.
Public Works Office
Naval Air Station Brunswick
Brunswick, Maine 04011
(207) 921-2445
Curtis Memorial Library
23 Pleasant Street
Brunswick, Maine 04011
Hours: .
Monday-Wednesday: 9:30 a.m. - 8:00 p.m.
Thursday-Friday: 9:30 a.m. - 6:00 p.m.
Saturday: 9:30 a.m. - 5:00 p.m.
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FIGt."RE 1
SITE LOCATION MAP
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II.
SUMMARY OF SITE HISTORY, ENFORCEMENT HISTORY AND SELECTED
REMEDY
A. Site Name, Location, and Description
NAS Brunswick is a National priorities List (NPL) site. There
are currently 13 areas (Sites) within NAS Brunswick under
investigation. This ESD relates to Sites 1 and 3. These sites
were grouped together based on their proximity and common
historical land use (i.e., landfill areas).
NAS Brunswick is located south of the Androscoggin River between
Brunswick and Bath, Maine, south of Route 1 and between Routes 24
and 123. 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 operation area
(approximately 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 9ther 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. The remaining 12
percent of the base includes the operations area (approximately 5
percent) and miscellaneous shrubland, marsh and open water. The
southern edge of the base borders coves, and estuaries of the
Gulf of Maine and Atlantic Ocean.
Property uses surrounding NAS Brunswick are primarily suburban
and rural residential, with some commercial and light industrial
uses along Routes 1, 24 and 123. An elementary school, a
college, and a hospital are located within 1 mile of the western
base boundary.
The general area of Site 1 covers more than 60 acres, although
the specific area of documented refuse disposal is much smaller,
approximately 8.5 acres. Site 3 consists of approximately 1.5
acres and is contiguous to Site 1. Site 1 is currently-an open,
slightly rOlling, grass-covered field bordered to the north,
west, and east by woodlands, and to the south by the Weapons
Compound and steep embankments bordering the Mere Brook beaver
marsh. Site 3 is next to Site 1 to the southwest, and currently
consists of a small knoll covered with grass and a pine grove.
Lowland areas along the Mere Brook beaver marsh are heavily
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wooded. The slopes along portions of the brook are typically
very steep in the areas next to the landfill. .
Groundwater associated with the site is not used for potable
purposes or any other uses. The base is connected to a public
water supply administered by the Brunswick-Topsham Water
District, with the exception of the golf course. The golf course
area is distant from Sites 1 and 3 and is not affected by
groundwater flow from Sites 1 and 3. Mere Brook, south of Sites
1 and 3, receives drainage from the runways as well as runoff and
leachate from the landfills. The brook is not commonly used for
recreational activities in the beaches near Sites 1 and 3 because
access to this area is restricted. Mere Brook flows into the
Atlantic Ocean at Harpswell Cove, which is designated as a
potential aquaculture area by the State of Maine. Harpswell Cove
supports various commercially i~portant fish species.
B. Site History
NAS Brunswick is an active facility supporting the U.S. Navy's
antisubmarine warfare operations in the Atlantic Ocean and
Mediterranean Sea. The base's primary mission is to operate and
maintain P-3 Orion aircraft. NAS Brunswick first became active
in the 1940s during World War II, and underwent major expansion
in the 1950s.
Sites 1 and 3 are located within a restricted area in the central
portion of NAS Brunswick. Historical records indicate that the
Site 1 landfill was used from 1955 to 1975. Material reportedly
disposed of in this landfill included garbage, food waste,
refuse, waste oil, solvents, pesticides, petroleum products,
paint wastes, aircraft and automobile parts, and various
chemicals.
Site 3 is defined as the area across from Site 1, next to the
access road into the Weapons Compound. Historical information
reports that Site 3 operated as a disposal area from 1960 to
1973. Wastes disposed of at this site included solvents, paints,
and isopropyl alcohol. No waste material was observed'at Site 3
and only low-level soil contamination was reported. Although
Site 3 was originally believed to be a separate disposal area
from Site 1, field sampling activities did not show a clear
delineation between these two sites.
Based on the proximity of the two sites, common historical land
use, and hydrogeologic characteristics, the impacts of past
disposal practices from Sites 1 and 3 cannot be distinguished.
Therefore; these areas of contamination are combined and
discussed as one site. Test pit information and field sampling
results were used to estimate the combined size of the landfills
at 10 acres. The waste estimate is based on test pit data and
boring logs. The waste in the trench area of the landfill is
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.
approximately 20 feet in the deepest areas with the depth of
waste decreasing to the east and west. An average depth of 15
feet was assumed to estimate an a~proximate combined refuse
volume of 300,000 cubic yards (yd) for Sites 1 and 3.
Environmental contamination was observed in several media at
Sites 1 and 3, including soils, groundwater, leachate/sediment,
and surface water/sediment. Contaminants detected above
background levels include PAHs and pesticides in soil; volatile
organic compounds (VOCs) and inorganic compounds in groundwater;
. inorganic compounds, VOCs, and semivolatiles (SVOCs) in leachate;
and inorganic compounds in surface water. The source area for
this contamination is considered to be the landfill (Sites 1 and
3) located north and west of the Weapons Compound. No single,
well-defined source of contamination has been identified in the
landfill.
C. Enforcement History
The enforcement history at NAB Brunswick, including Sites 1 and
3, is summarized as follows:
.
In 1983, an Initial Assessment Study (lAB) was completed
detailing historical hazardous material usage and waste
disposal practices at NAB Brunswick.
In 1984, a Pollution Abatement Confirmation Study was
conducted. These studies recommended further investigation
of seven of the nine hazardous waste sites originally
identified (i.e., Sites 1 through 4 and 7 through 9).
.
.
In 1987, NAB Brunswick was placed on the CERCLA National
priorities List.
.
The Remedial Investigation/Feasibility Study (RI/FS) process
was begun in 1987 for seven sites.
.
In February 1988, the first Technical Review Committee (TRC)
meeting was held. TRC meetings have been held quarterly
since that initial meeting.
.
Four sites were added to the RI/FS program in 1989 i.e.,
Sites 11, 12, 13, 14), as well as the two additional sites
originally identified in the lAB (i.e., Sites 5 and 6) .
Site 10, originally identified in the lAB, was no longer
under the jurisdiction of NAB Brunswick and is not included
in the Installation Restoration Program (IRP).
.
In August 1990, the Navy completed Draft
I FS reports (E.C. Jordan Co., 1990a and
Final RI Report described field sampling
geology, and hydrogeology, and presented
Final RI and Phase
1990b). The Draft
investigations,
contamination and
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.
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., 1991c and 1992b). The
Navy submitted: a Draft Final Supplemental RI Report for
the Eastern Plume and Sites 5, 6, 8, 12, and 14 in August
1991; an FFS Report for Sites 5, 6, and 12 in July 1991; and
a Feasibility Study for Sites 2, 4, 7,9, 11, and 13 in
March 1992 (E.C. Jordan Co., 1991b, 1991a, and 1992a,
respectively) .. .
In October 1990, the Navy entered into a Federal Facility
Agreement (FFA) with the USEPA and the MEDEP regarding the
cleanup of environmental contamination at NAS Brunswick.
The FFA sets forth the roles and responsibilities of each
party, contains deadlines for the investigation and cleanup
of hazardous waste sites, and establishes a mechanism to
resolve disputes among the parties.
.
The Navy and EPA signed a ROD for Sites 1 and 3 in June
1992, one for Sites 5 and 6 in August 1993, and one for
8 in August 1993. The MEDEP provided a letter of
concurrence on these RODs.
Site
D. Selected Remedy
The 1992 ROD for Sites 1 and 3 requires that the selected remedy
combine both a source control and groundwater component to obtain
a comprehensive approach for remediation. In summary, the
selected remedy includes the following components:
1.
A slurry wall will be placed around the landfill (with the
exception of the Weapons Compound Area)., and will divert
clean groundwater flow around the site, preventing
groundwater contact with waste material. Because the slurry
wall will be sealed into ~~e und~lying silty clay, and will
have a permeability of 10 to 10 centimeters per second.
(cm/sec), minimal volumes of groundwater will flow beneath
or through the wall. The final location of the slurry wall
will be outside the limits of the waste.
2.
A low-permeability cap will be placed over the landfill area
to reduce the amount of rainfall infiltration and thereby
reduce leachate production. The cap will also extend over
the slurry wall to prevent rainfall infiltration within the
slurry wall limits. The maximum permeability of t~e low-
permeability barrier layer of the cap will be 1x10 cm/sec.
The landfill cover, as required by the Sites 1 and 3 ROD,
was designed to meet or exceed Resource Conservation and
Recovery Act (RCRA) guidance as described in the USEPA
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3 .
4.
document, Desiqn and Construction of RCRA/CERCLA Final
Covers (USEPA, 1991b) and sound engineering design
practices.
A groundwater extraction system was designed and will be
installed to remove contaminated groundwater trapped beneath
the cap and within the slurry wall system. Approximately 16
million gallons of water (i.e., one pore volume) will be
removed and treated. Capturing this contaminated water will
prevent it from discharging to Mere Brook. These extraction
wells will decrease the time required for this water to
drain naturally. The extraction wells included in the
selected remedial. alternative will facilitate the collection
of the volume of contaminated ground-water remaining beneath
the landfill cap following installation of the slurry wall
and reduce the time required ,to lower groundwater to levels
below the waste.
The extracted groundwater will be pumped to a central
treatment plant located outside the Sites 1 and 3 area for
the pretreatment of dissolved metals and treatment of VOCs.
The groundwater treatment system will .handle extracted water
from Sites 1 and 3, as well as the Eastern Plume.
5.
Extracted groundwater from Sites 1 and 3 will be run through
a pretreatment system to remove inorganic compounds to the
appropriate discharge limits (based on the Publicly Owned
Treatment Work's (POTW) National Pollution Discharge
Elimination System (NPDES) permit) and concentrations that
would not interfere with VOC treatment. Once the inorganics
are removed, the water will be treated to remove or reduce
VOCs using ultraviolet (UV)/oxidation system. This
technology destroys organic compounds in water through
chemical oxidation enhanced by exposure to UV light. In the
oxidation process, organic contaminants are broken down into
simpler, nonhazardous substances such as carbon dioxide,
water, salts, organic and inorganic acids, or other by-
products. .
Treated water will be piped and tied into the existing base
sanitary sewer system (Brunswick Sewer District POTW).
Pretreatment standards will be established for the water
before it enters the POTW. These standards will then become
effluent limits for the groundwater treatment system.
6.
This alternative requires the implementation of
institutional controls and land-use restrictions to prevent
future use of the landfills or groundwater. Restrictions on
land use will be incorporated by NAS Brunswick to prevent
future land use of the landfills and groundwater affected by
the landfills.
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7.
A long-term environmental monitoring program will be
implemented following construction of the components
discussed above. The monitoring program will include
groundwater flow and quality, surface water, sediment, and
leachate seeps. Data collected under this program will
provide information necessary to assess the effectiveness of
the cap and slurry wall at diverting clean water around the
site and preventing further contamination of groundwater.
In addition, the monitoring program will assess the
dispersion and degradation of contamination that has alr~ady
emanated from the landfill. Ata minimum, the environmental
monitoring program will continue for 30 years.
Five-year reviews will also be required as part of the
environmental monitoring program. The five-year reviews
will assess the performance of the containment system.
III. DESCRIPTION OF SIGNIFICANT DIFFERENCES
The selected remedy for Sites 1 and 3 as described in section
II.D. above is contained in the Site 1 and 3 ROD issued in June
1992. Under the remedial actions selected in two later RODs, one
for Sites 5 and 6, and one for Site 8, both issued in August
1993, the Navy will excavate material from those sites and use it
as part of the necessary subgrade fill under the landfill cap
which meets RCRA Subtitle C requirements and is to be constructed
as part of the remedial action at Sites 1 and 3.
Since the June 1992 ROD for Sites 1 and 3 did not include the use
of material from Sites 5, 6 and 8 as subgrade fill for the Sites
1 and 3 cap, the Navy, as lead agency, is issuing this ESD.
Sections III.A. and III.B. below describe Sites 5 and 6, and
Site 8, including the remedial actions selected for those sites
and the relationship of those actions to the remedial action for
Sites 1 and 3~ Section III.C. and Table 1 describe additional
Applicable or Relevant and Appropriate Requirements (ARARs) to
the Sites 1 and 3 remedial action which will result from the use
of material from Sites 5, 6 and 8 at Sites 1 and 3.
A. Site 8
Under an August 1993 ROD, the Navy will
contaminated surface soil, construction
Site 8, and dispose of this material as
subgrade fill under the landfill cap to
and 3.
excavate and remove PAH-
debris and rubble from
part of the necessary
be constructed at Sites 1
The approximately 0.6-acre Site 8, the Perimeter Road Disposal
Site, is located in the northern portion of the base. Site 8 was
a disposal area reportedly used from 1964 to 1974 for rubble and
debris from NAB Brunswick. The site is a flat, open area with
steep, wooded embankments down to two small tributaries bordering
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the site on the northeast and northwest. Seeps have been
observed. at the base of the slope of the embankment down to the
northeastern tributary. Groundwater associated with the site is
not used for ~otable or any other purposes.
Soil boring and test pit samples were collected in the disposal
area at Site 8 to identify contaminants in surface and subsurface
soils. Environmental contamination was present in only four test
pits located in the northeastern area of Site 8. PARs were
determined to be the only contaminant of concern at this site.
PARs were detected in surface soil only, except for one test pit
where they were found in decreasing concentrations to a depth of
8 feet. Carcinogenic PAR concentrations ranged from less than
2.5 to 30 mg/kg. The total incremental human health carcinogenic
risks ass~ciated wi~p exposure to the levels of carcinogenic PARs
were 1x10 and 3x10 . This range is a conservative estimate
based on a future residential scenario assuming exposure to the
average and maximum detected concentrations of carcinogenic PARs.
Toxicity Characteristic Leachate Procedures (TCLP) tests were run
on the soils contaminated with PARs. The soil samples passed the
TCLP tests indicating that the contaminants have very low
mobility in the present site.
Groundwater, surface water, sediment and leachate seeps were all
evaluated during the remedial investigation. No TCL pesticides,
polychlorinated biphenyls (PCBs), VOCs or SVOCs were detected in
Site 8 monitoring wells. Several TAL inorganic contaminants were
detected above background levels. However it was determined that
the presence of these inorganics (sodium, chloride and cyanide)
were associated with runoff from an upgradient salt storage pile.
This salt pile has since been moved. Cadmium was also detected,
however the presence of cadmium is associated with the native
geologic soils in the area and is not associated with the past
activities at Site 8. Inorganic and organic compounds were
detected sporadically in surface water, sediment, and leachate
seeps adjacent to Site 8. Analytes detected in these media were
either not associated with past disposal practices at Site 8, or
if they were potentially associated were not present at levels
that posed a human health or environmental risk.
The selected remedy for Site 8 as outlined ip the ROD includes
excavation of an upper estimate of 14,000 yd of soil,
construction rubble and debris. Since the issuance of the ROD,
it has been determined tpat the excavation will be in the amount
of approximately 5600 yd. Material will be excavated and
transported to Sites 1 and 3. Transportation of the material
entails loading it onto dump trucks and transporting it by truck
approximately 3 miles on NASB property to Sites 1 and 3. The
material will then be placed and spread at Sites 1 and 3 as
subgrade material before landfill cap construction. No permanent
land-use restrictions will be required at Site 8 since all PAR
contaminated soil and construction debris will be removed.
16
-------
Use of the Site 8 material was not anticipated in 1992 when the
ROD for Sites 1 and 3 was finalized. However, an engineering
evaluation performed during the design phase of the Sites 1 and 3
cap indicated that the material from Site 8 is suitable subgrade
material and will provide some of the required fill necessary for
completion of the Sites 1 and 3 remediation.
B. Sites 5 and 6
Under an August 1993 ROD, the Navy will remove asbestos-
containing material from Site 5, and construction rubble and
asbestos-containing material from Sites 6, and dispose of this
material as part of the necessary subgrade fill under the
landfill cap to be constructed at Sites 1 and 3.
Records indicate that Site 5 was used once, in 1979, as a
disposal area for asbestos-covered pipes. The pipes were placed
in two trenches, one measuring three by 20 by seven feet deep and
the second, alongside the first, measuring 15 by 30 by 10 feet.
deep. One trench contained six asbestos pipes from four to 12
feet long and the second contained six to eight corrugated pipes
with smaller asbestos pipes inside. The trenches were covered
with soil.
Site 6 was reportedly used for general dumping of construction
debris until the late 1970s. A site inspection in 1980 reported
asbestos-covered pipes protruding from the surface. Aircraft
parts were also reportedly disposed of at Site 6. At the current
time, pipe, concrete, asphalt and other debris are visible at the
surface.
Geophysical surveys performed at Site 5 confirmed the location of
the reported trenches. Geophysical surveys at Site 6 did not
locate any primary anomalies, but did suggest a large semi- .
circular region where asbestos and rubble were likely disposed.
Additional test pitting further defined the area of disposal.
Surface soil samples were collected from both Sites 5 and 6.
Asbestos was not detected in any of these samples. Groundwater
contamination resulting from asbestos (the contaminant of concern
at Sites 5 and 6) was not of concern, because asbestos fibers are
very stable in the subsurface environment and are not likely to
migrate (Gilbert, et al., 1981). Therefore, groundwater at Sites
5 and 6 was not monitored for asbestos. TCLP tests were run on
the soils from Site 6. The soil samples passed the TCLP tests
indicating that there are no contaminants present that are mobile
in the environment.
Human health and ecological risk assessments were conducted for
Sites 5 and 6. While there is a human health risk associated
with future potential exposure to asbestos during construction or
17
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excavation-related activities, quantitative risks cannot be
estimated because no subsurface samples were collected. The
potential for increased future risks remains if any asbestos is
uncovered by activities at either site. The concentrations of
contaminants "in surface soils at Sites 5 and 6 were within
background concentrations and are not expected to adversely
affect environmental receptors.
The selected remedy for Sites 5 and 6 as o¥tlined in the ROD
includes excavation of approximately 12 yd of asbestos-
co~taining soil and pipes from ~te 5, and approximately 8,800
yd of material including 250 yd of aSbestos-containing
materials from Site 6. All excavated aSbestos-containing
material will be containerized in two layers of polyethylene,
each with a minimum thickness of 6 millimeters (mils), in
accordance with the Maine Landfill Disposal Regulations for the
Management, Testing, and Disposal of Special Wastes (38 MRSA
1304, Chapter 405.4) and labeled in accordance with Occupational
Safety and Health Administration regulations (29 CFR 1910.1001 or
1926.58). Since the issuancr of the ROD, it has been determined
that approximately 18,700 yd of construction debris and asbestos
material will be excavated from Sites 5 and 6. Containerized
asbestos material and other excavated debris will be transported
by dump trucks to Sites 1 and 3 where it will be used as subgrade
fill beneath the landfill cap. No permanent land-use
restrictions will be required at Sites 5 and 6 since all
asbestos-containing material and debris will be removed.
Use of the Sites 5 and 6 material was not anticipated in 1992
when the ROD for Sites 1 and 3 was finalized. However, an
engineering evaluation performed during the design phase. of the
Sites 1 and 3 cap indicated that the material from Sites 5 and 6
is suitable subgrade material and will provide some of the
required fill necessary for completion of the Sites 1 and 3
remediation.
c. Applicable or Relevant and Appropriate Requirements
Use of material from Sites 5, 6, and 8 as subgrade fill at Sites
1 and 3 requires compliance with certain ARARs, in addition to
those discussed in the 1992 ROD for Sites 1 and 3. These
additional ARARs, including a synopsis of the requirement and the
action to be taken to meet the requirement, are set forth in
Table 1 of this ESD.
Federal and State requirements relating to asbestos. Since the
material from Sites 5 and 6 to be used as subgrade fill at Sites
1 and 3 includes asbestos, the following Federal and State
requirements relating to asbestos must be met:
.
Clean Air Act, National Emission Standards for Hazardous Air
Pollutants (NESHAPs), 40 CFR Part 61. The NESHAP
18
-------
requirements for emission limits and personnel training for
the handling of asbestos (Subpart M) are relevant and
appropriate to the activities regarding the placement of
asbestos material from Sites 5 and 6 under the landfill cap
at Sites" 1 and 3.
.
Occupational Safety and Health Act, General Industry
Standards, 29 CFR Part 1910. Training requirements
specified in 29 CFR ~ 1910.120 for workers at asbestos
are applicable and will be complied with.
sites
.
Occupational Safety and Health Act, General Industry
Standards, 29 CFR Part 1926. This regulation, which
specifies the type of safety equipment and procedures for
handling asbestos, is applicable.
Maine Solid Waste Management Regulations, Testing and
Disposal of Special Wastes, MSWMR, Chapter 405. Section
405.4, which Sets forth the requirements that apply to the
storage, transport and disposal of asbestos wastes, is
applicable.
.
.
Maine Asbestos Abatement Regulations, Chapter 136. This
regulation which specifies the minimum work practice
requirements for asbestos aba~ement contractors, is
applicable.
Resource Conservation and Recovery Act (RCRA), Land Disposal
Restrictions, 40 CPR Part 268. Under this regulation, land
disposal of RCRA hazardous waste is restricted without specified
treatment. However, since the material from Sites 5, 6, and 8
were determined not to be RCRA hazardous waste, this regulation
is not an ARAR.
Pederal and State permits. Although Sites 1 and 3 will be
receiving waste material from Sites 5, 6, and 8, it is not
necessary for Sites 1 and 3 to obtain any Federal or State
permits. Sites 1, 3, 5, 6, and 8 may be viewed as separate
CERCLA facilities which are non-contiguous, as defined in CERCLA
~109(1). Therefore, Sites 1 and 3 are exempt from the permit
requirements because, under the NCP, it is appropriate to
aggregate these facilities for the purpose of the response action
since they are related based on the threat posed and based on
geography (55 FR 8690, March 8, 1990).
Maine Solid Waste Management Regulations, MSWMR, chapters 400 and
401. These regulations set forth requirements for alterations
(including vertical and horizontal expansions) to and closure of
solid waste disposal sites. The use of material from Sites 5, 6
and 8 as fill material necessary for completion of the remedial
19
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action at Sites 1 and 3 does not constitute a horizontal or
vertical expansion of a solid waste disposal site (EPA letter,
dated May 3, 1994). Therefore, the requirements of MSWMR,
chapters 400 and 401, which relate to expansions of solid waste
disposal sites (e.g. the bottom liner requirements of MSWMR
~401.4.(C)), are not applicable to this action.
These requirements, however, may be relevant since they relate to
the disposal of solid waste, including debris from construction
demolition such as that found at Site 8 and special waste such as
asbestos that is at Sites 5 and 6. Even if these requirements
are relevant, in order for them to be ARARs which must be
complied with, they must also be determined to be appropriate.
For the reasons discussed below, these regulations are not
appropriate.
Two of the factors to be looked at in determining if a
requirement is appropriate is the purpose of the requirement and
whether another requirement is available that more fully matches
the circumstances of the site (CERCLA Compliance with Other Laws
Manual: Interim Final, EPA/540/G-89/006, August 1988, at 1-67).
Here, the purpose of both the RCRA Subtitle C requirements
(which are ARARs for the remedial action contained in the Site 1
and 3 ROD) and the requirements of MSWMR, chapters 400 and 401,
which relate to expansions of solid waste disposal sites is to
prevent hazardous wastes from Sites 1 and 3 from infiltrating
into the ground water. Since the RCRA Subtitle C requirements
will provide equal or greater protectiveness than the
requirements regarding the expansion of solid waste disposal
sites set forth in the MSWMR, chapters 400 and 401, these Maine
regulations are not appropriate.
20
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REQUIREMENT
Federal
~ational
Emission
Standards for
Haz1lrdous
Pollutants
(NESHAPs)
(40 CFR Part
61).
tV
......
Occupat i onal Safety and.
Heal th Act (OSHA) -
General Industry
Standards (29 CFR Part
1910).
OSHA. Safety and Health
Standards (29 cFR Part
1926).
Resource, Conservation,
Recovery Act (RCRA) Land
Disposal Restrictions
(LORs) (40 CFR Part
268) .
Relevant and
Appropriate
Appl icable
Applicable
Not Appl i cabl e
TABLE 1
Action-Specific ARARS, criteria, and Guidance For Sites 1 and 3
ESO: Site 1 and 3
Naval Air Station Brunswick
STATUS
REQUIREMENT SYNOPSIS
Emission of asbestos fibers are regulated
Subpart H of 40 CFR Part 61. This regulation
includes requirements for inactive waste
disposal sites for asbestos mills and
manufacturing and fabricating operntions, for
active waste disposal sites, and for waste
disposal for demolition and renovation
operations. It does not include requirements
for inactive waste disposal sites like Sites 1
and 3. Therefore, the NESHAP will not be
applicable. However, the regulation is
"relevant and appropriate" to the control of
asbestos fiber emissions at an inactive waste
disposal site for demolition and renovation
operations because the situation is
sufficiently similar.
These regulations specify the 8-hour time-
weighted average concentration for various
organic compounds. Training requirements for
workers at hazardous waste, including asbestos,
operations are specified in 29 CFR Part
1910.120.
This regulation specifies the type of safety
equipment and procedures for handling asbestos.
Land disposal of RcRA hazardous waste is
restricted without specified treatment. It
must be determined that the waste meets the
definition of one of the specified restricted
wastes and the remedial action must constitute
""placement" for the land disposal restrictions
to be considered applicable. For each
hazardous waste, the LORs specify that the
waste must be treated either by a treatment
technology or to a concentration level prior to
disposal In a RCRA Subtitle C permitted
facility.
ACTION TO BE TAKEN TO MEET ARAR
The NESHAP requirements for emission
limits, and personnel training for the
handling and disposal of asbestos (Subpart
H) are relevant and appropriate to
activities regarding the placement of
asbestos material beneath the Inndflll cop
at Sites 1 and 3. Actions taken at Site 1
and 3 will meet these requirements.
Proper respiratory equipment will be worn
if it is impossible to maintain the work
atmosphere below the concentration.
Yorkers performing activities at Site 1
and 3 will be required to have completed
specific training requirements.
All appropriate safety equipment will be
worn on site. In addition, safety
procedures will be followed during on-site
activities.
Yaste materials from Site 5, 6 and 8 were
established as non-hazardous under RCRA
definitions; therefore these materials can
be disposed of at Site 1 and 3 without
begin subject to LDRs.
-------
REQUIREMENT
State
Haine Solid Uaste
Hanagement, Testing, and
Disposal of Special
Uastes (HEDEP
Regulations Chapter
(05) .
Haine Asbestos
Abatement Regulations
(HEDEP Regulations
Chopt er 136)
Applicable
Applicable
TABLE 1
Action-Specific ARARS, Criteria, and Guidance For Sites 1 and 3
ESO: Site 1 and 3
Naval Air Station Brunswick
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO MEET ARAR
These requirements will pertain to
activities involving disposal of asbestos
material at Site 1 and 3.
These requirements will apply to remedial
activities at Site 1 and 3.
:'-J
N
Section 405.4 sets forth requirements that
apply to the storage, transport and disposal of
asbestos wastes.
These regulations specify the minimum work
practice requirements for asbestos abatement
contractors.
-------
IV.
SUPPORT AGENCY COMMENTS
EPA and MEDEP have participated with the Navy as lead agency in
developing the changes to the 1992 ROD for Sites 1 and 3 and
support the changes described in this ESD. The changes allow the
Navy to address contamination at NAS Brunswick in a manner which
addresses the concerns of the community, and is still protective
of human health and the environment.
V.
STATUTORY DETERMINATIONS
Considering the above-described adjustments to the selected
remedy set forth in the 1992 ROD for Sites 1 and 3, the Navy
believes that the remedy remains protective of human health and
the environment; complies with Federal and State requirements
that are applicable or relevant and appropriate to the remedial
action; and is cost-effective. 'In addition, the revised remedy
results in permanent solutions (removal of all wastes) for
Sites 5, 6 and 8.
VI.
PUBLIC PARTICIPATION
This ESD, as well as all other material relating to
investigations and remedy selection, is available for public
review at the locations listed in Section I above. The public
has had the opportunity to comment during the public comment
periods for Sites 5 and 6, and Site 8 and supports the actions
described in this ESD.
23
-------
REFERENCES
ABB Environmental Services, Inc., 1993. "Technical Memorandum,
Detailed Evaluation of Alternative 8D, Excavation and Use as
Subgrade"Material at Sites 1 and 3"; Portland, Maine;
March.
E.C. Jordan Co., 1990a. "Draft Final Remedial Investigation
Report NAS Brunswick"; Portland, Maine; August.
E.C. Jordan Co., 1990b. "Draft Final Phase I Feasibility Study
Development and Screening of Alternatives NAS Brunswick";
Portland, Maine; August.
E.C. Jbrdan Co., 1991a. "Focused Feasibility Study Report for
Sites 5, 6, and 12 NAS Brunswick"; Portland, Maine; July.
E.C. Jordan Co., 1991b. "Draft Final Supplemental RI for Eastern
Plume and Sites 5, 6, 8, 12 and 14 NAS Brunswick"; Portland,
Maine; August.
E.C. Jordan Co., 1991c. "Focused Feasibility Study Sites 1 and 3
NAS Brunswick"; Portland, Maine; October.
E.C. Jordan Co., 1992a. Feasibility Study "for Sites 2, 4, 7, 9,
11, and 13 NAS Brunswick"; Portland, Maine; March.
E.C. Jordan Co., 1992b. "Focused Feasibility Study Site 8 NAS
Brunswick"; Portland, Maine; April.
Gilbert, et al., 1981. "Experimental Studies of Amphibole"
Stability"; Reviews in Minealoqv - Amnhiboles and other
Hydrous Pvriboles; vol. 9B, pp. 229-267.
Letter to Nancy Beardsley, Maine Deparment of Environmental"
Protection, from Robert Lim, U.S. Environmental Protection
Agency, regarding Maine Solid Waste Disposal Regulations,
chapters 400-401 -- Explanation of Significant Differences
for Sites 1 and 3; May 3, 1994.
Maine Department of Environmetal Protection, Maine Asbestos
Abatement Regulations, Chapter 136.
Maine Department of Environmental Protection, Maine Solid Waste
Regulations, Chapters 400 and 401.
Maine Department of Environmental Protection, Maine Landfill
Disposal Regulations for the Management, Testing, and
Disposal of Special Wastes, 38 MRSA 1304, Chapter 405.4.
Northern Division, Naval Facilities Engineering Command (NAVY),
1992. "Record of Decision for Remedial Action at Sites 1 &
24
-------
3 NAB Brunswick"; Portland, Maine; June.
Northern Division, Naval Facilities Engineering Command (NAVY),
1993a. "Record of Decision for Remedial Action at Sites 5 &
6 NAB Brunswick"; Portland, Maine; August.
Northern Division, Naval Facilities Engineering Command (NAVY),
1993b. "Record of Decision for Remedial Action at Sites 8
NAB Brunswick"; Portland, Maine; August.
Occupational Safety and Health Administration, 29 CFR Part 1910.
Occupational Safety and Health Administration, 29 CFR ~ 1910.1001.
or ~ 1926.58.
Occupational Safety and Health Administration, 29 CFR Part 1926.
u.S. Environmental Protection Agency (USEPA), 1988. "CERCLA
Compliance with Other Laws Manual: Interim Final";
EPA/540/G-89/006; August.
u.S. Environmental Protection Agency (USEPA), 1989. "Interim
Final Guidance on Preparing Superfund Decision Documents";
OSWER Directive 9355.3-02; June. .
u.S. Environmental Protection Agency (USEPA), 1991. "Design and
Construction of RCRA/CERCLA Final Covers"; Office of.
Research and Development, Washington, D.C.; EPA/625/4-
91/025; May.
u.S. Environmental Protection Agency (USEPA), 1992. "National
Oil and Hazardous Substances Pollution Contingency Plan (The
NCP) "; OSWER Directive 9200.2-14; January.
25
-------
ARARs
CERCLA
CFR
ESD
FFA
FFS
FR
IAS
IRP
MEDEP
MSL
MSWMR
NAS .
NCP
NESHAPs
NPDES
NPL
OSHA
OSWER
PAH
PCBs
POTW
RCRA
ROD
SVOC
TAL
TCL
TCLP
TRC
USEPA
UV
VOC
GLOSSARY
Applicable or Relevant and Appropriate Requirements
Comprehensive Environmental Response, Compensation, and
Liability Act
Code of Federal Regulations
Explanation of Significant Differences
Federal Facilities Agreement
Focused Feasibility Study
Federal Register
Initial Assessment Study
Installation Restoration Program
Maine Department of Environmental Protection
Mean sea level
~ine Solid Waste Management Regulations
Naval Air Station
National Oil and Hazardous Substances Contingency Plan
National Emission Standards for Hazardous Air'
Pollutants
National Pollution Discharge Elimination System
National priorities List'
Occupational Safety and Health Administration
Office of Solid Waste and Emergency Response
Polynuclear Aromatic Hydrocarbon
Polychlorinated biphenyl
Publicly Owned Treatment Works
Resource Conservation and Recovery Act
Record of Decision
Semi volatile Organic Compound
Target Analyte List
Target Compound List
Toxicity Characteristic Leaching Procedure
Technical Review Committee
United States Environmental Protection Agency
Ultraviolet
Volatile Organic Compound
26
-------
APPENDIX A
RESPONSE TO NAVY COMMENTS
-------
~.",
- . ~
~~~ '-
,'~,\,\II~ ~
"I~~
~~J/'
.,~
DEPARTMENT OF THE NAVY
NORTI-'!:::IN DIVISICN
NAVAL FACILITIES ;:NGINEERING C:::>MMAND
10 INDUS7RIAL HIGHWAY
MAIL 570P. #82
LESTE;:!. "A 19113.2Q90
IN MEPLY REFER TO
5090
S:?! 2005/1821/FE:
GEC 0 '; i9S3
Mr. Robert Lim
U.S. Enviro~~ental Protection Agency
Region I
J.F. Kennedy Federal Building
Boston, MA 02203-221:
-Subj: - CO~l'l'S. OR-DRAIT7EXPtANATION OF SIGNIFICANr DfFFERENG'.S -- -STIES
. 1 AND 3 DATED NOVEMBER 1993, NAS BRUNSWICK, ME
Dear Sir:
Enclosed is a copy of the Navy responses to your Draft Explanation or
Si~ficant Differences.
If ad~itional information is required, please contact Fred Ev-~~ at
215-3;5-0505, x159.
Sincerly,
--- ;/ -
. ;..- J I.. .J J J.
". I' f'.:::1-.... ----- .
FRANCO LA GRECA
Head, Restoration Mgmt Section
By direction of the Commanding Officer
End :
(1 )
Cornme~ts on Draft Explanation of Significant Differences
Copy to:
-. MI. J - Caruuers, NAS Brunswick
Ms. Nancy Beardsley, MEDEP
Mr. Robert McGirr, AEB Environmental
--...----..
1
-------
COM~ENTS ON SITES 1 Al~D 3
EXPL-\l"lA nON OF SIGNIFICPu'1T DIFFERENCES
General comment: Add the definitions of acronyms POTW, NPDES and OSHA the
first time they are used in the text.
Page 1, 4th paragraph, last sentence. Revise to read "...will be published in the
Brunswick Times-Record". This is the newspaper that has been used in the past to
notify the public of ongoing activities at the NAS.
Page 2, 2ad paragraph. 3rd sentence. Suggest revising to read: "Site 5 contains asbestos
materials and Site 6 contains asbestos materials and construction debris."
Page 2, 3rd paragraph and Page 7, 3rd paragraph, 3rd sentence. Suggest revising the
word "option" to "alternative" ; to read "...of all the material from Site 8 be
considered as a new alternative."
Page 2, 3rd para~aph 4th sentence.
"...permanent land-use restrictions...".
Suggest reVlsmg the semence to read:
Page 2, 3rd paragraph and yn paragraph. Last sentence in these paragraphs is
awkward.
Page 2, 4111 paragra,ph 4 and Page 7, 4111 paragraph. Suggest adding the following
sentence at the end of the paragraph: "No commentS were received."
. -. .-.---.-
Pa!!e 2. last par3.QjaDh. 3rt! semence. Su!!!!est revisin!! to read: "muse of the excavated
- . -" --.....
material as part of the necessary subgrade...".
Page 6, last paragraph, 2nd line. Suggest adding the words "and treatment" to read
"waste and recovery and treatment".
Page 7. 2n.i paragraFh. 1'1 semence. Change "are" to "is".
Page 7. 2nJ p:.iragr~.mh. 2nJ semence.
shown on Figure L'
Suggest re\l~mg 10 re:.iu: "...site~ in question :.ire
2
-------
Page 7, 2nd paragraph, 4t\ sentence. Suggest revising to read: "Site 5 contains asbestOs
materials and. Site 6 contains asbestOs materials and construction debris."
Page 7, 2nd paragraph, last sentence. Suggest revising to read: "...be used as part of
the necessary..."
Page 8, 1st paragraph, lot sentence. Suggest revising to read "...use of the excavated
material as part of the necessary subgrade...".
Page 9, 4th paragraph, 3rd sentence. Sentence should start with "Site 1", not "Site 3".
Page 9, 6th paragraph, 5th line from bottom of page. Change "beaches" to "reaches".
Page 12, paragraph D.2, 2nd sentence. Suggest revising to read: "The cap will also
extend over the slurry wall to prevent rainfall infiltration within the slurry.wall limitS."
Page 12, paragraph D.Z, 3M sentence. Revise this sentence to read: "The maximum
permeability of the low-permeability barrier layer of the cap will be...".
.Page 12, paragraph D3, 3M and 4th sentences. Delete these tWo sentences.
Page 13, 3rd paragraph, last sentence. Revise to read "..become effluent limitS for the
groundwater treatment system".
" - .-. .. .
Page 14, In paragraph. last sentence. Suggest revising to read: "...use it as pan of the
necessary subgrade...".
Page 14, 1st paragraph. last sentence. Should read "...fill under the landf1lI cap, which
is - n. The cap is nOt a RCRA Subtitle C cap. The cap meetS RCR.-\. Subtitle C cap
perfonnance criteria. This distinction should be maintained throughout the ESD. See
other comments for recommended text changes.
Pag~ 1-+. 5~~ par:lgraph. h:''' sem~nce. Suggcsi ;lddtr~g "is a conser"\:aIIVc"' aiLe;- 'ThiS"
and ~dore .'estimate" anc deletin~ "j{'
- 3
-------
Page 14, paragraph AI, I~ sentence, Delete" a smail amount of' and revise to read
"...remove PAH-comarninated...dispose of this material as subgrade fill under...".
Page 14, last paragraph, 5th and 6th sentences. Suggest revising for consistency.
Eithe: state one concentration and one risk. or a range of concentrations and the
corresponding range of risks.
Page 15, 2ad paragraph. Although the current wording is accurate, please be aware
that the construction cost estimate prepared for the bid documents reflect a smaller
volume o( debris (5,600 <:1) than originally estimated and cOlitained in the Site 8
ROD. '
Page 15, 2ad paragraph, 2ad sentence. Revise to read: "No TCL pesticides,...".
Page 15, 2ad paragraph, 3rd sentence. Revise to read: "Several TAL inorganic ...".
Page 15, paragraph B.1. Suggest revising to read: "Navy will remove asbestos-
containing material from Site 5 and construction rubble and asbestOs-comaiDing
material from Site 6, and dispose of this material as subgrade fill for the proposed
landfill cap...".
Page 16, 3M paragraph, 2ad sentence. Revise to read: "Asbestos was nOt detected...".
Page 16, last paragraph. The current wording is accurate. However, please be aware
that the construction cost estimate prepared for the bid documents reflect a
significantly greater volume of construction debris and asbestos material (totalling
18,700 <:1) than originally estimated and presented in the Sites 5 and 6 ROD. This _. - -
higher estimate is based on additional field efforts conducted in the Spring of 1993.
Page 18, 151 paragraph, 2na semence. Suggest revising to read: "However, since the
materials from Sites 5,6, and 8 were determined...".
Page 18. 3rd paragraph, 2nd semence. Suggest revising to read: "...rather, they are
abandoned sites which are...Sites 5. 6. and 8 as part of the required filL".
P~g-= :~. la~;: paragraph. .:;r.; sentence. Rcvi~c:: i:(' reaJ: "...reu,Ulrcmem is appropriate
arc :1'.;; purpnse..."
4
-------
. Page 18, last paragraph, 4th sentence. Revise to read: "...the purpose of the landfill
cap...in the Sites 1 and 3 ROD...to prevem migration of the hazardous wastes from
Sites 1 and 3 intO the groundwater."
Page 18, last paragraph, 51b sentence. Revise to read: "Since the landfill cap will
meet the performance criteria of a RCRA Subtitle C cap, it will provide equal or
greater protectiveness than the requirementS set fonh in the Maine Solid Waste
Regulations, the Maine regulations are not appropriate." Also, note that the Maine
Solid Waste Regulations were identified as an ARAR in the ROD and Design
Summary Report. .
Last page. No entties were made in Table 1 for the Maine Solid Waste Management
Rules.
- - .h. --... .- - ._--- -- ...- ._-- -- ..--- .....
.. .._. - --. -_.. ..- -..
- - - - -_. .----_._--- - - -
5
-------
1.
2.
Response to Navy Comments Dated December 3, 1993
(Comments are typed as they appear in original comment letter.)
Comment - General comment: Add the definitions of acronyms
POTW, NPDES, and OSHA the first time they are used in the
text.
Response - Text will be revise accordingly
Comment - Page 1, 4th paragraph, last sentence. Revise to
read "...will be published in the Brunswick Times Record."
This is the newspaper that has been used in the past to
notify the public of ongoing activities at the NASB.
3.
Response - Text "...will be published in the Brunswick Times
Record" will be added to paragraph.
Comment - Page 2, 200 paragraph, 3rd sentence. Suggest
revising to read: "Site 5 contains asbestos materials, and
Site 6 contains asbestos materials and construction debris."
4.
Response - Text will be revised accordingly.
Comment - Page 2, 3rd paragraph and Page 7, 3rd paragraph, 3rd
sentence. Suggest revising the word "option" to
"alternative"; to read "...of all the material from Site 9
be considered as a new alternative." .
5.
Response -Text will be revised accordingly.
Comment - Page 2, 3 rd paragraph 4 th paragraph. Suggest
revising the sentence to read: "...permanent land-use
restrictions..."
6..
Response - Text will be revised accordingly.
Comment - Page 2, 3rd paragraph and 5th paragraph.
sentence in these paragraphs is awkward.
Last
7.
Response - Sentence will be deleted.
Comment - Page 2, 4 rd paragraph, and Page 7, 4 th paragraph.
Suggest adding the following sentence at the end of the
paragraph: "No comments were recEd ved. "
..----..--- .
8.
Response - Text will be revised accordingly.
Comment -Page 2, last paragraph, 3rd sentence. Suggest
revising to read: "...use of the excavated materials as
part of the necessary subgrade..."
Response - Text will be revised accordingly.
6
-------
9.
10.
11.
12.
13.
14.
15.
16.
17.
Comment - Page 6, 'last paragraph, 2~ line. Suggest adding
the words "and treatment" to read "waste and recovery and
treatment."
Response - Text will be revised accordingly.
Comment - Page 7, 2~ paragraph, 1st line.
"is."
Change "are" to
Response - Text will be revised accordingly.
Comment - Page 7, 2~ paragraph, 2~ sentence. Suggest
revising to read: "...sites in question are shown on Figure
1."
Response - Text will be revised accordingly.
Comment - Page 7, 2~ paragraph, 4th sentence. Suggest
revising to read: "site 5 contains asbestos materials and
site 6 contains asbestos materials and construction debris."
Response - Text will be revised accordingly.
Comment - Page 7, 2~ paragraph, last sentence. Suggest
revising to read: "...be used as part of the necessary
subgrade..."
Response - Text will be revised accordingly.
Comment - Page 8 , 1st paragraph ,1st sentence. Suggest
revising to read: "...use of the excavated material as part
of the necessary subgrade..."
Response - Text will be revised accordingly.
Comment - Page 9, 4th paragraph, 3 rd sentence.
should start with "site 1," not "Site 3."
Sentence
Response - Text will be revised accordingly.
- ---.---- . - .
Comment - Page 9, 6th paragraph, 5th line from bottom of
page. Change "beaches" to "reaches."
Response. - Text is correct and does not need to be revised.
Comment - Page 12, paragraph D.2, 2~ sentence. Suggest
revising to read: "The cap will also extend over the slurry
wall to prevent rainfall infiltration within the slurry wall
limits."
Response - Text will be revised accordingly.
7
-------
18.
19.
20.
21.
22.
23.
----.
24.
Comment - Page 12, paragraph D. 2, 3rd sentence. Revise
sentence to read: liThe maximum permeability of the low-
permeability barrier layer of the cap will be...11
Response. - Text will be revised accordingly.
Comment - Page 12, paragraph D.3, 3rd and 4th sentence.
Delete. these two sentences.
Response - The EPA feels that sentences provide an adequate
summary of the selected remedy, and will remain in the
paragraph.
Comment - Page 13, 3rdparagraph, last sentence. Revise to
read: "...become effluent limits for the groundwater
treatment system."
Response - Text will be revised accordingly.
Comment - Page 14, 1st paragraph, last sentence. Suggest
revising to read: 1I...use it as part of the necessary
subgrade...11
Response - Text will be revised accordingly.
Comment - Page 14, 1st paragraph, last sentence. Should
read 1I...fill under the landfill cap, which is..." The cap
is not a RCRA Subtitle C cap. The cap meets RCRA Subtitle C
cap performance criteria. This distinction should be
maintained throughout the ESD. See other comments for
recommended text changes. .
Response - Text will be revised to read "a landfill cap
which meets RCRA Subtitle C requirements and which is to be
constructed, and the distinction will be maintained
throughout the text..
Comment - Page 14, 5th paragraph, 6th sentence. Suggest
adding "is a conservative" after "This" and before
"estimate" and deleting "is."
Response - Text will be revised accordingly.
Comment - Page 14, paragraph A. 1, 1st sentence. Delete" a
small amount of" and revise to read "...remove PAH-
contaminated...dispose of this material as subgrade fill
under. . . "
Response - Text will be revised to read "...remove PAH-
contaminated...dispose of this material as part of the
necessary subgrade fill under...."
8
-------
25.
26."
27.
28.
29.
Comment - Page 14, last paragraph, 5th and
Suggest revising for consistency. Either
concentration and one risk, or a range of
the corresponding range of risks.
6th sentences.
state one
concentrations and
" Response - Text will be revised to state the associated risk
range which will be consistent with the stated concentration
range.
Comment - Page 15, 2~ paragraph. Although the current
wording is accurate, please be aware that the construction
cost estimate prepared for the bid documents reflect a
smaller volume of debris (5,600 yd3) than originally
estimated and contained in the Site 8 ROD.
Response - Insert the following sentence after 2~ sentence.
"Since the issuance of the "ROD, it has been determined that
the excavation will be in the amount of approximately 5600
yd3. "
Comment - Page 15, 2~ paragraph, 2~ sentence.
read: "No TCL pesticides..."
Revise to
Response - Text will be revised accordingly.
Comment - Page 15, 2~ paragraph, 3rd sentence.
read: "Several TAL inorganic..."
Revise to
Response - Text will be revised accordingly.
Comment - Page 15, paragraph B.1. Suggest revising to read:
"Navy will remove aSbestos-containing material from site 5
and construction rubble and aSbestos-containing material
from Site 6, and dispose of this material as sub grade fill
for the proposed landfill cap..."
Response - Text will be revised accordingly.
30.
Comment- Page 16, 3rd paragraph, 2nd sentence.
read: "Asbestos was not detected..."
Revise - to - "
31.
Response - Text will be revised accordingly.
Comment - Page 16, last paragraph. The current wording is
accurate. However, please be aware that the construction
cost estimate prepared for the bid documents reflect a
significantly greater volume of construction debris and
asbestos material (totalling 18,700 yd3) than originally
estimated and presented in the Sites 5 and 6 ROD. This
higher estimate is based on additional field efforts
conducted in the Spring of 1993.
9
-------
32.
33.
34.
35.
36.
37.
Response - Before '''Containerized...'' insert sentence,
"since the issuance of the ROD, it has been determined that
approximately 18,700 yd3 construction debris and asbestos
material will be excavated from Sites 5 and 6."
Comment - Page 18, 1st paragraph, 2nd sentence. Suggest
revising to read: "However, since the materials from sites
5, 6, and 8 were determined..."
Response - No change is needed since comment ,and existing
text are the same.
Comment - Page 18, 3rd paragraph, 2nd sentence. Suggest
revising to read: "...rather, they are abandoned sites
which are...Sites 5, 6, and 8 as part of the required
fill..." .
Response - Text will be revised accordingly.
Comment - Page 18, last paragraph, 3rd sentence. Revise to
read: "...requirement is appropriate are the purpose..."
Response - Response not needed. Last paragraph has been
deleted and replaced with a new paragraph.
Comment - Page 18, la?t paragraph, 4th sentence. Revise to
read: "...the purpose of the landfill cap...in the Sites 1
and 3 ROD...to prevent migration of the hazardous wastes
from sites 1 and 3 into the groundwater."
Response - See response to Maine DEP second comment.
paragraph has been deleted and replaced with a new
paragraph.
Comment - Page 18, last paragraph, 5th sentence. Revise,to
read: "Since the landfill cap will meet the performance
criteria of a RCRA Subtitle C cap, it will provide equal or
greater protectiveness than the requirements set forth in
the Maine Solid Waste Regulations, the Maine regulations are
not appropriate." Also, note that the Maine Solid Waste
Regulations were identified as an ARAR in the ROD and ROD
Summary Report.
Last
Response _. See response to State of Maine second comment.
Last paragraph has been deleted and replaced with a new
paragraph.
comment - Last page. No entries were made in Table 1 for
the Maine Solid Waste Management Rules.
Response - Entry has been deleted because entry does not
effect sites 1 and 3, but only effects Site 8.
10
-------
APPENDIX B
RESPONSE TO STATE OF MAINE COMMENTS
-------
\~~\RONAtE.
~ "'I:
" ~
~ ..' """
" ---- ~
{..~ ..~-
'" ~
STATE OF MAINE
DEPA~TMENT OF ENVIRONMENTAL PROTECTION
. OF \l.t.\~""
JOHN R. McKERNAN. JR.
G:>VE"INOR
DEAN C. MARRIOTT
COMMISSIONER
DEBRAH RICHARD
DEF'lTTV COMMISSiONER
~mber20, 1993
Mr. Robert Lim
USEP A Region I
Remedial Project Manager'
JFK Federal Building
'Boston, Mass. 02203
RE: Comments on the Draft Explanation of Significant Differences, Sites 1 and 3,
NAS Brunswick
Dear Bob:
The Department has the following comments on the Explanation of Significant
Differences, Sites 1 and 3, Naval Air Station Brunswick.
1. Page 18, Maine Solid Waste Regulations, MEDEP, Chapters 401-404: The
Depanment's January 25, 1993 letter to Mr. James Shafer, was a response to a
telephone inquiry from Mr. Shafer ~ncerning whether a license was required to
dispose of asbestos from Sites 5 and 6 at Sites 1 and 3. In this letter, the Depamnent
did not notify the Navy that the Maine Solid Waste Regulations were not applicable to
Sites 1 and 3. The letter stated that the Director of the Division of Solid Waste Facility
Licensing did not believe a license for asbestos disposal at Sites 1 and 3 was required
because the disposal is part of a remedial activity. Asbestos is listed as a "Special
Waste" in Maine, not a hazardous waste.
2. Page 18, fourth paragraph: As we discussed on the telephone, the Department does
not support EPA's statements that the State of Maine Solid Waste Regulations,
Chapters 401-404, are not appropriate at Sites 1 and 3.
-.-- --.-.-- -.
The Department does not consider RCRA Subtitle C cap regulations to be as protective
as Maine's Solid Waste Management Regulations (SWMR) for the following reasons:
Maine's SWMR are more protective for final cover than RCRA Subtitle C
because SWMR address the protection of the cap from frost.
Maine's SWMR require a minimum of 30 years of long-term site monitoring, or
longer, if required by the Board of Environmental Protection. RCRA Subtitle C
requires a maximum of 30 years of monitoring.
1
AUGUST'"
STAT!; HOUSE STATION 1;
AUGUSTA MAINE O433J.OO~-
1207) 287.7688 FAA' (2071 2e-.-E2-:
~~1CE LOCATED A~ RA" B~':,,=,~ "'~5D1'TAl sn-::
PO~ ...ANt:
3~, :.t.HC~ ~OAD
P:'Q- ""'''l: fJE 04' C~
r~~, =~~ FAX:2:- 879-6303
BANGOR
106 HOGAN ROAD
BANGOR ME 04A0'
1207\ SOI~570 FA)(' 12071 SOI~S&<
P"ES:;:UE ISLE
12"'..5 CE>mIA:. DRIvE. SlNWAY "All'
PR~S::<;~ rs:.E. ME ()o&769
I~~. 7&<4'"77 FAA: (207) 760<-'507
""":rt,,d 'WI "n,trJ PGI"~
-------
A RCRA Subtitle C cap does not provide equal or greater protectiveness than the
requirements set fonh in the Maine SWMR. Maine SWMR are appropriate. Maine's
SWMR Chapters 401-404 should be an ARAR.
Please call me at 207-287-2651, if you have any questions or comments.
Sincerely,
. I
/.; ;W1. "t -"3.(( ,,'is! ~
. Nancy Beardsley
Project Manager, Federal Facilities Unit
Office of the Commissioner
cc:Jim Caruthers, NAS Brunswick
Carolyn Lepage, R.G. Gerber Inc.
Bob McGirr, ABB ES
Rene Bernier, Topsham
Sam Butcher, Harpswell
Susan Weddle, Brunswick
Brunswick Topsham Water District
Mark Hyland, DEP
Marianne Hubert, DEP
Troy Smith, DEP
.-----.- - --__'___0__-
-'---"-- --- "-----
._- ----- . . -------
2
-------
1.
Response to state Comments Dated December 20, 1993
(Comments are typed as they appear in original comment letter)
Comment - Page 18, Maine Solid Waste Regulations, MEDEP,
Chapters. 401-404: The Department's January 25, 1993 letter
to Mr. James Shafer, was a response to a telephone inquiry
from Mr. Shafer concerning whether a license was required to
dispose of asbestos from Sites 5 and 6 at Sites 1 and 3. In
this letter, the Department did not notify the Navy that the
Maine Solid Waste Regulations were not applicable to Sites 1
and 3. The letter stated that the Director of the Division
of Solid Waste Facility Licensing did not believe a license
for asbestos disposal at Sites 1 and 3 was required because
the disposal is part of a remedial activity. Asbestos is
listed as a "Special Waste" in Maine, not a hazardous waste.
Response: Instead of listing Chapter 401-404 of the Maine
Solid Waste Management Regulations (MSWMR), this section has
been revised to reflect only Chapter 400 and 401 which
covers new landfill disposal facilities or alterations to
existing solid waste disposal sites.
2.
Comment - Page 18, fourth paragraph: As discussed on the
telephone, the Department does not support EPA's statements
that the State of Maine Solid Waste Regulations, Chapters
401-404, are not appropriate at sites 1 and.3.
The Department does not consider RCRA Subtitle C cap
regulations to be as protective as Maine's Solid Waste
Management Regulations (SWMR) for the following reasons"
Maine's SWMR are more protective for final cover than
RCRA Subtitle C because SWMR address the protection of
cap from frost..
Maine's SWMR require' a minimum of 30 years
site monitoring, or longer, if required by
Environmental Protection. RCRA Subtitle C
maximum of 30 years of monitoring.
of long-term
the Board of
requires a
... ..' --,.-. _.--
Response: As stated in the previous comment, the scope of
this section has been narrowed to MSWMR Chapters 400 and
401. The reasons for the determination that MSWMR regarding
expansions are not appropriate at Sites 1 and 3 are
discussed in section C of the ESD.
In regard to frost protection, your have referred to the
cover requirements MSWMR 9401.7(C) (4) (a). The cover
requirements 9401.7(C) have been included as an ARAR in the
Sites 1 and 3 Record of Decision, dated June 1992 (Table D-
3, p. D-8). The requirements of 9401.7(C) remain an ARAR
notwithstanding the new action.
3
-------
In regard to long-term monitoring, the EPA considers the
federal and state requirements to be equally protective.
You indicate in your letter that MSWMR require a minimum of
30 years of site monitoring, or longer, if required by the
Board of" Environmental Protection. Federal requirements at
40 CFR ~264.117(a) (1) require monitoring for a period of 30
years after completion of closure. 40 CFR
~264.117(a) (2) (ii) provides that the Regional Administrator
may extend this period if he/she finds that it is necessary
to protect human health and the environment.
- -. .-- .on. -_._----~_...__.__._-_.__.._._. .----..- - .-.-.. ---,-_. --"'-'- -- ..- -- .----..
. -.---.--.-...-. .--.- .
4
-------
APPENDIX C
MAINE DEPARTMENT OF ENVIRONMENTAL PROTECTION LETTER OF
CONCURRENCE
-------
09/19/94
12:32
2137 772 4762
tt207 772 4762 ABB PORTLAND ME
I :
I .
STATE OF MAINE i
DEPARTMENT OF ENVIRPNMENTAL PROTECTION
~004
~\t'4\BO",,£;t. .
~....~..~.~
. ~$...<. :.":.. ~:'"~>~'%.
~ .....- . ~
...
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4'4ita"i tit.~'"
.-.
.ICIHN II. 1IcIaRU'N, .IR.
GOVERNOR
C£AN Co IIARRIaTT
COMMISSIONER
DEBIWI RIQI&III)
DEPUTY CO~
September ~6, ~994
W.A. Waters.
Captain, CEC, u.s. Navy
C()ItlTT1oT1d.ing Officer ' .
Department of the Navy, Northern Di {rision
Naval Facilities Engineering comman~ .
Building 77-L '
Philadelphia Naval Shipyard
Philadelphia, FA 10112-5094
I .
RE: Naval ~-T r Stat.ion Brtl!lswick Su-oerfund Site, Brunswick,
~~e -, .
Dear Captain waters:
! .
The Maine Department or Env2ronment~lPiotection (MEDEP) has
reviewed the Navy's ¥~x 1994 Explanation Of Signifi~ant
Differences (ESD) At Sites 1 and 3 Naval ~...ir Station,
Brunswick. i :
I
Under Section 1.1.7 (a) or the CCEICr~ensi ve Environmental
Response, Compensation, and Liabili~y Act, if the lead
agency determines that t.he remedial: action at a Site differs
significantly from ~he Record of De~ision (ROD) for the
Site, the lead agency shall publish an explanation of the
significant differences between thei remedial action being.
undertaken and the remedial action set forth in the ROD and
the reasons such changes are being kade~
i
The 1992 ROD for Sites ~ and 3 at NASB reouires that the
selec~ed remeqy combine both containment of waste and
recovery ot contaminated groU!ldwate~ to;obtain a
comprehensive approach for site rem~diation. In swnmary,
~e selected remedy inc~udedi the CP!lstruction of a slurry
wall around the waste, placement of! a low-permeability cap
over ~e landfill area extending over the sl1L..rry wall, the
installation of groundwater extraction wells, and the
construction of a treatment plant tb treat groundwater
extracted from ~-ithin the was~e - ; .
:
By this E:SD, t:.he Navy,. as ~ead e.9en~, with concurrence from
EPA and MEDEP, is including the movement of material from
Sites 5, 6, and 8 at ~~B to Sites i and 3 in the remedial
action for Sites 1 ~~d 3. Sites 5,1 6, and B are additional
sites at ~.sB undergoing remediation as part of the CERCLA
AUGUSTA
$rATE MOu5E Sl"ATIDM 17
~.. WAN; 00C333GtI7
121m 287~ 'AA:1:: (2177) aT.782IS
0A
-------
09/19/94
2137 772 4762
tt207 772 4762 ABB POR~LAND ¥E
! :
12:32
I :
process. S~te 5 contains asbestos ~terials, Site 6
contains asbestos materials and construc~ion debris, Site 8
contains PAR con~aminated soils and same construction
debris. The materia~ excavated from: Sites 5,6, and Swill
be used as necess~ sUbgrade materi~l in the con5truction
of the cap at Sites 1 and 3. :
I '
Since the June ~992 ROD for Sites 1 ~nd 3 did not include
the use of material from Sites 5, 6,; and 8 as subgrade fill
for the Sites 1 and 3 cap, the Navy,; as lead agen~, is
issuing this ESD. The MEDEP concurs; with i;l-1.is ESD.
I ..
Sincerely,
lirJt/k
Deborah N. Garrett
Acting Commissioner
pc:
. Capta.; 'n D. J. Nelson
Elizabeth Walter, JI...BB-ES
Robert !aim, USEPA Region ~
Mark Ryland, MEDEP
~005
-------
APPENDiX D
ADMiNiSTRATiVE RECORD iNDEX. AND GUiDANCE DOCUMENTS
-------
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
TABLE OF CONTENTS
Section
Title
Page No.
SECTION 1: PRELIMINARY ASSESSMENTS. . . . . . . . . . . . . . . . . . . .. 1
SECTION 2: SITE INSPECTIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1
SECTION 3: REM:OV AL ACTIONS. . . . . . . . .. . . . . . . . . . . . . . . . .. 2
SECTION 4: REMEDIAL INVESTIGATIONS. . . . . . . . . . . . . . . . . . . .. 4
SECTION 5: FEASffill..ITY STUDIES. . . . . . . . . . . . . . . . . . . . . . . .. 11
SECTION 6: PROPOSED PLANS AND PUBliC HEARING
. TRANSCRIPTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 16
SECTION 7: RECORDS OF DECISION. . . . . . . . . . . . . . . . . . . . . . .. 20
SECTION 8: POST-RECORD OF DECISION. . . . . . . . . . . . . . . . . . . .. 22
SECTION 9: COMMUNITY RELATIONS. . . . . . . . . . . . . . . . . . . . . .. 22
SECTION 10: PROGRAM GUIDANCE. . . . . . . . . . . . . . . . . . . . . . . .. 27
October 25, 1993
-------
SECTION 1:
Volwne 1: .
SECTION 2:
Volwne 1:
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
PRELIMJNARY ASSESSMENTS
Initial Assessment Study of Naval Air Station Brunswick, Maine, prepared by
Roy F. Weston, Inc.; June 1983 (Sites 1, 2, 3, 4, 5, 6, 7, 8, 9, and 10).
Correspondence:
1.
USEPA Notification of Hazardous Waste Site Forms identifying three landfills,
and one asbestos disposal area at Naval Air Station Brunswick; May 22, 1981.
SITE INSPECTIONS
Field Site Inspection Reportfor the U.S. Naval Air Station, Brunswick, Maine,
prepared by NUS Corporation; August 1984 (Sites 1, 2, and 3).
Pollution Abatement Confirmation Study, Step lA - 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 F.nvironmental 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 F.ngineering
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 F.ngineering
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 F.ngineering
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.
October 25, 1993
-------
SECTION 3:
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
6.
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 Draft. Confirmation Study
Verification Step report; April 15, 1985.
7.
Meeting minutes of May 22,1984[5], meeting among Department of the Navy,
Northern Division, NAS Bnmswick, 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 Confirmation Study
Verification Step Report; August 2, 1985.
9.
Letter to Robert Jackson, U.S. Environmental Protection Agency (USEPA),
from L.K. Jones, Naval Air Station, Bnmswick, regarding transmittal of the
June 1985 [pollution Abatement Confirmation Study, Step lA - Verification]
Report; December 3, 1985.
10.
Letter to L.K. Jones, Naval Air Station, Bnmswick, from Robert Jackson,
USEPA, regarding comments on the [June 1985] Pollution Abatement
Confirmation Study, Step lA - Verification Report; January 13, 1986.
11.
Letter to L.K. Jones, Naval Air Station, Bnmswick, from Anthony Leavitt,
Maine Department of Environmental Protection (DEP), regarding comments on
the [June 1985] Pollution Abatement Confirmation Study, Step lA - Verification
Report; January 13, 1986.
12.
Letter to Jim Shafer, Department of the Navy, 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 APPUCABLE TO SITES 1 AND 3
SECTION 4:
Volume 1:
REMEDIAL INVESTIGATIONS
Remedial Investigation/Feasibility Study Work Plan, formerly Draft Pollution
Abatement Confirmation Study Work PIan - Step 1 prepared by E.C. Jordan Co.
[ABB Environmental Services, Inc.]; April 1988 (Sites 1,2,3,4,7,8,9).
Addendum to RJ/FS Work Plan, prepared by E.C. Jordan Co. [ABB
Environmental Services, Inc.]; July 1988 (Sites 1,2,3,4,7,8,9).
October 25, 1993
2
-------
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
Additional Sampling Plan, prepared by E.C. Jordan Co. [ABB Environmental
Services, Inc.]; August 1989 (Sites 1,2,3,4,7,8,9).
Correspondence:
1.
Letter to Commander L.K. Jones, Naval Air Station Brunswick, 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 USEPA comments on the September 1986
Draft Pollution Abatement Confirmation Study Work Plan - Step IB:
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 n field activity; April 14, 1989.
5.
Letter to Charlotte Head, USEP A, 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 Confirmation Study, Step] IB - 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,
Massachu!>etts, among USEPA; U.S. Navy; E.C. Jordan Co. [ABB
Environmental Services, Inc.]; Maine DEP; NOAA; Camp, Dresser & McKee;
July 8, 1987.
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.
October 25, 1993
3
-------
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
10.
Letter to Captain E.B. Darsey, Naval Air Station Brunswick, from Merrill
Hohman, USEPA, regarding comments on the [January 1988] Pollution
Abatement Confirmation 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 Wildlife
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
Investigation! 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
Investigation! 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
Investigation! 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 Activity, 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.
19.
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.
20.
Letter to T.G. Sheckels, Naval Facilities Engineering Command, Northern
Division, from David Webster, USEPA, regarding comments on the April 1989
Draft Additional Sampling Plan; June 9, 1989.
October 25, 1993
4
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Volume 2:
21.
22.
23.
24.
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
Letter to Ronald Springfield, Naval Facilities Engineering Command, Northern
Division, from Denise Messier, Maine DEP, regarding approval of the Draft
Additional Sampling Plan; June 15, 1989.
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.
Letter tl:) 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.
Letter to 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 WorkPlan; May 1, 1990.
2.
Letter to Kenneth Marriott, Department 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-Screening Work
Plan; May 17, 1990.
3.
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.
4.
Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the July 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-Screening Work
Plan; August 30, 1990.
October 25, 1993
5
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Volwne 3:
Volwne 4:
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
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 n
Data Packages; March 13, 1989.
Round II Data Package, 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).
Correspondence:
Volwne 5:
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 n 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. .
4.
Letter to Ronald Springfield, Northern Division, Naval Facilities Engineering
Command, regarding comments on the Round ill Data Package; October 4,
1989.
Remedial Investigation Feasibility Study - Round N Data Package, prepared by
E.C. Jordan Co. [ABB Environmental Services, Inc.]; January 1990 (Sites
1,2,3,4,7,8,9,11,13).
October 25, 1993
6
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. Volmne 6:
V olmne 7:
Volmne 8:
Volwne 9:
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
Correspondence:
1.
Letter to Meghan Cruise, USEP A, 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, 199<;).
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 Final Remedial Investigation Report Volume 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).
Draft Final Remedial Investigalion Report Volume 3: Appendices K-P, prepared
by E.C. Jordan Co. [ABB Environmental Services, Inc.]; 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).
Correspondence:
October 25, 1993
7
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Vohnne 10:
Vohnne 11:
NA VAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
1.
Letter to Ronald Springfield, Naval Facilities Engineering Command, Northern
Division, from Charlotte Head for David Webster, USEPA, regarding the
inclusion of the [Step] lA Verification Study data in the risk assessment 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 Marriott, 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 Investigarion Feasibility Study Round V Dara 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, USEPA, from Kenneth Finkelstein, 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 12; May 1, 1991.
2.
Letter to Captain H.M. Wilson, Naval Air Station Brunswick, from Samuel
Butcher, regarding comments on the [April 1991] Draft Supplemental Remedial
Investigation Report; May 1, 1991.
3.
Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the [April 1991] 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 1991] Draft
Supplemental Remedial Investigation Report; May 30, 1991.
October 25, 1993
8
'':;:~~.
-------
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
.
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 Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the [August 1991] 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 1991] Draft
Final Supplemental Remedial Investigation Report; September 10, 1991.
Volwne U:
Draft Final Supplemental Rl 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).
Volwne 13:
SECTION 5:
Volmrie 1:
Draft Final Supplemental Rl Report Volume 3: Appendices K-Q, prepared by
E.C. Jordan Co. [ABB Environmental Services, Inc.]; August 1991 (Sites
5,6,8,9,11,12, Eastern Plume).
FEASmILITY STUDIES
Draft Final Phase I Feasibility Study Development and Screening 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 Investigation! 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.
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.
October 25, 1993
9
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V olwne 2:
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
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.
6.
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. .
7.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding comments on the August 1990 Draft Final
Phase I Feasibility Study Development and Screening of Alternatives; October
16, 1990.
9.
Letter to Meghan Cassidy, USEP A, from Kenneth Finkelstein, 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 12; May 1, 1991.
Focused Feasibility Study, prepared by E.C. Jordan Co. [ABB Environmental
Services, Inc.]; October 1991 (Sites 1 & 3)
Numerical Modeling Report, prepared by ABB Environmental Services, Inc.;
January 1993 (Sites 1 & 3; Eastern Plume).
Correspondence:
1.
Letter to Captain H.M. Wilson, Naval Air Station Brunswick, from Samuel
Butcher, regarding comments on the [April 1991] Draft Focused Feasibility
Study Report; May 1, 1991.
2.
Letter to Meghan Cassidy, USEPA, from Kenneth Finkelstein, 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 Draft Supplemental Feasibility Study for Sites
5, 6, and 12; May 1, 1991.
3.
Letter to James Shafer, Department of tbe Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding comments on the [April 1991] Draft
Focused Feasibility Study Report; May 9, 1991.
4.
Letter to Meghan Cassidy, USEPA, from Kenneth Finkelstein, National Oceanic
and Atmospheric Administration, regarding additional comments on the [April
1991] Draft Focused Feasibility Study for Sites 1 and 3; May 10, 1991.
October 25, 1993
10
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NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
5.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding additional comments on the [April 1991]
Draft Focused Feasibility Study Report; May 13, 1991.
6.
Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding state requirements for off-gas treatment for the
[April 1991] Draft Focused Feasibility Study Report; May 21, 1991.
7.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding comments on the July 1991 Draft Final
Focused Feasibility Study Report; August 14, 1991.
8.
Letter to Merrill S. Hohman, USEPA, from Capt. Thomas Dames, Department
of the Navy, Northern Division, regarding dispute resolution pertaining to the
Draft Final Focused Feasibility Study; August 14, 1991.
9.
Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the August 1991 Draft Final
Focused Feasibility Study Report; August 15, 1991.
10.
Letter to Ralph Lombardo, Department of the Navy, Northern Division, from
Ted Wolfe, MEDEP, regarding dispute resolution, August 28, 1991.
11.
Memorandum of agreement to resolve a dispute initiated under the Federal
Facility Agreement for the Focused Feasibility Study for Sites 1 and 3;
September 1991.
12.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEP A, regarding comments on the Focused Feasibility Study
for Sites 1 and 3, September 16, 1991.
13.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding comments on the October 1991 [Draft]
Numerical Modeling Work Plan; November 22, 1991.
14.
Letter to James Shafer, Department of the Navy, Northern Division, from Mark
Hyland, Maine DEP, regarding comments on the [October 1991] Draft
Numerical Modeling Work Plan; December 5, 1991.
15.
Letter to James Shafer, Department of the Navy, Northern Division, from
Loukie Lofchie, Brunswick Area Citizens for a Safe Environment, regarding
comments on the [October 1991 Draft] Numerical Modeling Work Plan;
January 13, 1992.
16.
Letter to James Shafer, Department of the Navy, Northern Division, from Mark
Hyland, Maine DEP, regarding comments on the Draft Numerical Modeling
Report; December 4, 1992.
October 25, 1993
11
-------
Volwne 3:
Volwne 4:
Volwne 5:
NA V AL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
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, USEPA, 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
Final Feasibility Study; December 26, 1991.
5.
Letter to James Shafer, Departme~t of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the November 1991 Draft Final
Feasibility Study Report; January 2, 1992.
6.
Comments from BACSE on the Feasibility Study Report, 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).
Focused Feasibility Study, prepared by B.C. Jordan Co. [ABB Environmental
Services, Inc.]; April 1992 (Site 8)
Correspondence:
1.
Memo to Mark Hyland, MEDEP, from Dick Bebr, Division of Technical
Services, regarding the Focused Feasibility Study (Site 8).
2.
Letter to Captain H.M. Wilson. Naval Air Station Brunswick. from Samuel
Butcher, regarding comments on the [May 1991] Draft Focused Feasibility
Study report; May 28, 1991.
3.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding comments on the May 1991 Draft Focused
Feasibility Study report; June 17, 1991.
October 25, 1993
12
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SECTION 6:
Vohune 1:
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
4.
lAter to Megban Cassidy, USEPA, from Kenneth Fmkelstein, National Oceanic
and Atmospheric Administration, regarding comments on the [May 1991] Draft
Focused Feasibility Study for Site 8; June 5, 1991.
5.
Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the May 1991 Draft Focused
Feasibility Study Site 8 report; June 27, 1991.
6.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding comments on the August 1991 Draft Final
Focused Feasibility Study Site 8 report; August 11, 1991.
7.
Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the August 1991 Draft Final
Feasibility Study Site 8 report; September 9, 1991.
8.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEP A, regarding the re-ca1culation of risk estimates for Site
8; February 19, 1992.
PROPOSED PLANS AND PUBLIC HEARING TRANSCRIPTS
Proposed Plan, prepared by E.C. Jordan Co. [ABB Environmental Services,
Inc.]; December 1991 (Sites 1 and 3).
Transcript of the Public Hearing for Sites 1 and 3 and the Eastern Plume,
prepared by Downing & Peters Reporting Associates; December 12, 1991
(Sites 1 and 3; Eastern Plume).
Correspondence:
3.
Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the August 1991 Draft Proposed
Plan - Sites 1 and 3; September 23, 1991.
4.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding comments on the August 1991 Draft
Proposed Plan - Sites 1 and 3; September 26, 1991.
7.
Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the October 1991 Draft Proposed
Plan - Sites 1 and 3; November 6, 1991.
8.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding comments on the October 1991 Draft
Proposed Plan - Sites 1 and 3; November 12, 1991.
October 25, 1993
13
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Volwne 2:
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
11.
Letter to James Shafer, Department of the Navy, Northern Division, from
Loukie Lofchie, Brunswick Area Citizens for a Safe Environment, regarding
comments on the December 1991 Proposed Plans, Sites 1 and 3 and Eastern
Plume; January 13, 1992.
12.
Letter to James Shafer, Department of the Navy, Northern Division, from Susan
C. Weddle, Brunswick community representative, regarding public comments
on the December 1991 Proposed Plan Eastern Plume, the December 1991
Proposed Plan Sites 1 and 3; January 13, 1992.
13.
Letter to James Shafer, Department of the Navy, Northern Division, from
EdImmd E. Benedikt, Friends of Menymeeting Bay, regarding comments on the
December 1991 Proposed Plans for Sites 1 and 3 and the Eastern Plume;
January 3, 1992.
Final Proposed Plan prepared by ABB Environmental Services, Inc.; September
1992 (Site 8).
Transcript of the Public Meeting {Hearing] for Proposed Plan, Site 8: Perimeter
Road Disposal Site, prepared by Mason & Lockhart; October 15, 1992 (Site 8).
Revised Proposed Plan for Site 8 prepared by ABB Environmental Services,
Inc.; March 1993.
Proposed Plan prepared by ABB Environmental Services, Inc.; March 1993
(Sites 5 and 6). .
Technical Memorandum prepared by ABB Environmental Services, Inc.; March
1993 (Sites 5 and 6).
Technical Memorandum, prepared by ABB Environmental Services, Inc., March
1993 (Site 8).
Correspondence:
1.
Letter to Loukie Lofchie, Brunswick Area Citizens for a Safe Environment,
from Carolyn A. Lepage and Andrews L. Tolman, Robert G. Gerber, Inc.,
regarding comments on the Draft Proposed Plan for Site 8; May 28, 1992.
2.
Memo to Mark Hyland, MEDEP, from Marianne Hubert, Technical Services,
regarding the Proposed Plan for Site 8, June 18, 1992.
3.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding comments on the May 1992 Draft
Proposed Plan for Site 8; June 29, 1992.
4.
Letter to James Shafer, Department of the Navy, Northern Division, from Mark
Hyland, MEDEP, regarding the Proposed Plan for Site 8, June 30, 1992.
October 25, 1993
14
-------
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
5.
Letter to Loukie Lofchie, BACSE, from Carolyn LePage, Robert G. Gerber,
Inc., regarding comments on the Proposed Plan for Site 8, August 27, 1992.
6.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding comments on the August 1992 Proposed
Plan for Site 8; August 31, 1992.
7.
Letter to James Shafer, Department of the Navy, Northern Division, from Mark
Hyland, Maine DEP, regarding comments on the August 1992 Proposed Plan;
September 10, 1992.
8.
Letter to James Shafer, Department Of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding comments on the February 1993 Revised
Draft Proposed Plan; August 31, 1992.
9.
Letter to Loukie Lofchie, BACSE, from Carolyn LePage, Robert G. Gerber,
Inc., regarding comments on the Proposed Plan for Site 8, October 28, 1992.
10.
Letter to James Shafer, Department of the Navy, Northern Division, from Mark
Hyland, MEDEP, regarding the Draft. Proposed Plan for Sites 5 and 6,
November 6, 1992.
11.
Letter to Loukie Lofchie, Brunswick Area Citizens for a Safe Environment,
from Carolyn A. Lepage and Andrews L. Tolman, Robert G. Gerber, Inc.,
regarding comments on the Draft Proposed Plan for Sites 5 and 6; November 6,
1992.
12.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding the Draft Proposed Plan for Sites 5 and 6,
November 10, 1992.
13.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding the Draft Final Proposed Plan for Sites 5
and 6, December 18, 1992.
14.
Letter to James Shafer, Department of the Navy, Northern Division, from Mark
Hyland, MEDEP, regarding the Proposed Plan for Sites 5 and 6, December 22,
1992. .
15.
Letter to James Shafer, Department of the Navy, Northern Division, from Mark
Hyland, MEDEP, regarding the Proposed Plan for Sites 5 and 6, January 25,
1993. .
16.
Letter to Loukie Lofchie, Brunswick Area Citizens for a Safe Environment,
from Carolyn A. Lepage and Andrews L. Tolman, Robert G. Gerber, Inc.,
regarding comments on the Draft Proposed Plan for Sites 5 and 6; January 27,
1993.
October 25, 1993
15
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SECTION 7:
Volume 1:
NA V AL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
.
17.
Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding the Technical Memorandum, January 29,
1993.
18.
Letter to Loukie Lofchie, Brunswick Area Citizens for a Safe Environment,
from Carolyn A. Lepage, Robert G. Gerber, Inc., regarding comments on the
Draft Technical Memorandum for Sites 5 and 6; February 2, 1993.
19.
Letter to JlID Shafer, Department of the Navy, Northern Division, from Meghan
Cassidy, USEPA, regarding USEPA's comments on the Revised Draft Proposed
Plan (Febnwy 1993) and Draft Technical Memorandum for Site 8; Febnwy 8,
1993.
20.
Letterto Jim Shafer, Department of the Navy, Northern Division, from Mark
Hyland, MEDEP, regarding MEDEP's comments on the Draft Revised
Proposed Plan and Draft Technical Memorandum for Site 8; Febnwy 17, 1993.
21.
Letter to Loukie Lofchie, Brunswick Area Citizens for a Safe Environment,
from Carolyn A. Lepage, Robert G. Gerber, Inc., regarding comments on the
Draft Revsied Proposed Plan and Draft Technical Memorandum for Site 8;
February 17, 1993.
22.
Letter to JlID Shafer, Department of the Navy, Northern Division, from Meghan
Cassidy, USEPA, regarding USEPA's comments on the Draft Final Proposed
Plan (February 1993) and Draft Final Technical Memorandum for Sites 5 and
6; February 24, 1992[3].
23.
Letter to Jim Shafer, Department of the Navy, Northern Division, from Mark
Hyland, MEDEP, regarding MEDEP's comments on the Draft Final Proposed
Plan and Draft Fmal Technical Memorandum for Sites 5 and 6; March 4, 1993.
24.
Letter to Loukie Lofchie, Brunswick Area Citizens for a Safe Environment,
from Carolyn A. Lepage and Andrews L. Tolman, Robert G. Gerber, Inc., .
regarding comments on the Draft Proposed Plan and Draft Fnial TechnicaI
Memorandum for Sites 5 and 6; March 5, 1993. .
25.
Letter to Jim Shafer, Department of the Navy, Northern Division, from Nancy
Beardsley, MEDEP, regarding MEDEP's comments on the Proposed Plan for
Sites 5 and 6; April 1, 1993.
RECORDS OF DECISION
Record of Decision for a Remedial Action prepared by ABB Environmental
Services, Inc.; June 1992 (Sites 1 and 3)
October 25, 1993
16
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Volmne 2:
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
Correspondence:
1.
Letter to Meghan Cassidy, USEPA, from Gordon Beckett, Fish and Wildlife
. Service, regarding the Draft Records of Decision for Sites 1 and 3 and the
Eastern Plume, March 25, 1992.
2.
Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the MaTch 1992 Draft Record of
Decision for Sites 1 and 3 and March 1992 Draft Interim. Record of Decision for
the: Eastern Plume; April 2, 1992.
4.
Letter to James Shafer, Department of the Navy, Northern Division, from Mary
Jane O'Donnell, USEPA, regarding USEPA's and U.S. Fish and Wildlife
Services' comments on the [March 1992] Draft Record of Decision for the:
Sites 1 and 3; April 6, 1992.
6.
Letter to Thomas Dames, Department of the Navy, Northern Division, from
Dean Marriott, Maine DEP, regarding Maine DEP's concurrence with the
interim. remedial action presented in the June 1992 Draft Record of Decision for
Sites 1 and 3; June 4, 1992.
Record of Decision for a Remedial Action prepared by ABB Environmental
Services, Inc.; August 1993 (Sites 5 and 6).
Record of Decision for a Remedial Action prepared by ABB Environmental
Services, Inc.; August 1993 (Site 8).
Correspondence:
1.
Letter to Jim Shafer, Department of the Navy, Northern Division, from Meghan
Cassidy, USEPA, regarding USEPA's comments on the Draft Record of
Decision for Site 8; May 25, 1993.
2.
Letter to Jim Shafer, Department of the Navy, Northern Division, from Mark
Hyland, MEDEP, regarding MEDEP's comments on the Draft Record of
Decision for Site 8; May 26, 1993.
3.
Letter to Jim Shafer, Department of the Navy, Northern Division, from Loukie
Lofchie, Brunswick Area Citizens for a Safe Environment, enclosing a letter
dated May 25, 1993 to Loukie Lofchie, from Carolyn A. Lepage and Andrews
L. Tolman, Robert G. Gerber, Inc., regarding comments on the Draft Record
of Decision for Site 8; May 26, 1993.
4.
Letter to .rIm Shafer, Department of the Navy, Northern Division, from Meghan
Cassidy, USEPA, regarding USEPA's comments on the Draft Record of
Decision for Sites 5 and 6; June 24, 1993.
October 25, 1993
17
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SECTION 8:
Volwne 1:
SECTION 9:
Volwne 1:
5.
6.
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
Letter to Loukie Lofchie, Brunswick Area Citizens for a Safe Environment,
from Carolyn A. Lepage, Robert G. Gerber, Inc., regarding comments on the
Draft Record of Decision for Sites 5 and 6; June 24, 1993.
Letter to Jim Shafer, Department of the Navy, Northern Division, from Nancy
Beardsley, MEDEP, regarding MEDEP's comments on the Draft Final Record
of Decision for Sites 5 and 6; June 25, 1993.
7.
Letter to Jim Shafer, Department of the Navy, Northern Division, from Nancy
Beardsley, MEDEP, regarding MEDEP's comments on the Draft Final Record
of Decision for Site 8; June 25, 1993.
8.
Letter to Loukie Lofchie, Brunswick Area Citizens for a Safe Environment,
from Carolyn A. Lepage, Robert G.' Gerber, Inc., regarding comments on the
Draft Final Record of Decision for Site 8; June 25, 1993.
9.
Letter to Jtm Shafer, Department of the Navy, Northern Division, from Meghan
Cassidy, USEPA, regarding USEPA's comments on the Draft Final Record of
Decision for Site 8; June 29, 1993.
10.
Letter to Jtm Shafer, Department of the Navy, Northern Division, from Meghan
Cassidy, USEPA, regarding USEPA's comments on the Draft Final Record of
Decision for Sites 5 and 6; July 11, 1993.
11.
Facsimile to Bob McGirr, ABB Environmental Services, Inc., froin Meghan
Cassidy, USEPA, regarding additional USEPA comments on the Draft Final
Record of Decision for Site 8; August 3, 1993.
12.
Facsimile to Kathy Kern, ABB Environmental Services, Inc., from Meghan
Cassidy, USEPA, regarding additional USEPA comments on the Draft Final
Record of Decision for Sites 5 and 6; August 13, 1993.
13.
Letter to Jim Shafer, Department of the Navy, Northern Division, from Nancy
Beardsley, MEDEP, regarding MEDEP's comments on the Draft Final Record
of Decision for Sites 5 and 6; August 16, 1993.
POST-RECORD OF DECISION
Remedial Design Sununary Repon, prepared by ABB Environmental Services,
Inc.; May 1993 (Sites 1, 3, 5, 6, 8, and the Eastern Plume). '
COMMUNITY RELATIONS
Community Relations Plan - for NASB NPL Sites prepared jointly by Public
Affairs Office, Navy Northern Division, and E.C Jordan Co. [ABB
Environmental Services, Inc.]; September 1988
October 25, 1993
18
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NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
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.
4.
Letter to Commander Geoffrey Cullison, Naval Air Station Brunswick, from
Ted Wolfe, Maine DEP, regarding analytical results from water samples
colIected from a Coombs Road residence; December 27, 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.
7.
Letter to [Joshua] Katz, from T.J. Purul, 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 12, 1990.
9.
Letter to file from Geoffrey Cullison, Naval Air Station Brunswick, regarding
Site 8 and off-site influences; April 23, 1990.
10.
Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding data from the sampling at Consolidated Auto, and
the revised May 30, 1990 Maximum Exposure Guidelines; June 22, 1990.
11.
Fact sheet for Naval Air Station Brunswick regarding question and answers
about National Priorities List Sites; August 15, 1990.
12.
Press release announcing the public comment period for the Federal Facility
Agreement for Brunswick Naval Air Station; November 2, 1990.
13.
Press release regarding Brunswick citizens receiving a $50,000 federal grant for
a Superfund advisor; January 3, 1991. .
October 25, 1993
19
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Volwne 2:
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
14.
Fact sheet regarding the Sites 1 and 3 Proposed Plan, and the Eastern Plume
Proposed Plan; December 1991.
15.
Public notice announcing the public meetinglhearing and public comment period
for the Sites 1 and 3 Proposed Plan, and the Eastern Plume Proposed Plan;
December 1991.
16.
Press release regarding the signing of the Record of Decision for Sites 1 and 3
cleanup at Naval Air Station Brunswick; June 1992.
17.
Public notice announcing the public meetinglhearing and public comment period
for cleanup of the Perimeter Road Disposal Area [Site 8] at Naval Air Station
Brunswick; October 1992.
18.
Fact sheet regarding the Site 8 Proposed Plan; October 1992.
19.
Public notice announcing the public meetinglhearing and public comment period
for removal of Building 95 pesticide shop and surrounding soils; November
1992.
20.
Fact sheet regarding the proposed removal actions at Building 95; November
1992.
21.
Public notice announcing the public meetinglhearing and public comment period
for the revised Proposed Plan for Site 8 that now includes excavation; March
1993.
22.
Public notice announcing the public meetinglhearing and public comment period
for the Sites 5 and 6 Proposed Plan; March 1993.
23.
Fact sheet regarding the Proposed Plan for Sites 5, the Orion Street Asbestos
Disposal Site, and Site 6, the Sandy Road Rubble and Asbestos Disposal Site;
March 1993.
Technical Review Committee Meeting Minules (November 1987 to December 10,
1992).
1.
Meeting minutes of December 3, 1987, Technical Review Committee (TRC)
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.
3.
Memo to 'IRC members from Geoffrey Cullison, Naval Air Station, Brunswick,
regarding corrections to the January 11, 1988, meeting minutes; Febrwuy 3,
1988.
October 25, 1993
20
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NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
.
4.
Meeting minutes of May 17, 1988, 'IRC meeting to discuss the draft charter for
the 'IRC at Bnmswick and a review of the revised April 1988 RIfFS WOIK plan;
undated.
5.
Meeting minutes of July 8, 1988, 'IRC meeting to attend a site tour and to
confirm proposed locations; of field investigations, undated.
6.
Meeting minutes of November 22, 1988, 'IRC 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, 'IRC 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'IRC 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, 'IRC meeting minutes; Apri118, 1989.
10.
Letter to Senator William Cohen from E.B. Darsey, Department of the Navy,
Naval Air Station, Brunswick, regarding a copy of the requested 'IRC meeting
minutes, and the contact for the IRP program at the base; April 28, 1989.
11.
Meeting minutes of June 20, 1989, 'IRC meeting to discuss the Additional
Sampling Plan, the RIIFS program, and the schedule for its implementation;
July 11, 1989.
12.
Meeting minutes of August 10, 1989, 'IRC meeting to discuss the third round
of sampling; undated.
13.
Meeting minutes of February 13, 1990, 'IRC meeting to discuss the fourth
round of sampling; January 22, 1990.
14.
Letter to 'IRC members from James Shafer, Department of the Navy, Northern
Division, regarding the May 22, 1990, 'IRC 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 'IRC members from James Shafer, Department of the Navy, Northern
Division, regarding minutes from the September 13, 1990, 'IRC meeting;
October 31, 1990.
October 25, 1993
21
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. Volume 3:
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
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.
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 investigation at Swampy Road Debris site and Merriconeag Extension
Debris site; undated.
Technical Review Committee Meeting Minutes (March 1993 to September 1993)
Correspondence:
1.
Meeting minutes of March 18, 1993, TRC meeting to discuss the accelerated
schedule, undated.
2.
Meeting minutes of June 10, 1993, TRC meeting to discuss schedule update,
undated.
3.
Meeting minutes of September 23, 1993, TRC meeting to discuss schedule
update, undated.
SECTION 10: PROGRAM GUIDANCE
Volume 1:
Quality Assurance Program Plan, prepared by E.C. Jordan Co. [ABB
Environmental Services, Inc.]; February 1988 (all sites)
October 25, 1993
22
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NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
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
for Brunswick Naval Air Station; February 25, 1986.
3.
Letter to Naval Facilities Engineering Command, Northern Division, from L.K.
Jones, Naval Air Station Brunswick, regarding the Navy's assessment and
control of installation pollutants (NACIP) program and guidance involving
federal and state regulatory agency oversight; March 11, 1986.
4.
Letter to Commanding Officer, Naval Air Station Brunswick, from Commanding
Officer, Naval Facilities Engineering Command, Northern Division, regarding
federal and state environmental agencies oversight authority of the NACIP
program.; April 7, 1986.
5.
Letter to David Webster, USEPA, from K.J. Vasilik, Naval' Air Station
Brunswick, regarding the definition of the RIIFS 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.
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
Brunswick, and outlining the Navy's understanding of the responsibilities of the
various agencies involved in the RIIFS program; October 22, 1987.
8.
Letter to Charlotte Head, USEPA, from Kenneth Finkelstein, National Oceanic
and Atmospheric Administration, regarding the June 10, 1987, Trustee
Notification Form for Naval Air Station Brunswick; November 10, 1987.
9.
Letter to Charlotte Head, USEPA, from T.G. Sheckels, Department of the
Navy, Northern Division, regarding the listing of Naval Air Station Brunswick
on the NPL, 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
Division, from David Webster, USEPA, regarding the schedule to be published
by February 1988, a mechanism for delineating the roles and responsibilities of
October 25, 1993
23
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NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
the agencies, and the USEPA's concerns over the progress to date; November
20, 1987.
11.
Memo to Charlotte Head, USEPA, from Joan Coyle, USEPA Water 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,
Naval Facilities Engineering Command, Northern Division, from David
Webster, USEPA, regarding the definition of the commencement of the RIfFS
under the Comprehensive Environmental Response, Compensation, and liability
Act; December 17, 1987.
13.
Letter to Merrill Hohman, USEP A, from E.B. Darsey, Naval Air Station
Brunswick, regarding comments received at the February 10, 1988, mc
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 PIysunka, Maine DEP, regarding
comments on the Federal Facility Agreement; November 8, 1989.
17.
Letter to Meghan Cruise, USEPA, from Susan Weddle, mc 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 extension for review and
comment of [the 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, B.C. Jordan Co. [ABB Environmental Services, Inc.],
from R.L. Gillespie, Department of the 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, USEPA, regarding an amendment to the Federal Facility
Agreement; February 9, 1990.
October 25, 1993
24
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NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX
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.
23.
Letter to Ken Marriott, Naval Facilities Engineering Command, Northern
Division, from Meghan Cassidy, USEPA, regarding a request concurrence
between the agencies for an extension to the Remedial Investigation schedule;
March 12, 1990.
24.
Letter to Thomas Sheckels, 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, USEPA, from K.R. Marriott, Department of the
Navy, Northern Division, regarding an extension under the FF A 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
FF A 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.
29.
Letter to Cmdr. Ron Terry, Naval Air Station Brunswick, from Meghan
Cassidy, USEPA, regarding sampling of Mere Brook, April 23, 1992.
30.
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:
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 Final;
October 1988.
u.S. Environmental Protection Agency, 1988. "Engineering Evaluation! Cost
Analysis
October 25, 1993
25
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