Superfund Record of Decision Naval Air Station Brunswick Brunswick Maine Record of Decision for No Further Action at Sites 4 11 and 13 and a Remedial Action for the Eastern Plume

                                    EPA/ROD/R01-98/004
                                    1998
EPA Superfund
     Record of Decision:
     BRUNSWICK NAVAL AIR STATION
     EPA ID: ME8170022018
     OU05
     BRUNSWICK, ME
     02/10/1998

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EPA 541-R98-004
September 1998

                                  U.S. DEPARTMENT OF THE NAVY
                               INSTALLATION RESTORATION PROGRAM

                                   NAVAL AIR STATION BRUNSWICK
                                        BRUNSWICK, MAINE

                                       RECORD OF DECISION

                                      FOR NO FURTHER ACTION
                                      AT SITES 4,11, AND 13
                                                 AND
                                         A  REMEDIAL ACTION
                                      FOR THE EASTERN PLUME

                                            FEBRUARY 1998

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  U.S.  DEPARTMENT OF THE NAVY
INSTALLATION RESTORATION PROGRAM

   NAVAL AIR STATION BRUNSWICK
          BRUNSWICK, MAINE
          RECORD OF DECISION
        FOR NO FURTHER ACTION
        AT SITES 4, 11, AND 13
        AND A REMEDIAL ACTION
        FOR THE EASTERN PLUME
             Prepared for

      U.S.  Department of the Navy
           Northern Division
  Naval Facilities Engineering Command
   Contract No. N62472-91-C-1013
              Prepared by:

     ABB Environmental Services, Inc.
         Portland,  Maine 04112
          Project No. 9205-01

             FEBRUARY 1998

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TABIiE OF CONTENTS

Contents Page No.

DECLARATION 1

DECISION SUMMARY 5
I. SITE NAME, LOCATION, AND DESCRIPTION 5
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 9
A. LAND USE AND RESPONSE HISTORY 9
B. ENFORCEMENT HISTORY 10
III. COMMUNITY PARTICIPATION 12
IV. SCOPE AND ROLE OF RESPONSE ACTION 13
V. SUMMARY OF SITE CHARACTERISTICS 14
VI. SUMMARY OF SITE RISKS 22
A. HUMAN HEALTH RISK ASSESSMENT 22
B. ECOLOGICAL RISK ASSESSMENT 25
VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES 26
A. STATUTORY REQUIREMENTS/RESPONSE OBJECTIVES 26
B. TECHNOLOGY AND ALTERNATIVE DEVELOPMENT AND SCREENING 27
VIII. DESCRIPTION OF ALTERNATIVE 28
IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES 29
A. OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 29
B. COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS 29
C. LONG-TERM EFFECTIVENESS AND PERMANENCE 29
D. REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH TREATMENT 30
E . SHORT-TERM EFFECTIVENESS 30
F. IMPLEMENTABILITY 30
G. COST 31
H. STATE ACCEPTANCE 31
I. COMMUNITY ACCEPTANCE 31
X. THE SELECTED REMEDY 32
A. EASTERN PLUME GROUNDWATER 32
B. GROUNDWATER MONITORING 32
C . FIVE YEAR REVIEWS 34
D. COST 34
XI. STATUTORY DETERMINATIONS 35
A. THE SELECTED REMEDY IS PROTECTIVE OF HUMAN HEALTH AND THE ENVIRONMENT 35
B. THE SELECTED REMEDY ATTAINS ARARs 36
C. THE SELECTED REMEDIAL ACTION IS COST-EFFECTIVE 36
D. THE SELECTED REMEDY UTILIZES PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT OR
RESOURCE RECOVERY TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE 36
E. THE SELECTED REMEDY SATISFIES THE PREFERENCE FOR TREATMENT WHICH PERMANENTLY
AND SIGNIFICANTLY REDUCES THE TOXICITY, MOBILITY, OR VOLUME OF THE HAZARDOUS,
SUBSTANCES AS A PRINCIPAL ELEMENT 37
XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES 38
XIII. STATE ROLE 39

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REFERENCES

GLOSSARY OF ACRONYMS AND ABBREVIATIONS

APPENDICES

APPENDIX A-          RESPONSIVENESS SUMMARY AND PUBLIC MEETING TRANSCRIPT
APPENDIX B-          ARARs TABLES FOR EASTERN PLUME
APPENDIX C-          MEDEP LETTER OF CONCURRENCE
APPENDIX D-          ADMINISTRATIVE RECORD INDEX AND GUIDANCE DOCUMENTS
APPENDIX E-          COST ESTIMATE FOR THE SELECTED REMEDY

                                            LIST OF FIGURES

Figure                                                                                 Page No.

1 Site Location Map	6
2 Estimated Boundaries of Eastern  Plume	8
3 East-West Schematic of Eastern Plume Geology	19
4 North-South Schematic of Eastern Plume Geology	20

                                          LIST OF  TABLES
Table                                                                                Page No.

1 Comparison of Contaminants in Groundwater  (Eastern  Plume)  to Maximum Contaminant
  Levels and Maine Maximum Exposure Guidelines	24
2 Groundwater Remediation Goals	33

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                                                   DECLARATION

SITE NAME AND LOCATION

Naval Air Station  (NAS) Brunswick
Acid/Caustic Pit: Site 4;
Fire Training Area: Site 11;
Defense Reutilization and Marketing Office Area: Site 13; and
the Eastern Plume
Brunswick, Maine

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected final remedial action for the Eastern Plume and the no action
decision for Sites 4, 11, and 13 at NAS Brunswick. This decision document was developed in accordance with
the Comprehensive Environmental Response, Compensation, and Liability Act  (CERCLA) of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986, and to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan. Through this document, the Navy plans to remedy, by
hydraulic containment, recovery, and treatment, the threat to human health and the environment caused by
contaminated groundwater. The decision to select these remedial actions is based on information contained in
the Administrative Record for the site which was developed in accordance with Section 113(k) of CERCLA and is
available for public review at the information repositories located at the Public Works Office at NAS
Brunswick and the Curtis Memorial Library, 23 Pleasant Street, Brunswick, Maine.

The State of Maine Department of Environmental Protection (MEDEP) concurs with the selected remedy.

ASSESSMENT OF THE SITE

The Navy has determined that No Further Action is necessary for the soil at Sites 4, 11, and 13 since risk
estimates for direct contact and incidental ingestion exposure to site soil are below U.S.  Environmental
Protection Agency  (USEPA) and MEDEP target risk levels. Risks associated with the Eastern Plume, groundwater
that originated at Sites 4, 11, and 13, exceed the target risk levels. An interim remedial action consisting
of extraction, treatment, and discharge of the groundwater has been operating since 1995 to address
groundwater contamination.

Actual or threatened releases of hazardous substances from the Eastern Plume, if not addressed, may pose a
risk to human health and the environment. This risk will be addressed by continued operation of the
groundwater remedy outlined in the Eastern Plume Interim Record of Decision  (ROD) signed in June 1992, by
expanding the long-term groundwater monitoring program with additional monitoring wells in the vicinity of
Sites 4, 11, and 13, and by assessing the need for additional soil investigations at Site 4 in the event that
Building 584 should ever be demolished.

DESCRIPTION OF THE SELECTED REMEDY

The Navy and USEPA, with concurrence of MEDEP, have determined that No Further Action is necessary for soil
at Sites 4, 11, and 13 because the soil do not pose an unacceptable risk from direct contact or incidental
ingestion. The selected final remedy for the Eastern Plume (the groundwater associated with Sites 4, 11, and
13) is the same remedy that was implemented as an interim remedial action, and includes:

       •      operation of the groundwater extraction and treatment system installed in 1995;
       •      discharge of the treated water to the publicly-owned treatment works (Brunswick Sewer District)
              or returning the treated water to the aguifer  through an Infiltration gallery (this would
              reguire USEPA and MEDEP review and approval);
       •      long-term groundwater monitoring to evaluate the effectiveness of the extraction system and
              confirm that the source areas are not continuing to impact groundwater,  and
       •      five-year reviews.

This action addresses the threat of discharge of contaminated groundwater to surface water by containing the
Eastern Plume. The potential threat to human health is not an immediate threat because water from the
contaminated plume is not used as a drinking water supply.

STATUTORY DETERMINATIONS

The statutory reguirements of CERCLA Section 121 for remedial actions are not applicable to the No Further
Action decision for the source area soil at Sites 4, 11, and 13.

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For the Eastern Plume, the selected remedy meets the mandates of CERCLA Section 121. It protects human health
and the environment, complies with federal and state requirements that are legally applicable or relevant and
appropriate to the remedial action, and is cost-effective. The selected remedy uses permanent solutions and
alternative treatment or resource recovery technologies to the maximum extent practicable, and satisfies the
statutory preference for treatment that reduces toxicity, mobility, or volume as a principal element.

Because the Eastern Plume remedy will result in hazardous substances remaining on-site in groundwater above
health-based cleanup levels, a review will be conducted by the Navy, the USEPA, and the MEDEP at intervals
not to exceed every five years to ensure that the remedy continues to provide adequate protection of human
health and the environment. This review will evaluate both the effectiveness of the groundwater extraction
system and the appropriateness of the No Further Action decision for Sites 4, 11, and 13.

DECLARATION

This ROD represents No Further Action for source area soil at Sites 4, 11, and 13, and the selection of a
final remedial action under CERCLA for the Eastern Plume. The foregoing represents the selection of a
remedial action by the Department of the Navy, and the U.S. Environmental Protection Agency Region I, with
concurrence of the Maine Department of Environmental Protection.

Concur and recommend for immediate implementation:

Department of the Navy

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DECISION SUMMARY

I. SITE NAME, LOCATION, AND DESCRIPTION

The U.S. Naval Air Station (NAS) Brunswick is located in Brunswick, Maine. In 1987, NAS Brunswick was placed
on the National Priorities List (NPL). There are currently 16 areas (Sites) within NAS Brunswick that have
been investigated. This Record of Decision (ROD) relates to the No Further Action decision for source area
soil at Sites 4, 11, and 13, and the final remedial action for the groundwater contamination within the
Eastern Plume.

NAS Brunswick is located south of the Androscoggin River between Brunswick and Bath, Maine, south of Route I
and between Routes 24 and 123 (Figure 1). Undisturbed topography at NAS Brunswick is characterized by low,
undulating hills with deeply incised brooks; ground surface elevations range from mean sea level (MSL) in
lowland drainage areas and the Harpswell Cove estuary, to over 110 feet MSL west and southeast of the
southern end of the runways. Topography in the developed areas of the base has been modified by construction,
with ground surface elevations generally ranging from 50 to 75 feet above MSL.

NAS Brunswick is located on 3,094 acres. The operations area (138 acres) lies east of the two parallel
runways and consists of numerous office buildings, a steam plant, fuel farm, barracks, recreational
facilities, base housing, hangars, repair shops, and other facilities to support NAS Brunswick aircraft.
Forested areas (approximately 48 percent), grasslands (approximately 28 percent), and paved areas
(approximately 12 percent) comprise most of the base property. Paved areas are mostly flight ramps and
runways. The remaining 12 percent of the base includes the operations area (approximately 5 percent) and
miscellaneous shrubland, marsh, and open water. The southern edge of the base borders the estuary of
Harpswell Cove.

Property uses surrounding NAS Brunswick are primarily suburban and rural residential, with some commercial
and light industrial uses along Routes 1, 24, and 123. An elementary school, a college, and a hospital are
located within 1 mile of the western base boundary.

Sites 4, 11, and 13 are all located within several hundred feet of each other off Old Gurnet Road between the
intersection of Orion Street and Sandy Road (see Figure 1). Site 4, the Acid/Caustic Pit, is under the
eastern portion of Building 584. The pit was used from 1969 to 1974 for the disposal of liguid wastes The
wastes were poured into the pit, which was approximately 4 feet sguare and 3 feet deep.

Site 11 is a former Fire Training Area (FTA) that was used regularly over a 30-year period but has not been
used since the fall of 1990. Waste liguids (fuels, oils, degreasing, solvents) were used as fuel for the fire
training exercises.

Site 13 is the Defense Reutilization and Marketing Office (DRMO) Area immediately south of Building 584 and
Site 4. Site 13 consisted of three underground storage tanks: one for diesel fuel, the other two for storing
waste fuels, oils and degreasing solvent. All three tanks were removed in the late 1980s. The diesel tank was
replaced with a fiberglass underground storage tank; however, this tank was subseguently removed and replaced
with an above-ground tank.

The Eastern Plume is the groundwater contamination resulting from Sites 4, 11, and 13. The 1990 estimated
boundaries of the Eastern Plume groundwater contamination and current boundaries exceeding federal maximum
contaminant levels (MCLs) or State of Maine maximum exposure guidelines (MEGs) are shown on Figure 2. The
boundaries of the exceedances are based on the current distribution of the monitoring wells and may not be
the actual distribution of contamination. The installation of additional monitoring wells based on a
reevaluation of the monitoring network could modify the areas inferred to be above the State MEGs/federal MCL
groundwater concentrations. Groundwater in the area of the plume is not currently used for drinking water or
other purposes, therefore, there are no human receptors. The likely future discharge point of the plume was
projected to be Harpswell Cove, potentially affecting many ecological receptors. Because the Navy has
implemented a groundwater extraction and treatment system, the plume is no longer expected to reach Harpswell
Cove. The contamination of groundwater in the Eastern Plume has not affected the current use of natural
resources. Use of groundwater and surface water in this area is very limited; however, the presence of
contaminated groundwater does prevent the use of this natural resource in the future.

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II. LAND USE AND RESPONSE HISTORY

NAS Brunswick is an active facility supporting the U.S. Navy's antisubmarine warfare operations in the
Atlantic Ocean and Mediterranean Sea. The bases 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 4, 11, and 13 at NAS Brunswick are believed to be past contributors to groundwater contamination in the
Eastern Plume. Site 4, the Acid/Caustic Pit, was used from 1969 to 1974 for the disposal of liguid wastes.
The wastes were poured into the pit, which was approximately 4 feet sguare and 3 feet deep. The actual
location of the former disposal pit could not be sampled because a structure (Building 584) was constructed
at that location in approximately 1975. However, investigations showed that subsurface soil around Site 4 did
not contain detectable concentrations of volatile organic compounds (VOCs), and only one of the six
groundwater monitoring wells at Site 4 contained detectable levels of VOCs (trichloroethylene [TCE] in MW-405
at concentrations ranging from non-detectable to 26 micrograms per liter [Ig/L]). Based on these results, it
is believed that Site 4 no longer contributes to groundwater contamination in the Eastern Plume. In the event
that Building 584 is ever demolished, the Navy, in consultation with the U.S. Environmental Protection Agency
(USEPA), Maine Department of Environmental Protection (MEDEP), and the public, will assess the need for
additional soil sampling at Site 4.

Site 11 is a former Fire Training Area that was used regularly over a 30-year period until it was closed in
the fall of 1990. Waste liguids including fuels, oils, and degreasing solvents were used as fall for the fire
training exercises. The most prevalent contaminants in groundwater (i.e., 1,1,1-trichloroethane [TCA] and
TCE) are consistent with the wastes used at the Fire Training Area, soil from the ground surface down to the
groundwater table also contained these contaminant, however, the Navy removed these soil from Site 11 in two
separate removal actions. This eliminated the direct exposure risks (i.e., dermal contact, inhalation, and
ingestion). There is the potential that contaminated soil still exist below the groundwater table, with a
continuing impact to groundwater. The groundwater exposure pathway will be assessed under the groundwater
monitoring program and additional groundwater investigation at Site 11.

Site 13, the DRMO Area, consisted of three underground storage tanks located south of Site 4. One tank was
used for diesel fuel. The other tanks reportedly were used for storage of waste fuels, oils, and degreasing
solvents (R.F. Weston, Inc., 1983). All three tanks were removed during the late 1980s. Groundwater sampling
downgradient of Site 13 has shown decreasing VOC contamination since removal of the tanks. The most recent
groundwater samples from this area contained only low levels of contamination, indicating that Site 13 is no
longer acting as a source of contamination for the Eastern Plume.

A more detailed description of the history of Sites 4, 11, and 13 can be found in the Draft Final RI Report
in Subsections 8.1, 12.1, and 13.1 (E.G. Jordan Co., 1990b).

B. ENFORCEMENT HISTORY

The Navy's cleanup of hazardous wastes at NAS Brunswick falls under the Navy's Installation Restoration
Program (IRP) and meets the reguirements of the Comprehensive Environmental Response, Compensation and
Liability Act and the Superfund Amendments and Reauthorization Act (CERCLA) . The program was conducted in
several stages:

• In 1983, an Initial Assessment Study (IAS) detailed historical hazardous material usage and
waste disposal practices at NAS Brunswick.

• In 1984, a Pollution Abatement Confirmation Study was conducted. These studies recommended
further investigation of seven of the nine hazardous waste sites originally identified.

In 1987, NAS Brunswick was placed on the USEPA's NPL.

• The Remedial Investigation/Feasibility Study (RIFS) process began in 1987 for seven sites.

• In February 1988, the first Technical Review Committee (TRQ meeting was held. The TRC meetings
(now known as the Restoration Advisory Board [RAB] meetings) have been held guarterly since
that initial meeting.

• Two sites were added to the RI/FS program in 1989, as well as the two additional sites
originally identified in the IAS.

• Two other sites were added to the program in 1990.
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In October 1990, the Navy entered into a Federal Facility Agreement (FFA) with the USEPA and
MEDEP regarding the cleanup of environmental contamination at NAS Brunswick. The FFA sets forth
the roles and responsibilities of each agency, contains deadlines for the investigation and
cleanup of hazardous waste sites, and establishes a mechanism to resolve disputes among the
agencies.

In August 1990, the Navy completed Draft Final RI and Phase I FS Reports (E.G. Jordan Co.,
1990b and 1990c). The RI described field sampling investigations, geology, and hydrogeology,
and presented contamination and risk assessments. The Phase I FS identified remedial action
objectives, and developed and screened remedial alternatives for the nine original sites
studied in the Draft Final RI.

• The Navy submitted a Draft Final Supplemental RI report for an additional four sites in August
1991. The report also contained additional field sampling results for Site 11 and the Eastern
Plume.

Each of the stages and documents listed above pertain to Sites 4, 11, and 13 and the Eastern Plume.
Information on many of the other sites at NAS Brunswick is also included in these reports.

Because the Navy is committed to providing a timely response to environmental contamination at NAS Brunswick,
a strategy was developed to expedite the RI/FS process. This strategy involved identifying the sites for
which enough information currently existed to proceed to the ROD and design phases of the process. Separate
timetables were established for completing the Final FS reports and RODs for those sites. The Navy identified
the groundwater associated with Sites 4, 11, and 13 (i.e., the Eastern Plume) as a distinct area of
contamination and initiated the remedial process in 1992 by signing an Interim ROD for the Eastern Plume
(NAVY, 1992). The interim remedial action was intended to control and prevent further migration of
contaminated groundwater toward Harpswell Cove and to begin reducing the amount of contamination within the
Eastern Plume.

Because the RI/FS concluded that Sites 4, 11, and 13 did not pose unacceptable direct-contact risks, and that
only Site 11 posed a potential continuing risk of impact to groundwater, the Navy postponed a final decision
for Sites 4, 11, and 13 to a later date.

III. COMMUNITY PARTICIPATION

Throughout the sites' investigative and remediation history, the community has been active and involved in
the IRP at NAS Brunswick. Community members and other interested parties have been informed of site
activities through informational meetings, fact sheets, press releases, public meetings, TRC meetings, and
RAB meetings.

In September 1988, the Navy released a Community Relations Plan outlining a program to address public
concerns and keep citizens informed about and involved in remedial activities. On August 16, 1990, the Navy
held an informational meeting at the Jordan Acres School in Brunswick to discuss the results of the RI.

In August 1987, the Navy established an information repository for public review of site related documents at
the Curtis Memorial Library in Brunswick. On October 8, 1996, the Navy placed the Proposed Plan detailing the
Preferred Alternative for Sites 4, 11, and 13 in the information repository at the Curtis Memorial Library
(ABB-ES, 1996). The Administrative Record for Sites 4, 11, and 13, and the Eastern Plume is available for
public review at NAS Brunswick in the Public Works office and at the Curtis Memorial Library. A notice and
brief analysis of the Proposed Plan was published in the local newspaper, The Times Record, on October 11,
1996.

From October 11 to November 9, 1996, the Navy held a 30-day public comment period to accept public input on
the alternatives presented in the Proposed Plan. On October 17, 1996, the Navy and regulatory representatives
held an informational public meeting to discuss the Proposed Plan for Sites 4, 11, and 13. A transcript of
this meeting and the Responsiveness Summary is included as Appendix A. The Navy received several verbal
comments on the Sites 4, 11, and 13 Proposed Plan at the public meeting. These are discussed in the
Responsiveness Summary. No written comments were received by the Navy during the 30-day public comment
period.

From 1988 until July 1995, the TRC was an important vehicle for community participation. In July 1995, the
TRC became known as a RAB whose membership includes the Navy, USEPA, MEDEP, and various community
representatives. The community members of the RAB include representatives from Brunswick, Harpswell, and
Topsham as well as the Brunswick Area Citizens for a Safe Environment, who became active participants
subseguent to 1988. The RAB also has representatives from the Brunswick-Topsham Water District. The RAB meets
guarterly, reviews the technical aspects of the program, and provides community input to the program.
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IV. SCOPE AND ROIiE OF RESPONSE ACTION

The Navy has determined that No Further Action under CERCLA is appropriate for soil at Sites 4, 11, and 13,
and that continued operation of the groundwater extraction and treatment system, discharge of treated water
to the Publicly Owned Treatment Works (POTW) , and groundwater monitoring are the appropriate actions for the
Eastern Plume. An additional option that will be pursued is the discharge of the treated water to the
groundwater. This will reguire USEPA and MEDEP review and approval.

The No Further Action decision for Sites 4, 11, and 13 is based on the FS which concluded that the only risk
at these sites was for the potential of continuing impacts to groundwater from soil at Site 11. Removal
actions completed at Site 11 since the FS included excavation of metallic debris, drums, and contaminated
soil. The metallic debris and drums were disposed off-base (Halliburton NUS, 1995), and the soil were used as
sub-grade fill beneath the Sites 1 and 3 landfill cover (OHM 1996). Because the CERCLA contaminants have been
removed to acceptable risk levels or are at levels that do not pose a risk, No Further Action is reguired for
soil at Sites 4, 11, and 13. The No Further Action decision can be revisited if future conditions indicate
that an unacceptable risk to human health or the environment would result from exposure to contaminants at
these sites or there is a change in land use. However, while the direct contact pathways have been
eliminated, there may be residual contamination in the subsurface soil contributing to the Eastern Plume. The
No Further Action decision for Site 11 may be revisited if groundwater monitoring or further investigation
shows the soil below the water table are a continuing source of contamination to the Eastern Plume. Also, if
Building 584 is removed, the Navy, with input from USEPA, MEDEP and the public, will evaluate whether
additional investigations are appropriate.

The selected remedy for contaminated groundwater associated with these sites, the Eastern Plume, is
extraction, treatment, and discharge as outlined in the Eastern Plume Interim ROD (NAVY, 1992). The interim
action was intended to control and prevent further migration of contaminated groundwater off NAS Brunswick
property and to reduce the contaminant concentrations until the final remedy was chosen. A long-term
monitoring program was included in the interim action to assess the effectiveness of the groundwater
extraction system. The monitoring program will also continue, and will be modified as necessary to ensure
proper coverage of the Eastern Plume area.

V. SUMMARY OF SITE CHARACTERISTICS

Site 4 (the Acid/Caustic Pit), Site 11 (FTA) , and Site 13 (the DRMO Area) are all located within several
hundred feet of each other off Old Gurnet Road between the intersection of Orion Street and Sandy Road (see
Figure 1). Based on RI results, the Navy combined these sites to address both source (e.g., soil) and
groundwater contamination. The results and discussions presented in the RI and the risk assessment indicate
similar contaminants at the three sites including VOCs such as tetrachloroethylene (PCE) and TCE in soil and
groundwater (E.G. Jordan Co., 1990b). Groundwater is the medium most impacted by past disposal activities at
these sites.

The area of contaminated groundwater associated with these three sites has been studied and reported in the
Draft Final Supplemental RI Report (E.G. Jordan Co., 1991). The region of contaminated groundwater has been
designated as the Eastern Plume. The Navy identified the Eastern Plume for expedited remediation and
initiated an interim action for groundwater remediation, postponing a source control decision for Sites 4,
11, and 13 until a later time.

Because the magnitude and distribution of contamination differs at and downgradient of these sites, each is
discussed separately in this section. A more detailed discussion of the site history, geology, hydrogeology,
risk, and contamination is in the Draft Final RI and Draft Final Supplemental RI reports (E. C. Jordan Co.,
1990b and 1991, respectively).

Acid/Caustic Pit: Site 4. The potential source for Site 4 contamination was believed to be the Acid/Caustic
Pit currently located under the eastern portion of Building 584 (R.F. Weston, Inc., 1983). The Acid/Caustic
Pit was used from 1969 to 1974 for the disposal of liguid wastes. The wastes were poured into the pit, which
was approximately 4 feet long by 4 feet wide and 3 feet deep. To evaluate the presence and extent of
potential contamination associated with the Acid/Caustic Pit, a soil gas survey was conducted, and subsurface
soil and groundwater were sampled and analyzed for Target Compound List (TCL) organic and Target Analyte List
inorganic compounds.

Halocarbon soil gases were detected in locations near Building 584, but below detection levels in all other
samples. Similarly, VOC contamination in groundwater is restricted to low levels of TCE in one monitoring
well adjacent to Building 584. The TCE results are consistent with soil gas data collected in the same area
as the monitoring well. Subsurface soil adjacent to Building 584 at Site 4 did not contain detectable
guantities of VOCs; however, subsurface soil samples were not collected directly from the suspected pit
location due to the presence of Building 584 at that location. If this building is ever removed, further
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investigations and remedial actions may be required.

Groundwater contamination was not detected in monitoring wells at Site 4 except for monitoring well (MW)
MW-405 where 6 to 23 mg/L of TCE was reported in two of the four sampling rounds (E.G. Jordan Co., 1990b).
The federal MCL for TCE is 5 Ig/L and the State of Maine MEG is 3 Ig/L. There are several wells downgradient
of Building 584 (and MW-405) that do not have solvent contamination. These observations suggest that only low
concentrations of TCE are present at or near the source, and that these low levels are diluted to values
below detection downgradient of the building. Additional groundwater sampling in this area to confirm these
findings will be incorporated into the long-term groundwater monitoring program.

Air monitoring was not performed within Building 584, but air blanks taken outside of the building did not
detect VOCs (E.G. Jordan Co., 1990b). Outdoor monitoring was proposed in the RI/FS Work Plan that was
approved by the USEPA, and was done to characterize the ambient air at Site 4. Indoor monitoring was never
proposed or required by the USEPA or MEDEP, and was not considered by the Navy due to the low level of
detected soil and groundwater contamination.

FTA: Site 11. Site 11, the FTA, was added to the list of sites under investigation in 1989. Three sampling
rounds (Rounds IV and V and the Post-Screening Work Plan) have been conducted at Site 11 including monitoring
wells, test pits, and soil and groundwater screening. The FTA was used regularly for approximately 30 years,
but was closed in the Fall of 1990.

Environmental contamination was found in subsurface soil and groundwater at Site 11. Apparently, the site was
contaminated during fire training exercises as the detected compounds are consistent with that practice. The
IAS reports the use of waste liquids as fuel for the fire training exercises (R.F. Weston, Inc., 1983). The
waste liquids identified in the study include
fuels, oils, and degreasing solvents.

Results from sampling surface and shallow soil identified VOCs, semivolatile organic compounds (SVOCs), and
inorganics-1 VOCs and lead were reported in the groundwater immediately downgradient of Site 11 (E.G. Jordan
Co., 1990a, 1990b, and 1991). Interpretive groundwater flow directions at Site 11 indicate potential flow to
the northeast, east, and southeast. Additional data were collected from Site 11 during the Post-Screening
Work Plan to further characterize the extent of soil and groundwater contamination.

Test pit excavation and subsurface soil sampling demonstrated the presence of VOCs and SVOCs in shallow soil,
and VOCs in deeper soil. No samples were collected from beneath the fire training pit during the RI due to
the presence of the concrete pad. Calculations were used to assess the potential for contamination beneath
the pad. These calculations estimated that concentrations of TCE in soils beneath the concrete pad may be on
the order of 16 milligrams; per kilogram (mg/kg) . For the other contaminants, 1, 1-dichloroethane (DCA) ,
1,2-dichloroethylene (1,2-DCE), TCA, and PCE, the estimated concentrations were 16, 794, 693, and greater
than 50 micrograms per kilogram (Ig/kg), respectively.

Based on these samples, a 50-by-100 foot area of soil contamination extending from the southern end of the
fire training pit, north to the location of hallow-stem auger HA-1102, was assumed. It was also assumed that
contamination extended to the groundwater table approximately 10 feet below ground surface (bgs). However,
because the primary contaminants are dense non-aqueous phase liquids (DNAPL), there is a potential for
residual contaminants to remain at depth.

The VOC and lead contamination in groundwater previously identified at Site 11 was confirmed by resampling
MW-1103. To evaluate potential deeper groundwater contamination at Site 11, a monitoring well was installed
below MW-1103 above the clay layer (MW-304). Groundwater sampling results demonstrated that concentrations of
total TCL VOCs increased in MW-1103, a shallow well, from 500 to 2,900 mg/L over the period from fall 1989 to
fall 1990, and low levels of total VOCs (18 mg/L) were reported in the deeper groundwater. (MW-304). This
increase in VOCs was also correlated with a 2-foot increase in water level, and groundwater upgradient of
Site 11 did not contain VOC contamination. These observations indicated that the source of groundwater
contamination at Site 11 was the contaminated soil at the site. The correlation of increasing water level
with increasing groundwater contamination observed at Site 11 amplified that the capillary fringe region of
the subsurface soil acted as a source of groundwater contamination (E.G. Jordan Co., 1991). However, because
the primary contaminants are DNAPLs, there is a potential for residual contaminants to remain at depth. The
capillary fringe in sandy soil is typically 1 to 3 feet thick. When groundwater levels were low, less of the
capillary fringe was in contact with groundwater and the concentration of VOCs was lower. When groundwater
was at higher elevations, more of the capillary fringe zone of contamination was in contact with groundwater
and VOC concentrations were higher.

The Navy has implemented two removal actions at Site 11 since completion of the RI. The first, completed in
December 1994, consisted of the excavation and removal of buried drums and metallic debris from several
locations around the site (Halliburton NUS Corporation, 1995). The second was completed in June 1995, and
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included the removal of the concrete pad and approximately six to ten feet of soil from the 0.5-acre site
(OHM 1996). This material was placed under the landfill cap that was being constructed at Sites 1 and 3.
Samples were collected from the bottom of the excavation area to document the condition of the soil left in
place. Analytical results showed that TCA ranged from non-detect to 6.5 mg/kg TCE ranged from not-detect to
5.3 mg/kg, and PCE ranged from non-detect to 1.4 mg/kg, TCE ranged at Site 11 was then filled with clean soil
and planted with grass.

DRMO Area: Site 13. The DRMO Area is immediately south of Building 584 and Site 4. Originally, these two
sites were considered the same; however, additional sampling and the identification of underground storage
tanks (USTs) warranted separation of the two.

Environmental contamination detected at Site 13 during the RI program was observed in shallow soil,
subsurface soil, and groundwater. Dichlorodiphenyltrichloroethane (DDT) was detected in several surface and
shallow soil samples from test pits at relatively low (e.g., less than 0.02 mg/kg) concentrations, and is
probably related to historic use of DDT in this area.

Fuel-related SVOCs (i.e., naphthalene and 2-methylnaphthalene) were detected in the subsurface soil at one
monitoring well location. A visible sheen and odor were noticed on the soil above the water table and on
drilling eguipment at this location. The soil contamination is believed related to an old diesel UST.
However, fuel-related contamination was not detected in groundwater from this monitoring well. The diesel UST
was removed in the late 1980s and replaced with a fiberglass UST. The fiberglass UST was subseguently removed
and replaced with an above-ground tank.

Site 13 groundwater contamination in the area next to the DRMO is restricted to VOCs. Groundwater flow
direction in the Site 13 area is to the southeast, and the contaminated groundwater was detected downgradient
of three former UST locations. Two 5,000-gallon tanks were located on the southern side and one 10,000-gallon
tank was on the southeastern side of the DRMO. These USTs were used to store waste fuels, oils, and
degreasing solvents, as well as the diesel fuel referred to above (R.F. Weston, Inc., 1983). The two USTs on
the southern side of Site 13 were removed in the late 1980s; the UST on the southeastern side of the DRMO was
removed in October 1989. Soil were not removed with the USTs.

Monitoring wells directly downgradient of the UST locations on the southeastern and southern sides of Site 13
(MW-GZA3 and MW-1303) have shown decreasing VOC contamination through time. MW-GZA3 is downgradient of the
southwestern USTs removed in 1986. Before removal of the eastern UST, levels of 1,2-DCE exceeded 700 mg/L in
MW- 1303. Groundwater sampling at MW-1303 after the UST was removed demonstrated that 1,2-DCE levels had
decreased to 63 mg/L. These data indicate that the decrease in VOC concentrations is a result of the UST
removals.

Eastern Plume. The contaminated groundwater downgradient of Sites 4, 11, and 13 is referred to as the Eastern
Plume. The distribution of contaminants within this plume was determined by sampling monitoring wells and
piezometric cone penetrometer testing sampling. Based on the sampling results, an area of VOC-contaminated
groundwater was identified northeast, east, and southeast of Sites 4, 11, and 13. Total VOC concentrations
within the Eastern Plume vary from low levels near the plume boundary, to concentrations as high as 12,000
mg/L within the plume. Groundwater contamination has not been observed in bedrock monitoring wells within the
plume boundary or east of the plume.

Groundwater flow at the site occurs within an unconfined to semi-confined aguifer system composed primarily
of transitional stratified silty sands and coarse sands. These transitional soil overlay a glacio-marine,
clay considered to be an underlying aguitard to the shallow groundwater flow system. The clay unit ranges
from about 20 to 60 feet thick, and is found throughout most of the Eastern Plume area. Tlhe transitional
soil are separated into an upper stratified sandy silt unit and a lower coarse sand unit. Schematic
depictions of the geology of the Eastern Plume area in east-west and north-south orientations are shown in
Figures 3 and 4, respectively.

In general, VOCs occur within the lower coarse sand unit. Groundwater flow is generally to the southeast at
the site, although radial flow away from the source areas also occurs. Groundwater flow is largely influenced
by Mere Brook and Merriconeag Stream. Average hydraulic conductivities at the site range from 9.4 feet per
day (ft/day) for the coarse sands, 0.5 ft/day in the stratified silts, and 0.11 ft/day for the stream bottom
sediments. Groundwater seepage velocities range from 1,200 feet per year (ft/yr) in the vicinity of the
source areas to 85 ft/yr in the vicinity of the clay trough area. Downward vertical gradients exist near the
source areas with upward gradients generally present throughout the remaining portions of the site. See the
Draft Final Supplemental RI Report (E.G. Jordan Co., 1991) for addition discussion and data.
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Groundwater monitoring is underway which monitors the plume boundaries. To date, no evidence of contamination
from the Eastern Plume has been found in any surface water bodies. The ultimate discharge zone for the
contaminated groundwater has been predicted to be to local surface water. Although the affected portion of
the aguifer is not currently being used, the groundwater is a potential drinking water source. The
groundwater monitoring plan will track changes in contamination concentrations and potential migration. A
more detailed discussion of the hydrology and contaminant distribution in the Eastern Plume is in the Draft
Final Supplemental RI (E.G. Jordan Co., 1991).

A risk assessment was performed to estimate the probability and magnitude of potential adverse human health
and environmental effects from exposure to contaminants associated with the Sites 4, 11, and 13. The risk
assessment followed a four step process:

1) contaminant identification identified those hazardous substances that, given the specifics of the
site, were of significant concern;

2) exposure assessment identified current or future potential exposure pathways, characterized the
potentially exposed populations, and determined the extent of possible exposure;

3) toxicity assessment considered the types and magnitude of adverse health effects associated with
exposure to hazardous substances; and

4) risk characterization integrated the three previous steps to summarize the potential and actual
carcinogenic and non-carcinogenic risks posed by hazardous substances at the site.

Carcinogenic and noncarcinogenic risks are guantitatively evaluated for each site. Carcinogenic risks are
compared to the USEPA target carcinogenic risk range of 1x10 -4 to 1x10 -6, and to the NEDEP maximum
acceptable incremental lifetime carcinogenic risk of 1x10 -5. Noncarcinogenic risks are compared to the USEPA
noncarcinogenic Hazard Index (HI)of 1.0 (USEPA, 1989b).

A. HUMAN HEALTH RISK ASSESSMENT

Human health risks associated with contaminant exposure at Sites 4, 11, and 13 and the Eastern Plume were
estimated based on analytical data collected during Sampling Rounds I through IV, and are presented in
Appendix Q of the Draft Final RI (E.G. Jordan Co., 1990b). Analytical data collected during the
Post-Screening Work Plan were reviewed and additional risk estimates calculated for exposure to contaminated
soil at Site 11. The groundwater data collected as part of the Post-Screening Work Plan were consistent with
earlier data and additional risk calculations were not considered necessary. No additional contaminants of
concern or routes of exposure were identified. These data are presented in the Draft Final Supplemental RI
report (E. C. Jordan Co., 1991).

The baseline risk assessment identified ingestion of groundwater as the route of exposure associated with a
human health risk. VOCs were detected in the Eastern Plume at concentrations exceeding drinking water
standards (e.g., MCLs and MEGs) and health-based criteria (e.g., maximum contaminant level goals and
Reference Doses). Although groundwater in the Eastern Plume is not currently used for potable purposes, human
health risks associated with exposure to groundwater were considered. The contaminants of concern in
groundwater include 1,1-dichloroethylene (1,1-DCE), DCA, 1,2-DCE, TCA, TCE, and PCE. These contaminants, and
their respective MCLs and MEGs, are listed in Table 1. Benzene, lead, and cadmium were eliminated as
contaminants of concern based on their low concentrations and freguency of detection. This rationale is
consistent with USEPA guidance for selecting contaminants of concern (USEPA, 1989a and b). The decrease in
concentrations observed in the wells immediately downgradient of Site 13 may be attributed to the removal of
the USTs.

Risks associated with exposure to contaminants through direct contact and ingestion of soil were evaluated
separately for Sites 4, 11, and 13. These risk estimates are presented in Appendix Q of the Draft Final RI
and the Supplemental RI reports (E.G. Jordan Co., 1990b and 1991). Minimal health risks were associated with
exposure to surface soil at Sites 4 and 13. The area of potential contamination at Site 4 is located beneath
the eastern portion of Building 584, effectively limiting any potential exposure. Contamination in surface
soil at Site 13 was limited to DDT. However, the maximum detected concentration (i.e., 0.02 mg/kg) of this
compound is below levels considered to present a health risk (direct contact and incidental ingestion
exposure). The guantitative risk estimates calculated for Site 13 (residual scenario) range from 3 x 10 -9 to
6 x 10 -10 for incremental carcinogenic risks and 0.00005 to 0.000003 for noncarcinogenic His. These risk
estimates are well below the USEPA target risk range (10 -4 to 10 -6) and the MEDEP maximum incremental risk
(10 -5) for carcinogenic risks, and an HI of 1.0 for noncarcinogenic risks (Appendix Q, Draft Final RI).

Additional soil samples were collected at Site 11 during the Post-Screening Work Plan to better delineate the
distribution of contamination in the source area. Analytical results indicated that surface soil
contamination (i.e., down to 1 foot bgs) was limited to one test pit location (i.e., TP-1106). SVOCs and
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inorganic metals were the only contaminants detected in this sample. The polynuclear aromatic hydrocarbon
(PAH) compounds fluoranthene, benzo(b)fluoranthene and benzo(k)fluoranthene were detected at a total
concentration of 2.8 mg/kg. The sum of benzo(b)fluoranthene and benzo(k)fluoranthene (probable carcinogenic
PAHs) concentrations was 1.8 mg/kg. Human health risks were estimated based on exposure to the maximum
detected PAH concentration. These compounds were considered contaminants of concern. No VOCs were detected in
surface soil at Site 11. The distribution of contamination at Site 11 was similar to those observed at fire
training areas at other military installations. This distribution is characterized by minimal surface soil
contamination with much greater contamination in deeper soils. The noncarcinogenic HI was less than 1.0. The
lifetime incremental carcinogenic risk for direct contact and incidental ingestion exposure was 6.7 xlO -5.
The carcinogenic risk estimate fell within the USEPA target risk range of 10 -4 to 10 -6, but slightly
exceeded the MEDEP maximum acceptable risk of 1x10 -5.

B. ECOLOGICAL RISK ASSESSMENT

An ecological risk assessment evaluated the potential risks to terrestrial organisms from contaminant
exposure at Sites 4, 11, and 13 (E. C. Jordan Co., 1990b). Since sampling from both the remedial
investigation and the current long-term monitoring program has determined that the Eastern Plume has not
migrated beyond the most downgradient wells (i.e., MW-230A, MW-231A&B, MW-318) , exposure to aguatic receptors
in Harpswell Cove has not been evaluated. If the Eastern Plume does migrate and discharge to surface water,
potential exposure may result. If it appears that the plume has migrated beyond the most downgradient points,
the Navy will institute additional downgradient monitoring wells and/or conduct monitoring in surface water.

The ecological risk assessment evaluated the risks to terrestrial receptors from soil contaminant exposure.
As discussed, relatively low concentrations (e.g., 0.02 mg/kg of DDT and 1.8 mg/kg of PAHs) of surface soil
contamination have been detected at these sites. The risk assessment concluded that exposure to soil
contaminants by terrestrial receptors appears minimal (E.G. Jordan Co., 1990b). Therefore, no remedial
response action objectives were developed.

VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES

Since Sites 4, 11, and 13 reguire no further action under CERCLA, this section applies only to the Eastern
Plume. Additional groundwater remediation alternatives were not developed because alternatives for the
Eastern Plume were developed in the Feasibility Study prior to the issuance of the ROD. Since the issuance of
the Interim ROD, existing data no longer indicate Sites 4, 11, and 13 are major source areas of the Eastern
Plume. Therefore, it was unnecessary to reopen the FS or to develop additional alternatives.

A. STATUTORY REQUIREMENTS/RESPONSE OBJECTIVES

The primary goal at NPL and similar sites is to undertake remedial actions that are protective of human
health and the environment. Sections 120 and 121 of CERCLA establish several statutory reguirements and
preferences, including: a reguirement that the remedial action, when complete, must comply with all federal
and more stringent state environmental standards, reguirements, criteria or limitations, unless a waiver is
invoked; a reguirement that the remedial action is cost-effective and uses permanent solutions and
alternative treatment technologies or resource recovery technologies to the maximum extent practicable; and a
preference for remedies that include treatment to permanently and significantly reduce the toxicity,
mobility, or volume of hazardous substances as a principal element over remedies not involving such
treatment. Response alternatives were developed to be consistent with these congressional mandates.
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TABIiE 1
COMPARISON OF CONTAMINANTS IN GROUNDWATER (EASTERN PLUME)
TO MAXIMUM CONTAMINANT LEVELS
AND MAINE MAXIMUM EXPOSURE GUIDELINES

SITES 4, 11, 13, AND EASTERN PLUME ROD
NAS BRUNSWICK

RANGE OF CONCENTRATIONS DETECTED

SHALLOW WELLS DEEP WELLS FEDERAL STATE
(NEAR SOURCE) (DOWNGRADIENT) MCLs MEGs
COMPOUND (ppb) (ppb) (ppb) (ppb)

1,1-DCE ND-6 ND-1,810 7 7

1,1-DCA ND-130 ND-170 - 5(70**)

cis-l,2-DCE 63-680* ND-98* 70 70

trans-l,2-DCE * * 100 70

1,1,1-TCA 13-1,200 11-11,000 200 200

TCE 5-770 6-2,800 5 5

PCE ND-42 ND-68 5 3

Notes:

* Dichloroethene was reported by the laboratory as total (i.e., the distinction between cis-
and trans- was not determined).
** revised MEG recommended by State of Maine on June 19, 1995
MCL Maximum Contaminant Level
MEG Maximum Exposure Guideline
ND Not detected
ppb parts per billion

Based on types of contaminants, environmental media of concern, and potential exposure pathways, remedial
action objectives were developed to mitigate existing and future potential threats to human health and the
environment. These response objectives are:

1. To minimize further migration of the Eastern Plume.
2. To minimize any future negative impact to surface water resulting from discharge of contaminated
groundwater.
3. To reduce the potential risk associated with ingestion of contaminated groundwater to acceptable
levels.
4. To restore the aquifer.

B. TECHNOLOGY AND ALTERNATIVE DEVELOPMENT AND SCREENING

In making the transition from an interim action to a final action, additional remedial action alternatives
were not developed because the FS report identified and analyzed alternatives for both source and groundwater
contamination. The Navy's selection of the interim remedial action as the final action is the result of a
comprehensive evaluation of different groundwater treatment options.

The FS report described and evaluated five alternatives: no action; groundwater extraction and treatment; and
three different source control options for Site 11 in conjunction with groundwater extraction and treatment.
Since groundwater extraction and treatment was common to each treatment alternative and because it was
desirable to stop the migration, an interim remedial action for groundwater was chosen. It was acknowledged
that groundwater extraction and treatment could be part of a final site remedy even if additional time were
taken to evaluate a source control alternative for Site 11. The decision to take an interim action provided a
timely response to the migration of the Eastern Plume groundwater contamination.
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In the time since the Interim ROD, the Navy conducted two removal actions at Site 11 under their removal
authority. Existing data no longer indicate Sites 4, 11 and 13, are major source areas of the Eastern Plume.
Therefore, no source control alternatives are evaluated and only groundwater extraction and treatment will be
discussed further in this final ROD.

VIII. DESCRIPTION OF ALTERNATIVE

This section summarizes the remedial action for the Eastern Plume. The remedial action consists of
extraction, treatment, and discharge of treated groundwater. The extraction system consists of five
groundwater extraction wells that are designed to hydraulically contain the plume and reduce contamination
throughout the plume. A monitoring program has been developed to ensure that the remedial action obtains
hydraulic capture of the Eastern Plume. Changes to the remedial action will be made if the monitoring results
determine that the remedial action does not achieve hydraulic capture of the plume or that such changes would
improve the effectiveness and/or efficiency of the remedial action.

Extracted groundwater is treated to remove iron and manganese. If iron and manganese are not removed, they
would interfere with the VOC treatment processes. The VOC treatment technology for the remedial action is
ultraviolet(UV)/oxidation. The effluent is sampled to ensure that the water meets appropriate discharge
reguirements.

Discharge of the treated water is through a new sewer connection from the on-site treatment building to the
public sewer system for conveyance to the local POTW. A discharge permit with the Brunswick POTW outlines
specific discharge limitations.

Other discharge methods were considered, and at least one, infiltration of treated water back into the
aguifer upgradient of the. Eastern Plume, is potentially feasible. In the event that circumstances make
discharge to the POTW undesirable, the Navy may evaluate infiltration again, and with the concurrence of
USEPA and MEDEP, may propose to change the discharge method to infiltration into the aguifer.

IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

This section applies to only the Eastern Plume remedial action. Section 121(b)(1) of CERCLA presents several
factors that at a minimum must be considered in the assessment of alternatives. Building upon these specific
statutory mandates the National Contingency Plan articulates nine evaluation criteria to be used in assessing
the individual remedial alternatives.

A. OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

Overall Protection of Human Health and the Environment addresses how an alternative as a whole will protect
human health and the environment. This includes an assessment of how human health and environmental risks are
properly eliminated, reduced, or controlled through treatment, engineering controls, or institutional
controls.

The remedial action for addressing groundwater contamination provides overall protection of human health and
the environment. Protection is provided by containment of the plume to prevent the migration of contaminated
groundwater to currently uncontaminated areas, and by restoration of the aguifer to potentially allow the
future use of the aguifer. A long-term groundwater monitoring program is included to provide data to verify
the effectiveness of the remedial action, or for modifying the remedial action as necessary.

B. COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

Compliance with Applicable or Relevant and Appropriate Reguirements (ARARs) addresses whether or not a remedy
complies With all state and federal environmental and public health laws and/or provides grounds for invoking
a waiver. A list of ARARs is included in Appendix B of this ROD. The remedial action for the Eastern Plume is
designed to meet action- and chemical-specific ARARs for the discharge of treated groundwater and disposal of
sludge resulting from the pretreatment process. All location-specific ARARs are also met.

C. LONG-TERM EFFECTIVENESS AND PERMANENCE

Long-term Effectiveness and Permanence refers to the ability of an alternative to maintain reliable
protection of human health and the environment over time once cleanup goals are met.

The remedial action is expected to fulfill the cleanup objectives by preventing migration of the plume and by
removing and treating the water.
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D. REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH TREATMENT

Reduction of Toxicity, Mobility, or Volume Through Treatment are three principal measures of the overall
performance of an alternative. The 1986 amendments to the Superfund statute emphasize that, whenever
possible, the USEPA should select a remedy that uses a treatment process to permanently reduce the level of
toxicity of contaminants at a site, the spread of contaminants away from the source of contamination, and the
volume or amount of contamination at a site.

The purpose of groundwater extraction and treatment for the Eastern Plume is to prevent further migration of
contaminants and to restore the aguifer. Five extraction wells, placed within the plume, control plume
migration and reduce groundwater contaminant concentrations. The extraction wells are designed to address the
majority of the Eastern Plume contamination which is located in deeper portions of the aguifer. Groundwater
from the extraction wells is treated using UV/oxidation for the volatile organic compounds. Treatment of the
extracted water permanently reduces the toxicity and mobility of contaminants.

E. SHORT-TERM EFFECTIVENESS

Short-term Effectiveness refers to the likelihood of adverse impacts on human health or the environment that
may be posed during the construction and implementation of an alternative until cleanup goals are achieved.
In continuing the operation of the groundwater extraction and treatment system, no short-term impacts are
expected since no significant construction is anticipated.

F. IMPLEMENTABILITY

Implementability refers to the technical and administrative feasibility of an alternative, including the
availability of materials and services needed to implement the alternative. There are no implementability
issues with continuing the operation of the groundwater extraction and treatment system. As part of discharge
reguirements, the Navy provides the Brunswick Sewer District with monthly reports detailing sampling and
analysis results and total volumes of treated water.

G. COST

Cost includes the capital (up-front) cost of implementing an alternative as well as the cost of operating and
maintaining the alternative over the projected life of the remedial action. Because the groundwater
extraction and treatment system has already been constructed, the, capital costs of the remedial alternative
are minimal. Annual costs are estimated at approximately $725,000 per year, not including 5-year reviews. The
total present worth cost estimate is $8,450,000, and is presented in Appendix E, Cost Estimate for the
Selected Remedy.

H. STATE ACCEPTANCE

State Acceptance addresses whether, based on its review of the RI/FS and Proposed Plan, the state concurs
with, opposes, or has no comment on the alternative the Navy proposes for the remedial action.

As a party to the FFA, the State of Maine provided comments on the Sites 4, 11, and 13 proposed plan and
documented its concurrence with the remedial action. A copy of the letter of concurrence is presented in
Appendix C of this ROD.

I. COMMUNITY ACCEPTANCE

Community Acceptance addresses whether the public concurs with the Navy's Proposed Plan. The community has
access to documents pertaining to Sites 4, 11 and 13 and the Eastern Plume in the Administrative Record
which resides at the Curtis Memorial Library in Brunswick, Maine. A list of these documents is included as
Appendix D. Community acceptance of the Eastern Plume Proposed Plan was evaluated based on comments received
at the public meetings and during the public comment period for that plan. This was documented in the
Responsiveness Summary for the Eastern Plume Interim ROD and the Responsiveness Summary attached to this ROD
(Appendix A).

X. THE SELECTED REMEDY

Since the soils at Sites 4, 11, and 13 reguire no action under CERCLA, this section applies only to the
Eastern Plume.
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A. GROUNDWATER EXTRACTION AND TREATMENT

In June 1992, the Navy and the USEPA, with concurrence of the MEDEP, signed an Interim ROD for construction
of a groundwater extraction and treatment system for the Eastern Plume. The system, which began operation in
May 1995, includes pretreatment to remove inorganics, UV/oxidation to destroy volatile organic compounds,
discharge of treated water to the local POTW, and periodic disposal of filter press sludge from the
inorganics treatment process. The remedial action was designed to: prevent further movement of contaminants
toward surface water; reduce concentrations of contaminants in the portions of the plume with the highest
levels; and, together with natural degradation, result in the attainment of cleanup levels throughout the
plume over a time period estimated to be between 13 and 71 years. When operating at full capacity, the system
treats approximately 110 gallons per minute of groundwater.

It is the Navy's objective to attain the groundwater remediation goals, shown in Table 2, throughout the
Eastern Plume area. Groundwater extraction and treatment is generally the most effective method of reducing
concentrations of highly contaminated groundwater, but may be less effective in further reducing low levels
of contamination to achieve remediation goals. Natural attenuation may play a vital role in achieving the
final increment of cleanup once the groundwater extraction and treatment system reaches the point of
diminishing returns. USEPA, MEDEP, and the public will review all proposed changes, and all comments received
by the Navy will be addressed, prior to implementing any changes to the final remedy.

B. GROUNDWATER MONITORING

Beginning in March 1995, the Navy has been collecting groundwater samples at regular intervals from a network
of 39 monitoring wells throughout the Eastern Plume area. This long-term monitoring program is designed to
measure the performance of the groundwater extraction system, and ensure that the contaminants currently in
the groundwater do not continue migrating towards surface water. The Navy will be revising the number of
wells to refine the coverage in the area Sites 4, 11, and 13. The actual number of wells and their locations
will be determined in discussions with USEPA and MEDEP. The groundwater monitoring plan will be revised and
reviewed and approved by USEPA, MEDEP, and the community. The goals of the plan are as follows:

• provide a tiered approach to attain the reguirements of NIEDEP water guality standards;
• monitor changes in the plume boundaries and potential migration pathways;
• monitor changes in the groundwater contamination;
• monitor the effectiveness of the remedial action for the protection of human health and the
envi ronment; and
• monitor the treatment plant effluent.

The Navy issues monitoring reports after each sampling event and an annual report that evaluates the progress
the system is making towards attaining remedial action objectives. The Navy will continue this monitoring
program until it is no longer necessary, as decided in consultation with the USEPA and the MEDEP.

TABIiE 2
GROUNDWATER REMEDIATION GOALS

SITES 4, 11, 13, AND EASTERN PLUME ROD
NAS BRUNSWICK

COMPOUND FEDERAL MCL MAINE MEG REMEDIATION GOAL
(PPB) (PPB) (PPB)
1,1-DCE 77 7
1,1-DCA - 5 (70**) 5
1,2-DCA 55 5
cis-l,2-DCE 70 70 70
trans-l,2-DCE 100 70 70
1,1,1-TCA 200 200 200
1,1,2-TCA 53 3
TCE 55 5
PCE 53 3

Notes:
Not available
MCL Maximum Contaminant Level
MEG Maximum Exposure Guideline
ppb parts per billion
** revised MEG recommended by State of Maine on June 19, 1995
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C. FIVE-YEAR REVIEWS

Because the Eastern Plume remedy will result in hazardous substances remaining in on-site groundwater above
health-based levels for a period estimated to exceed five years, a review of the monitoring data will be
conducted at least every five years to ensure that the remedy continues to provide adeguate protection of
human health and the environment. Based on this evaluation, the Navy may propose modifications to the final
remedy. Possible revisions could include changes to the location, number, or operation of extraction wells,
modifications to the long-term monitoring program, changes to the treatment plant configuration, and/or
termination of the groundwater treatment system. In addition, conditions at Sites 4, 11, and 13 will be
evaluated to determine whether additional actions may be necessary at those sites. For example, if Building
584 was to be removed the need for additional sampling in that area will be assessed.

D. COST

The present worth cost of operating the groundwater extraction and treatment system, conducting long-term
groundwater monitoring and performing five-year reviews is approximately $8,450,000. The present worth cost
analysis is included in Appendix E.

XI. STATUTORY DETERMINATIONS

The remedial action selected for implementation at NAS Brunswick for Sites 4, 11, 13, and the Eastern Plume
is consistent with CERCLA and, to the extent practicable, the National Contingency Plan. The final remedy
will be protective of human health and the environment, attain ARARs, and be cost-effective. The selected
remedy also satisfies the statutory preference for treatment that permanently and significantly reduces the
toxicity, mobility, or volume of hazardous substances as a principal element. Additionally, the selected
remedy uses alternate treatment technologies or resource recovery technologies to the maximum extent
practicable.

Although the Feasibility Study evaluated both source control and groundwater alternatives, the decision to
select groundwater extraction and treatment was taken because there was a concern with controlling the
migration of the Eastern Plume. Since it was a common component of all the remedial alternatives, it was
acknowledged that groundwater extraction and treatment could be consistent with the final remedy and the only
difference would be the source control alternative for Site 11. In the time since the Interim ROD, the Navy
conducted two removal actions at Site 11 under their removal authority obviating the need for further action
under their program. It was, therefore, not necessary to reopen the Feasibility Study and develop remedial
alternatives for the Eastern Plume.

A. THE SELECTED REMEDY IS PROTECTIVE OF HUMAN HEALTH AND THE ENVIRONMENT

The selected remedy at this site will permanently reduce the risks posed to human health and the environment
by eliminating, reducing, or controlling exposures to human and environmental receptors through treatment;
more specifically, protection is provided by containment of the plume to prevent the migration of
contaminated groundwater to currently uncontaminated areas, and by permanent reduction of contaminant
concentrations in the water through treatment. The selected remedy treats extracted groundwater to levels
that are protective of human health, posing human health risks that are below the USEPA and MEDEP incremental
cancer risk targets and are less than the Hazard Quotient of 1.0 for noncarcinogens. Finally, continuation of
groundwater extraction and treatment does not pose any unacceptable short-term risks or cross-media impacts,
there is little danger to workers or the community during treatment and the contaminants removed will be
destroyed.

B. THE SELECTED REMEDY ATTAINS ARARs

This remedy will attain all applicable or relevant and appropriate federal and state reguirements that apply
to this final action. The selected remedy for the Eastern Plume will meet the federal and state ARARs listed
in Appendix B.

C. THE SELECTED REMEDIAL ACTION IS COST-EFFECTIVE

The selected remedy is cost-effective, that is, the remedy affords overall effectiveness proportional to its
costs. The Navy evaluated the overall effectiveness of the remedial action by assessing the relevant three
criteria: long-term effectiveness and permanence, reduction in toxicity, mobility, and volume through
treatment; and short-term effectiveness, in combination. The relationship of the overall effectiveness of
this remedial alternative was determined to be proportional to its costs.
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D. THE SELECTED REMEDY UTILIZES PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT OR RESOURCE RECOVERY
TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE

The selected remedy uses permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. The selected remedy was evaluated for the balance of
trade-offs in terms of: (1) long-term effectiveness and permanence; (2) reduction of toxicity, mobility, or
volume through treatment; (3) short-term effectiveness; (4) implementability; and (5) cost. The balancing
test emphasized long-term effectiveness and permanence and the reduction of toxicity, mobility, and volume
through treatment; and considered the preference for treatment as a principal element, the bias against
off-site land disposal of untreated waste, and community and state acceptance. The final remedial action
provides the best balance of trade-offs among these criteria prior to determination of a final remedy.

E. THE SELECTED REMEDY SATISFIES THE PREFERENCE FOR TREATMENT WHICH PERMANENTLY AND SIGNIFICANTLY REDUCES THE
TOXICITY, MOBILITY, OR VOLUME OF THE HAZARDOUS SUBSTANCES AS A PRINCIPAL ELEMENT

The principal element of the selected remedy is the extraction of groundwater and treatment with
UV/oxidation. The final remedial action satisfies the statutory preference for treatment as a principal
element by destroying contaminants in the extracted groundwater with UV/oxidation.

XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES

The Navy presented a Proposed Plan for Sites 4, 11, and 13 (ABB-ES, 1996). The Proposed Plan described the
Navy's decision to pursue No Further Action at Sites 4, 11, and 13. In addition, the final remedy for the
Eastern Plume will be the same as has been implemented as an interim remedy for groundwater: extraction,
treatment, and discharge. No significant changes have been made to the No Action decision stated in the Sites
4, 11, and 13 Proposed Plan.

XIII. STATE ROIiE

MEDEP has reviewed the RI Report and Proposed Plan, and indicated its support for the selected remedy. MEDEP
concurs with the selected remedy for NAS Brunswick Sites 4, 11, and 13, and the Eastern Plume. A copy of the
letter of concurrence is presented in Appendix C of this ROD.
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GLOSSARY OF ACRONYMS AND ABBREVIATIONS
ABB-ES ABB Environmental Services, Inc.
ARARs applicable or relevant and appropriate requirements
bgs below ground surface
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (the Superfund
statute)
DCA 1,1-dichloroethane
1,1-DCE 1,1-dichloroethylene
1,2-DCE 1,2-dichloroethylene
DDT di chlorodiphenyltri chloroethane
DNAPL dense non-aqueous phase liquid
DRMO Defense Reutilization and Marketing Office
FFA Federal Facility Agreement
FS Feasibility Study
FTA Fire Training Area
ft/day feet per day
ft/yr feet per year
HI Hazard Index
IAS Initial Assessment Study
IRP Installation Restoration Program
MCL maximum contaminant level
MEDEP Maine Department of Environmental Protection
MEG maximum exposure guideline
mg/kg milligrams per kilogram
MSL mean sea level
MW monitoring well
NAS Naval Air Station
NPL National Priorities List
PAH polynuclear aromatic hydrocarbon
PCE tetrachloroethylene
POTW publicly owned treatment works
RAB Restoration Advisory Board
RI Remedial Investigation
ROD Record of Decision
SVOC semivolatile organic compound
TCA 1,1,1-trichloroethane
TCE trichloroethylene
TCL Target Compound List
TRC Technical Review Committee
Ig/kg micrograms per kilogram
Ig/L micrograms per liter
USEPA U.S. Environmental Protection Agency
USTs underground storage tanks
UV ultraviolet
VOC volatile organic compound
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REFERENCES

ABB Environmental Services, Inc. (ABB-ES) 1996. "Proposed Plan Sites 4, 11, and 13", Portland, Maine;
October.

E.G. Jordan Co., 1990a. "Post-Screening Work Plan"; Portland, Maine; July.

E.G. Jordan Co., 1990b. "Draft Final Remedial Investigation Report NAS Brunswick", Portland, Maine; August.

E.G. Jordan Co., 1990c. "Draft Final Phase I Feasibility Study Development and Screening of Alternatives NAS
Brunswick"; Portland, Maine; August.

E.G. Jordan Co., 1991. "Draft Final Supplemental Remedial Investigation Report NAS Brunswick"; Portland,
Maine, August.

E.G. Jordan Co., 1992. "Feasibility Study NAS Brunswick"; Portland, Maine; March.

Halliburton NUS Corporation, 1995. "Drum Investigation Summary Report, Revision 1, for Site 11 - Fire
Training Area (FTA) , Naval Air Station, Brunswick, Maine." August.

Northern Division, Naval Facilities Engineering Command (Navy), 1992b. "Record of Decision for an Interim
Remedial Action at the Eastern Plume Operable Unit Naval Air Station Brunswick, Maine", Portland, Maine;
June.

OHM Remediation Services Corporation (OHM), 1996. "Final Report, Remediation of Sites 1,3,5,6, and 8",
Volumes I through IV; July.

Roy F. Weston, Inc; 1983. "Initial Assessment Study of Naval Air Station, Brunswick, Maine"; West Chester,
Pennsylvania; June.

U.S. Environmental Protection Agency (USEPA), 1989a. "Supplemental Risk Assessment Guidance for the Superfund
Program"; EPA/901/5-89/001; Region I; Boston, Massachusetts; June.

U.S. Environmental Protection Agency (USEPA), 1989b. "Risk Assessment Guidance for Superfund Volume 1 Human
Health Evaluation Manual (Part A)"; EPA/540/1-89/002; Washington D.C.; December.
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APPENDIX A

RESPONSIVENESS SUMMARY
AND
PUBLIC MEETING TRANSCRIPT

The Navy held a 30-day comment period from October 11 to November 9, 1996, to provide an opportunity for the
public to comment on the Proposed Plan and other documents developed for Sites 4, 11, 13 and the Eastern
Plume. Sites 4, 11, 13 and the Eastern Plume are located at the Naval Air Station Brunswick Superfund Site,
in Brunswick, Maine. The Proposed Plan is the document that recommends an alternative to address a site.

The Navy made a recommendation of its preferred alternative in the Sites 4, 11, and 13 Proposed Plan. The
Proposed Plan was issued on October 8, 1996, before the start of the comment period. All documents on which
the preferred alternative is based were placed in the Administrative Record for review. The Administrative
Record is a collection of the documents considered by the Navy when choosing the remedial action for Sites 4,
11, 13 and the Eastern Plume.

The Navy received no written comments on the Proposed Plan during the 30-day public comment period. Several
verbal guestions and comments were offered at the public meeting on October 17, 1996. Many of these were
seeking clarifications of the information being presented at the meeting, or were pointing out subjects that
were not covered in the technical presentation but were of interest to the public. Responses were provided
verbally for each guestion and comment during the meeting, and these are documented in the Public Meeting
Transcript, which is attached to this Responsiveness Summary. There were no comments that indicated
disagreement with the proposed remedy.

The Navy is selecting the No Further Action Alternative for Sites 4, 11, and 13. In addition, the Eastern
Plume interim action is being selected as the final action for the groundwater contamination associated with
these sites. Since May 1995, an extraction, treatment, and discharge system has been in place to contain the
Eastern Plume. The Eastern Plume remedial action also consists of long-term groundwater monitoring to measure
the performance of the extraction system and to ensure that the contaminants currently in the groundwater do
not continue migrating towards surface water.
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NAVAL AIR STATION - BRUNSWICK

PUBLIC MEETING

SITES 4, 11, 13 PROPOSED PLAN

OCTOBER 17, 1996

OLD BRUNSWICK HIGH SCHOOL
Brunswick, Maine

7:00 p.m. - 8:00 p.m.

PANEL MEMBERS
CAPTAIN E. F. CARTER, JR.

FRED EVANS

JEFF BRANDOW

BOB LIM

NANCY BEARDSLEY

GREG APRAHAM
Commanding officer,
NAS Brunswick

Program Manager, NORTHDIV

Project Manager, ABB-ES

EPA Project Manager

Maine DEP Project Manager

NAS Brunswick
Robin Jansen
BROWN & MEYERS
Post Office Box 937
Yarmouth, ME 04096-0937
(207) 846-0420
BROWN & MEYERS
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1 MR. APRAHAM: My name is Greg Apraham and

2 tonight we are going to talk about the proposed

3 plan for the sites 4, 11 and 13 on the Naval Air

4 Station, that the remedial advisory board, a

5 working group of both the State and Federal

6 regulators, Naval personnel, as well as the

7 citizens representative of the Town of Brunswick

8 and the BACSE group, that has been working on this

9 for several years.

10 The people at the front table is our new

11 Commanding Officer, Captain Carter; he took over

12 September 6th. Bob Lim is from EPA, Region 1.

13 Jeff Brandow is the Project Manager from ABB

14 Environmental in Portland; he is our consultant on

15 the work. Next to him is Nancy Beardsley, who is

16 the Maine DEP Project Manager, and then Fred Evans

17 who works for the Naval Command down in

18 Philadelphia, Pennsylvania, who's the technical

19 contract folks, as well as the technical experts

20 for the Navy in his field. And the lady down the

21 end of the table is the court reporter.

22 There is a mailing list sign-up sheet out at

23 the table out here in the ante room. There is a

24 complete and full administrative record of the

25 entire remedial work, investigation and feasibility

BROWN & MEYERS
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1 studies that the Navy has undertaken at the Naval

2 Air Station at the Curtis Memorial Library. It has

3 all of the records, all of the proposed plans, if

4 anybody cares to see anything. All of the

5 documents that have been produced over the years

6 are over there.

7 There is also a proposed plan for what we're

8 looking to talk about tonight, Sites 4, 11 and 13,

9 also out in the ante room by the sign-out table.

10 And the court reporter is here to record the public

11 hearing because it becomes part of the public

12 record, and there will be a guestion-and-comment

13 period at the end of the presentation.

14 Having said that, I'm going to turn this over

15 to Jeff to do the presentation with regard to the

16 proposed plan. Oh, I'm sorry. Captain Carter has

17 a few remarks.

18 Captain Carter: Good evening. Again, my name

19 is Captain Fred Carter, as was stated took over

20 command on 6th of September. Again, I'd like to

21 welcome you all to this public meeting to present

22 the Navy's proposed plans for Sites 4, 11 and 13.

23 The meeting is the latest in a series of public

24 forums where the Navy presents for public input its

25 plan for the environmental cleanup of the Navy Air

BROWN & MEYERS
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1 Station, Brunswick.

2 Tonight you will be hearing about the Navy's

3 proposed plans for the group of three sites, 4, 11

4 and 13. These sites constitute the sources of the

5 Eastern Plume as it is described, the subject that

6 many of you have heard about in the past and all of

7 you will hear about it again tonight. As I

8 understand it, the past has witnessed a great deal

9 of activity at the Naval Air Station, Brunswick.

10 We completed the work on 8 of 13 sites. And the

11 groundwater treatment plant is actively treating

12 the Eastern Plume.

13 As mentioned, I took command of the Naval Air

14 Station at Brunswick a little over a month ago and

15 am certainly a new member of the team, but

16 personally wanted to reassure all of you that I'm

17 fully committed to continuing the Installation

18 Restoration Program and the cleanup that will occur

19 from that. Obviously, I'm learning, as well as

20 perhaps some of you out there, on all of the

21 aspects of the Installation Restoration Program at

22 Naval Air Station, Brunswick.

23 In the short time I've been here, however, the

24 Navy has -- but in front of you tonight the Navy

25 has assembled a team of people here that are

BROWN & MEYERS
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1 certainly experts on the subject and had a great

2 deal of interaction with the base in that regard.

3 With that I'11 allow the team to provide their

4 briefing, and I hope to learn as well as the rest

5 of you in answering your guestions.

6 MR. EVANS: We're here tonight for the public

7 meeting portion of the CERCLA or Superfund Process.

8 Up to this point for Sites 4, 11 and 13, we've

9 performed a remedial investigation and a

10 feasibility study. And as part of the process for

11 the record of decision for the end of the

12 feasibility study, we need to propose our plan to

13 the public and give the public a chance to comment

14 and recommend if they have changes to what we want

15 to do.

16 This is a critical point in the process of

17 what we need to do. Following the completion of

18 this meeting, any comments that are recorded as

19 part of this meeting or that are written and mailed

20 in to myself, as part of the public comments

21 period, will be addressed in the Responsiveness

22 Summary, which will be included as part of the

23 record. And then we will go into the design and

24 long-term monitoring operation phase of the

25 cleanup.

BROWN & MEYERS
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1 And, with that I'd like to turn it over to Jeff

2 Brandow of ABB to explain what we've done, what

3 we've proposed to do.

4 MR. BRANDOW: Thanks, Fred. I guess I'll

5 start off by saying that I'm not a professional

6 public speaker; I'm an engineer. And hopefully I

7 can try to avoid using a lot of technical jargon

8 and not make that too terribly boring. I'd like to

9 do just a general overview background description

10 of the site that we're here to talk about tonight

11 and then talk a little bit about some of the

12 actions that the Navy has taken thus far to try to

13 address some of the environmental concerns that are

14 related to those sites and then guickly summarize

15 the proposed plan, the formal plan that the Navy is

16 proposing to move forth from this point.

17 We're talking about three of the original 13

18 installation restoration sites on the base, Sites

19 4, 11 and 13. They're located more or less in the

20 east central portion of the Air Station, just south

21 of the major developed part of the installation.

22 As you can see, these three sites are located

23 guite close to each other. And it's just to orient

24 you here, this photograph was taken looking to the

25 south, so the orientation of the three sites is

BROWN & MEYERS
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1 sort of reversed from that previous overhead. But

2 the three sites are located quite close together.

3 This has caused the Navy over the years to tend to

4 group these three sites together when they're

5 evaluating the impact they may have had on the

6 environment. We're going to continue doing that

7 tonight.

8 I'm going just guickly describe the three

9 sites. I'm just going right through in order and I

10 will start with Site 4. I'll just draw your

11 attention here for the moment to this building

12 that's located at Site 4. Site 4 is known as the

13 former acid and caustic waste disposal pit. This

14 was basically a hole in the ground about 4 feet by

15 4 feet and about 3 feet deep. It was used over a

16 period of approximately five years from 1969 to

17 1974 for disposal of waste liquids. Liquids were

18 essentially just dumped into the pit and allowed to

19 infiltrate.

20 Types of waste that generally were disposed of

21 at the site were acidics and caustics, though there

22 are some reports that there may have been some

23 waste oils and waste solvents also disposed of in

24 the pit. The pit no longer exists. It was filled

25 in and a building that I pointed out to you was

BROWN & MEYERS
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1 built on top of that location. So this is not a

2 site that you can actually go out and see at this

3 point.

4 Site 11, this is the former fire training area

5 on base. And it's probably the more interesting of

6 the three sites. The fire training area is a

7 location where the emergency response crews would

8 go to practice their fire fighting training

9 exercises. Site 11 was used for at least 30 years

10 for this purpose. In general, what would happen is

11 waste, flammable liguids consisting of waste fuels,

12 waste oils, solvents, whatever was available, was

13 placed directly onto the ground and ignited, and

14 then the response crews would practice their fire

15 fighting techniques as they extinguished the fire.

16 The site was upgraded in 1987 to include that

17 concrete pad you saw in the previous photograph.

18 And also there was an underground storage tank

19 installed at that time to collect any excess

20 liguids that might have remained at the end of the

21 training exercise.

22 In 1990 the Navy ceased its fire training

23 exercises at Site 11; and in fact, currently is not

24 conducting any fire training exercises with live

25 fires.

BROWN & MEYERS
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1 And finally Site 13 is the DRMO, or Defense

2 Reutilization and Marketing Office. This is the

3 facility on base that is -- that deals with surplus

4 and waste products. Of most interest at the DRMO

5 was the presence of three underground storage

6 tanks. These tanks were used to store wastes,

7 solvents, oils and waste fuels. The three tanks

8 have all been removed. They were removed in the

9 late '80s, and currently there are no underground

10 storage tanks at the DRMO.

11 Fred already mentioned the CERCLA Process.

12 CERCLA, being the Superfund Process. That process

13 generally starts with a remedial investigation and

14 feasibility study. And the remedial investigation

15 feasibility study activities at these sites

16 occurred over the 1989, 1990 time frame. The

17 investigation consisted of numerous soil and

18 groundwater samples collected from around the three

19 sites and adjacent areas.

20 I'm not going to go through these studies in

21 any detail tonight. That's been done in previous

22 public meetings. And these documents are available

23 at the Curtis Memorial Library for your review if

24 you would like additional information. I'm just

25 going to hit on a couple of key points from these

BROWN & MEYERS
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1 studies.

2 Probably the most important finding from the

3 remedial investigation was the identification of a

4 fairly extensive area of groundwater that is down

5 gradient or down stream, if you will, of the three

6 sites. And this area of groundwater contains

7 site-related chemicals that we believe originated

8 from the three sites. This figure represents the

9 entire area encompassing any location that we

10 actually had a detection of any of these chemicals.

11 It does not represent an area that exceeds any

12 particular number, but just any detection of

13 chemicals. This was as of 1991 when that -- when

14 that study was completed.

15 Now, I've referred to site-related chemicals,

16 and just to let you know what I'm talking about

17 here, the chemicals that we see in the groundwater

18 that we believe are related to the site are

19 primarily solvents. And of these, probably

20 trichloroethane and trichloroethylene are the most

21 abundant. These are both common degreasing

22 solvents that have been used widely in industry and

23 used widely in the Air Station, as well as for

24 degreasing purposes and other purposes.

25 This table shows the target cleanup levels

BROWN & MEYERS
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1 that were established for the interim remedial

2 action in the ROD. I'm kind of getting ahead of

3 myself there. Let's set that aside for a moment.

4 Now, the feasibility study is a report that

5 evaluates the cleanup options that are available to

6 address the contamination that's identified in the

7 remedial investigation. In the feasibility study

8 we've identified three principle conclusions that

9 are related to the three sites we're talking about

10 tonight.

11 And the first is, of course, there was

12 groundwater in that Eastern Plume area that has

13 been identified that exceeded drinking water

14 standards. Nobody is currently drinking that

15 groundwater. There are no wells in that area, and

16 nobody uses it as a drinking-water source, but

17 because there is the potential that at some point

18 in the future somebody could use that water as a

19 drinking -- water-well source, we have used a very

20 conservative evaluation criteria, which is drinking

21 water standards.

22 The second conclusion that we came to was that

23 the soils, the surface and subsurface soils at the

24 three sites, did not pose a risk from direct

25 contact. In other words, if you were walking out

BROWN & MEYERS
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1 on the site or even digging in the soil at the

2 site, you were not getting an exposure to chemicals

3 that was considered to be harmful to you. So the

4 concentration in the soils were not causing a

5 direct contact risk. However, we did conclude that

6 the soils at Site 11 could be causing a continued

7 groundwater impact and could be acting as a source

8 of continued groundwater contamination.

9 Now, by source, you typically think of a

10 source as a landfill or a leaking underground

11 storage tank or in the case of Site 4, a pit. But

12 even after you have removed those types of items,

13 you may still have an area of soil that has

14 absorbed contaminants. And then as rain falls on

15 the soil, it moves through the soil; it can move

16 those contaminants down into the groundwater if the

17 concentrations are high enough. And we believe

18 that there was reason to believe that might be the

19 case at Site 11 but not at the other two sites. So

20 we have basically two issues to deal with, the

21 groundwater in the Eastern Plume and the soil at

22 Site 11.

23 Now, since the RI and the FS have been

24 completed, the Navy has taken a number of actions

25 to start to address those issues. And these

BROWN & MEYERS
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1 include a couple of excavation activities at Site

2 11, the design and construction of a groundwater

3 extraction treatment system at the Eastern Plume

4 area and a groundwater monitoring program to

5 evaluate the conditions in that groundwater in the

6 Eastern Plume. I'll go through each of these in a

7 little bit of detail.

8 MR. HOLBROOK: Could you redefine Eastern

9 Plume for me, please?

10 MR. BRANDOW: Sure. A plume is an area of

11 groundwater, groundwater being water that's down

12 beneath the ground. It fills the spaces between

13 the soil particles. And this is water that's

14 generally in the soil throughout the State of

15 Maine. It's what you sink your well into to get

16 drinking water. A plume is an area of groundwater

17 where you have detectible concentrations of

18 chemicals that may have originated from a source

19 area. So you can think of it as an area of

20 groundwater contamination that has moved with the

21 groundwater flow away from those sites.

22 MR. HOLBROOK: Why do you say "Eastern"?

23 MR. BRANDOW: We call it the Eastern Plume

24 primarily because it's located on the eastern

25 portion of the base, along the eastern boundary of

BROWN & MEYERS
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1 the base. That's all.

2 Let me talk first about the removal action

3 that occurred at Site 11. The Navy discovered

4 buried metallic objects at Site 11 in 1994 when

5 they were following up some verbal reports from

6 some of the former fire fighting crews. And these

7 buried metal objects were thought to probably be

8 drums, possibly containing liguid wastes. Because

9 a drum of liguid waste in the ground represents a

10 real potential threat of major impact to

11 groundwater, the Navy decided they wanted to go

12 ahead and get those materials out of there. So in

13 1994 the Navy located and excavated those buried

14 metallic objects at Site 11. And they were

15 properly packaged and taken off-site to a permanent

16 facility for disposal. Also at that time they

17 removed that underground storage tank that had been

18 tied to the fire training pad.

19 In 1995, the Navy installed a series of

20 groundwater extraction wells throughout the Eastern

21 Plume area. If you go out in that area today,

22 you'll see a series of five of these concrete

23 blocks, each of which contains a groundwater

24 extraction well, a well that's been placed into the

25 ground to try to capture that underground water.

BROWN & MEYERS
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1 The wells have been -- let me go back to an

2 earlier overhead, the one that shows the plume.

3 The wells have been located generally in a north

4 south pattern through the plume. There's five of

5 them. And their main purpose is, Number one, to

6 prevent this area of groundwater from moving any

7 further to the south toward Harpswell Cove, which

8 is -- it starts about down here. And then the

9 second objective is to begin the restoration of the

10 groundwater system.

11 Now, the water that's being pumped from those

12 extraction wells is pumped out of the ground and

13 sent to a groundwater treatment plant that the Navy

14 has constructed on the Air Station. This was

15 designed and constructed by the Navy in 1995. The

16 treatment plant houses a series of tanks and

17 treatment units who's purpose is to remove the

18 chemicals from the groundwater. It's a fairly

19 complex treatment scheme. But the major treatment

20 unit is — this UV/Oxidation Unit — this is a

21 treatment unit where the organic chemicals, the

22 solvents that are in the groundwater are destroyed

23 by a combination of ultraviolet light and hydrogen

24 peroxide. So this is where the actual treatment

25 and the destruction of the chemicals occurs prior

BROWN & MEYERS
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1 to the treated groundwater being discharged to a

2 sewer and then to the Brunswick treatment plant.

3 However, there's several additional treatment

4 processes that have to occur before the water goes

5 into that system, and this is mainly to prepare

6 that water so that the destruction unit is more

7 efficient and more effective.

8 I guess that I should point out that some of

9 these have just recently been added. For instance,

10 these processes here have been added to deal with a

11 cloudy-water issue that we have found in a couple

12 of the wells. The water coming out of the wells is

13 cloudy due to very fine soil particles in the

14 water. If that cloudy water were to get to the

15 treatment unit, it could interfere with the

16 effectiveness. So we're going to change the design

17 slightly to make sure that does not happen.

18 I guess I should also point out, though, that

19 the system has been operating effectively since its

20 start-up in the spring of 1995, and it has been

21 meeting its discharge standards that were set by

22 the treatment plant.

23 MR. HOLBROOK: Water which comes into the

24 extraction wells, do you obtain that water because

25 there's a dug hole in the ground, or because it's a

BROWN & MEYERS
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1 overgrown point, shall we say, that has been driven

2 into the ground?

3 MR. BRANDOW: It's a drilled well. We had a

4 large well-drilling unit come out and drill a large

5 diameter hole into the ground about a hundred feet

6 deep, and we placed a six-inch diameter well.

7 MR. HOLBROOK: Okay. So six inches, about 100

8 feet, and the submersible pump is down at the

9 bottom?
10 MR. BRANDOW: Yes, it is.

11 MR. HOLBROOK: Is that well strictly in the

12 clays? Do any of them go into the bedrock?

13 MR. BRANDOW: No. The wells are located in

14 the zone of soils just above the clays. That's the

15 area we're most concerned with, the area from the

16 top of the groundwater down to the clay area.

17 Now, back to Site 11 for a minute, in order to

18 deal with the concern that the soils at Site 11

19 were acting as a continuing source of groundwater

20 impact, in 1995 the Navy decided to just go ahead

21 and dig all that soil up. They did so and

22 transported all of that soil over to the old base

23 landfill, which was being closed under a related

24 program at the base. The soil was placed

25 underneath the engineered cap that was being put on

BROWN & MEYERS
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1 top of the landfill. It was used primarily as

2 grading fill to help establish the necessary grades

3 or slopes with a cap on the landfill.

4 So this became an option that was both

5 technically and financially very desirable for the

6 Navy, and the Navy went ahead and did that. So all

7 of the soils at Site 11 were excavated and removed.

8 The site was then backfilled with clean soil and we

9 seeded it. And now if you go out there, you'll see

10 a nice grassy field at Site 11.

11 MR. HOLBROOK: You stopped at six feet in

12 excavating these soils?

13 MR. BRANDOW: Well, actually we went as deep

14 as we could. We went down to the groundwater

15 elevation which was as far as we could practically

16 excavate.

17 And finally the other action that the Navy has

18 been taking is the long-term monitoring program.

19 This is a program where groundwater samples are

20 regularly collected throughout the Eastern Plume

21 area. And the Navy's been doing this since March

22 of 1995 to help keep track of the progress that the

23 extraction and treatment system is making in

24 containing the Eastern Plume.

25 Now, the results of these sampling events are

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1 reported. Each event is reported and each year an

2 annual report is prepared which describes -- which

3 discusses the Navy's interpretation of those -- of

4 all that data that's been collected. And these

5 reports are available also at the Curtis Memorial

6 Library. So that brings us to where we are today,

7 which is the Navy's proposed plan.

8 Now, the actions that have been taken to date

9 have been considered to be interim actions by the

10 EPA. And that's dictated by the process that we

11 are going through under CERCLA. The Navy believes,

12 though, that these actions have been the

13 appropriate ones to address the issues that we've

14 seen from Site 4, 11 and 13.

15 Under the CERCLA Process, the Navy must now

16 propose a final plan or final remedy for those

17 sites. Hopefully, you've had a chance to see the

18 Navy's proposed plan which was issued about two

19 weeks ago. The cover looks like this. It's on

20 blue paper. If you haven't, we have some copies

21 here tonight, and there's also additional copies at

22 the library.

23 Now, in this plan, the Navy is formally

24 recommending that the actions taken to date become

25 the final remedy for Sites 4, 11 and 13. And in

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1 particular, the Navy will continue to operate the

2 groundwater extraction and treatment system as long

3 as it's determined to be necessary.

4 We do not see the need for any additional

5 source removal action. We have removed the soils

6 from Site 11. And the soils associated with the

7 other sites were not considered to be posing any

8 type of a problem.

9 The Navy will also continue to perform the

10 groundwater monitoring program to provide the data

11 necessary to evaluate the ongoing treatment system.

12 And they will perform periodic reviews of the whole

13 program in conjunction with the Maine DEP and the

14 U.S. Environmental Protection Agency and in

15 conjunction with the members of the public to

16 evaluate the conditions at the site, including

17 performance of the treatment system and extraction

18 system and any changed conditions that might occur

19 that would effect the overall remedies, such as,

20 for instance, if this Building 584 were ever torn

21 down, the Navy would evaluate whether there's a

22 need to do additional soil investigations in that

23 area, because that area was not accessible to us

24 when we did our studies.

25 MR. HOLBROOK: Building 584, as I might drive

BROWN & MEYERS
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1 around the areas that are available to the public,

2 is there a Number 584 in evidence on a building?

3 CAPTAIN CARTER: Yes, there is.

4 MR. HOLBROOK: As I would be driving along,

5 that is clearly evident that it is 584?

6 CAPTAIN CARTER: Yes.

7 MR. BRANDOW: You would be able to see that

8 from the roadway that heads down to the golf

9 course.

10 MR. HOLBROOK: As I went from the main gate to

11 the golf course it would be on my left?

12 MR. BRANDOW: Yes. That's the extent of the

13 technical portion of our presentation tonight. I'm

14 going to bring Fred Evans back up for a couple of

15 words before we have our guestion-and-answer

16 period.

17 MR. EVANS: The public comments period runs

18 from -- it opened on October 11 and it's running

19 until November 9th. We will be willing to answer

20 any oral comments that we can at tonight's meeting

21 and any written comments to be forwarded to myself

22 at the address in Philadelphia. And we will

23 address all comments in the Responsiveness Summary

24 which will be included as part of the Record of

25 Decision which will document how we went through

BROWN & MEYERS
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1 our decision process to do what we ultimately

2 decide to do based on the comments and what we

3 propose.

4 Before we open it up for oral comments, I

5 would like to say that the current proposed plan is

6 saying that we will clean up the groundwater to the

7 Federal Drinking Water Standards. And the State of

8 Maine has taken the position that we should clean

9 them up to the maximum exposure guidelines, and

10 that is currently under review by both EPA and the

11 Navy. With that I'd like to open --

12 MR. APRAHAM: For those of you who are

13 interested, that gray piece of paper has the

14 address for Philadelphia to send your written

15 comments to.

16 We'll take guestions and comments at this

17 point in time now. Because this is a public

18 hearing and becomes part of the public record,

19 would you please state your name and address when

20 you have a guestion or comment.

21 MR. BRUSAL: My name is Frank Brusal;

22 Brunswick is my home. Sites 4, 11 and 13 are they

23 the only sites under surveillance or consideration?

24 Will there be more? Or has whatever survey been

25 made satisfied the Navy and EPA and so on? Are

BROWN & MEYERS
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1 these the only sites of concern?

2 MR. APRAHAM: No. They are not the only sites

3 of concern. As a matter of fact, I think by last

4 count --

5 MR. EVANS: I think we have a total of 17

6 right now.

7 MR. APRAHAM: Yes. I was going to say there's

8 like 17 different areas we have looked at on the

9 base. This process has been ongoing on the base

10 since 1981 when we did the initial assessment

11 study. Then the Technical Review Committee got

12 started in the mid '80s. And subseguent to that

13 with the signing of the Federal Facilities

14 Compliance Agreement that brought the EPA and the

15 DEP and the Navy, as well as the citizen

16 representative from the town, as well as the

17 representative from the Brunswick Citizen's --

18 Concerned Citizen for a Safe Environment as part of

19 the decision-making process, so this has been going

20 on for well over the 10 or 12 years. And what

21 we've done is, because all of the units on the base

22 are in essence discrete, except for the Eastern

23 Plume as a process that's gone, we've been able to

24 close some of the landfills and some of the old

25 sites out. We've done that through public hearings

BROWN & MEYERS
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1 and mailings. And a complete record of everything

2 that's ever been done for the last 12 years is in

3 the Curtis Library.

4 So, no. These are not the only three sites.

5 These are the three sites that we're addressing

6 specifically tonight.

7 Any other guestions? Comments?

8 MR. KATZ: I have a guestion. Josh Katz; I'm

9 a Brunswick resident. Do you ever test any of the

10 drilled wells on Coombs Road?

11 MR. APRAHAM: We've done that once, Josh, and

12 we've just sent letters out to the residents with

13 wells in this area asking permission to go back on

14 the property and do it again.

15 MR. KATZ: I know there has been at least one

16 well drilled since, I hope there certainly will be

17 others. Thank you.

18 MR. APRARAM: That's always been one of our

19 prime concerns is the potential effects.

20 MR. KATZ: One other guestion. What's the

21 difference between the maximum exposure guidelines

22 and Federal Drinking Water Standards?

23 MR. EVANS: For the most part they're very

24 close, but there are some particular chemicals that

25 there's a significant difference on. Of the

BROWN & MEYERS
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1 solvents that we're currently protecting in the

2 Eastern Plume, I don't think there's a significant

3 difference.

4 MR. KATZ: Do you think these are State of

5 Maine proposed MEGs?

6 MR. EVANS: No. These were —

7 MS. BEARDSLEY: They're not proposed. They

8 are actually the MEGs that were issued in 1992?

9 MR. APRAHAM: For the State of Maine.

10 MS. BEARDSLEY: For the State of Maine; right.

11 Usually they are the same as MCLs. But in some

12 cases they can be slightly different.

13 MR. KATZ: Do they tend to be more or less

14 stringent?

15 MS. BEARDSLEY: They tend to be more

16 stringent.

17 MR. APRAHAM: The state has always been a

18 little more stringent than the Federal guidelines.

20 MR. EVANS: If they were less stringent we

21 wouldn't be having to review the -- these are the

22 MEGs over in this column here. And then the MCLs

23 are here. So the differences would be that this

24 would be 70 parts per million for the MEG versus --

25 per billion -- versus 100 parts per billion. The

BROWN & MEYERS
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1 significant difference would be vinyl chloride,

2 which for the state is .15. And for the Federal

3 Drinking Waters is 2 parts per billion. And we

4 have not detected that in the Eastern Plume at this

5 point.

6 MR. APRAHAM: Josh, we'll be happy to leave

7 that out for you to take a look at.

8 MR. KATZ: That answers my guestion. Thank

9 you.

10 MR. APRAHAM: Do we have anymore guestions or

11 comments?

12 MS. WEDDLE: Susan Weddle from Brunswick. I

13 also will say these comments are from Brunswick

14 Area Citizens for the Environment. One guestion

15 was, can you define at all what additional

16 investigation you might do beneath building 584 if

17 in fact it is removed? Do you have anything

18 planned for that? Any contingencies or deed

19 restrictions or anything like that in the event

20 that it comes down later?

21 MR. APRAHAM: Well, there is going to be a

22 notation, obviously, made with regard to the sites

23 there. If the building is ever destroyed, then we

24 will go in and treat it the same as we did with

25 Site 7 with a magnetometer survey with the test

BROWN & MEYERS
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1 pits until we actually locate it and take a look at

2 it and determine what's there and go through this

3 whole process again.

4 But right now, and maybe somebody else can

5 shed some more light on it, Fred possibly, is

6 there's nothing more than the deed restriction,

7 guote, unguote, per say, with regard to the site

8 being there. My guess is, and it is just a guess

9 at this point in time, is the same kinds of things

10 that went there, that went into Site 7, we would

11 find the same kind of thing.

12 MR. EVANS: As with the other investigations

13 that we've done, we would develop a work plan and

14 have that available to review. And we would answer

15 whatever comments so that we could develop a work

16 plan that everybody felt comfortable with to try

17 and determine whether or not there was anything

18 still left at that site.

19 MS. WEDDLE: Okay. The additional wells that

20 you talk about in page 4 of your handout to

21 increase the area of coverage, do you have any more

22 information on the number of those, the location or

23 the time frame for installation and testing?

24 MR. EVANS: At this point in time, no. Our

25 experience has been that when you do a groundwater

BROWN & MEYERS
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1 extraction system we try to make the best estimate

2 in the beginning of where these wells should go.

3 And then we have --we find, based on our

4 monitoring program, then we're able to go back and

5 refine that system so that we can make it even

6 better.

7 So at this time, no. We know that we're going

8 to have to modify the system. We're not sure how

9 we have to modify it at this point. But we know we

10 do have the possibility that we will need to

11 install additional extraction wells. We have done

12 additional investigations because of higher levels

13 of contamination, and we've also since completed

14 construction of the treatment plant that Jeff has

15 pointed out. We're going to install the new

16 clarifiers so we can clear up the cloudy water.

17 And that will be online in January.

18 So we are taking measures and we will continue

19 to take measures to keep that treatment plant

20 running to effectively clean up the plume.

21 MR. APRAHAM: This whole process is going to

22 be brought before the Remediation Advisory Board as

23 well as all the other sites. All the modifications

24 will be brought to the Board to be thrown out on

25 the table and discussed among the Navy, the

BROWN & MEYERS
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1 regulators, the citizens representatives. This is

2 for those that are not familiar with what we call

3 the RAB. This is discussed in detail amongst that

4 forum for which Captain Carter chairs.

5 MS. WEDDLE: Another guestion was, in your

6 handout you said that the plume had been predicted

7 to reach the discharge zone as early as 1997. I

8 was wondering if you could tell the people here

9 where you think the leading edge of the plume is,

10 if it has, in fact, moved from the diagram that you

11 had up there and also any investigations that you

12 have in the future for doing samplings to try to

13 better determine the configuration of the plume at

14 this point?

15 MR. EVANS: We don't know the exact location

16 of the leading edge of the plume. We do have the

17 extraction wells, one extraction well. One which

18 is the southernmost well extraction well is

19 designed to be able to draw the plume back. And we

20 do have monitoring wells in our monitoring well

21 program over below this point, which we have not

22 picked up detections at this point.

23 MS. WEDDLE: When was the last time those were

24 sampled?

25 MR. EVANS: The last time those were sampled

BROWN & MEYERS
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1 was in July.

2 MS. WEDDLE: Okay.

3 MR. EVANS: And that report was just issued, I

4 believe, last week.

5 MS. WEDDLE: Currently, you're discharging the

6 water from the treatment plant to the Brunswick

7 Sewer Department. But the possibility has also

8 been discussed at some point in time of recharging

9 it in the ground. How will that be addressed in

10 terms of the final ROD? Is the final ROD just

11 using the PTOW? Or does the final Rod include

12 contingencies for both?

13 MR. EVANS: The final ROD would be written the

14 same as the interim. We would propose to write it

15 to allow contingency for either discharge to POTW

16 or to discharge into that -- back into the ground,

17 somewhere in the area of Site 11. And that would

18 be discussed at our RAB meetings. And you would be

19 involved in that.

20 MR. APRAHAM: Susan, if you have got guestions

21 specifically on the Eastern Plume, we can, if you

22 don't mind, take those after we close out the

23 Hearing on 4, 11 and 13. I understand there is

24 some kind of a nexus.

25 MS. WEDDLE: Right. What I was doing now was

BROWN & MEYERS
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1 just making points that our consultants -- in

2 review of this we wanted to have these points,

3 Number one, upon the record because this is part of

4 the hearing. And these are things that are just

5 comments that I want the other members of the

6 public that are here to also know, for example,

7 that there is the possibility that the discharge

8 could be in the ground as well as the -- to the

9 sewer system. So these are just bringing up the

10 points in the public forum and also for the public

11 record.

12 MR. EVANS: If we did discharge back to the

13 ground, we would also need to either, depending on

14 what the decision is, either the Federal drinking

15 water levels or the Maine Maximum Exposure

16 Guidelines, also, so that we would have a stricter

17 criteria on us than what is the current agreement

18 of your district. I think for all but maybe one

19 contaminant, we meet the drinking water levels for

20 discharge into sewer level.

21 MR. APRAHAM: Any more comments?

22 MR. HOLBROOK: As he defined --

23 MR. APRAHAM: Excuse me. Could we have your

24 name and address, please?

25 MR. HOLBROOK: I have written it down on the

BROWN & MEYERS
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1 sheet there. I will read it into the record soon.

3 Are there other plumes on the base besides

4 this Eastern Plume that you're watching for other

5 reasons?

6 MR. EVANS: There is a landfill associated

7 with Sites 1 and 3 right here. Sites 1 and 3 were

8 a landfill right here, and there is a plume

9 associated with that. And that groundwater

10 contamination is also being treated by the same

11 treatment plant. We've already gone through a

12 public meeting and public comment period on that

13 five years ago.

14 MR. HOLBROOK: I understand from the other

15 gentleman's definition that the plume tends to

16 move. You're seeing this plume move, seeing the

17 north arrow on there, sort of in a south, southeast

18 direction?

19 MR. EVANS: I'm — I can't really — I'm not

20 prepared to answer the guestion on Sites 1 and 3.

21 We need to get back beyond that. But I believe

22 that the major problem in the area is the Eastern

23 Plume, which is --

24 MR. HOLBROOK: To which I refer. Is that

25 Eastern Plume Site 4 and —

BROWN & MEYERS
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1 MR. EVANS: 4 and 11.

2 MR. HOLBROOK: Does that tend to move toward

3 the ocean?

4 MR. EVANS: It tends to move towards Harpswell

5 Cove, which is right down here.

6 MR. HOLBROOK: As I said it showed no tendency

7 to move in a northerly direction?

8 MR. EVANS: No.

9 MR. APRAHAM: Any other questions or comments

10 on Site 4, 11 or 13?

11 MR. HOLBROOK: Yes, I want to read onto the

12 record that my last name is Holbrook,

13 H-o-l-b-r-o-o-k, my first name is, Sumner,

14 S-u-m-n-e-r. I'm representing my son tonight, who

15 is Seth, S-e-t-h, Holbrook. He's already on your

16 mailing list, but I'll give you his address again

17 if you choose. I will read onto the record as I

18 understand it that you can submit comments to Mr.

19 Evans up to and including November 9. And I have

20 no verbal comment tonight but have a proposal to

21 write to Mr. Evans bef ore the deadline, November

22 9th. Thank you.

23 MR. APRAHAM: Thank you. Any other comments,

24 guestions on 4, 11 or 13? I think our public

25 hearing is closed and if anybody has any guestions

BROWN & MEYERS
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1 they would like to ask on the Eastern Plume, we can

2 take a five minute break and come back and do

3 those.

4 Fred? Jeff? Nancy? No? Thank you very much

5 for your attention.

6 (The hearing concluded at 8:05 P.M.)

BROWN & MEYERS
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APPENDIX B
ARARs TABLES FOR EASTERN PLUME

TABLE B-l
CHEMICAL-SPECIFIC ARARs, CRITERIA, ADVISORIES, AND GUIDANCE
ROD: SITES 4, 11, 13
NAS BRUNSWICK
REQUIREMENT
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
GROUNDWATER/
SURFACE WATER
SDWA - MCLGs (40 CFR
141 .50 - 141.51)
Relevant and
Appropriate
MCLs have been promulgated for several common
organic and inorganic contaminants. These levels
regulate the concentration of contaminants in public
drinking water supplies, but may also be considered
relevant and appropriate for groundwater aqui fers used
for drinking water.
MCLGs are health-based criteria. As promulgated under
SARA, MCLGs are to be considered for drinking water
sources. MCLGs are available for several organic and
inorganic contaminants.
Primary MCLs have been set as the cleanup goals
when the primary MCL is available and a more
stringent State standard does not exist. Groundwater
extraction and treatment of the Eastern Plume will
continue to prevent further migration and to restore
the aqui fer. Monitoring of the Eastern Plume will
continue to determine i f cleanup goals have been
met. It is estimated that cleanup goals will be
attained throughout the plume over a time period
between 13 and 71 years.
The 1990 National Contingency Plan states that non-
zero MCLGs are to be used as goals. Because
groundwater at NAS Brunswick is not a current
source of drinking water, MCLGs are not applicable,
but may be relevant and appropriate. Contaminant
concentrations in groundwater were compared to
their MCLGs.
Maine Drinking Water Rules Relevant and
(10-144 CMR Chapters Appropriate
231-233)
Rules Relating to Testing Relevant and
of Private Water Systems Appropriate
Maine's Primary Drinking Water Standards are Groundwater at NAS Brunswick is not a current
equivalent to federal MCLs. When state levels are more source of drinking water; therefore, State Drinking
stringent than federal levels, the state levels may be Water Standards are relevant and appropriate.
used. Contaminant concentrations in groundwater were
compared to State standards to assess the potential
risks to human health due to consumption of
groundwater.
Appendix C outlines MEGs for organic and inorganic
compounds. MEGs include health advisories, which are
Groundwater at NAS Brunswick is not a current
source of drinking water; therefore, MEGs are
for Potentially Hazardous
Contaminants (10-144
CMR Chapter 233,
Appendix C)
relevant and appropriate. Contaminant
concentrations in groundwater were compared to
MEGs to assess the potential risks to human health
due to consumption of groundwater.
ARAR = Applicable or Relevant and Appropriate
Requirement
AWQC = Ambient Water Quality Criteria
CFR = Code of Federal Regulations
CMR = Code of Maine Rules
MCL = Maximum Contaminant Level
MCLG = Maximum Contaminant Level Goal
MEG= Maximum Exposure Guidelines
MRSA = Maine Revised Statues Annotated
NAS = Naval Air Station
SARA = Superfund Amendments and Reauthor!zation Act
SDWA = Safe Drinking Water Act
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TABLE B-2
LOCATION-SPECIFIC ARARS, CRITERIA, ADVISORIES, AND GUIDANCE

ROD: SITES 4, 11, 13
NAS BRUNSWICK
MEDIA
State
REQUIREMENT

Maine Standards for
Classification of
Groundwater (38
MRSA, Section 470)
Maine Site Location
Development Law and
Regulations (06-096
CMR Chapters
371-377)
Surface Water Toxics
Control Program (06-
696 CMR Chapter
530.5)
STATUS REQUIREMENT SYNOPSIS

Applicable This law reguires the classification of the state's
groundwater to protect, conserve, and maintain*
groundwater resources in the interest of the health,
safety, and general welfare of the people of the
state. Under the Maine standards, groundwater is
classified as GW-A.

Applicable This act and associated regulations govern new
developments, including those that handle
hazardous waste. New developments cannot
adversely affect existing uses, scenic character, or
natural resources in the municipality or neighboring
municipality.
Relevant and Except as naturally occurs, surface waters must be
Appropriate free of pollutants in concentrations which impart
toxicity and cause those waters to be unsuitable for
the existing and designated uses of the water body.
This rule promulgates federal water guality criteria
established by USEPA pursuant to Section 304(a) of
the Clean Water Act.
ACTION TO BE TAKEN TO ATTAIN ARAR

This regulation will apply if treated groundwater is
discharged back to groundwater. The Navy's
current discharge option is the Brunswick POTW. If
discharge to groundwater is employed, the
classification and uses of groundwater will
evaluated during development of discharge limits.

Those regulations concerning No Adverse
Environmental Impact (i.e., Chapter 375) are
applicable to implementation of the remedy. In
particular, standards for protection of groundwater
apply to construction and groundwater treatment
activities. However, any licenses reguired, by
reference, will not need to be obtained since
permits are not reguired for actions conducted on-
site at federal Superfund sites.
Groundwater is to be managed such that Maine's
water guality standards are met.
Notes:
ARAR = Applicable or Relevant and Appropriate Reguirements
CMR = Code of Maine Rules
MRSA = Maine Revised Statutes Annotated
MEDEP = Maine Department of Environmental Protection
NAS = Naval Air Station
POTW = publicly owned treatment works
RCRA = Resource Conservation and Recovery Act
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TABIiE B-3
ACTION-SPECIFIC ARARs, CRITERIA, ADVISORIES, AND GUIDANCE

ROD: SITES 4, 11, 13
NAS BRUNSWICK
REQUIREMENT

Federal
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN ARAR
RCRA Land Disposal Restrictions (40 CFR 268)
Underground Injection Control Program
To be Land disposal of RCRA hazardous wastes is restricted
determined without specified treatment. It must be determined that
the waste, beyond a reasonable doubt, meets the
definition of one of the specified restricted wastes and
including TCLP testing. LDRs are
the remedial action must constitute "placement" for the
land disposal restrictions to be considered applicable. For
each hazardous waste, the LDRs 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.

Applicable These regulations outline minimum program and
recordkeeping as required for permitting are set forth in
Part 146.
During treatment of groundwater, sludge containing
hazardous constituents will be generated. The selected
remedy includes provisions for analysis of this sludge,
potentially applicable if the sludge fails TCLP. The

selected remedy does address handling and disposal of
the sludge as a hazardous waste, if necessary.
This regulation will be applicable if treated
groundwater is (40 CFR 144, 146, 147, 1000)
performance standards for underground injection
discharged back to groundwater. The Navy's current
programs. Technical criteria and standards for siting,
discharged option is the Brunswick POTW. Discharge of
operation and maintenance, and reporting and
treated groundwater, by well as meet all state
Underground Injection Control Program requirements.
Treated groundwater must meet all SDWA standards prior
to well injection.
-------
CWA - Pretreatment Standards for POTW Applicable This regulation specifies pretreatment standards for
Discharge (40 CFR Part 403) discharges to a POTW. If treated groundwater is
discharge to a POTW, the POTW must have mechanisms
available to meet the reguirements of the National
Pretreatment Program - Introduction of Pollutants which
cause pass through or interference are prohibited.
Discharges must also comply with any local POTW
regulations. If hazardous waste is discharged to the
POTW, the POTW may be subject to RCRA permit-by-rule.

Maine Rules to Control the Subsurface Discharge Applicable This regulation prohibits the injection of hazardous waste
of Pollutants by Well Injection (06-096 CMR,
Chapter 543)
into or above water-bearing formations via a new Class IV
well. The subsurface discharge into or through a Class IV
well that would cause or allow the movement of fluid into
an underground source of drinking water that may result
in a violation of any Maine Primary Drinking Water
Standard, or which may otherwise adversely affect public
health, is prohibited.
This regulation is applicable since the Navy's current
discharge option is the Brunswick POTW. Because
treated groundwater is discharged to a POTW, the treated
water must meet all discharge limitations imposed by the
POTW.
These regulations will be applicable if treated
groundwater
is discharged back to groundwater. The Navy's current
discharge option is the Brunswick POTW. For discharge
to the subsurface, groundwater must be treated to a
target clean-up level less than or egual to the Maine MEGs
to be recharged to the aguifer.
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TABIiE B-3
ACTION-SPECIFIC ARARS, CRITERIA, ADVISORIES, AND GUIDANCE
REQUIREMENT
ROD: SITES 4, 11, 13
NAS BRUNSWICK
STATUS
REQUIREMENT SYNOPSIS
Maine Underground Storage Tank Rules relating
to standards for the installation, operation, and

proper closure of USTs 106-096 CMR Chapter
Maine Hazardous Waste Management Rules Relevant and
06-096 CMR, Chapters 800-802, 850, 851, Appropriate
853-857)
Notes:
CFR = Code of Federal Regulations
CMR = Code of Maine Regulations
CWA = Clean Water Act
DHS = Department of Human Services (State of Maine)
LDRs = Land Disposal Restrictions
MCL = Maximum Contaminant Level
MEDEP = Maine Department of Environmental Protection
MEG = Maximum Exposure Guidelines
NAS = Naval Air Station
POTW = publicly owned treatment works
RCRA = Resource Conservation and Recovery Act
Applicable The rules reguire the registration of all existing, new and
replacement underground storage facilities with the

MEDEP and authorizes and provides direction for the
Board of Environmental Protection to develop rules for the
design, installation, replacement, operation and closure of
underground oil storage tanks except for tanks used for
the storage of propane. The reguirements for corrective
action specify that when a leek or discharge occurs, the
contamination should be mitigated. These rules define
contamination as applied to groundwater, soils, and
surface water when one of the following is present: 1) the
presence of free product of an oil sheen; 2) an
exceedance of primary drinking water standards (i.e.,
Maine MCLs); 3) an exceedance of MEGs (as set forth in
Maine DHS memorandum dated 10/23/92); or 4) a
statistically significant increase in the concentration of
measured parameters when compared to background.

The rules provide a comprehensive program for handing,
storage, and recordkeeping at hazardous waste facilities.
They supplement the RCRA regulations.
ACTION TO BE TAKEN TO ATTAIN ARAR

Groundwater impacted by underground tanks shall be
mitigated.
Because these reguirements supplement RCRA hazardous
waste regulations, they are relevant and appropriate.
SDWA = Safe Drinking Water Act
TCLP = Toxicity Characteristic Leachate Procedure
UST = underground storage tank
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APPENDIX C

MEDEP LETTER OF CONCURRENCE

This concurrence is based on the State's understanding that the DEP will continue to participate in the
Federal Facilities Agreement and in the review and approval of operation, design, and monitoring of the
monitoring and extraction well network and treatment system. This concurrence is also based upon the
understanding that the proposed site investigation outlined in the January 08,1998, letter is implemented and
that the revised language shown in the enclosure (1) included with the letter dated January 22, 1998, is
included in the final ROD.

The Department looks forward to working with the Department of the Navy and the Environmental Protection
Agency to resolve the environmental problems posed by these sites. If you need additional information, do not
hesitate to contact me or my staff.

pc: etc

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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: REMOVAL ACTIONS 2

SECTION 4: REMEDIAL INVESTIGATIONS 3

SECTION 5: FEASIBILITY STUDIES 10

SECTION 6: PROPOSED PLANS AND PUBLIC HEARING
TRANSCRIPTS 12

SECTION 7: RECORDS OF DECISION 14

SECTION 8: POST-RECORD OF DECISION 16

SECTION 9: COMMUNITY RELATIONS 18

SECTION 10:PROGRAM GUIDANCE 25
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NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX

SECTION 1: PRELIMINARY ASSESSMENTS

Volume 1: 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.

SECTION 2: SITE INSPECTIONS

Volume 1: Field Site Inspection Report for the U.S. Naval Air Station, Brunswick, Maine,
prepared by NUS Corporation; August 1984 (Sites 1, 2, and 3).

Pollution Abatement Confirmation Study, Step 1A - Verification, prepared by
E.G. Jordan Co. [ABB Environmental Services, Inc.]; June 1995 (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.G. Jordan Co. [ABB Environmental Services,
Inc.], regarding the schedule of on-site exploration and sampling activities
during the Pollution Abatement Confirmation Study; October 30, 1984.

3. Memo of conversation between Robert Kowalczyk, Naval Facilities Engineering
Command, Northern Division, and William Fisher, E.G. Jordan Co. [ABB
Environmental Services, Inc.], regarding the preliminary data from the
Confirmation Study at Brunswick and the status of fieldwork; December 11, 1984.

4. Memo of conversation between Robert Kowalczyk, Naval Facilities Engineering
Command, Northern Division, and William Fisher, E.G. Jordan Co. [ABB
Environmental Services, Inc.], regarding the preliminary results of the NACIP
Study at Brunswick and the expected completion of the sampling; January 3, 1985.

5. Memo of conversation between Robert Kowalczyk, Naval Facilities Engineering
Command, Northern Division, and William Fisher, F.C. Jordan Co. [ABB
Environmental Services, Inc.], regarding the results of the NACIP Study at
Brunswick and the expected submittal of the report; January 15, 1985.

6. Letter to William Fisher, E.G. 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 Brunswick, and E.G. Jordan Co. [ABB Environmental
Services, Inc.], regarding the NACIP Confirmation Study Verification Phase
report; May 24, 1985.

8. Letter to William Fisher, E.G. 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, Brunswick, regarding transmittal of the
June 1985 [Pollution Abatement Confirmation Study, Step 1A - Verification]
Report; December 3, 1985.
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10. Letter to L.K. Jones, Naval Air Station, Brunswick, from Robert Jackson,
USEPA, regarding comments on the [June 1985] Pollution Abatement
Confirmation Study, Step 1A - Verification Report; January 13, 1986.

11. Letter to L.K. Jones, Naval Air Station, Brunswick, from Anthony Leavitt,
Maine Department of Environmental Protection (DEP), regarding comments on
the [June 1985] Pollution Abatement Confirmation Study, Step 1A - 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.

SECTION 3: REMOVAL ACTIONS

Volume 1: Not applicable to Sites 4, 11, 13 and the Eastern Plume

Volume 2: Not applicable to Sites 4, 11, 13 and the Eastern Plume

Volume 3: Action Memorandum, Site 11 - Fire Training Area, prepared by Halliburton
NUS, Corp.; October 1994.

Drum Investigation Summary Report Revision 1 for Site 11 - Fire Training Area,
prepared by Halliburton NUS, Corp.; August 1995.

SECTION 4 REMEDIAL INVESTIGATIONS

Volume 1: Remedial Investigation/Feasibility Study Work Plan, formerly Draft Pollution
Abatement Confirmation Study Work Plan - Step 1 prepared by E.G. Jordan Co.
[ABB Environmental Services, Inc.); April 1988 (Sites 1,2,3,4,7,8,9).

Addendum to RI/FS Work Plan, prepared by E.G. Jordan Co. [ABB
Environmental Services, Inc.]; July 1988 (Sites 1,2,3,4,7,8,9).

Additional Sampling Plan, prepared by E. C. Jordan Co. [ABB Environmental
Services, Inc.]; August 1989 (Sites 1,2,3,4,7,8,9).

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, USEPA, from Kenneth Finkelstein, National Oceanic
and Atmospheric Administration (NOAA), regarding comments on the RI/FS
Workplan for Phase II field activity; April 14, 1989.

5. Letter to Charlotte Head, USEPA, from Sharon Christopherson, National
Oceanic and Atmospheric Administration (NOAA), regarding responses to Navy
comments on NOAA's work plan recommendations; May 8, 1987.

6. Letter to David Epps and Robert Kowalczyk, Naval Facilities Engineering
Command, Northern Division, from Charlotte Head, USEPA, regarding the
[Pollution Abatement Confirmation Study, Step] IB - Characterization Work
Plan meeting, and a discussion for the Superfund program; June 29, 1987.
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7. Meeting summary of June 12, 1987, planning meeting at USEPA Region I
offices in Boston, Massachusetts, among USEPA; U.S. Navy; E.G. Jordan Co.
[ABB Environmental Services, Inc.]; Maine DEP; NORA; Camp, Dresser &
McKee; June 30, 1987.

8. Letter to Robert Kowalczyk, Naval Facilities Engineering Command, Northern
Division, from Jack Hoar, Camp, Dresser & McKee, regarding meeting notes
from a June 12, 1987, planning meeting at USEPA Region I offices in Boston,
Massachusetts, among USEPA; U.S. Navy; E.G. Jordan Co. [ABB
Environmental Services, Inc.]; Maine DEP; NCAA; 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.

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] RI/FS 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 RI/FS 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 RI/FS 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.

21. 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.
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22. Letter to Ronald Springfield, Naval Facilities Engineering Command, Northern
Division, from Melville Dickenson, E.G. Jordan Co. [ABB Environmental
Services, Inc.], regarding transmittal of the Additional Sampling Plan and
some outstanding issues that needed further discussion with the regulatory
agencies; August 9, 1989.

23. Letter to Ronald Springfield, Naval Facilities Engineering Command, Northern
Division, from David Webster, USEPA, regarding comments on the August
1989 Draft Additional Sampling Plan; September 26, 1989.

24. Letter 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.

Volume 2: Post-Screening Work Plan, prepared by E.G. 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.G. Jordan Co. [ABB
Environmental Services, Inc.]; November 1990 (Sites 1,2,5,6,8,9,11,12,13,14,
Eastern Plume; Treatability Studies 8; 11).

Correspondence:

1. Letter to Kenneth Marriott, Department of the Navy, Northern Division, from
Ted Wolfe, Maine DEP, regarding comments on the April 1990 Draft Post-
Screening Work Plan; May 1, 1990.

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.

Volume 3: Round I Data Package, Phase I - Remedial Investigation, prepared by E.G.
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.G. Jordan Co. [ABB-ES] regarding the transmittal of the
Round I Data Package; January 13, 1989.

3. Letter to T.G. Sheckels, Department on the Navy, Northern Division, from
David Webster, USEPA, regarding comments on the Round I Data Package and
recommendations on future data packages; March 13, 1989.

4. Letter to Charlotte Head, USEPA, from Kenneth Finkelstein, National Oceanic
and Atmospheric Administration, regarding comments on the Rounds I and II
Data Packages; March 13, 1989.
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Volume 4: Round II Data Package, Phase I - Remedial Investigation, prepared by E.G.
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.G.
Jordan Co. [ABB Environmental Services, Inc.]; July 1989 (Sites 1,2,3,4,7,8,9).

Correspondence:

1. Letter to Ronald Springfield, Northern Division, Naval Facilities Engineering
Command, from David Gulick, E.G. Jordan, Co. [ABB-ES], regarding
transmittal of and comments on the Round II Data Package; March 10, 1989.

2. Letter to Ronald Springfield, Northern Division, Naval Facilities Engineering
Command, from David Gulick, E.G. Jordan, Co. [ABB-ES], regarding
transmittal of and comments on the Round III 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 III Data
Package; August 31, 1989.

4. Letter to Ronald Springfield, Northern Division, Naval Facilities Engineering
Command, regarding comments on the Round III Data Package; October 4, 1989.

Volume 5: Remedial Investigation Feasibility Study - Round IV Data Package, prepared by
E.G. Jordan Co. [ABB Environmental Services, Inc.]; January 1990 (Sites
1,2,3,4,7,8,9,11,13) .

Correspondence:

1. Letter to Meghan Cruise, USEPA, from Kenneth Finkelstein, National Oceanic
and Atmospheric Administration, regarding comments on the Round 4 [IV] Data
Package; August 28, 1989.

2. Letter to Kenneth Marriott, Northern Division, Naval Facilities Engineering
Command, regarding comments on the Round IV Data Package; March 5, 1990.

Volume 6: Draft Final Remedial Investigation Report Volume I, prepared by E.G. 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.

Volume 7: Draft Final Remedial Investigation Report Volume 2: Appendices A-J, prepared
by E.G. Jordan Co. [ABB Environmental Services, Inc.]; August 1990 (Sites
1,3; 2; 4,11,13; 7; 8; 9).

Volume 8: Draft Final Remedial Investigation Report Volume 3: Appendices K-P, prepared
by E.G. Jordan Co. [ABB Environmental Services, Inc.]; August 1990 (Sites
1,3; 2; 4,11,13; 7; 8; 9) .
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Volume 9: Draft Final Remedial Investigation Report Volume 4: Appendix Q - Risk
Assessment, prepared by E.G. Jordan Co. [ABB Environmental Services, Inc.];
August 1990 (Sites 1,3; 2; 4,11,13; 7; 8; 9).

Correspondence:

1. Letter to Ronald Springfield, Naval Facilities Engineering Command, Northern
Division, from Charlotte Head for David Webster, USEPA, regarding the
inclusion of the [Step] 1A Verification Study data in the risk 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.

Volume 10: Remedial Investigation Feasibility Study Round V Data Package, prepared by
E.G. Jordan Co. [ABB Environmental Services, Inc.]; March 1991 (Sites
5,6,8,9,11,12,14, Eastern Plume; Treatability Study for Sites 8,11).

Volume 11: Draft Final Supplemental RI Report Volume 1, prepared by E.G. 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.

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.

Volume 12: Draft Final Supplemental RI Report Volume 2: Appendices A-J, prepared by
E.G. Jordan Co. [ABB Environmental Services, Inc.]; August 1991 (Sites
5,6,8,9,11,12, Eastern Plume).
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Volume 13: Draft Final Supplemental RI Report Volume 3: Appendices K-Q, prepared by
E.G. Jordan Co. [ABB Environmental Services, Inc.]; August 1991 (Sites
5,6,8,9,11,12, Eastern Plume).

Volume 14: Technical Memorandum: Site 11, prepared by ABB, Environmental Services,
Inc.; January, 1994.

Correspondence:

1. Letter to Fred Evans, Department of the Navy, Northern Division, from Robert
Lim, USEPA, regarding comments on the [November 1993] Draft Technical
Memorandum: Site 11; December 6, 1993.

2. Letter to Fred Evans, Department of the Navy, Northern Division, from Nancy
Beardsley, Maine DEP, regarding comments on the [November 1993] Draft
Technical Memorandum: Site 11; December 8, 1993.

3. Letter to Fred Evans, Department of the Navy, Northern Division, from Loukie
Lofchie, BACSE, regarding comments on the [November 1993] Draft Technical
Memorandum: Site 11; December 10, 1993.

Volume 15: Not applicable to Sites 4, 11, 13 and the Eastern Plume

SECTION 5: FEASIBILITY STUDIES

Volume 1: Draft Final Phase I Feasibility Study Development and Screening of Alternatives,
prepared by E.G. 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
Reguirements (ARARs) for Remedial Investigation/Feasibility Study (RI/FS);
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.

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.

Volume 2: Numerical Modeling Report, prepared by ABB Environmental Services, Inc.;
January 1993 (Sites 1 & 3; Eastern Plume).
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Correspondence:

1. 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.

2. 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.

3. 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.

4. 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.

Volume 3: Feasibility Study Volume 1, prepared by E.G. 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, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the November 1991 Draft Final
Feasibility Study Report; January 2, 1992.

6. Comments from BACSE on the Feasibility Study Report, February 18, 1992.

Volume 4: Feasibility Study Volume 2: Appendices A - 0, prepared by E.G. Jordan Co.
[ABB Environmental Services, Inc.]; March 1992 (Sites 2; 4,11,13; 5,6; 7; 9;
12; 14; Eastern Plume).

Volume 5: Not applicable to Sites 4, 11, 13 and the Eastern Plume

SECTION 6: PROPOSED PLANS AND PUBLIC HEARING TRANSCRIPTS

Volume 1: Proposed Plan for the Eastern Plume, prepared by E.G. Jordan Co. [ABB
Environmental Services, Inc.]; December 1991.

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:

1. Letter to James Shafer, Department of the Navy Northern Division, from
Meghan Cassidy, USEPA, regarding comments on the July 1991 Draft Proposed
Plan - Eastern Plume; August 2, 1991.
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2. Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the July 1991 Draft Proposed Plan -
Eastern Plume; August 15, 1991.

3. Letter to James Shafer, Department of the Navy, Northern Division, from
Meghan Cassidy, USEPA, regarding comments on the October 1991 Draft
Proposed Plan - Eastern Plume; October 31, 1991.

4. Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding comments on the October 1991 Draft Proposed
Plan - Eastern Plume; November 6, 1991.

5. Letter to James Shafer, Department of the Navy, Northern Division, from
Edmund Benedikt, regarding comments on the Brunswick Naval Air Station
clean-up proposals [Proposed Plans for Eastern Plume and Sites 1 and 3, dated
December 1991] submitted for public review; January 3, 1992.

6. Letter to James Shafer, Department of the Navy, Northern Division, from Ralph
F. Keyes, Merrymeeting Audubon Society, regarding comments on the Proposed
Remedial Action Plan [Proposed Plans for the Eastern Plume and Sites 1 and 3,
dated December 1991]; January 8, 1992.

7. 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.

8. 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.

9. Letter to James Shafer, Department of the Navy, Northern Division, from
Edmund E. Benedikt, Friends of Merrymeeting Bay, regarding comments on the
December 1991 Proposed Plans for Sites 1 and 3 and the Eastern Plume;
January 3, 1992.

Volume 2: Not applicable to Sites 4, 11, 13 and the Eastern Plume

Volume 3: Proposed Plan for Sites 4, 11 and 13, prepared by ABB Environmental
Services, Inc.; October 1996.

Transcript of the Public Meeting [Hearing] for Proposed Plan, Sites 4, 11, and
13, prepared by Brown & Meyers; October 17, 1996.

Correspondence:

1. Letter to Fred Evans, Department of the Navy, Northern Division, from Nancy
Beardsley, Maine DEP, regarding comments on the Draft Proposed Plan - Sites
4, 11, and 13; July 24, 1996.

2. Letter to Fred Evans, Department of the Navy, Northern Division, from Loukie
Lofchie, BACSE, regarding comments on the Draft Proposed Plan - Sites 4, 11,
and 13; July 25, 1996.

3. Letter to Fred Evans, Department of the Navy, Northern Division, from Robert
Lim, USEPA, regarding comments on the Draft Proposed Plan - Sites 4, 11,
and 13; July 26, 1996.

SECTION 7: RECORDS OF DECISION
Volume 1: Record of Decision for an Interim Remedial Action - Eastern Plume, prepared
by ABB Environmental Services, Inc.; June 1992.
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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 March 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.

3. Letter to James Shafer, Department of the Navy, Northern Division, from Mary
Jane O'Donnell, USEPA, regarding comments on the [March 1992] Draft
Interim Record of Decision for the: Eastern Plume; April 2, 1992.

4. 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 Interim Record of
Decision for the Eastern Plume; June 4, 1992.

Volume 2: Not applicable to Sites 4, 11, 13 and the Eastern Plume

Volume 3: Record of Decision for No Further Action at Sites 4, 11, and 13 and a Remedial
Action for the Eastern Plume, prepared by ABB Environmental Services, Inc.;
February 1998.

Correspondence:

1. Letter to Loukie Lofchie, BACSE, from Carolyn Lepage, Lepage Environmental
Services, Inc., regarding comments on the Draft Record of Decision for a
Remedial Action at Sites 4, 11, and 13; April 3, 1997.

2. Letter to Fred Evans, Department of the Navy, Northern Division, from Claudia
Salt, MEDEP, regarding comments on the Draft Record of Decision for a
Remedial Action at Sites 4, 11, and 13; April 4, 1997.

3. Letter to Fred Evans, Department of the Navy, Northern Division, from Robert
Lim, USEPA, regarding comments on the Draft Record of Decision for a
Remedial Action at Sites 4, 11, and 13; April 10, 1997.

4. Letter to Loukie Lofchie, BACSE, from Carolyn Lepage, Lepage Environmental
Services, Inc., regarding comments on the Draft Final Record of Decision for
No Further Action at Sites 4, 11, and 13 and a Remedial Action for the Eastern
Plume; August 16, 1997.

5. Letter to Fred Evans, Department of the Navy, Northern Division, from Robert
Lim, USEPA, regarding comments on the Draft Final Record of Decision for
No Further Action at Sites 4, 11, and 13 and a Remedial Action for the Eastern
Plume; August 18, 1997.

6. Letter to Fred Evans, Department of the Navy, Northern Division, from Claudia
Salt, MEDEP, regarding comments on the Draft Final Record of Decision for
No Further Action at Sites 4, 11, and 13 and a Remedial Action for the Eastern
Plume; August 25, 1997.

7. Letter to Fred Evans, Department of the Navy, Northern Division, from Robert
Lim, USEPA, regarding comments on the Revised Draft Final Record of
Decision for No Further Action at Sites 4, 11, and 13 and a Remedial Action
for the Eastern Plume; December 17, 1997.

8. Letter to Fred Evans, Department of the Navy, Northern Division, from Claudia
Salt, MEDEP, regarding comments on the Revised Draft Final Record of
Decision for No Further Action at Sites 4, 11, and 13 and a Remedial Action
for the Eastern Plume; December 30, 1997.
-------
9. Letter to Loukie Lofchie, BACSE, from Carolyn Lepage, Lepage Environmental
Services, Inc., regarding comments on the Revised Draft Final Record of
Decision for No Further Action at Sites 4, 11, and 13 and a Remedial Action
for the Eastern Plume; January 5, 1998.

10. Letter to Robert Lim, USEPA, and Claudia Salt, MEDEP, from Emil Klawitter,
Department of the Navy, Northern Division, regarding comments on the Revised
Draft Final Record of Decision for No Further Action at Sites 4, 11, and 13 and
a Remedial Action for the Eastern Plume; January 22, 1998.

11. Letter to Carolyn Lepage, Lepage Environmental Services, Inc., from Emil
Klawitter, Department of the Navy, Northern Division, regarding comments on
the Revised Draft Final Record of Decision for No Further Action at Sites 4,
11, and 13 and a Remedial Action for the Eastern Plume; January 22, 1998.

Volume 1: Remedial Design Summary Report, prepared by ABB Environmental Services,
Inc.; May 1993 (Sites 1, 3, 5, 6, 8, and the Eastern Plume).

Long Term Monitoring Plan: Building 95, Sites 1 and 3, and Eastern Plume,
prepared by ABB Environmental Services, Inc.; August 1994.

Correspondence:

1. Letter to Fred Evans, Department of the Navy, Northern Division, from Robert
Lim, USEPA, regarding comments on the Draft Long Term Monitoring Plan:
Building 95, Sites 1 and 3, and Eastern Plume; December 20, 1993.

2. Letter to Fred Evans, Department of the Navy, Northern Division, from Robert
Lim, USEPA, regarding comments on the Draft Final Long Term Monitoring
Plan: Building 95, Sites 1 and 3, and Eastern Plume; March 2, 1994.

3. Letter to Fred Evans, Department of the Navy, Northern Division, from Nancy
Beardsley, Maine DEP, regarding comments on the Draft Final Long Term
Monitoring Plan: Building 95, Sites 1 and 3, and Eastern Plume; March 7, 1994.

Volume 2: Environmental Contaminants in Fish From Mere Brook, prepared by U.S. Fish
and Wildlife Service; February 1997.

Correspondence:

1. Letter to Fred Evans, Department of the Navy, Northern Division, from Claudia
Salt, Maine DEP, regarding comments on the Packer Test Pilot Study of the
Eastern Plume; March 12, 1997.

2. Letter to Fred Evans, Department of the Navy, Northern Division, from Claudia
Salt, Maine DEP, regarding comments on the Work Plan for the Geostatistical
Assessment of the Eastern Plume; February 7, 1997.

3. Letter to Fred Evans, Department of the Navy, Northern Division, from Robert
Lim, USEPA, regarding comments on the Work Plan for the Geostatistical
Assessment of the Eastern Plume; February 13, 1997.

4. Letter to Fred Evans, Department of the Navy, Northern Division, from Claudia
Salt, Maine DEP, regarding comments on the Final Work Plan for the
Geostatistical Assessment of the Eastern Plume; July 16, 1997.

Quarterly Monitoring Event 1 - March 1995, Sites 1 and 3 and Eastern Plume, prepared by EA
Engineering, Science, and Technology; June 1995.

Quarterly Monitoring Event 2 - May 1995, Sites 1 and 3 and Eastern Plume, prepared by EA
Engineering, Science, and Technology; August 1995.

Quarterly Monitoring Event 3 - August 1995, Sites 1 and 3 and Eastern Plume, Vol. 1 of 2,
prepared by EA Engineering, Science, and Technology; December 1995.

Quarterly Monitoring Event 3 - August 1995, Sites 1 and 3 and Eastern Plume, Vol. 2 of 2,
prepared by EA Engineering, Science, and Technology; December 1995.
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Quarterly Monitoring Event 4 - November 1995, Sites 1 and 3 and Eastern Plume, Vol. 1 of 2,
prepared by EA Engineering, Science, and Technology; February 1996.

Quarterly Monitoring Event 4 - November 1995, Sites 1 and 3 and Eastern Plume, Vol. 2 of 2,
prepared by EA Engineering, Science, and Technology; February 1996.

1995 Annual Report - Monitoring Events 1 Through 4, prepared by EA Engineering, Science,
and Technology; July 1996.

Quarterly Monitoring Event 5 - February 1996, Sites 1 and 3 and Eastern Plume, Vol. 1 of 2,
prepared by EA Engineering, Science, and Technology; July 1996.

Quarterly Monitoring Event 5 - February 1996, Sites 1 and 3 and Eastern Plume, Vol. 2 of 2,
prepared by EA Engineering, Science and Technology; July 1996.

Final Report Remediation of Sites 1, 3, 5, 6 and 8, Vols. I-IV, prepared by OHM Remediation
Services Corp.; July 1996.

Quarterly Monitoring Event 6 - June 1996, Sites 1 and 3 and Eastern Plume, Vol. 1 of 2,
prepared by EA Engineering, Science, and Technology; October 1996.

Quarterly Monitoring Event 6 - June 1996, Sites 1 and 3 and Eastern Plume, Vol. 2 of 2,
prepared by EA Engineering, Science, and Technology; October 1996.

Results of Direct-Push Groundwater Sampling Conducted on 27-29 August and 4 September 1996
in the Vicinity of MW-311, prepared by EA Engineering, Science, and Technology; October 25, 1996.

Final Report Eastern Plume Groundwater Treatment Plant, prepared by OHM Remediation
Services Corp.; July 1996.

Packer Test Pilot Study of the Eastern Plume, prepared by EA Engineering, Science, and
Technology; January 1997.

Quarterly Monitoring Event 7 - November 1996, Sites 1 and 3 and Eastern Plume, Vol. 1 of 2,
prepared by EA Engineering, Science, and Technology; March 1997.

Quarterly Monitoring Event 7 - November 1996, Sites 1 and 3 and Eastern Plume, Vol. 2 of 2,
prepared by EA Engineering, Science, and Technology; March 1997.

Final Report Monitoring Event 8 - March 1997, Sites 1 and 3 and Eastern Plume, Vol. 1 of 2,
prepared by EA Engineering, Science, and Technology; July 1997.

Final Report Monitoring Event 8 - March 1997, Sites 1 and 3 and Eastern Plume, Vol. 2 of 2,
prepared by EA Engineering, Science, and Technology; July 1997.

Final Work Plan for the Geostatistical Assessment of the Eastern Plume, prepare by EA
Engineering, Science, and Technology; July 1997.

SECTION 9: COMMUNITY RELATIONS

Volume 1: 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

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
collected 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 reguest; 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 reguested 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 reguest; 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 guestion 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.

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 meeting/hearing 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 meeting/hearing 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 meeting/hearing 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 meeting/hearing and public comment period
for the revised Proposed Plan for Site 8 that now includes excavation; March 1993.

22. Public notice announcing the public meeting/hearing 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.
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Volume 2: Technical Review Committee Meeting Minutes (November 1987 to December 10,1992).

1. Meeting minutes of December 3, 1987, Technical Review Committee (TRC)
meeting to get acguainted, 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 TRC members from Geoffrey Cullison, Naval Air Station, Brunswick,
regarding coffections to the January 11, 1988, meeting minutes; February 3, 1988.

4. Meeting minutes of May 17, 1988, TRC meeting to discuss the draft charter for
the TRC at Brunswick and a review of the revised April 1988 RI/FS work plan; undated.

5. Meeting minutes of July 8, 1988, TRC meeting to attend a site tour and to
confirm proposed locations; of field investigations, undated.

6. Meeting minutes of November 22, 1988, TRC meeting to review analytical data
from the first round of sampling, and to establish parameters for the second
round of sampling; undated.

7. Meeting minutes of February 22, 1988, TRC meeting to review validated
analytical data from the first round of sampling, and to present preliminary
information for the forthcoming risk analysis and alternative development
deliverables; undated.

8. Memo of TRC meeting minutes of March 28, 1989, to discuss the structure of
the third round of sampling; April 10, 1989.

9. Letter to Bruce Darsey, Department of the Navy, Naval Air Station, Brunswick,
reguesting copies of the March 27, 1989, TRC meeting minutes; April 18, 1989.

10. Letter to Senator William Cohen from E.B. Darsey, Department of the Navy,
Naval Air Station, Brunswick, regarding a copy of the reguested TRC meeting
minutes, and the contact for the IRP program at the base; April 29, 1989.

11. Meeting minutes of June 20, 1989, TRC meeting to discuss the Additional
Sampling Plan, the RI/FS program, and the schedule for its implementation;
July 11, 1989.

12. Meeting minutes of August 10, 1989, TRC meeting to discuss the third round
of sampling; undated.

13. Meeting minutes of February 13, 1990, TRC meeting to discuss the fourth
round of sampling; January 22, 1990.

14. Letter to TRC members from James Shafer, Department of the Navy, Northern
Division, regarding the May 22, 1990, TRC meeting minutes in which the Draft
Initial Screening report, Draft Remedial Investigation report, and Draft Post
Screening Plan were discussed; July 12, 1990.

15. Memo to James Shafer, Department of the Navy, Northern Division, from
Geoffrey Cullison, Naval Air Station, Brunswick, transmitting the omitted
handout from the previous letter; July 19, 1990.

16. Letter to TRC members from James Shafer, Department of the Navy, Northern
Division, regarding minutes from the September 13, 1990, TRC meeting;
October 31, 1990.

17. Letter to TRC members from James Shafer, Department of the Navy, Northern
Division, regarding minutes from the January 10, 1991, TRC meeting; January 28, 1991.

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.
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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 Debhs 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.

Volume 3: Technical Review Committee/Restoration Advisory Board Meeting Minutes
(March 1993 to April 1997)
Technical Meeting Minutes (March 1994 to September 1996)

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.

4. Meeting minutes of January 13, 1994, TRC meeting to discuss the Site 11
Technical Memorandum; Site 9 Interim Groundwater Record of Decision;
Remedial Design for Sites 1, 3, 5, 6, 8, Eastern Plume, and Building 95; and
the Site Investigation report for the Swampy Road and Merriconeag Extension
Debris Sites; undated.

5. Meeting minutes of March 17, 1994, technical meeting to discuss the Site 11
Time Critical Removal Action; Building 95 construction project; West Runway
Study Area Site Investigation Report; and well purging and sampling.
procedures; undated.

6. Meeting minutes of April 28, 1994, TRC meeting to discuss the Site 11 Time
Critical Removal Action; Site 9 Interim Groundwater Record of Decision;
Remedial Design for Sites 1, 3, 5, 6, 8, Eastern Plume, and Building 95; Long
Term Monitoring for Building 95, Sites 1 and 3 and Eastern Plume; undated.

7. Meeting minutes of May, 19, 1994, technical meeting to discuss additional
source investigations at Site 9; undated.

8. Meeting minutes of June 9, 1994, technical meeting to discuss Site 11 Time
Critical Removal Action,

9. Meeting minutes of June 23, 1994, TRC meeting to discuss the Site 11 Time
Critical Removal Action; Site 9 Proposed Plan and Interim Groundwater ROD;
Remedial Design for Sites 1, 3, 5, 6, 8, Eastern Plume, and Building 95;
confirmatory sampling at West Runway Study Area; undated.
-------
10. Meeting minutes of August 4, 1994, technical meeting to discuss the
construction status for remediation of Building 95 and Sites 1, 3, 5, 6, 8 and
Eastern Plume, the Site 11 Removal Action; Site 9 Interim Groundwater ROD
and Long Term Monitoring Plan, Site, 9 Site Investigation Work Plan; migration
of the Eastern Plume; additional sampling at Building 95; undated.

11. Meeting minutes of September 22, 1994, TRC meeting to discuss the Site 11
Time Critical Removal Action; Site 9, Long Term Monitoring Plan and Site
Investigation Work Plan; construction status for remediation of Sites 1, 3, 5,
6, 8, Eastern Plume, and Building 95; establishment of a Restoration Advisory
Board; undated.

12. Meeting minutes of November 3, 1994, technical meeting to discuss Proposed
Plans and RODs for Sites 2, 7, 12, and 14; the construction status for
remediation of Building 95 and Sites 1, 3, 5, 6, 8 and Eastern Plume; the Site
11 Removal Action; Site 9 Long Term Monitoring Plan and Site Investigation
Work Plan; additional sampling at Building 95; undated.

13. Meeting minutes of December 8, 1994, technical meeting to discuss the
construction status for remediation of Building 95 and Sites 1, 3, 5, 6, 8 and
Eastern Plume; Proposed Plans and RODs for Sites 2, 7, 12, and 14; the Site
11 Removal Action; Site 9 Site Investigation Work Plan; confirmatory sampling
at Building 95; relative risk evaluation; undated.

14. Meeting minutes of January 11, 1995, TRC meeting to discuss Proposed Plans
and RODs for Sites 2, 7, 12, and 14; the Site 9 Source Investigation Sampling
and Analysis Plan; construction status of remediation of Sites 1, 3, 5, 6, 8,
Eastern Plume, and Building 95; status of the Restoration Advisory Board; undated.

15. Meeting minutes of March 8, 1995, technical meeting to discuss the construction
status for remediation of Building 95 and Sites 1, 3, 5, 6, 8 and Eastern
Plume; Proposed Plans and RODs for Site 2; Site 11 Soil Analysis, Site 9 Long
Term Monitoring; confirmatory sampling at Building 95; undated.

16. Meeting minutes of April 19. 1995, TRC meeting to discuss the Site 9 Source
Investigation; construction status of remediation of Sites 1, 3, 5, 6, 8,
Eastern Plume, and Building 95; Site 11 excavation; basewide long term
monitoring; status of the Restoration Advisory Board; undated.

17. Meeting minutes of July 25, 1995, RAB meeting to discuss the construction
status of the remediation of Sites 1, 3, 5, 6, 8, Eastern Plume, and Building
95; basewide long term monitoring; Site 9 Source Investigation; Site 11
excavation; undated.

18. Meeting minutes of September 13, 1995, technical meeting to discuss the
construction status of the remediation of Sites 1, 3, 5, 6, 8, Eastern Plume
and Building 95; Site 9 Source Investigation; basewide long term monitoring;
Site 11 post-removal action; undated.

19. Meeting minutes of October 25, 1995, RAB meeting to discuss the construction
status of the remediation of Sites 1, 3, 5, 6, 8, Eastern Plume, and Building
95; Site 9 Source Investigation; basewide long term monitoring; undated.

20. Meeting minutes of January 25, 1996, RAB meeting to discuss the construction
status of the remediation of Sites 1, 3, 5, 6, 8, Eastern Plume, and Building
95; Proposed Plans and RODS for Site 2, Sites 4, 11, and 13, Site 7, Site 12,
and Site 14; Site 9 Source Investigation; basewide long term monitoring;
undated.

21. Meeting minutes of May 1, 1996, RAB meeting to discuss the construction
status of the remediation of Sites 1, 3, 5, 6, 8, Eastern Plume, and Building
95; Proposed Plans and RODS for Site 2, and Sites 4, 11, and 13; Site 9 Source
Investigation; basewide long term monitoring; Pump Test Report/Numerical
Modeling Report; Building 95 Closure Report; undated.
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22. Meeting minutes of August 1, 1996, RAB meeting to discuss Proposed Plans
and RODS for Site 2, and Sites 4, 11, and 13; basewide long term monitoring;
Remedial Action Final Inspection; extraction well issues; monitoring well MW-
311; undated.

23. Meeting minutes of September 5, 1996, technical meeting to discuss Proposed
Plans and ROD for Sites 4, 11, and 13; basewide long term monitoring;
extraction well status; monitoring well MW-311; undated.

24. Meeting minutes of October 31, 1996, RAB meeting to discuss the ROD for
Sites 4, 11, and 13; basewide long term monitoring; extraction well issues;
monitoring well MW-311; undated.

25. Meeting minutes of January 30, 1997, RAB meeting to discuss the Proposed
Plan and ROD for Site 2; ROD for Sites 4, 11, and 13; basewide long term
monitoring; geostatistical analysis work plan; Site 9 Source Investigation
Report; extraction well issues; treatment plant modifications; undated.

26. Meeting minutes of April 23, 1997, RAB meeting to discuss the ROD for Sites
4, 11, and 13; basewide long term monitoring; geostatistical analysis work
plan; extraction well issues; treatment plant status; status of the IRP sites; undated.

Volume 1: Quality Assurance Program Plan, prepared by E.G. Jordan Co. [ABB
Environmental Services, Inc.]; February 1988 (all sites)

Federal Facility Agreement among the U.S. Department of the Navy, USEPA,
and Maine DEP; October 19, 1990.
SECTION 10 (continued)

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 RI/FS program at the NAS
Brunswick; January 20, 1987.

6. Letter to David Epps and Robert Kowalczyk, Naval Facilities Engineering
Command, Northern Division, from Charlotte Head, USEPA, regarding the
current status and goals of the investigations; June 29, 1987.

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 RI/FS 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
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 RI/FS
under the Comprehensive Environmental Response, Compensation, and Liability
Act; December 17, 1987.

13. Letter to Merrill Hohman, USEPA, from E.B. Darsey, Naval Air Station
Brunswick, regarding comments received at the February 10, 1988, TRC
meeting on the status of the RI/FS program; February 17, 1988.

14. Letter to Ronald Springfield, Naval Facilities Engineering Command, Northern
Division, from David Webster for Charlotte Head, USEPA, regarding the extent
of quality assurance and quality control of validation for samples at Naval Air
Station Brunswick; April 25, 1988.

15. Letter to Ronald Springfield, Naval Facilities Engineering Command, Northern
Division, from David Webster for Charlotte Head, USEPA, regarding the
evaluation of sites that were not incorporated into the [Hazard Ranking System]
package, especially Sites 5 and 6; April 25, 1988.

16. Letter to Meghan Cruise, USEPA, from Alan Prysunka, Maine DEP, regarding
comments on the Federal Facility Agreement; November 8, 1989.

17. Letter to Meghan Cruise, USEPA, from Susan Weddle, TRC community
member, regarding comments on the Federal Facility Agreement; November 16, 1989.

18. Letter to Meghan Cruise, USEPA, from Jeanne Johnson, Town of Brunswick
Conservation Commission, regarding a request for an 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, E.G. 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.

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.
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24. Letter to Thomas Sheckels, Naval Facilities Engineering Command, Northern
Division, from Alan Prysunka, Maine DEP, regarding ARARs [Applicable or
relevant and appropriate reguirements] 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 FFA for preparing
the response to comments on the Draft Feasibility Study and Draft Remedial
Investigation reports; May 18, 1990.

26. Letter to James Shafer, Naval Facilities Engineering Command, Northern
Division, from Meghan Cassidy, USEPA, regarding a notice to proceed with the
Feasibility Study activities at Naval Air Station Brunswick; June 21, 1990.

27. Letter to Meghan Cassidy, USEPA, from James Shafer, Naval Facilities
Engineering Command, Northern Division, regarding an extension under the
FFA for preparing the response to comments on the Draft Feasibility Study and
Draft Remedial Investigation reports; June 25, 1990.

28. Letter to James Shafer, Department of the Navy, Northern Division, from Ted
Wolfe, Maine DEP, regarding invertebrate tissue analysis for mercury along the
Maine coast for establishing background mercury levels; February 24, 1992.

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"
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APPENDIX E

COST ESTIMATE FOR THE SEIiECTED REMEDY

TABIiE E-l
COST ESTIMATE FOR THE SEIiECTED REMEDY

SITES 4, 11, 13, AND EASTERN PLUME ROD
NAS BRUNSWICK
Cost Item
Cost
Present Worth
Treatment Plant Operation and Maintenance
Utilities
Disposal Fee to Sewer District
Long-term Groundwater Monitoring
5-year Reviews
Sub-total
Administrative & misc. (10 percent)
Total Present Worth

Notes:
$300,000/yr
$ 75,000/yr
$200,000/yr
$150,000/yr
$ 75,000/5-yr
$3,120,000
$ 780,000
$2,080,000
$1,560,000
$ 140,000
$7,680,000
$ 770,000
$8,450,000
i = 7%
n = 20 yrs
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