Superfund Record of Decision Brunswick Naval Air Station Site 2 Orion Street LF (South) Brunswick ME


                                    EPA/ROD/R01-98/129
                                    1998
EPA Superfund
     Record of Decision:
     BRUNSWICK NAVAL AIR STATION
     EPA ID: ME8170022018
     OU07
     BRUNSWICK, ME
     09/29/1998

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EPA 541-R98-129

                         U.S. DEPARTMENT OF THE NAVY
                       INSTALLATION RESTORATION PROGRAM

                         NAVAL AIR STATION BRUNSWICK
                               BRUNSWICK, MAINE

                                    FINAL
                              RECORD OF DECISION
                                  FOR SITE 2
                                     AT
                         NAVAL AIR STATION BRUNSWICK
                              BRUNSWICK, MAINE
                                Prepared for

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

                                 Prepared by

                           Harding Lawson Associates
                             Portland, Maine 04112
                              Project No. 9219-02

                                 SEPTEMBER 1998

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                           TABIiE OF CONTENTS

Contents                                                                      Page No

DECLARATION 	  1

DECISION SUMMARY 	  4
    I.    SITE NAME,  LOCATION,  AND DESCRIPTION 	  4
    II.   SITE HISTORY AND ENFORCEMENT ACTIVITIES 	  6
          A. Land Use and Site History 	  6
          B. Response and Enforcement History 	  6
    III.  COMMUNITY PARTICIPATION	  8
    V.     SCOPE AND ROLE OF RESPONSE ACTION 	  9
    V.    SUMMARY OF SITE CHARACTERISTICS 	 10
    VI.    SUMMARY OF SITE RISKS	 13
          A. Human Health Risk Assessment 	 13
          B. Ecological Risk Assessment 	 14
    VII.   DEVELOPMENT AND SCREENING OF ALTERNATIVES 	 15
          A. Statutory Reguirements/Response Objectives 	 15
          B. Technology and Alternative Development and Screening 	 15
    VIII.   DESCRIPTION OF ALTERNATIVES 	 16
          A. No Action 	 16
          B. Minimal Action 	 16
    IX.    SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES 	 18
          A. Overall Protection Of Human Health and the Environment	 18
          B. Compliance with Applicable or Relevant and Appropriate
             Reguirements 	 18
          C. Long Term Effectiveness And Permanence	 19
          D. Reduction Of Toxicity, Mobility,  or Volume Through Treatment 	 19
          E. Short-Term Effectiveness 	 19
          F. Implementability 	 20
          G. Cost 	 20
          H. State Acceptance 	 21
          I. Community Acceptance  	 21
    X.    THE SELECTED REMEDY 	 22
          A. Institutional Controls 	 22
          B. Removal of Surface Debris 	 22
          C. Additional Groundwater Monitoring Well 	 22
          D. Environmental Monitoring 	 22
          E. Five Year Reviews 	 23
          F. Cost 	 23
     XI. STATUTORY DETERMINATIONS	 25
           A.  The Selected Remedy is Protective of Human Health and the
              Environment 	 25
           B.  The Selected Remedy Attains ARARs 	 25
           C.  The Selected Remedial Action is Cost-Effective 	 25
           D.  The Selected Remedy Utilizes Permanent Solutions And
              Alternative Treatment Or Resource Recovery Technologies to
              the Maximum Extent Practicable 	 25
           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 	 26
     XII.  DOCUMENTATION OF NO SIGNIFICANT CHANGES 	 27
    XIII.  STATE ROLE 	 28

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GLOSSARY OF ACRONYMS AND ABBREVIATIONS
REFERENCES
APPENDICES
APPENDIX A-
APPENDIX B -
APPENDIX C -
APPENDIX D-
RESPONSIVENESS SUMMARY AND PUBLIC MEETING TRANSCRIPT
MEDEP LETTER OF CONCURRENCE
APPLICABLE OR RELEVANT AND APPROPRIATE  REQUIREMENTS
ADMINISTRATIVE RECORD INDEX AND  GUIDANCE  DOCUMENTS
                            LIST OF  FIGURES
Figure

1 Site Location Map
2 Site Features
                                                                 Page No.

                                                                .  5
                                                                 11

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DECLARATION

SITE NAME AND LOCATION

Naval Air Station (NAS) Brunswick
Orion Street Landfill (South): Site 2
Brunswick, Maine

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected final remedy for Site 2 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 (SARA) of
1986, and to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP). The remedy selected 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 for
Site 2.

ASSESSMENT OF THE SITE

The Navy has determined that the Minimal Action Alternative is appropriate for Site 2 since risk
estimates are below U.S. Environmental Protection Agency (USEPA) and MEDEP target risk levels.
Investigations conducted at Site 2 in 1984 (E.G. Jordan Co., 1985) and in 1988-89 (E.G. Jordan Co.,
1990a) have shown that soil, groundwater, and surface water pose no unacceptable risks. Low levels of
inorganic constituents such as mercury and lead were detected in sediment and leachate samples at Site 2,
but are below target risk levels.
Geophysical investigations determined that unidentified metal debris is present throughout the landfill.

DESCRIPTION OF THE SELECTED REMEDY

The Navy and USEPA, with the concurrence of MEDEP, have determined that the selected remedy for Site 2 is
Minimal Action. Implementation of the Minimal Action Alternative would include the following activities:

• institutional controls, including maintenance of the existing fence, installation of warning
signs and land use restrictions. Land use restrictions shall be documented in the NAS
Brunswick Operations Instructions for site development which reguire environmental review.
Should NAS Brunswick ever close and/or transfer this property, USEPA and MEDEP shall be
notified and appropriate wording shall be included in the necessary real estate documents.

• removal of surface debris that is visible in the depression immediately south and east of
the landfill;

• installation of an additional groundwater monitoring well;

• environmental monitoring, including collection and analysis of samples of groundwater,
seeps, surface water and sediment;

• five-year site reviews; and

• modifications to the selected remedy, if necessary.

At least once every five years, the Navy will perform a review of the monitoring data to be presented in
a report. The report will recommend either to continue the minimal action activities or to make
modifications to the selected remedy. In addition to the five-year reviews, monitoring data will also be
evaluated more freguently by a process to be outlined in the long-term monitoring plan. Data will be
reviewed at guarterly Restoration Advisory Board meetings, where decisions for more immediate actions can
be made, if necessary,

STATUTORY DETERMINATIONS

The selected remedy meets the mandates of CERCLA Section 121. It protects human health and the
environment, complies with federal and state reguirements that are legally applicable or relevant and

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appropriate for this action, and is cost-effective. The selected remedy does not satisfy the statutory
preference for treatment as a principal element. Treatment is unnecessary at this site since current risk
estimates are below USEPA and MEDEP target risk levels. However, because MEDEP has expressed a concern
that unidentified debris within the   landfill may create a potential for future impacts to groundwater
and/or surface water, an environmental monitoring plan will be developed to evaluate changes in the
site's condition.

A review will be conducted by the Navy, USEPA, and MEDEP at intervals not to exceed every five years to
ensure that the remedy continues to provide adeguate protection of human health and the environment. This
review will evaluate the appropriateness of a Minimal Action decision for Site 2.

DECLARATION

This Record of Decision represents the selection of a Minimal Action under CERCLA for Site 2. 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:

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DECISION SUMMARY
1. 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). This Record of Decision (ROD) relates to the selected
remedy decision for Site 2.

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

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

Site 2, the Orion Street Landfill - South, is located adjacent to Mere Brook near the southern end of the
main runways (see Figure 1). The actual waste disposal area covers approximately 2 acres partially
filling a former borrow pit. Currently, the site is covered by a dense grove of conifers

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

A. Land Use and Site History

NAS Brunswick is an active facility supporting the U.S. Navy's antisubmarine warfare operations in the
Atlantic Ocean and Mediterranean Sea. The base's primary mission is to operate and maintain P-3 Orion
aircraft. NAS Brunswick first became active in the 1940s during World War II, and underwent major
expansion in the 1950s.

Site 2 reportedly was used as the primary base landfill from 45 to 1955 (R.F. Weston, Inc., 1983). The
actual operation may have been less than 10 years because the Air Station was closed from 1946 to 1951,
although non-military tenants used the property. Solid waste was incinerated at the site before being
placed in the landfill and covered with soil. In addition to conventional solid waste and debris, wastes
reportedly disposed of at Site 2 included paints, solvents, oils, toluene, methyl ethyl ketone, and
medical supplies. Miscellaneous debris is exposed along the eastern face of the landfill, otherwise the
landfill has been covered with soil and supports a dense grove of conifers. The site lies within the
fenced Weapons Compound Area; therefore, access is strictly limited. A more detailed description of the
history of Site 2 can be found in the Draft Final Remedial Investigation (RI) Report in Subsection 7.1
(E.G. Jordan Co., 1990a).

B. Response and 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 (CERCLA) and the Superfund Amendments and Reauthorization Act (SARA). 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.

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• 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 USEPA's NPL.

• The RI/Feasibility Study (FS) process began in 1987 for seven sites.

In February 1988, the first Technical Review Committee (TRC) 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.

In 1990, the Navy entered into a Federal Facility Agreement (FFA) with 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.,
1990a and 1990b, respectively). 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.

In 1995, U.S. Fish and Wildlife Service (USFWS) conducted a study to determine
concentrations of trace elements and pesticides in fish samples collected from Mere Brook
near Site 2 (USFWS, 1997).

A Proposed Plan (ABB-ES, 1997) was submitted for public review in May 1997.

• A public comment period was held from May 9, 1997 to June 9, 1997.

Each of the stages and documents listed above pertains to Site 2. Information on many of the other sites
at NAS Brunswick is also included in several of these reports.

III. COMMUNITY PARTICIPATION

Throughout the sites' investigative and remediation history, the community has been active and invoked 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.

Prior to 1989, the Navy used the existing Hazardous Waste Subcommittee on the Military-Community Council
to provide direct information regarding the IRP to the community. From its creation in 1998 until July
1995, the TRC became 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.

In August 1987, the Navy established an information repository for public review of site-related
documents at the Curtis Memorial Library in Brunswick.

On August 16, 1990, the Navy held an informational meeting at the Jordan Acres School in Brunswick to
discuss the results of the RI.

On May 2, 1997, the Navy placed the Proposed Plan detailing the Preferred Alternative for Site 2 in the
information repository at the Curtis Memorial Library (ABB-ES, 1997). The Administrative Record for Site

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2 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 May 9, 1997.

From May 9 to June 9, 1997, the Navy held a 30-day public comment period to accept public input on the
alternatives presented in the Proposed Plan, On May 13, 1997, the Navy and regulatory representatives
held an informational public meeting to discuss the Proposed Plan for Site 2. A transcript of this
meeting and a Responsiveness Summary is included as Appendix A The Navy received several verbal comments
on the Site 2 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.

IV. SCOPE AND ROIiE OF RESPONSE ACTION

The Navy has determined that Minimal Action under CERCLA is appropriate for Site 2. The concentrations of
organic and inorganic compounds detected in soil, groundwater, surface water, sediment, and leachate do
not pose risks in exceedance of either the USEPA target carcinogenic risk range of 1x10 -4 to 1x10 -6, or
the MEDEP maximum acceptable incremental lifetime carcinogenic risk of 1x10 -5 for the hypothetical
future residential use scenario evaluated in the risk assessment. Non-carcinogenic risks were also well
below the target Hazard Index (HI) of 1.0 for all potential exposures evaluated.

Components of the selected alternative for Site 2 would include the following:

       •      institutional controls;
       •      removal of surface debris;
       •      installation of an additional groundwater monitoring well;
       •      environmental monitoring;
       •      five-year site reviews;  and
       •      modifications to the selected remedy,  if necessary.

At least once every five years,  the Navy will perform a review of the monitoring data to be presented in
a report. The report will recommend either to continue the minimal action activities or to make
modifications to the selected remedy.  In addition to the five-year reviews, monitoring data will also be
evaluated more freguently by a process to be outlined in the long-term monitoring plan. Data will be
reviewed at quarterly RAB meetings, where decisions for more immediate actions can be made, if necessary.

V. SUMMARY OF SITE CHARACTERISTICS

Section 3.0 of the FS  (E.G. Jordan, 1992) contains an overview of the site characteristics and remedial
investigations at Site 2. A more detailed discussion of the site history, geology, hydrogeology, risk,
and RI results can be found in the Draft Final RI report (E.G. Jordan Co., 1990a). A summary of site
characteristics and the significant findings of the RI is included below. Pertinent site features are
shown on Figure 2.

The subsurface geology at Site 2 includes an upper sand layer ranging in thickness from 14 to 21 feet,
and a transitional layer of interbedded silts and sand ranging in thickness from 5 to 11 feet. A clay
layer occurs below the transition layer.  The surface of the clay layer dips strongly to the east (i.e.,
toward Mere Brook).

Groundwater flow in the Site 2 area was assessed based on subsurface exploration data from four
monitoring wells. Groundwater flow above the shallow clay layer is to the northeast, toward Mere Brook.
Based on the flow direction, the presence of the shallow clay, and the results from stream gauging on
Mere Brook, the groundwater at Site 2 is believed to discharge to Mere Brook.

Environmental contamination attributable to Site 2 is observed in the leachate and sediment associated
with seeps, and in stream sediments (E.G. Jordan, 1990a). Contamination principally consists of inorganic
compounds, with low levels of pesticides (less than 1.0 milligram per kilogram  [mg/kg]) and polycyclic
aromatic hydrocarbon (PAH) compounds (maximum of 1.7 mg/kg). These contaminants are consistent with the
historical land use and disposal of incinerated wastes at this site. Buried ash would contribute to
inorganic contamination in groundwater and leachate downgradient of the landfill. The low levels of
pesticides detected are assumed to be residual concentrations resulting from historical, basewide use of
these compounds in the 1960s and 1970s.  In the groundwater samples from Site 2, lead was the only
inorganic compound detected  (in two out of a total of ten samples) in excess of its respective federal
Maximum Contaminant Level  (MCL)  of 15 micrograms per liter  (Yg/1) or Maine Maximum Exposure Guideline
(MEG)  of 20 Yg/1. The two lead detections included 180 Yg/1 in monitoring well MW-103 and 60 Yg/1 in
monitoring well MW-212. The groundwater data was collected from the shallow aguifer that discharges to
Mere Brook.

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The highest levels of contamination observed at Site 2 were detected in the leachate seeps. A wide
variety of inorganics were reported in leachate and sediment samples, with iron and mercury having the
highest concentrations relative to background values, Low levels of dichlorodiphenyltrichloroethane (DDT)
were observed in leachate samples and adjacent surface soils.

PAHs possibly could result from buried ash, but the level of contamination is consistent with PAH
concentrations reported for background surface water/sediment locations.

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assessment for the ingestion of groundwater was not developed for Site 2.

B. ECOLOGICAL RISK ASSESSMENT

An ecological risk assessment (ERA) was conducted to evaluate the potential risks to aguatic and
terrestrial organisms from exposure to contaminants at Site 2. The ERA reviewed organic and inorganic
contaminant concentrations in surface water, sediments, leachate seeps, and surface soil. Contaminants of
potential concern (COCs) for ecological receptors were determined by comparing sampling results to
Ambient Water Quality Criteria (AWQCs) for surface water, USEPA interim sediment guality criteria (where
available) for sediments, and lowest effect level estimates derived from published toxicological studies
for leachate seeps and surface soil, The ERA is described in detail in the FS (E.G. Jordan Co., 1990a;
Appendix Q). The conclusions from the ERA are summarized below.

Iron and zinc were identified as COCs in surface water in Mere Brook. These contaminants, however, were
also found at elevated concentrations in Mere Brook upgradient of the Site 2 area, as well as other
surface water locations throughout NAS Brunswick, and do not appear to be directly related to Site 2.

Iron and the PAH phenanthrene were identified as COCs in Mere Brook sediments. As was the case with
surface water, these contaminants are widespread throughout NAS Brunswick, including areas upgradient of
Site 2, and were concluded to be unrelated to the site.

COCs identified in leachate seeps include DDT, DDE, arsenic, cadmium, chromium, lead, mercury and nickel.
Because the seeps are not large enough to support aguatic populations, the ecological risk assessment
evaluated an exposure scenario consisting of wildlife drinking from the seeps. Even with a conservative
assumption that the modeled terrestrial organisms would obtain all of their drinking water from the
seeps, which is unlikely given the abundant flowing water in the adjacent Mere Brook, the ERA concluded
that only slight risks would exist, and that deleterious effects would be unlikely under actual exposure
conditions.
For surface soil, only mercury in soils associated with seep locations was selected as a COG. A
terrestrial food-web model based on five classes of receptors was used to evaluate COCs for surface soil.
The evaluation concluded that the hazard index for potential exposure to mercury ranged from 0.006 to
0.141, well below the target HI of 1.0.

VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES

This Section presents the development and screening of two remedial alternatives for Site 2: the No
Action Alternative and the Minimal Action Alternative. This range of alternatives is appropriate for Site
2 because site conditions did not warrant the development of remedial response objectives.

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.

Remedial action objectives consist of media-specific goals for protecting human and ecological receptors.
Based on the results of the baseline risk assessments, remedial action objectives were not developed for
this site. There are no unacceptable current or future potential risks to either human or ecological
receptors from exposure to site-related contaminants.

B. TECHNOLOGY AND ALTERNATIVE DEVELOPMENT AND SCREENING

The FS developed two remedial alternatives for Site 2: the No Action Alternative and the Minimal
Action Alternative. Based on the results of the baseline risk assessments, there are no unacceptable
potential risks to either human or ecological receptors from exposure to site-related contaminants.
However, because the waste material disposed of at Site 2 will remain on site, a Minimal Action
Alternative of long-term environmental monitoring was developed in addition to a No Action Alternative
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VIII. DESCRIPTION OF ALTERNATIVES

This section provides a narrative summary of the alternatives evaluated in the FS. The alternatives
developed for Site 2 include No Action and Minimal Action. A detailed assessment of each alternative can
be found in Section 3.0 of the FS (E.G. Jordan Co., 1992).

A. No Action

The No Action Alternative was developed to comply with the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) and to compare with other remedial action alternatives. This alternative
does not involve implementing remedial actions, controls, or monitoring, except that access to the site
is already strictly controlled by virtue of its location within the Weapons Compound, which is accessible
only to authorized personnel.

B. Minimal Action

A Minimal Action Alternative was also considered for Site 2. The components of this alternative are as
follows:

• institutional controls;
• removal of surface debris;
• installation of an additional groundwater monitoring well;
• environmental monitoring;
• five-year site reviews; and
• modifications to the selected remedy, if necessary.

Institutional controls would consist of maintaining the existing fence at Site 2 and posting signs to
notify site personnel of potential hazards. Land Use Restrictions shall be documented in the current NAS
Brunswick Operations Instructions. The Operations Instructions are used by NAS Brunswick to identify and
screen environmental areas from inappropriate construction or development activities. Should NAS
Brunswick ever close and/or transfer this property, USEPA and MEDEP shall be notified and appropriate
wording shall be included in the necessary real estate documents to prevent disturbance of buried wastes
or the extraction or use of groundwater at Site 2 without regulatory review and approval. The base
closure process would include an evaluation of actions necessary for decommissioning the Air Station,
including the need for land use restrictions on specific areas such as Site 2. Removal of debris would
be limited to items visible on the ground surface in the depression immediately south and east of the
landfill. The long-term environmental monitoring program would be implemented to ensure that contaminant
concentrations in the leachate do not increase over time. An additional groundwater monitoring well would
be installed to provide an additional downgradient monitoring point. A long-term monitoring plan would be
prepared for RAB review and regulatory agency approval. The plan would include a process for determining
whether more immediate actions are needed to address potential risks to human health or the environment.
Data will also be reviewed at guarterly RAB meetings, where decisions for more immediate actions can be
made, if necessary. Additionally, data collected during the monitoring program would be evaluated during
the five-year site reviews as mandated by SARA and described in the FFA.

IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

Section 121(b)(1) of CERCLA presents several factors that at a minimum must be considered in the
assessment of alternatives. Building upon these specific 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 baseline risk assessment did not identify a significant risk to either human or ecological receptors
based on current or assumed future exposure to contaminants at Site 2. Natural degradation and dispersion
processes are expected to continue to act on contaminated media, resulting in decreased contaminant
levels over time.

The Minimal Action Alternative would provide an adeguate level of protection to human and ecological
receptors through the implementation of institutional controls. To ensure that there continues to be no
risk to human health or the environment from Site 2, a long term monitoring program is included to
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provide data to verify the effectiveness of the remedial action, or for modifying the remedial action as
necessary.

The No Action Alternative would provide no additional protection to human or ecological receptors over
baseline conditions. However, the baseline risk assessment does not indicate a risk to either ecological
or human receptors based on current and assumed future exposure conditions.

B. Compliance with Applicable or Relevant and Appropriate Requirements

Compliance with 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.

The No Action alternative would not trigger ARARs. The Minimal Action alternative would need to comply
with the Maine Natural Resources Protection Act Permit by Rule regulations for erosion control (06-696
CMR Chapter 305) during the removal of surface debris and subseguent minor filling and regrading. Also,
water guality standards under federal and state drinking water programs, the Maine Surface Water Toxics
Control Program, and the Maine Hazardous Waste Management Rules are relevant and appropriate for the
long-term monitoring program at Site 2. In the Minimal Action alternative, the long-term monitoring
program would allow the Navy to monitor the condition of groundwater and surface water to determine
whether these ARARS are met. No monitoring would be performed under the No Action alternative, and
compliance with ARARs would not be determined. A listing and synopsis of the ARARs can be found in
Appendix C.

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 clean-up goals are met.

Environmental monitoring and five-year reviews included in the Minimal Action Alternative would provide
data and interpretation of the degradation, dispersion, and movement of contaminants in the leachate,
groundwater, surface water, sediment, and surface soils at Site 2. The data would be used to confirm
that risks associated with the wastes disposed at Site 2 remain below levels of concern. The No Action
Alternative is intended to provide a baseline for comparison to other alternatives. Because this
alternative does not include long-term monitoring, there would be no additional data available to confirm
that risks were remaining below levels of concern.

D. Reduction of Toxicitv, 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.

Based on the results of the risk assessment, reduction of toxicity, mobility, or volume is not reguired
at Site 2 to be protective of human health or the environment. However, for both the Minimal Action and
No Action Alternatives, it is expected that natural degradation and dispersion processes will result in a
decrease in contaminant levels over time.

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.

The Minimal Action Alternative would not involve any remedial construction, and only minimal invasive
activities (i.e., installation of a monitoring well & removal of surface debris). Therefore, no adverse
impacts to the public or the environment would be expected. Workers involved in removal of surface
debris, well installation and monitoring activities would have to be trained in health and safety for
work at hazardous waste sites. Proper personal protective eguipment, work area monitoring, and safe work
practices would minimize the possibility of chemical exposure or injury under this alternative.

The No Action Alternative would not involve any remedial construction, invasive activities, or further
sampling. Therefore, no adverse impacts to workers, the public, or the environment would occur.
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F. Implementabilitv

Implementability refers to the technical and administrative feasibility of an alternative, including the
availability of materials and services needed to implement the alternative.

Environmental monitoring and analytical procedures for surface water, groundwater, sediment, and seep
samples are well developed and widely used at many hazardous waste sites. Therefore, technical problems
are not expected to limit the implementability of the Minimal Action Alternative. Implementation of this
alternative would not interfere with possible future remedial actions at this site should they be
reguired.

The proposed monitoring plan would be submitted for regulatory agency review and approval prior to
implementation. Coordination between the party responsible for carrying out monitoring activities and
officials at NAS Brunswick would be reguired for individuals to gain safe and legal access to sampling
locations near Site 2. These activities would be carried out on a regular, periodic basis, so obtaining
passes for work at NAS Brunswick should not present difficulty. The five-year review would be conducted
jointly by the Navy, MEDEP, and USEPA.

Because environmental monitoring is a well-developed and widely available technigue, several contractors
would be able to provide competitive bids for reguired services.

The No Action Alternative has no components and reguires no action. Therefore, implementability is not an
issue.

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.

The Minimal Action Alternative is expected to cost approximately $253,000 and include the costs for
environmental monitoring and five-year reviews. The costs were estimated for a 30-year monitoring
program.

Capital, indirect, and O&M costs are not incurred for the No Action Alternative.

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 selected remedial alternative.

As a party to the FFA, the State of Maine provided comments on the Site 2 Proposed Plan and documented
its concurrence with the Minimal Action Alternative. A copy of the letter of concurrence is presented in
Appendix B of this ROD.

I. Community Acceptance

Community Acceptance addresses whether the public concurs with the Navy's Proposed Plan, Community
acceptance of the Site 2 Proposed Plan was evaluated based on comments received at the public meeting and
during the public comment period for that plan. This is documented in the Responsiveness Summary in
Appendix A of this ROD.

X. THE SEIiECTED REMEDY

The selected remedy for Site 2 is the Minimal Action Alternative which will include institutional
controls, debris removal, installation of an additional groundwater monitoring well, environmental
monitoring, and five-year site reviews. Remedial action objectives were not developed for this site
because no risk to human or ecological receptors was indicated by the baseline risk assessment. A
long-term environmental monitoring program will be implemented to confirm the protectiveness of the
selected remedy. Data collected during the monitoring program will be evaluated during the five-year site
reviews as mandated by SARA and described in the FFA. The components of the Minimal Action Alternative
are described in detail in the following subsections.

A. Institutional Controls

Institutional controls will consist of signs posted around the perimeter of Site 2, and near leachate
seeps along Mere Brook, to notify site personnel of potential hazards, Routine maintenance of the
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existing fence will also be included.

In the event of future base closure and/or transfer of this property, institutional controls will also
include land use restrictions to limit future development at Site 2. At a minimum, land use restrictions
would apply to the area shown on Figure 2. The objective of these restrictions will be to prevent the
disturbance of buried wastes and the extraction or use of groundwater at Site 2 without regulatory review
and approval. In the event of closure or property transfer, the base closure process will become the
mechanism under which such restrictions will be developed and implemented.

B. Removal of Surface Debris

Debris removal will consist of collection and proper disposal of surface debris in the depression
immediately south and east of the landfill. Clearing of vegetation will be minimized, and disturbed areas
will be filled or graded as necessary to support revegetation.

C. Additional Groundwater Monitoring Well

An additional monitoring well will be installed to provide an additional downgradient monitoring
location. The actual location and design of the additional well will be established in the environmental
monitoring plan for Site 2.

D. Environmental Monitoring

An environmental monitoring program will be implemented as part of the Minimal Action Alternative at Site
2. The monitoring will include collection and analysis of samples of groundwater, seeps, surface water
and sediment. The purpose of the monitoring program will be to:

1. monitor changes in the groundwater, surface water and sediment since wastes remain buried at
the site;
2. provide a tiered approach to attaining the MEDEP water quality standards; and
3. monitor the effectiveness of the remedial action for the protection of human health and the
environment.

A monitoring plan will be submitted for regulatory agency review and approval prior to implementation.
Details of the monitoring program will be discussed at upcoming RAB meetings following signature of this
ROD. The monitoring plan will include procedures for routine, periodic sampling of groundwater, leachate,
surface water, and sediments. In addition, the plan will discuss future fish tissue sampling, as
appropriate, based on the findings and recommendations of the USFWS report. Sampling methodology and
locations, frequency of sampling, and analytical parameters will be specified in the plan for all
proposed environmental monitoring.

Data generated from this sampling will provide information on potential contaminant migration,
accumulation or attenuation of inorganics sorbed onto sediment and surface soils, and the potential
impact of contamination in leachate seeps to Mere Brook. The monitoring plan will also establish
procedures for determining whether any actions are appropriate, based on analytical results. For example,
data can be reviewed at quarterly RAB meetings, where decisions for short-term actions can be made, if
necessary.

E. Five Year Reviews

The FFA, consistent with the NCP, requires a five-year site review for sites at which wastes have not
been permanently treated, to assure that human health and the environment are being protected. The
purpose of the five-year review would be to organize, analyze, and present the data gathered during
sampling events in a report format. The five-year review would be conducted jointly by the Navy, MEDEP,
and USEPA. The review would make a recommendation regarding future actions at the site. This
recommendation could be to continue environmental monitoring and five-year reviews, or to make
modifications to the selected remedy.

On federal facilities, five-year reviews occur simultaneously for all separate sites or operable units
where decision documents have been finalized and five-year reviews are required. At NAS Brunswick, a
facility-wide five-year review is required in the year 2000, and Site 2 will be included in the scope of
that review.

F. 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.
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The Minimal Action Alternative is estimated to cost approximately $253,000 and includes the costs for
environmental monitoring and five-year reviews. Monitoring is assumed to continue forSO years for
cost-estimating purposes; however, this time frame will be continually re-evaluated during the five-year
site review.

XI. STATUTORY DETERMINATIONS

The remedial action selected for implementation at NAS Brunswick for Site 2 is consistent with CERCLA
and, to the extent practicable, the NCP. The selection of the Minimal Action Alternative will be
protective of human health and the environment and be cost-effective.

A. The Selected Remedy is Protective of Human Health and the Environment

The baseline risk assessment did not identify a significant risk to either human or ecological receptors
based on current or assumed future exposure to contaminants at Site 2.

Natural degradation and dispersion processes are expected to continue to act on contaminated media,
resulting in decreased contaminant levels over time. This alternative would provide an adeguate level of
protection to human and ecological receptors.

B. The Selected Remedial Action attains ARARs

The selected remedy will attain ARARs. The ARARs for this remedy and the manner in which they will be met
are summarized in Appendix C.

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 selected remedy 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.

D. The Selected Remedy Utilizes Permanent Solutions And Alternative Treatment or Resource Recovery
Technologies to the Maximum Extent Practicable

The selected remedy was evaluated for the best balance among the following criteria: (1) long-term
effectiveness and permanence; (2) reduction of hazardous waste toxicity, mobility, or volume through
treatment; (3) short-term effectiveness; (4) implementability; and (5) cost. The balance test prefers a
permanent, long-term solution which reduces waste toxicity, mobility or volume through treatment or
recovery. Less desirable is off-site land disposal of untreated wastes. However, the trade-off of higher
costs for a permanent solution in the context of community and state acceptance and the risk posed by the
site are carefully considered. The selected final remedial action provides the best balance of these
criteria for Site 2.

E. The Selected Remedy Does Not Satisfy the Preference for Treatment Which Permanently and Significantly
Reduces the Toxicitv, Mobility, or Volume, of the Hazardous Substances as a Principal Element

Because the risk assessment concluded that current and potential future risks are already at acceptable
levels, this statutory preference is not applicable.

XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES

The Navy presented a Proposed Plan for Site 2 (ABB-ES, 1997) outlining the proposed alternative of
Minimal Action. The Proposed Plan was presented to the public and public comments have been considered in
the selection of the preferred alternative. No significant changes have been made to the preferred
alternative described in the Proposed Plan.

XIII. STATE ROIiE

MEDEP has reviewed the RI Report, Risk Assessment, Feasibility Study and Proposed Plan, and has indicated
its support for the selected remedy. MEDEP concurs with the selected remedy for NAS Brunswick Site 2. A
copy of the letter of concurrence is presented in Appendix B of this ROD.
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GLOSSARY OF ACRONYMS AND ABBREVIATIONS
ABB-ES ABB Environmental Services, Inc.
ARAR Applicable or Relevant and Appropriate Requirement
AWQC Ambient Water Quality Criteria
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(the Superfund statute)
COG contaminant of concern
DDT di chlorodiphenyltri chloroethane
ERA ecological risk assessment
FFA Federal Facility Agreement
FS Feasibility Study
HI Hazard Index
IAS Initial Assessment Study
IRP Installation Restoration Program
MCL maximum contaminant level
MEDEP Maine Department of Environmental Protection
MEG Maine Maximum Exposure Guideline
Ig/1 micrograms per liter
mg/kg milligrams per kilogram
MSL mean sea level
NAS Naval Air Station
NCP National Oil and Hazardous Substances Contingency Plan
NPL National Priorities List
PAH polycyclic aromatic hydrocarbon
RAB Restoration Advisory Board
RI Remedial Investigation
ROD Record of Decision
SARA Superfund Amendments and Reauthorization Act
TRC Technical Review Committee
USEPA U.S. Environmental Protection Agency
USFWS U.S. Fish and Wildlife Service
VOC volatile organic compound
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REFERENCES

ABB Environmental Services, Inc, (ABB-ES) 1997. "Proposed Plan Site 2"; Portland, Maine, May 1997.

E.G. Jordan Co, 1985. "Pollution Abatement Confirmation Study, Step 1A - Verification",
Portland, Maine; June 1985.

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

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

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

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

U.S. Environmental Protection Agency (USEPA), 1988. "Guidance for Conducting Remedial
Investigations and Feasibility Studies Under CERCLA"; EPA/540/G-89/004; Washington
D.C. ; October 1988,

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 1989.

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 1989.

U.S. Fish and Wildlife Service (USFWS), 1997. "Environmental Contaminants in Fish From
Mere Brook"; Special Project Report: FY97-MEFO-3EC; New England Field Office;
February 1997.
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APPENDIX A

RESPONSIVENESS SUMMARY
AND
PUBLIC MEETING TRANSCRIPT

The Navy held a 30-day comment period from May 9 to June 9, 1997, to provide an opportunity for the
public to comment on the Proposed Plan for Site 2, The Orion Street Landfill (South). Site 2 is located
at the Naval Air Station Brunswick Superfund Site, in Brunswick, Maine. The Proposed Plan is the document
that recommends the remedial alternative that best meets the evaluation criteria for Site 2.

In the Proposed Plan, the Navy recommended the Minimal Action alternative as its preferred alternative
for Site 2. The Proposed Plan was issued on May 2, 1996, before the start of the comment period. All
documents on which selection of 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 Site 2.

The Navy received no written comments on the Proposed Plan during the 30-day public comment period.
Several verbal comments were offered at the public meeting on May 13, 1997, by a representative of the
citizens' group, Brunswick Area Citizens for a Safe Environment. Responses were provided verbally for
each 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 Minimal Action Alternative for Site 2, which includes institutional controls,
land use restrictions, surface debris removal, and environmental monitoring. Five-year site reviews will
be conducted to ensure that the remedial action continues to be protective of human health and the
environment.
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BRUNSWICK NAVAL AIR STATION

Hearing
RE: IR Site 2
COPY
9

25
HEARING, held at Curtis Memorial Library,

Pleasant Street, Brunswick, Maine, on May 13,

1997, commencing at 7:05 p. m. , before Kristin E.

Lively, a Notary Public in and for the State of

Maine.
HELD BEFORE:

James Caruthers
Kristin E. Lively
BROWN & MEYERS
Post Office Box 937
Yarmouth, ME 04096-0937
(207) 846-0420
BROWN & MEYERS
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1 EXHIBITS

2 NUMBER DESCRIPTION PAGE

3 None.

BROWN & MEYERS
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1 PROCEEDINGS

3 MR. APHAM: Good evening. We're here tonight —

4 I'm Greg Apham from the Public Works Office for the

5 Naval Air Station Brunswick. We're here for a public

6 meeting for the Proposed Plan for Site 2 underneath

7 the Superfund Program at the Naval Air Station.

8 And with us at the head table is Captain Carter

9 who is the base commanding officer, Fred Evans from

10 Northern Division, Naval Facilities Engineering

11 Command, Claudia Sait from D.E.P, Bob Lim from the

12 E.P.A. , and then we've got Jeff Brandow who is from

13 ABB Environmental who is the contractor for the Navy

14 and is the project manager for the station.

15 Tonight's public hearing is to talk about the

16 Proposed Plan. And I guess, at this particular point

17 in time, I'll turn it over to Fred.

18 MR. EVANS: Tonight's meeting we,re going to —

19 Greg's already performed the introduction, and I will

20 explain the CERCLA Decision Process and Jeff Brandow

21 will provide the Site description and our Proposed

22 Plan. I'll provide a description of the public

23 comment process, and then we will answer any guestions

24 that you have on our Proposed Plan.

25 The CERCLA process starts after a site gets

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1 listed on the National Priorities List. We start with

2 a Remedial Investigation where we do soil borings,

3 sample seeps, and other types of investigations, do a

4 Risk Assessment. And all the information from the

5 Remedial Investigation, we take that and we do a

6 Feasibility Study. We look at various alternatives on

7 how we can address the individual sites, to clean them

8 up, if we need to do some type of construction or

9 anything like that. And there's nine criteria that it

10 gets ranked against.

11 Then at the end of the Feasibility Study, which

12 is the stage we're at now with Site 2, we have a

13 Record of Decision, and before we do the Record of

14 Decision we put out a Proposed Plan, have a public

15 comment period, which started May 9th and ends June

16 9th, and take comments, and then those comments get

17 addressed in the Responsiveness Summary and the Record

18 of Decision. And, if necessary, we then, after the

19 Record of Decision, do design and go into long-term

20 monitoring and operation and construction. And that's

21 it for the general process, and I'll turn it over to

22 Jeff.

23 MR. BRANDOW: Well, good evening. We're here

24 tonight to talk about Site 2, the Orion Street

25 Landfill - South. Site 2 is one of the 17 sites that

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1 the Navy is investigating at the Brunswick Naval Air

2 Station under its Installation/Restoration Program.

3 I'm going to start off tonight by describing Site 2

4 and including the history of its operation, and then

5 I'll follow that with a discussion of the studies that

6 have been performed to date, and then summarize the

7 Navy's Proposed Plan for the Site.

8 Site 2 is located near the south end of the

9 runways just off of Orion Street which is the road

10 that leads down to the golf course. The Site is an

11 old dump or landfill and was the primary landfill for

12 the air station from about 1945 until 1955. The

13 landfill received general refuse from the Air Station,

14 as well as reports of waste paints, solvents, and

15 oils. It's been reported that the wastes were

16 incinerated before they were buried in the landfill.

17 And although the dump was open for a period of ten

18 years, the Air Station actually was inactive for about

19 half of that time, from 1946 to 1951, although, there

20 may have been some other tenants that used the

21 landfill during that period of time, but the landfill

22 is really guite small, just under two acres in size.

23 The landfill has been closed since 1955, and

24 currently it's covered, for the most part, with a

25 dense stand of pine trees, as you can see in this

BROWN & MEYERS
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1 photograph. Now, as Fred mentioned, the Site is

2 included in the Superfund process at the Air Station.

3 And, therefore, it has undergone a Superfund-type

4 Remedial Investigation and Feasibility Study, or RIFS

5 for short.

6 The purpose of an RIFS to collect sufficient

7 soil, groundwater, surface water and sediment samples

8 to determine whether or not the wastes that may be

9 present at the Site are having an adverse impact to

10 human health or the environment. Let me go back to

11 this for a second. The RIFS that was conducted at the

12 base covered many of the sites around the Air Station,

13 and the results of that investigation are described in

14 detail in a fairly large report that is available to

15 the public downstairs in the library here in our

16 information repository. I do not intend to go through

17 that study tonight in any detail. We have covered it

18 in past public meetings, but I do want to summarize

19 the key findings from the Remedial Investigation and

20 Feasibility Study that pertain to Site 2. And I'll

21 start with the RI results.

22 The investigations were conducted during 1988

23 and 1989 and the investigations consisted of a series

24 of steps. The first step was to conduct a

25 Magnetometer Survey of the Site 2 area. A

BROWN & MEYERS
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1 Magnetometer is a device similar to a powerful metal

2 detector and it's a very good technigue for

3 identifying the limits of the buried waste at an old

4 landfill at Site 2. The Site figure shows the

5 approximate limits of the buried waste as determined

6 by the Magnetometer Survey.

7 After that, we conducted a soil vapor or soil

8 gas survey at the Site to look for volatile organic

9 compounds in the soil above the buried waste. The

10 Soil Gas Survey that we conducted did not find any

11 real indication of volatile organics at Site 2.

12 Samples were collected from four monitoring wells at

13 the Site to determine whether or not the buried wastes

14 were having an impact on groundwater. And although we

15 did detect — in one sampling round we detected lead

16 at a level exceeding the drinking water standard, for

17 the most part, the results of the groundwater sampling

18 indicated that we did not have a significant

19 groundwater impact from Site 2.

20 I'll just go back to the Site figure and show

21 you the location of those monitoring wells. The four

22 wells that generally represent the groundwater

23 associated with Site 2 are 103, 212 and 213 and 104.

24 We found groundwater generally moving toward the north

25 toward Mere Brook and it runs along here. We also

BROWN & MEYERS
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1 found three areas of seeps that we sampled. You see

2 them here in these black areas, and those -- at those

3 seep locations we collected samples of water,

4 sediment, and soils. And what we found there was

5 elevated inorganics in all three locations, and also

6 we found very low levels of DDT in one of the seep

7 locations in the water.

8 After collecting that data, the Navy conducted a

9 Risk Assessment to determine whether the

10 concentrations that we observed in the samples were

11 posing a risk to human health or the environment, and

12 a Feasibility Study to determine whether or not any

13 actions might be required to address those concerns.

14 Now, the main potential for concern was the

15 inorganics that we saw in the seeps and, to a lesser

16 extent, in the groundwater. The Risk Assessment

17 concluded, however, that the concentrations observed

18 were not high enough to pose a risk to human health or

19 to aguatic life in Mere Brook. And, therefore, since

20 the risk levels were at acceptable levels, the

21 Feasibility Study did not evaluate any treatment or

22 removal options for Site 2. The study did recommend

23 long-term environmental monitoring for the Site since

24 waste remained buried at the Site, and the Feasibility

25 Study also evaluated institutional controls to limit

BROWN & MEYERS
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1 access and restrict future use of the Site as part of

2 a minimal action alternative.

3 Now, these studies that I've described so far

4 were all completed four or five years ago. And since

5 that time, there's been ongoing discussions between

6 the Navy and E.P.A., D.E.P., and Citizens

7 Representatives about the potential concerns for these

8 inorganics reaching Mere Brook. In response to that,

9 the U.S. Fish & Wildlife Service conducted a survey, a

10 fish sampling survey, using funds provided by the Navy

11 to sample fish in Mere Brook. The main purpose of

12 this study was to look for potential impacts to the

13 fish from the inorganics that we've seen at Site 2.

14 The study also looked at pesticides in the fish.

15 What was found in the study was that the trace

16 elements, such as mercury, were all at or below

17 Federal and State averages for fish. However, the

18 study did find that several pesticides were present in

19 the fish samples at slightly elevated concentrations.

20 Now, on the basis of all of these studies, the

21 Navy is ready to propose a final plan for Site 2. For

22 any of you that haven't gotten a copy of the Proposed

23 Plan yet, we have copies in the back of the room.

24 This was issued by the Navy last week. The Navy is

25 proposing to leave the buried waste on-site, to

BROWN & MEYERS
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1 maintain the access and future use restrictions, to

2 prevent disturbance of the waste, and to conduct

3 long-term environmental monitoring of groundwater and

4 seeps in the area of Site 2 for the purpose of making

5 sure that the concentrations that we have observed

6 remain at or below those levels. As part of that plan

7 remedy, the Navy will conduct a regular evaluation of

8 all of monitoring data collected at least once every

9 five years and the results of that evaluation would be

10 discussed with the D.E.P., E.P.A., and the public.

11 And based on those reviews, if any modifications to

12 the -- of the approach for the Site are determined to

13 be necessary, they would be made to make sure that

14 human health and the environment continue to be

15 protected.

16 Now, one last item, there is some surface debris

17 along the northern boundary of the Site consisting

18 primarily of empty steel containers, and the Navy is

19 proposing to go in and clean this embankment up.

20 They'll pull out the surface debris and then do any

21 necessary filling and regrading of the slope to

22 stabilize it. And that basically is the plan that's

23 being proposed tonight by the Navy. The Navy believes

24 that these measures described are reasonable and

25 appropriate for the conditions that we've observed at

BROWN & MEYERS
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1 the Site and is now looking to hear any public

2 comments that you might have on the proposed approach.

3 And, Fred, would you like to go over the process

4 for the public comments?

5 MR. EVANS: As I had said earlier, the public

6 comment period runs from May 9th to June 9th. We'd be

7 willing to take any oral comments tonight or you can

8 submit written comments to me, and they need to be

9 postmarked by June 9th, and my address is in the

10 Proposed Plan and it's also in this handout for

11 tonight's meeting. And we will prepare a

12 Responsiveness Summary for the Record of Decision

13 which will include responses to all the comments.

14 And, with that, I'd like to open it up for comments.

15 MS WEDDLE: I can give you a few comments.

16 Susan Weddle, and I'm speaking for Brunswick Area

17 Citizens for a Safer Environment. One, how will the

18 long-term monitoring for this site tie in with the

19 base-wide monitoring? Will it be done at the same

20 time or --

21 MR. EVANS: We have to prepare a long-term

22 monitoring plan for Site 2, and we envision that that

23 would be an addendum to the existing long-term

24 monitoring plan for the other sites under this

25 program, but we would develop that, as we did the

BROWN & MEYERS
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1 others, through the Restoration Advisory Board.

2 MS. WEDDLE: So, that's still to be

3 MR. EVANS: Right.

4 MS. WEDDLE: Now, the Fish & Wildlife Report did

5 recommend monitoring of this area. I can read you

6 from the -- it says based on the results of this study

7 of re-sampling of surface water, sediments, and fish

8 or other wildlife should be conducted following

9 remedial actions to monitor environmental contaminants

10 in Mere Brook, particularly mercury and -- do you know

11 if they're planning on doing any follow-up or if

12 you're planning on doing any follow-up along their

13 recommendations?

14 MR. EVANS: We're looking at — you know, the

15 long-term monitoring plan will include a lot of those

16 items and that will be -- you know, that will be

17 discussed with the Restoration Advisory Board.

18 MS. WEDDLE: Okay. And do you have any time

19 frame as to when the first round of sampling would be

20 for that long-term monitoring?

21 MR. EVANS: At this time, no.

22 MS. WEDDLE: The seeps that had the high

23 mercury, are they still active at all?

24 MR. EVANS : I don' t know.

25 MR. BRANDOW: We haven't been out to look at

BROWN & MEYERS
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1 them for some time

2 MS. WEDDLE: I mean, that's my biggest area of

3 concern over the whole site itself is the leachate

4 from seeps because that was what appeared to be the

5 most contaminated. And I would just have a concern if

6 those were continuing to break out. You know, how are

7 you going to control access to that area. And also,

8 if they are readily, you know, leaching, I'd like to

9 see some sampling done to see how -- what it's like at

10 this point in time because, it's been a while since

11 they've been tested, as far as I know.

12 MR. EVANS: Okay.

13 MS. WEDDLE: And I guess if you could just

14 clarify how you are going to limit access to the Site

15 or what kind of -- right now, is it all fenced in?

16 MR. EVANS: It's within the weapons area right

17 now, so it's already fenced. That area is off limits

18 to most personnel.

19 MS. WEDDLE: And that includes the whole site

20 including where the leachate --

21 MR. EVANS: Yes.

22 MR. APHAM: Fred, if you want to go back to that

23 diagram Jeff had put up of Site 2 specifically -- I

24 mean, this is the road, this is the fence line around

25 it, and that up there is another weapons compound

BROWN & MEYERS
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1 that's inside of this existing fence. So, this whole

2 area is already covered by a fence all the way around

3 down to this area by the golf course and swings over

4 towards the. Bailey/Orr's Island Road and then it comes

5 back up the line north of that where the last of the

6 hangers are and it's all locked up and the only

7 entrance now is up in that northeast corner which has

8 a —

9 MR. BRANDOW: And I can tell you, Susan, from

10 firsthand experience that when I took this photograph

11 I was there less than three minutes before a security

12 officer showed up at my car wondering why I was there.

13 So, they do maintain security.

14 MR. APHAM: And that's a picture of the fence

15 that's currently surrounding that whole area.

16 MS. WEDDLE: Okay. Okay. And then I guess the

17 only other comment is radiation hazards have been

18 something that have been discussed on a base-wide

19 concern because there's been very little monitoring of

20 that over the course of this. I don't think any

21 radiation monitoring has been done at Site 2 at all,

22 has it?

23 MR. EVANS: I think there were badges, Jeff, but

24 nothing -- we didn't to test pitting. There was no

25 log or whatever the meter was when we did test

BROWN & MEYERS
-------
1 pitting.

2 MS. WEDDLE: Okay. Well, just with the

3 proximity of the weapons compound and, you know, not

4 knowing what went in. it, that would be just a concern,

5 is there a radiation hazard there.

6 MR. EVANS: Yes. We don't believe so. if I

7 recall -- I might have to go back and look at the

8 aerial photographs. The time this was in use was

9 before the weapons compound was even in place. So, we

10 don't expect there to be a problem with this site.

11 MS. WEDDLE: Okay. Maybe something could be

12 done to the effect that if, at any point in time,

13 there's excavation done, have something to say that,

14 you know, that should be something to consider, like

15 monitoring. I mean, I assume that you're not planning

16 any on any excavations in this area --

17 MR. EVANS: No.

18 MS. WEDDLE: But along with the — what you

19 refer to as land use restrictions that would limit

20 future development at the Site, if you can just

21 include in that that, you know, the radiation hazard

22 has never been determined and if, in the future, there

23 were excavations, that that's something you should —

24 MR. EVANS: We'll look at that.

25 MS. WEDDLE: Okay. I think for right now that's

BROWN & MEYERS
-------
1 -- that's it for the comments that we have.

2 MR. APHAM: Well, there being no further

3 comments, I guess that concludes our public meeting.

4 Thank you.

6 (The hearing concluded at 7:31 P. M.)

BROWN &. MEYERS
-------
1 CERTIFICATE OF REPORTER

4 I, Kristin E. Lively, a Notary Public in and

5 for the State of Maine, do hereby certify that this

6 hearing was stenographically reported by me and later

7 reduced to print through Computer-Aided Transcription.

10 I further certify that I am a disinterested

11 person in the event or outcome of the above-named

12 cause.

15 IN WITNESS WHEREOF, I subscribe my hand and

16 affix my seal this date, May 24, 1997.

17 Dated at Boothbay Harbor, Maine.

24 My Commission Expires

25 January 18, 2002

BROWN & MEYERS
-------
APPENDIX B
MEDEP IiETTER OF CONCURRENCE

STATE OF MAINE
Department of Environmental Protection

ANGUS S. KING, JR. EDWARD 0. SULLIVAN
GOVERNOR September 17, 1998 COMMISSIONER

Mr. Emil Klawitter
Code 1823 EK
Department of the Navy, Northern Division
Naval Facilities Engineering Command
10 Industrial Highway, Mail Stop 82
Lester, PA 19113-2090

Re: Record of Decision for Site 2
Naval Air Station-Brunswick, Maine

Dear Mr. Klawitter:

The Maine Department of Environmental Protection (MEDEP or Department) has reviewed the Final Record of
Decision (ROD) for Site 2 (September 1998) for Brunswick Naval Air Station, Brunswick, Maine.

Based on the Final Record of Decision, the Department concurs with the Navy's selected remedy of minimal
action as outlined in Section X which is summarized below.

Minimal Action has been selected for Site 2 (Orion Street Landfill-South) because a baseline risk
assessment indicated no risk to human or ecological receptors.

The selected remedy for Site 2 includes monitoring for the potential discharge of contaminants to
groundwater and/or surface water bodies. The major components of the minimal action include:

• institutional controls;

• removal of surface debris;

• installation of an additional monitoring well;

• implementation of an environmental monitoring, program;

• and five year reviews to ensure that the selected remedy continues to provide adeguate
protection of human health and the environment.

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 operational, design, and monitoring plans.

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: file
Mark Hyland-DEP Michael Barry-EPA
Claudia Sait-DEP Jeff Brandow-HLA
-------
APPENDIX C

APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
TABLE C-l
ARARS, Criteria, Advisories, and Guidance
Site 2 RECORD OF DECISION
NAS Brunswick
Media

GROUNDWATER

Federal
Requirement
SDWA - MCLs (40 CFR
141.11 - 141 16)
Requirement Synopsis
MCLs have been promulqated for several common
and inorqanic contaminants. These levels requlate the
concentration of contaminants in public drinkinq water
supplies, but may also be considered relevant and
appropriate for qroundwater aquifers used for drinkinq
water.
Groundwater at NAS Brunswick is not a current source
of drinkinq water; therefore, MCLs are not applicable, but
may be relevant and appropriate. To assess the potential
risks to human health due to consumption of
qroundwater, contaminant concentrations in qroundwater
measured durinq lonq-term monitorinq will be compared
to their MCLs.
MCLGs are health-based criteria. As promulqated under
SARA, MCLGs are to be considered for drinkinq water
sources. MCLGs are available for several orqanic and
inorqanic contaminants.
The 1990 National Continqency Plan states that non-zero
MCLGs are to be used as qoals. Because qroundwater
at NAS Brunswick is not a current source of drinkinq
water, MCLGs are not applicable, but may be relevant
and appropriate. Contaminant concentrations in
qroundwater measured durinq lonq-term monitorinq will
be compared to their MCLGs.
Maine Drinkinq Water Rules
(10-144 CMR Chapters 231 -
233)
Rules Relatinq to Testinq
of Private Water Systems
for Potentially Hazardous
Contaminants (10-144 CMR
Relevant and
Appropriate
Maine's Primary Drinkinq Water Standards are equivalent to
federal MCLs. When state levels are more strinqent
federal levels, the state levels may be used.
Appendix C of this requlation outlines Maximum Exposure
Guidelines (MEGs) for orqanic and inorqanic compounds.
MEGs include health advisories, which are maximum
allowable concentrations of specific contaminants in
Groundwater at NAS Brunswick is not a current source of
of drinkinq water; therefore, State Drinkinq Water
Standards are not applicable but may be relevant and
appropriate. Contaminant concentrations in qroundwater
will be compared to State standards to assess the
potential future risks to human health due to consumption
of qroundwater.

Groundwater at NAS Brunswick is not a current source
of drinkinq water; therefore, MEGs are not applicable but
may be relevant and appropriate. Contaminant
concentrations in qroundwater will be compared to MEGs
-------
SURFACE WATER

State
Table C-l
ARARS, Criteria, Advisories, and Guidance
Site 2 Record of Decision
NAS Brunswick
Natural Resources Protection
Act Permit by Rule (06-696
CMR Chapter 305, Section 2)
Surface Water Toxics Control
Program (06-696 CMR
Chapter 530.5)
Applicable
Regulates activities in and adj acent to freshwater wetlands
and streams. Soil disturbance in or adj acent to a freshwater
wetland or surface water body reguires erosion control
measures to prevent erosion and sedimentation of the
protected natural resources.
Except as naturally occurs, surface waters must be 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
to assess the potential future risks to human health due
to consumption of groundwater.
If it is determined that site topography does not preclude
disturbed soil from being washed into Mere Brook,
erosion control barriers will be installed prior to any
disturbance in or adj acent to the freshwater wetland or
stream. Any disturbed areas will be stabilized prior to
removing the erosion control barriers.

Contaminant concentrations measured during long-term
monitoring will be evaluated to assess whether Maine's
State Water Quality Criteria (SWQC) are being met.
GROUNDWATER £
SURFACE WATER
Notes:

AWQC =
CFR =
CMR =
MCL =
MCLG =
MEG =
NAS =
SARA =
SDWA =
SWQC =
Applicable or Relevant and Appropriate Reguirement
Ambient Water Quality Criteria
Code of Federal Regulations
Code of Maine Rules
Maximum Contaminant Level
Maximum Contaminant Level Goal
Maximum Exposure Guidelines
Naval Air Station
Super fund Amendments and Reauthorization Act
Safe Drinking Water Act
State Water Quality Criteria
Rules set forth reguirements for hazardous waste disposal
in Maine, including landfill contaminants may not migrate
beyond the waste management unit at levels which exceed
background, MEGs, or SWQCs.
-------
APPENDIX D

ADMINISTRATIVE RECORD INDEX
AND
GUIDANCE DOCUMENTS

(EDITED TO LIST ONLY THOSE DOCUMENTS APPLICABLE TO SITE 2)

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 2

SECTION 5: FEASIBILITY STUDIES 9

SECTION 6: PROPOSED PLANS AND PUBLIC HEARING
TRANSCRIPTS 10

SECTION 7: RECORDS OF DECISION 11

SECTION 8: POST-RECORD OF DECISION 11

SECTION 9: COMMUNITY RELATIONS 12

SECTION 10: PROGRAM GUIDANCE 19
-------
NAVAL AIR STATION BRUNSWICK
ADMINISTRATIVE RECORD INDEX (SITE 2)

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 1985 (Sites
1,2,3,4,7,8,9).

Correspondence:

1. Memo to Don Smith, NUS Corporation, from Colin Young, NUS Corporation,
regarding the site inspection at the U.S. Naval Air Station; September 22, 1983.

2. Memo to Robert Kowalczyk, Naval Facilities Engineering Command, Northern
Division, from William Fisher, E.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, E.G. 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, 1995.
-------
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 1995) 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

Not applicable to the Site 2 ROD.

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.G. 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.

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; NOAA; Camp, Dresser &
McKee; June 30, 1987.
-------
8. Letter to Robert Kowalczyk, Naval Facilities Engineering Command, Northern
Division, from Jack Hoar, Camp, Dresser & McKee, regarding meeting notes from a
June 12, 1987, planning meeting at USEPA Region I offices in Boston, Massachusetts,
among USEPA; U.S. Navy; E.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 1998 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, 1998.

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.

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, regardling 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.

Volume 4: Round II Data Package, Phase I - Remedial Investigation, prepared by E.C:
Jordan Co. [ABB Environmental Services, Inc.]; March 1989 (Sites 1,2,3,4,7,8,9).

Round III Data Package, Phase I - Remedial Investigation, prepared by E.C.
Jordan Co. [ABB Environmental Services, Inc.]; July 1989 (Sites 1,2,3,4,7,8,9).

Correspondence:
-------
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, 1999.

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 1, 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).

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: Not applicable to Site 2.

Volume 11: Not applicable to Site 2.

Volume 12: Not applicable to Site 2 .

Volume 13: Not applicable to Site 2.

Volume 14: Not applicable to Site 2.

Volume 15: Not applicable to Site 2.

SECTION 5: FEASIBILITY STUDIES

Volume 1: Draft Fund 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: Not applicable to Site 2.

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 Site 2 .

SECTION 6: PROPOSED PLANS AND PUBLIC HEARING TRANSCRIPTS

Volume 1: Not applicable to Site 2.

Volume 2: Not applicable to Site 2 .

Volume 3: Proposed Plan for Site 2, prepared by ABB Environmental Services, Inc.; May 1997.

Transcript of the Public Meeting [Hearing] for Proposed Plan, Site 2, prepared
by Brown & Meyers; May 13, 1997.

SECTION 7: RECORDS OF DECISION

Volume 1: Not applicable to Site 2.

Volume 2: Not applicable to Site 2 .

Volume 3: Record of Decision for Site 2, prepared by Harding Lawson Associates; September
1998.

Correspondence:

1. Letter to Emil Klawitter, Department of the Navy, Northern Division, from
Claudia Sait, MEDEP, regarding comments on the Draft Record of Decision for
Site 2; February 12, 1998.
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2. Letter to Emil Klawitter, Department of the Navy, Northern Division, from
Michael Barry, USEPA, regarding comments on the Draft Record of Decision
for Site 2; February 24, 1998.

3. Letter to Loukie Lofchie, BACSE, from Carolyn Lepage, Lepage Environmental
Services, Inc., regarding comments on the Draft Record of Decision for Site 2;
February 24, 1998.

4. Letter to Emil Klawitter, Department of the Navy, Northern Division, from
Michael Barry, USEPA, regarding comments on the Draft Final Record of
Decision for Site 2; July 23, 1998.

5. Letter to Loukie Lofchie, BACSE, from Carolyn Lepage, Lepage Environmental
Services, Inc., regarding comments on the Draft Final Record of Decision for
Site 2; July 31, 1998.

6. Letter to Emil Klawitter, Department of the Navy, Northern Division, from
Claudia Sait, MEDEP, regarding comments on the Draft Final Record of
Decision for Site 2; August 13, 1998.

7. Letter to Emil Klawitter, Department of the Navy, Northern Division, from
Michael Barry, USEPA, regarding supplemental comments on the Draft Final
Record of Decision for Site 2; August 18, 1998.

SECTION 8: POST-RECORD OF DECISION

Volume 1: Not applicable to Site 2.

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

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 corrections 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 IRC at Brunswick and a review of the revised April 1989 RI/FS work plan,
undated.
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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, 1989, 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, 1989, 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 28, 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, 1999.

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.

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.
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21. Meeting minutes of October 1, 1992, TRC meeting to discuss schedules for the
Sites 1 and 3 and Eastern Plume Records of Decision and remedial design, the
Building 95 Removal Action, the site investigation at Swampy Road Debris site
and Merriconeag Extension Debris site, the proposed plans for Site 8, and
Sites 5 and 6; the minutes also included a discussion of the future actions
scheduled for other sites; undated.

22. Meeting minutes of December 10, 1992, TRC meeting to discuss schedules for
the Building 95 Removal Action, the proposed plans for Sites 5 and 6, Site 8,
and Site 9, the Sites 1 and 3 and Eastern Plume Records of Decision and
remedial design, the remedial designs for Sites 5, 6, 8, 9, and Building 95, and
the site investigation at Swampy Road Debris site and Merriconeag Extension
Debris site; undated.

Volume 3: Technical Review Committee/Restoration Advisory Board Meeting Minutes
(March 1993 to January 1998)

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, 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, and status of the Remedial Action contract for Sites 1
and 3, 5, 6, 8, and the Eastern Plume; undated.

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.
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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.
9, Eastern Plume, and Building 95; establishment of a Restoration Advison,
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.

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.
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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.

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

28. Meeting minutes of October 8, 1997, RAB meeting to discuss the ROD for Sites
4, 11, and 13; basewide long term monitoring; groundwater infiltration study;
geostatistical analysis; cessation of Sites 1 and 3 extraction wells; monitoring
well MW-311 pumping study; treatment plant status; status of the IRP sites;
undated.

29. Meeting minutes of January 14, 1998, RAB meeting to discuss the schedule for
1998; ROD for Sites 4, 11, and 13; basewide long term monitoring; groundwater
infiltration study; geostatistical analysis; installation of extraction well
EW-2A; treatment plant status; status of the IRP sites; undated.

30. Meeting minutes of April 29, 1998, RAB meeting to discuss updates to the
schedule; Site 2 Record of Decision; Site 9 Proposed Plan; additional sampling
at Site 11 and Building 95; Sites 1 and 3 Landfill cap inspection; long-term
monitoring; undated.

31. Meeting minutes of July 29, 1998, RAB meeting to discuss updates to the
schedule; Site 9 Proposed Plan; Site 2 Record of Decision; Building 95 closure;
long-term monitoring; status of Site 7; undated.

SECTION 10: PROGRAM GUIDANCE

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.

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, 1996.

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.
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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, 1997.

10. Letter to R.L. Gillespie, Naval Facilities Engineering Command, Northern
Division, from David Webster, USEPA, regarding the schedule to be published
by February 1989, 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 remits 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, 1989.

14. Letter to Ronald Springfield, Naval Facilities Engineering Command, Northern
Division, from David Webster for Charlotte Head, USEPA, regarding the extent
of guality assurance and guality 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 9, 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 reguest 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.
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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
Reguirements (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 reguest concurrence
between the agencies for an extension to the Remedial Investigation schedule;
March 12, 1990.

24. Letter to Thomas Sheckels, Naval Facilities Engineering Command, Northern
Division, from Alan Prysunka, Maine DEP, regarding ARARs [Applicable or
relevant and appropriate 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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The U.S. Department of the Navy Announces
the Availability of a Record of Decision for
Site 2: Orion Street Landfill - South
at NAS Brunswick

On September 29, 1998, officials from the U.S. Navy and the U.S. Environmental Protection Agency (USEPA)
jointly signed a Record of Decision (ROD) for Site 2: Orion Street Landfill - South, located at the Naval
Air Station (NAS) in Brunswick, Maine. The ROD formally selects the Minimal Action Alternative as the
final remedy for this site. The Navy and the USEPA have determined that the Minimal Action Alternative is
appropriate for Site 2 since risk estimates are below federal and state target risk levels. In support of
the ROD, the Maine Department of Environmental Protection (MEDEP) provided a letter of concurrence to the
Navy expressing their agreement with this decision.

Implementation of the Minimal Action Alternative will include the following activities:

• institutional controls, including maintenance of the existing fence, installation of warning
signs and land use restrictions;

• removal of surface debris that is visible in the depression immediately south and east of
the landfill;

• installation of an additional groundwater monitoring well;

• environmental monitoring, including collection and analysis of samples of groundwater,
seeps, surface water and sediment;

• five-year site reviews; and

• modifications to the selected remedy, if necessary.

At least once every five years, the Navy will perform a review of the monitoring data to be presented in
a report. The report will recommend either to continue the minimal action activities or to make
modifications to the selected remedy. In addition to the five-year reviews, monitoring data will also be
evaluated more freguently at guarterly Restoration Advisory Board meetings, where decisions for more
immediate actions can be made, if necessary.

The ROD and the documents which form the basis for this decision are part of the Administrative Record.
The record is a public information file maintained at:
Curtis Memorial Library
temporarily housed at
Old Brunswick High School
McKeen Street
Brunswick, ME 04011
Hours: Monday, Wednesday: 9:30 - 8:00 pm
Thursday, Friday: 9:30 - 6:00 pm
Saturday: 9:30 - 5:00 pm
Questions about this decision or the Installation Restoration Program at NAS Brunswick should be directed
to:
John James
Public Affairs Office
Naval Air Station Brunswick
Brunswick, ME 04011
(207) 921-2527
Michael Barry
USEPA - Region I
JFK Federal Building (HBT)
Boston, MA 02203-2211
(617) 223-5579
Claudia Sail
Maine DEP
State House Station #17
Augusta, ME 04333
(207)287-7713
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