INSTALLATION RESTORATION PROGRAM NAVAL AIR STATION … · INSTALLATION RESTORATION PROGRAM NAVAL...

U.S. DEPARTMENT OF THE NAVYINSTALLATION RESTORATION PROGRAM

NAVAL AIR STATION BRUNSWICKBRUNSWICK, MAINE

FINALRECORD OF DECISION

FORSITE 2

SEPTEMBER 1998

U.S. DEPARTMENT OF THE NAVYINSTALLATION RESTORATION PROGRAM


FINALRECORD OF DECISION

FOR SITE 2AT


Preparedfor

U.S. Department of the NavyNorthern Division

Naval Facilities Engineering CommandContract No. N62472-91-C-1013

Prepared by

Harding Lawson AssociatesPortland, Maine 04112Project No. 9219-02

SEPTEMBER 1998

NAVAL AIR STATION BRUNSWICKRECORD OF DECISION

SITE 2

TABLE OF CONTENTS

Contents Page No

DECLARATION 1

DECISION SUMMARY 4I SITE NAME, LOCATION, AND DESCRIPTION 4H SITE HISTORY AND ENFORCEMENT ACTIVITIES 6

A LAND USE AND SITE HISTORY 6B RESPONSE AND ENFORCEMENT HISTORY 6

m COMMUNITY PARTICIPATION 8IV SCOPE AND ROLE OF RESPONSE ACTION 9V SUMMARY OF SITE CHARACTERISTICS 10VI SUMMARY OF SITE RISKS 13

A HUMAN HEALTH RISK ASSESSMENT 13B ECOLOGICAL RISK ASSESSMENT 14

VH DEVELOPMENT AND SCREENING OF ALTERNATIVES 15A STATUTORY REQUIREMENTS/RESPONSE OBJECTIVES 15B TECHNOLOGY AND ALTERNATIVE DEVELOPMENT AND SCREENING 15

VIE DESCRIPTION OF ALTERNATIVES 16A No ACTION 16B MINIMAL ACTION 16

LX SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES 18A OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 18B COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE

REQUIREMENTS 18C LONG-TERM EFFECTIVENESS AND PERMANENCE 19D REDUCTION OF TOXICFTY, MOBILITY, OR VOLUME THROUGH TREATMENT 19E SHORT-TERM EFFECTIVENESS 19F iMPLEMENTABILrrY 20

G COST 20H STATE ACCEPTANCE 21I COMMUNITY ACCEPTANCE 21

X THE SELECTED REMEDY 22A iNSTrrunoNAL CONTROLS 22B REMOVAL OF SURFACE DEBRIS 22C ADDITIONAL GROUNDWATER MONITORING WELL 22

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SITE 2

TABLE OF CONTENTScontinued

Contents _ Page No.

D. ENVIRONMENTAL MONITORING ..................................................................... 22E. FIVE YEAR REVIEWS ...................................................................................... 23F. COST ............................................................................................................... 23

XI. STATUTORY DETERMINATIONS ................................................................ 25A. THE SELECTED REMEDY is PROTECTIVE OF HUMAN HEALTH AND THE

ENVIRONMENT ............................................................................................... 25B. THE SELECTED REMEDY ATTAINS ARARs ..................................................... 25C. THE SELECTED REMEDIAL ACTION is COST-EFFECTIVE ................................. 25D. THE SELECTED REMEDY UTILIZES PERMANENT SOLUTIONS AND

ALTERNATIVE TREATMENT OR RESOURCE RECOVERY TECHNOLOGIES TOTHE MAXIMUM EXTENT PRACTICABLE .......................................................... 25

E. THE SELECTED REMEDY SATISFIES THE PREFERENCE FOR TREATMENTWHICH PERMANENTLY AND SIGNIFICANTLY REDUCES THE TOXICITY,MOBILITY, OR VOLUME OF THE HAZARDOUS SUBSTANCES AS APRINCIPAL ELEMENT ..................................................................................... 26

DOCUMENTATION OF NO SIGNIFICANT CHANGES ............................. 27. STATEROLE .................................................................................................. 28

GLOSSARY OF ACRONYMS AND ABBREVIATIONS

REFERENCES

APPENDICES

APPENDIX A- RESPONSIVENESS SUMMARY AND PUBLIC MEETINGTRANSCRIPT

APPENDIX B - MEDEP LETTER OF CONCURRENCEAPPENDIX C - APPLICABLE OR RELEVANT AND APPROPRIATE

REQUIREMENTSAPPENDIX D - ADMINISTRATIVE RECORD INDEX AND GUIDANCE

DOCUMENTS

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SITE 2

LIST OF FIGURES

Figure Page No

1 Site Location Map 52 Site Features 11

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iii

DECLARATION

SITE NAME AND LOCATION

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

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected final remedy for Site 2 at NAS Brunswick. Thisdecision document was developed in accordance with the Comprehensive EnvironmentalResponse, Compensation, and Liability Act (CERCLA) of 1980, as amended by the SuperfundAmendments and Reauthorization Act (SARA) of 1986, and to the extent practicable, theNational Oil and Hazardous Substances Pollution Contingency Plan (NCP). The remedy selectedis based on information contained in the Administrative Record for the site which was developedin accordance with Section 113(k) of CERCLA, and is available for public review at theinformation repositories located at the Public Works Office at NAS Brunswick and the CurtisMemorial Library, 23 Pleasant Street, Brunswick, Maine.

The State of Maine Department of Environmental Protection (MEDEP) concurs with the selectedremedy for Site 2.

ASSESSMENT OF THE SITE

The Navy has determined that the Minimal Action Alternative is appropriate for Site 2 since riskestimates are below U.S. Environmental Protection Agency (USEPA) and MEDEP target risklevels. 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 unacceptablerisks. Low levels of inorganic constituents such as mercury and lead were detected in sedimentand leachate samples at Site 2, but are below target risk levels. Geophysical investigationsdetermined 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 selectedremedy for Site 2 is Minimal Action. Implementation of the Minimal Action Alternative wouldinclude the following activities:

• institutional controls, including maintenance of the existing fence, installation ofwarning signs and land use restrictions. Land use restrictions shall be documentedin the NAS Brunswick Operations Instructions for site development which require

Installation Restoration Program

fiilrod2.doc 1 9219-02

environmental review. Should NAS Brunswick ever close and/or transfer thisproperty, USEPA and MEDEP shall be notified and appropriate wording shall beincluded in the necessary real estate documents.

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

• installation of an additional groundwater monitoring well;

• environmental monitoring, including collection and analysis of samples ofgroundwater, 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 bepresented in a report. The report will recommend either to continue the minimal action activitiesor to make modifications to the selected remedy. In addition to the five-year reviews, monitoringdata will also be evaluated more frequently by a process to be outlined in the long-termmonitoring plan. Data will be reviewed at quarterly Restoration Advisory Board meetings, wheredecisions 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 andthe environment, complies with federal and state requirements that are legally applicable orrelevant and appropriate for this action, and is cost-effective. The selected remedy does notsatisfy the statutory preference for treatment as a principal element. Treatment is unnecessary atthis 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 apotential for future impacts to groundwater and/or surface water, an environmental monitoringplan 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 everyfive years to ensure that the remedy continues to provide adequate protection of human health andthe environment. This review will evaluate the appropriateness of a Minimal Action decision forSite 2.


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DECLARATION

This Record of Decision represents the selection of a Minimal Action under CERCLA for Site 2The foregoing represents the selection of a remedial action by the Department of the Na\y, andthe U S Environmental Protection Agency Region I. with concurrence of the Maine D e p a r t m e n tof Environmental Protection

Concur and recommend for immediate implementation

Department of the Navy

By a - - _ DateE F Carter, Jr. 'Captain, U.S. Na\Commanding OfficerNaval Air Station Brunswick, Maine

United States Environmental Protection Agency^ ^ ) -7- < /- - , , ,

By v —^Z's ; --^'^^ -^ ' -/^ ./.,- Date-.Patricia L MeaneyDirectorOffice of Site Remediation and RestorationReeion I


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DECISION SUMMARY

I. SITE NAME, LOCATION, AND DESCRIPTION

The U.S. Naval Air Station (NAS) Brunswick is located in Brunswick, Maine. In 1987, NASBrunswick 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 NASBrunswick is characterized by low, undulating hills with deeply incised brooks; ground surfaceelevations range from mean sea level (MSL) in lowland drainage areas and the Harpswell Coveestuary, 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 groundsurface 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 twoparallel 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 NASBrunswick aircraft. Forested areas (approximately 48 percent), grasslands (approximately28 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 includesthe operations area (approximately 5 percent) and miscellaneous shrubland, marsh, and openwater. The southern edge of the base borders the estuary of Harpswell Cove.

Property uses surrounding NAS Brunswick are primarily suburban and rural residential, withsome commercial and light industrial uses along Routes 1, 24, and 123. An elementary school, acollege, 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 endof 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


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BaseBoundary

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INSTALLATION RESTORATION PROGRAM

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D. 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 operationsin the Atlantic Ocean and Mediterranean Sea. The base's primary mission is to operate andmaintain P-3 Orion aircraft. NAS Brunswick first became active in the 1940s during World WarII, and underwent major expansion in the 1950s.

Site 2 reportedly was used as the primary base landfill from 1945 to 1955 (R.F. Weston, Inc.,1983). The actual operation may have been less than 10 years because the Air Station was closedfrom 1946 to 1951, although non-military tenants used the property. Solid waste was incineratedat the site before being placed in the landfill and covered with soil. In addition to conventionalsolid 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 theeastern face of the landfill, otherwise the landfill has been covered with soil and supports a densegrove of conifers. The site lies within the fenced Weapons Compound Area; therefore, access isstrictly limited. A more detailed description of the history of Site 2 can be found in the Draft FinalRemedial 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 InstallationRestoration Program (IRP) and meets the requirements of the Comprehensive EnvironmentalResponse, Compensation and Liability Act (CERCLA) and the Superfund Amendments andReauthorization Act (SARA). The program was conducted in several stages.

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

• In 1984, a Pollution Abatement Confirmation Study was conducted. These studiesrecommended further investigation of seven of the nine hazardous waste sitesoriginally 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 quarterly since that initial meeting.



• Two sites were added to the RI/FS program in 1989, as well as the two additionalsites 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 USEPAand MEDEP regarding the cleanup of environmental contamination at NASBrunswick. The FFA sets forth the roles and responsibilities of each agency,contains deadlines for the investigation and cleanup of hazardous waste sites, andestablishes 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 samplinginvestigations, geology, and hydrogeology, and presented contamination and riskassessments. The Phase I FS identified remedial action objectives, and developedand screened remedial alternatives for the nine original sites studied in the DraftFinal RI.

• In 1995, U.S. Fish and Wildlife Service (USFWS) conducted a study to determineconcentrations of trace elements and pesticides in fish samples collected from MereBrook 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 theother sites at NAS Brunswick is also included in several of these reports.



m. COMMUNITY PARTICIPATION

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

In September 1988, the Navy released a Community Relations Plan outlining a program toaddress public concerns and keep citizens informed about and involved in remedial activities.

Prior to 1988, the Navy used the existing Hazardous Waste Subcommittee on the Military-Community Council to provide direct information regarding the IRP to the community. From itscreation in 1988 until July 1995, the TRC became an important vehicle for communityparticipation. In July 1995, the TRC became known as a RAB whose membership includes theNavy, USEPA, MEDEP, and various community representatives. The community members ofthe RAB include representatives from Brunswick, Harpswell, and Topsham as well as theBrunswick Area Citizens for a Safe Environment, who became active participants subsequent to1988. The RAB also has representatives from the Brunswick-Topsham Water District. The RABmeets quarterly, reviews the technical aspects of the program, and provides community input tothe program.

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

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

On May 2, 1997, the Navy placed the Proposed Plan detailing the Preferred Alternative for Site 2in the information repository at the Curtis Memorial Library (ABB-ES, 1997). TheAdministrative Record for Site 2 is available for public review at NAS Brunswick in the PublicWorks office and at the Curtis Memorial Library. A notice and brief analysis of the ProposedPlan 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 publicinput on the alternatives presented in the Proposed Plan. On May 13, 1997, the Navy andregulatory representatives held an informational public meeting to discuss the Proposed Plan forSite 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 theNavy during the 30-day public comment period.



IV. SCOPE AND ROLE OF RESPONSE ACTION

The Navy has determined that Minimal Action under CERCLA is appropriate for Site 2. Theconcentrations 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 carcinogenicrisk range of IxlO"4 to IxlO"6, or the MEDEP maximum acceptable incremental lifetimecarcinogenic risk of IxlO"5 for the hypothetical future residential use scenario evaluated in the riskassessment. Non-carcinogenic risks were also well below the target Hazard Index (HI) of 1.0 forall 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 bepresented in a report. The report will recommend either to continue the minimal action activitiesor to make modifications to the selected remedy. In addition to the five-year reviews, monitoringdata will also be evaluated more frequently by a process to be outlined in the long-termmonitoring plan. Data will be reviewed at quarterly RAB meetings, where decisions for moreimmediate actions can be made, if necessary.


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V. SUMMARY OF SITE CHARACTERISTICS

Section 3.0 of the FS (E.G. Jordan, 1992) contains an overview of the site characteristics andremedial 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 to21 feet, and a transitional layer of interbedded silts and sand ranging in thickness from 5 to11 feet. A clay layer occurs below the transition layer.. The surface of the clay layer dips stronglyto the east (i.e., toward Mere Brook).

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

Environmental contamination attributable to Site 2 is observed in the leachate and sedimentassociated with seeps, and in stream sediments (E.G. Jordan, 1990a). Contamination principallyconsists of inorganic compounds, with low levels of pesticides (less than 1.0 milligram perkilogram [mg/kg]) and polycyclic aromatic hydrocarbon (PAH) compounds (maximum of1.7mg/kg). These contaminants are consistent with the historical land use and disposal ofincinerated wastes at this site. Buried ash would contribute to inorganic contamination ingroundwater and leachate downgradient of the landfill. The low levels of pesticides detected areassumed to be residual concentrations resulting from historical, basewide use of these compoundsin the 1960s and 1970s. In the groundwater samples from Site 2, lead was the only inorganiccompound detected (in two out of a total of ten samples) in excess of its respective federalMaximum Contaminant Level (MCL) of 15 micrograms per liter (ug/1) or Maine MaximumExposure Guideline (MEG) of 20 ug/1. The two lead detections included 180 ng/1 in monitoringwell MW-103 and 60 ug/1 in monitoring well MW-212. The groundwater data was collected fromthe shallow aquifer that discharges to Mere Brook.

The highest levels of contamination observed at Site 2 were detected in the leachate seeps. A widevariety of inorganics were reported in leachate and sediment samples, with iron and mercuryhaving the highest concentrations relative to background values. Low levels ofdichlorodiphenyltrichloroethane (DDT) were observed in leachate samples and adjacent surfacesoils.

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



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A magnetometer survey was performed to determine the landfill boundaries and ascertain thepresence of buried drums. The significant anomalies that were found can be explained by highconcentrations of ferrous metallic debris at or near the ground surface along the landfill fringes.Visible debris included drums, containers, office furniture, and domestic waste.

A soil gas survey, performed to evaluate volatile organic compound (VOC) contamination in thevadose zone, did not indicate the presence of significant subsurface VOC contamination.

Subsurface soil samples collected from four borings located in the Site 2 area did not contain anyVOC or SVOC contaminants, and detected inorganics were consistent with background valuesfor NAS Brunswick.

In 1995, USFWS conducted a study to determine concentrations of trace elements and pesticidesin fish samples collected from Mere Brook near Site 2 (USFWS, 1997). These samples wereanalyzed to look for adverse effects on fish in the brook. The testing found no adverse impacts tothe fish from inorganic constituents. The report does note the presence of elevated concentrationsof some pesticide-related compounds, but the source of these compounds was not determined aspart of this study.


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VL SUMMARY OF SITE RISKS

A risk assessment was performed to estimate the probability and magnitude of potential adversehuman health and environmental effects from exposure to contaminants associated with Site 2.The risk assessment followed a four step process:

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

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

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

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

Carcinogenic and noncarcinogenic risks are quantitatively evaluated for each site. Carcinogenicrisks are compared to the USEPA target carcinogenic risk range of IxlO"4 to IxlO"6 and to theMEDEP maximum acceptable incremental lifetime carcinogenic risk of IxlO'5. Noncarcinogenicrisks are compared to the USEPA noncarcinogenic Hazard Index (HI) of 1.0 (USEPA, 1989b).

A. HUMAN HEALTH RISK ASSESSMENT

Human health risks associated with contaminant exposure at Site 2 were estimated based onanalytical data collected during Sampling Rounds I through IV, and are presented in Appendix Qof the Draft Final RI (E.G. Jordan Co., 1990a).

Human health risks were evaluated for Site 2 based on a hypothetical future residential land usescenario at this site. This exposure scenario is considered overly conservative because of therestricted access to Site 2. Risks were estimated based on most probable and realistic worst-caseexposures. Carcinogenic risk estimates associated with contaminant exposure under futureresidential land use ranged from l.SxlO'9 to 9.2xlO'8, well below USEPA and MEDEP risktargets. Non-carcinogenic hazard indices ranged from 0.03 to 0.2, well below the target HI of1.0. Lead was the only contaminant detected in ground water above its respective federal drinkingwater standard (i.e. MCL). There is no current exposure to groundwater as this portion of thebase is serviced by public water supply. Future use of groundwater is not considered likely basedon both potential future land use and because the shallow aquifer between Site 2 and Mere Brookis not likely to be used as a drinking water source. Therefore, a quantitative exposure assessmentfor the ingestion of groundwater was not developed for Site 2.


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B. ECOLOGICAL RISK ASSESSMENT

An ecological risk assessment (ERA) was conducted to evaluate the potential risks to aquatic andterrestrial organisms from exposure to contaminants at Site 2. The ERA reviewed organic andinorganic contaminant concentrations in surface water, sediments, leachate seeps, and surface soil.Contaminants of potential concern (COCs) for ecological receptors were determined bycomparing sampling results to Ambient Water Quality Criteria (AWQCs) for surface water,USEPA interim sediment quality criteria (where available) for sediments, and lowest effect levelestimates derived from published lexicological studies for leachate seeps and surface soil. TheERA is described in detail in the FS (E.G. Jordan Co., 1990a; Appendix Q). The conclusionsfrom 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 bedirectly related to Site 2.

Iron and the PAH phenanthrene were identified as COCs in Mere Brook sediments. As was thecase 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 aquatic populations, theecological risk assessment evaluated an exposure scenario consisting of wildlife drinking from theseeps. Even with a conservative assumption that the modeled terrestrial organisms would obtainall of their drinking water from the seeps, which is unlikely given the abundant flowing water inthe adjacent Mere Brook, the ERA concluded that only slight risks would exist, and thatdeleterious effects would be unlikely under actual exposure conditions.

For surface soil, only mercury in soils associated with seep locations was selected as a COC. Aterrestrial food-web model based on five classes of receptors was used to evaluate COCs forsurface soil. The evaluation concluded that the hazard index for potential exposure to mercuryranged from 0.006 to 0.141, well below the target Ffl of 1.0.



VH. DEVELOPMENT AND SCREENING OF ALTERNATIVES

This Section presents the development and screening of two remedial alternatives for Site 2: theNo Action Alternative and the Minimal Action Alternative. This range of alternatives isappropriate for Site 2 because site conditions did not warrant the development of remedialresponse objectives.

A. STATUTORY REQUIREMENTS/RESPONSE OBJECTIVES

The primary goal at NPL and similar sites is to undertake remedial actions that are protective ofhuman health and the environment. Sections 120 and 121 of CERCLA establish several statutoryrequirements and preferences, including: a requirement that the remedial action, when complete,must comply with all federal and more stringent state environmental standards, requirements,criteria or limitations, unless a waiver is invoked; a requirement that the remedial action is cost-effective and uses permanent solutions and alternative treatment technologies or resourcerecovery technologies to the maximum extent practicable; and a preference for remedies thatinclude treatment to permanently and significantly reduce the toxicity, mobility, or volume ofhazardous substances as a principal element over remedies not involving such treatment.

Remedial action objectives consist of media-specific goals for protecting human and ecologicalreceptors. Based on the results of the baseline risk assessments, remedial action objectives werenot developed for this site. There are no unacceptable current or future potential risks to eitherhuman 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 theMinimal Action Alternative. Based on the results of the baseline risk assessments, there are nounacceptable potential risks to either human or ecological receptors from exposure to site-relatedcontaminants. However, because the waste material disposed of at Site 2 will remain on site, aMinimal Action Alternative of long-term environmental monitoring was developed in addition to aNo Action Alternative



DESCRIPTION OF ALTERNATIVES

This section provides a narrative summary of the alternatives evaluated in the FS. Thealternatives developed for Site 2 include No Action and Minimal Action. A detailed assessmentof 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 HazardousSubstances Pollution Contingency Plan (NCP) and to compare with other remedial actionalternatives. This alternative does not involve implementing remedial actions, controls, ormonitoring, except that access to the site is already strictly controlled by virtue of its locationwithin 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 alternativeare as follows:

• institutional controls;• removal of surface debris;• installation of an additional ground water 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 tonotify site personnel of potential hazards. Land Use Restrictions shall be documented in thecurrent NAS Brunswick Operations Instructions. The Operations Instructions are used by NASBrunswick to identify and screen environmental areas from inappropriate construction ordevelopment activities. Should NAS Brunswick ever close and/or transfer this property, USEPAand MEDEP shall be notified and appropriate wording shall be included in the necessary realestate documents to prevent disturbance of buried wastes or the extraction or use of groundwaterat Site 2 without regulatory review and approval. The base closure process would include anevaluation of actions necessary for decommissioning the Air Station, including the need for landuse restrictions on specific areas such as Site 2. Removal of debris would be limited to itemsvisible on the ground surface in the depression immediately south and east of the landfill. Thelong-term environmental monitoring program would be implemented to ensure that contaminantconcentrations in the leachate do not increase over time. An additional groundwater monitoringwell would be installed to provide an additional downgradient monitoring point. A long-termmonitoring plan would be prepared for RAB review and regulatory agency approval. The planwould include a process for determining whether more immediate actions are needed to addresspotential risks to human health or the environment. Data will also be reviewed at quarterly 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 reviewsas mandated by SARA and described in the FFA.



IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

Section 121(b)(l) of CERCLA presents several factors that at a minimum must be considered inthe assessment of alternatives. Building upon these specific statutory mandates, the NationalContingency Plan articulates nine evaluation criteria to be used in assessing the individualremedial alternatives.

A. OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

Overall Protection of Human Health and the Environment addresses how an alternative as a wholewill protect human health and the environment. This includes an assessment of how human healthand 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 ecologicalreceptors based on current or assumed future exposure to contaminants at Site 2. Naturaldegradation 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 adequate level of protection to human andecological receptors through the implementation of institutional controls. To ensure that therecontinues to be no risk to human health or the environment from Site 2, a long term monitoringprogram is included to provide data to verify the effectiveness of the remedial action, or formodifying the remedial action as necessary.

The No Action Alternative would provide no additional protection to human or ecologicalreceptors over baseline conditions. However, the baseline risk assessment does not indicate a riskto 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 federalenvironmental 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 needto comply with the Maine Natural Resources Protection Act Permit by Rule regulations forerosion control (06-696 CMR Chapter 305) during the removal of surface debris and subsequentminor filling and regrading. Also, water quality standards under federal and state drinking waterprograms, the Maine Surface Water Toxics Control Program, and the Maine Hazardous WasteManagement 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 tomonitor the condition of groundwater and surface water to determine whether these ARARs aremet. No monitoring would be performed under the No Action alternative, and compliance with


fnlrod2.doc 18 9219-02

ARARs would not be determined A listing and synopsis of the ARARs can be found inAppendix C

C. LONG-TERM EFFECTIVENESS AND PERMANENCE

Long-term Effectiveness and Permanence refers to the ability of an alternative to maintain reliableprotection 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 Alternativewould provide data and interpretation of the degradation, dispersion, and movement ofcontaminants in the leachate, groundwater, surface water, sediment, and surface soils at Site 2The data would be used to confirm that risks associated with the wastes disposed at Site 2 remainbelow levels of concern. The No Action Alternative is intended to provide a baseline forcomparison 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 ofconcern

D. REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH TREATMENT

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

Based on the results of the risk assessment, reduction of toxicity, mobility, or volume is notrequired at Site 2 to be protective of human health or the environment However, for both theMinimal Action and No Action Alternatives, it is expected that natural degradation and dispersionprocesses 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 theenvironment that may be posed during the construction and implementation of an alternative untilcleanup goals are achieved

The Minimal Action Alternative would not involve any remedial construction, and only minimalinvasive 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 inremoval of surface debris, well installation and monitoring activities would have to be trained inhealth and safety for work at hazardous waste sites Proper personal protective equipment, work


fnlrocttdoc 19 9219-02

area monitoring, and safe work practices would minimize the possibility of chemical exposure orinjury under this alternative.

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

F. IMPLEMENTABILITY

Implementability refers to the technical and administrative feasibility of an alternative, includingthe 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 ActionAlternative. Implementation of this alternative would not interfere with possible future remedialactions at this site should they be required.

The proposed monitoring plan would be submitted for regulatory agency review and approvalprior to implementation. Coordination between the party responsible for carrying out monitoringactivities and officials at NAS Brunswick would be required for individuals to gain safe and legalaccess 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. Thefive-year review would be conducted jointly by the Navy, MEDEP, and USEPA.

Because environmental monitoring is a well-developed and widely available technique, severalcontractors would be able to provide competitive bids for required services.

The No Action Alternative has no components and requires 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 ofoperating 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 costsfor environmental monitoring and five-year reviews The costs were estimated for a 30-yearmonitoring program.

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


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H. STATE ACCEPTANCE

State Acceptance addresses whether, based on its review of the RI/FS and Proposed Plan, thestate 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 anddocumented its concurrence with the Minimal Action Alternative. A copy of the letter ofconcurrence 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 atthe public meeting and during the public comment period for that plan. This is documented in theResponsiveness Summary in Appendix A of this ROD.



X. THE SELECTED REMEDY

The selected remedy for Site 2 is the Minimal Action Alternative which will include institutionalcontrols, debris removal, installation of an additional groundwater monitoring well, environmentalmonitoring, and five-year site reviews. Remedial action objectives were not developed for thissite because no risk to human or ecological receptors was indicated by the baseline riskassessment. A long-term environmental monitoring program will be implemented to confirm theprotectiveness of the selected remedy. Data collected during the monitoring program will beevaluated during the five-year site reviews as mandated by SARA and described in the FFA. Thecomponents 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 leachateseeps along Mere Brook, to notify site personnel of potential hazards. Routine maintenance ofthe existing fence will also be included.

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

B. REMOVAL OF SURFACE DEBRIS

Debris removal will consist of collection and proper disposal of surface debris in the depressionimmediately south and east of the landfill. Clearing of vegetation will be minimized, and disturbedareas 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 monitoringlocation. The actual location and design of the additional well will be established in theenvironmental monitoring plan for Site 2.

D. ENVIRONMENTAL MONITORING

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



1. monitor changes in the groundwater, surface water and sediment since wastesremain buried at the site;

2. provide a tiered approach to attaining the MEDEP water quality standards; and3. 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 toimplementation. Details of the monitoring program will be discussed at upcoming RAB meetingsfollowing signature of this ROD. The monitoring plan will include procedures for routine,periodic sampling of groundwater, leachate, surface water, and sediments. In addition, the planwill discuss future fish tissue sampling, as appropriate, based on the findings andrecommendations of the USFWS report. Sampling methodology and locations, frequency ofsampling, and analytical parameters will be specified in the plan for all proposed environmentalmonitoring.

Data generated from this sampling will provide information on potential contaminant migration,accumulation or attenuation of inorganics sorbed onto sediment and surface soils, and thepotential impact of contamination in leachate seeps to Mere Brook. The monitoring plan will alsoestablish procedures for determining whether any actions are appropriate, based on analyticalresults. 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 havenot been permanently treated, to assure that human health and the environment are beingprotected. The purpose of the five-year review would be to organize, analyze, and present thedata gathered during sampling events in a report format. The five-year review would beconducted jointly by the Navy, MEDEP, and USEPA. The review would make arecommendation regarding future actions at the site. This recommendation could be to continueenvironmental 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 unitswhere decision documents have been finalized and five-year reviews are required. At NASBrunswick, a facility-wide five-year review is required in the year 2000, and Site 2 will beincluded in the scope of that review.

F. COST

Cost includes the capital (up-front) cost of implementing an alternative as well as the cost ofoperating and maintaining the alternative over the projected life of the remedial action.



The Minimal Action Alternative is estimated to cost approximately $253,000 and includes thecosts for environmental monitoring and five-year reviews. Monitoring is assumed to continue for30 years for cost-estimating purposes; however, this time frame will be continually re-evaluatedduring the five-year site review.



XL STATUTORY DETERMINATIONS

The remedial action selected for implementation at NAS Brunswick for Site 2 is consistent withCERCLA and, to the extent practicable, the NCP. The selection of the Minimal ActionAlternative 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 ecologicalreceptors based on current or assumed future exposure to contaminants at Site 2.

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

B. THE SELECTED REMEDY ATTAINS ARARs

The selected remedy will attain ARARs. The ARARs for this remedy and the manner in whichthey 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 effectivenessproportional to its costs. The Navy evaluated the overall effectiveness of the selected remedy byassessing the relevant three criteria: long-term effectiveness and permanence; reduction intoxicity, mobility, and volume through treatment; and short-term effectiveness, in combination.The relationship of the overall effectiveness of this remedial alternative was determined to beproportional to its costs.

D. THE SELECTED REMEDY UTILIZES PERMANENT SOLUTIONS AND ALTERNATIVETREATMENT OR RESOURCE RECOVERY TECHNOLOGIES TO THE MAXIMUM EXTENTPRACTICABLE

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 volumethrough treatment; (3) short-term effectiveness; (4) implementability; and (5) cost. The balancetest prefers a permanent, long-term solution which reduces waste toxicity, mobility or volumethrough 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 andstate acceptance and the risk posed by the site are carefully considered. The selected finalremedial action provides the best balance of these criteria for Site 2.



E. THE SELECTED REMEDY DOES NOT SATISFY THE PREFERENCE FOR TREATMENTWHICH PERMANENTLY AND SIGNIFICANTLY REDUCES THE TOXICITY, MOBILITY, ORVOLUME OF THE HAZARDOUS SUBSTANCES AS A PRINCIPAL ELEMENT

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



XH. DOCUMENTATION OF NO SIGNIFICANT CHANGES

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



XHI. STATE ROLE

MEDEP has reviewed the RI Report, Risk Assessment, Feasibility Study and Proposed Plan, andhas indicated its support for the selected remedy. MEDEP concurs with the selected remedy forNAS Brunswick Site 2. A copy of the letter of concurrence is presented in Appendix B of thisROD.


fiilrod2doc 28 9219-02


ABB-ES ABB Environmental Services, Inc.ARAR Applicable or Relevant and Appropriate RequirementAWQC Ambient Water Quality Criteria

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980(the Superfimd statute)

COC contaminant of concern

DDT dichlorodiphenyltrichloroethane

ERA ecological risk assessment

FFA Federal Facility AgreementFS Feasibility Study

HI Hazard Index

IAS Initial Assessment StudyIRP Installation Restoration Program

MCL maximum contaminant levelMEDEP Maine Department of Environmental ProtectionMEG Maine Maximum Exposure Guideline(ig/1 micrograms per litermg/kg milligrams per kilogramMSL mean sea level

NAS Naval Air StationNCP National Oil and Hazardous Substances Contingency PlanNPL National Priorities List

PAH polycyclic aromatic hydrocarbon

RAB Restoration Advisory BoardRI Remedial InvestigationROD Record of Decision

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SARA Superfund Amendments and Reauthorization Act

TRC Technical Review Committee

USEPA U.S. Environmental Protection AgencyUSFWS 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

EC Jordan Co, 1985 "Pollution Abatement Confirmation Study, Step 1A - Verification",Portland, Maine, June 1985

E C Jordan Co , 1990a "Draft Final Remedial Investigation Report NAS Brunswick", Portland,Maine, August 1990

E C Jordan Co , 1990b "Draft Final Phase I Feasibility Study Development and Screening ofAlternatives NAS Brunswick", Portland, Maine, August 1990

E C 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 RemedialInvestigations and Feasibility Studies Under CERCLA", EPA/540/G-89/004, WashingtonD C , October 1988

U S Environmental Protection Agency (USEPA), 1989a "Supplemental Risk AssessmentGuidance for the Super-fund Program", EPA/901/5-89/001, Region I, Boston,Massachusetts, June 1989

U S Environmental Protection Agency (USEPA), 1989b "Risk Assessment Guidance forSuperfund 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 FromMere Brook", Special Project Report FY97-MEFO-3EC, New England Field Office,February 1997


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APPENDIX A

RESPONSIVENESS SUMMARYAND

PUBLIC MEETING TRANSCRIPT



RESPONSIVENESS SUMMARY

The Navy held a 30-day comment period from May 9 to June 9, 1997, to provide an opportunityfor 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. TheProposed Plan is the document that recommends the remedial alternative that best meets theevaluation criteria for Site 2.

In the Proposed Plan, the Navy recommended the Minimal Action alternative as its preferredalternative for Site 2. The Proposed Plan was issued on May 2, 1996, before the start of thecomment period. All documents on which selection of the preferred alternative is based wereplaced in the Administrative Record for review. The Administrative Record is a collection of thedocuments 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 commentperiod. Several verbal comments were offered at the public meeting on May 13, 1997, by arepresentative of the citizens' group, Brunswick Area Citizens for a Safe Environment.Responses were provided verbally for each comment during the meeting, and these aredocumented 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 institutionalcontrols, land use restrictions, surface debris removal, and environmental monitoring. Five-yearsite reviews will be conducted to ensure that the remedial action continues to be protective ofhuman health and the environment.


fhlrod2doc 9219-02

©FT

1 BRUNSWICK NAVAL AIR STATION

2 Hearing

3

4

5

6 RE: IR Site 2

7

8

9

10 HEARING, held at Curtis Memorial Library,

11 Pleasant Street, Brunswick, Maine, on May 13,

12 .19JLZ' commencing at 7:05 p.m., before Kristin E

13 Lively, a Notary Public in and for the State of

14 Maine.

15

16

17

18 HELD BEFORE:

19 James Caruthers

20

22Krist in E. Lively

23 BROWN & MEYERSPost Office Box. 937

24 Yarmouth, ME 04096-0937(207) 846-0420

25

BROWN & MEYERS

1 E X H I B I T S

2 NUMBER DESCRIPTION PAGE

3 None.

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BROWN & MEYERS

1 PROCEEDINGS

2

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 questions

24 that you have on our Proposed Plan.

25 The CERCLA process starts after a site gets

BROWN & MEYERS

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

BROWN & MEYERS

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 quite 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

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

1 Magnetometer is a device similar to a powerful metal

2 detector and it's a very good technique 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

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 aquatic 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

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

10

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

11

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

12

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 - - d o 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

13

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

14

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, butp;ft./n ̂

24 nothing - - w e didn't do test bidding. There was no

25 log or whatever the meter was when we did test

BROWN & MEYERS

15

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

16

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.

5

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

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

BROWN & MEYERS

17

1 CERTIFICATE OF REPORTER

2

3

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.

8

9

10 I further certify that I am a disinterested

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

12 cause.

13

14

15 IN WITNESS WHEREOF, I subscribe my hand and

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

17 Dated at Boothbay Harbor, Maine.

18

19

20

21 Kristin E. Lively

22

23

24 My Commission Expires

25 January 18, 2002

BROWN & MEYERS

APPENDIX B

MEDEP LETTER OF CONCURRENCE


fhlrod2.doc 9219-02

STATE OF MAINEDEPARTMENT OF ENVIRONMENTAL PROTECTION

ANGUS S KING, JR EDWARD O SULLIVAN

GOVERNOR Co~t,»mU ,̂. 1 1 1 OQO COMMISSIONERSeptember 17, 1998

Mr. Emil KlawitterCode 1823 EKDepartment of the Navy, Northern DivisionNaval Facilities Engineering Command10 Industrial Highway, Mail Stop 82Lester, PA 19113-2090

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

Dear Mr. Klawitter:

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

Based on the Final Record of Decision, the Department concurs with the Navy's selectedremedy 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 abaseline risk assessment indicated no risk to human or ecological receptors.

The selected remedy for Site 2 includes monitoring for the potential discharge ofcontaminants to groundwater and/or surface water bodies. The major components ofthe 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 provideadequate protection of human health and the environment.

AUGUSTA17 STATE HOUSE STATION BANGOR PORTLAND PRESQUE I S L EAUGUSTA, M A I N E 04333-0017 106 HOGAN ROAD 312 CANCO ROAD 1235 CENTRAL D R I V E , SKYWAY( 2 0 7 ) 2 8 7 - 7 6 8 8 BANGOR, M A I N E 04401 PORTLAND, M A I N E 04103 PRESQUE ISLE, MAI NE 04769-2094RAY BLDG., HOSPITAL ST. (207) 941-4570 FAX: (207) 941-4584 ( 2 O 7 ) 822-6300 FAX: (207) 822-6303 (207) 764-0477 FAX- ( 2 0 7 ) 764 1507

web site, v,ww.state.me.us/ dep printed on recycled paper

of2

This concurrence is based on the State's understanding that the DEP will continue toparticipate in the Federal Facilities Agreement and in the review and approval ofoperational, design, and monitoring plans.

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

Sincerely,

Edward O. SullivanDepartment of Environmental Protection

pc: fileMark Hyland-DEPClaudia Sait-DEPMichael Barry-EPAJeffBrandow-HLA

APPENDIX C

APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS


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APPENDIX D

ADMINISTRATIVE RECORD INDEXAND

GUIDANCE DOCUMENTS



NAVAL AIR STATION BRUNSWICKADMINISTRATIVE RECORD INDEX

(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 HEARINGTRANSCRIPTS 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 BRUNSWICKADMINISTRATIVE RECORD INDEX (SITE 2)

SECTION 1; PRELIMINARY ASSESSMENTS

Volume 1: Initial Assessment Study of Naval Air Station Brunswick, Maine, prepared byRoy 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 byE.G. Jordan Co. [ABB Environmental Services, Inc.]; June 1985 (Sites1,2,3,4,7,8,9).

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, NorthernDivision, from William Fisher, E.C. Jordan Co. [ABB Environmental Services,Inc.], regarding the schedule of on-site exploration and sampling activitiesduring the Pollution Abatement Confirmation Study; October 30, 1984.

3. Memo of conversation between Robert Kowalczyk, Naval Facilities EngineeringCommand, Northern Division, and William Fisher, E.C. Jordan Co. [ABBEnvironmental Services, Inc.], regarding the preliminary data from theConfirmation Study at Brunswick and the status of fieldwork; December 11,1984.

4. Memo of conversation between Robert Kowalczyk, Naval Facilities EngineeringCommand, Northern Division, and William Fisher, E.C. Jordan Co. [ABBEnvironmental Services, Inc.], regarding the preliminary results of the NACIPStudy at Brunswick and the expected completion of the sampling; January 3,1985.

5. Memo of conversation between Robert Kowalczyk, Naval Facilities EngineeringCommand, Northern Division, and William Fisher, E.C. Jordan Co. [ABBEnvironmental Services, Inc.], regarding the results of the NACIP Study atBrunswick and the expected submittal of the report; January 15, 1985.

September 16, 1998


SECTION 2 (continued)

6. Letter to William Fisher, E.C. Jordan Co. [ABB Environmental Services, Inc.],from A. Rhoads, Department of the Navy, Northern Division EnvironmentalProtection Section, regarding comments on the Draft Confirmation StudyVerification 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.C. Jordan Co. [ABB EnvironmentalServices, Inc.], regarding the NACIP Confirmation Study Verification Phasereport; May 24, 1985.

8. Letter to William Fisher, E.C. Jordan Co. [ABB Environmental Services, Inc.],from A. Rhoads, Department of the Navy, Northern Division EnvironmentalProtection Section, regarding comments on the revised Confirmation StudyVerification 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 theJune 1985 [Pollution Abatement Confirmation Study, Step 1A - Verification]Report; December 3, 1985.

10. Letter to L.K. Jones, Naval Air Station, Brunswick, from Robert Jackson,USEPA, regarding comments on the [June 1985] Pollution AbatementConfirmation 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 onthe [June 1985] Pollution Abatement Confirmation Study, Step 1A - VerificationReport; January 13, 1986.

12. Letter to Jim Shafer, Department of the Navy, Northern Division, from NancyBeardsley, MEDEP, regarding MEDEP's comments on future planned fieldactivities 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 PollutionAbatement Confirmation Study Work Plan - Step 1 prepared by E.C. Jordan Co.[ABB Environmental Services, Inc.]; April 1988 (Sites 1,2,3,4,7,8,9).

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

September 16, 1998



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

Correspondence:

1. Letter to Commander L.K. Jones, Naval Air Station Brunswick, from MatthewHoagland, USEPA, regarding comments on the September 1986 Draft PollutionAbatement Confirmation Study Work Plan - Step IB: Characterization;November 24, 1986.

2. Letter to Matthew Hoagland, USEPA, from T.G. Sheckels, Naval Air StationBrunswick, regarding responses to USEPA comments on the September 1986Draft Pollution Abatement Confirmation Study Work Plan - Step IB:Characterization; March 31, 1987.

3. Letter to Commander L.K. Jones, Naval Air Station Brunswick, from DavidWebster, USEPA, regarding clarification as to the status of incorporatingUSEPA's comments into the revised report, and communication of theirconcerns for Site 8; April 9, 1987.

4. Letter to Charlotte Head, USEPA, from Kenneth Finkelstein, National Oceanicand Atmospheric Administration (NOAA), regarding comments on the RI/FSWorkplan for Phase H field activity; April 14, 1989.

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

6. Letter to David Epps and Robert Kowalczyk, Naval Facilities EngineeringCommand, Northern Division, from Charlotte Head, USEPA, regarding the[Pollution Abatement Confirmation Study, Step] IB - Characterization WorkPlan meeting, and a discussion for the Superfund program; June 29, 1987.

7. Meeting summary of June 12, 1987, planning meeting at USEPA Region Ioffices 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, NorthernDivision, from Jack Hoar, Camp, Dresser & McKee, regarding meeting notesfrom a June 12, 1987, planning meeting at USEPA Region I offices in Boston,Massachusetts, among USEPA; U.S. Navy; E.C. Jordan Co. [ABBEnvironmental Services, Inc.]; Maine DEP; NOAA; Camp, Dresser & McKee;July 8, 1987.

9. Letter to Charlotte Head, USEPA, from Kenneth Finkelstein, National Oceanicand Atmospheric Administration, regarding the June 10, 1987, TrusteeNotification Form; November 10, 1987.

September 16, 1998



10. Letter to Captain E.B. Darsey, Naval Air Station Brunswick, from MerrillHohman, USEPA, regarding comments on the [January 1988] PollutionAbatement Confirmation Study RI and Extended SI Studies, the Site QualityAssurance Plan, the Site Health and Safety Plan, and the Quality AssuranceProgram Plan; March IS, 1988.

11. Letter to Ronald Springfield, Naval Facilities Engineering Command, NorthernDivision, from Cynthia Kuhns, Maine DEP, regarding comments on the January1988 Remedial Investigation Work Plan, and the January 1988 QualityAssurance Program Plan (see Section 10 of this index); April 7, 1988.

12. Letter to Charlotte Head, USEPA, from Gordon Beckett, U.S. Fish and WildlifeService, regarding comments on the [April 1988] RI/FS Work Plan; May 10,1988.

13. Letter to Charlotte Head, USEPA, from Kenneth Finkelstein, National Oceanicand Atmospheric Administration, regarding the [April 1988 RemedialInvestigation/ Feasibility Study] Work Plan; May 13, 1988.

14. Letter to Captain E.B. Darsey, Naval Air Station Brunswick, from CynthiaKuhns, Maine DEP, regarding comments on the April 1988 RemedialInvestigation/ Feasibility Study Work Plan; June 6, 1988.

15. Letter to Captain E.B. Darsey, Naval Air Station Brunswick, from DavidWebster, USEPA, regarding comments on the April 1988 RemedialInvestigation/ Feasibility Study] Work Plan; June 17, 1988.

16. Memo from M. Aucoin, Naval Air Station Brunswick, regarding laboratoryanalytical methods discussed in the RI/FS Work Plan; August 12, 1988.

17. Letter to Naval Facilities Engineering command, Northern Division, fromAnthony Sturtzer, Naval Energy and Environmental Support Activity, regardinglaboratory approval for Installation Restoration Program analyses; August 22,1988.

18. Letter to Charlotte Head, USEPA, from T.G. Sheckels, Department of theNavy, Northern Division, regarding status and completion of the first phase offieldwork and sampling under the RI/FS Work Plan: October 26, 1988.

19. Letter to Ronald Springfield, Naval Facilities Engineering Command, NorthernDivision, from Denise Messier, Maine DEP, regarding comments on the April1989 Draft Additional Sampling Plan; May 22, 1989.

20. Letter to T.G. Sheckels, Naval Facilities Engineering Command, NorthernDivision, from David Webster, USEPA, regarding comments on the April 1989Draft Additional Sampling Plan; June 9, 1989.

September 16, 1998



21. Letter to Ronald Springfield, Naval Facilities Engineering Command, NorthernDivision, from Denise Messier, Maine DEP, regarding approval of the DraftAdditional Sampling Plan; June 15, 198$.

22. Letter to Ronald Springfield, Naval Facilities Engineering Command, NorthernDivision, from Melville Dickenson, E.C. Jordan Co. [ABB EnvironmentalServices, Inc.], regarding transmittal of the Additional Sampling Plan and someoutstanding issues that needed further discussion with the regulatory agencies;August 9, 1989.

23. Letter to Ronald Springfield, Naval Facilities Engineering Command, NorthernDivision, from David Webster, USEPA, regarding comments on the August1989 Draft Additional Sampling Plan; September 26, 1989.

24. Letter to Ronald Springfield, Naval Facilities Engineering Command, NorthernDivision, from Denise Messier, Maine DEP, regarding comments on the August1989 Additional Sampling Plan; December 28, 1989.

Volume 2: Post-Screening Work Plan, prepared by E. C. Jordan Co. [ABB EnvironmentalServices, 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. [ABBEnvironmental 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, fromTed Wolfe, Maine DEP, regarding comments on the April 1990 Draft Post-Screening Work Plan; May 1, 1990.

2. Letter to Kenneth Marriott, Department of the Navy, Northern Division, fromMichael Jasinski for David Webster, USEPA, regarding the April 1990 DraftRemedial Investigation Report and the April 1990 Draft Post-Screening WorkPlan; May 17, 1990.

3. Letter to Kenneth Marriott, Department of the Navy, Northern Division, fromSusan Weddle, TRC community member, regarding comments on the February1990 Draft Phase I Feasibility Study - Development and Screening ofAlternatives, and the April 1990 Draft Remedial Investigation Report and theApril 1990 Draft Post-Screening Work Plan; May 23, 1990.

4. Letter to James Shafer, Department of the Navy, Northern Division, from TedWolfe, Maine DEP, regarding comments on the July 1990 Post-Screening WorkPlan; July 27, 1990.

September 16, 1998



5. Letter to James Shafer, Department of the Navy, Northern Division, from DavidWebster, USEPA, regarding comments on the July 1990 Post-Screening WorkPlan; 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 (Sites1,2,3,4,7,8,9).

Correspondence:

2. Letter to Ronald Springfield, Department of the Navy, Northern Division, fromDavid Gulick, E.C. Jordan Co. [ABB-ES] regarding the transmittal of theRound I Data Package; January 13, 1989.

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

4. Letter to Charlotte Head, USEPA, from Kenneth Finkelstein, National Oceanicand Atmospheric Administration, regarding comments on the Rounds I and nData 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 (Sites1,2,3,4,7,8,9).

Round III Data Package, Phase I - Remedial Investigation, prepared by E.C.Jordan Co. [ABB Environmental Services, Inc.]; July 1989 (Sites1,2,3,4,7,8,9).

Correspondence:

1. Letter to Ronald Springfield, Northern Division, Naval Facilities EngineeringCommand, from David Gulick, E.C. Jordan, Co. [ABB-ES], regardingtransmittal of and comments on the Round n Data Package; March 10, 1989.

2. Letter to Ronald Springfield, Northern Division, Naval Facilities EngineeringCommand, from David Gulick, E.C. Jordan, Co. [ABB-ES], regardingtransmittal of and comments on the Round HI Data Package; July 14, 1989.

3. Letter to Jack Jojokian, USEPA, from John Walker, Camp, Dresser & McKeeFederal Programs Corporation, regarding comments on the Round HI DataPackage; August 31, 1989.

September 16, 1998



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

Volume 5: Remedial Investigation Feasibility Study - Round IV Data Package, prepared byE.G. Jordan Co. [ABB Environmental Services, Inc.]; January 1990 (Sites1,2,3,4,7,8,9,11,13).

Correspondence:

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

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

Volume 6: Draft Final Remedial Investigation Report Volume 1, prepared by E.C. JordanCo. [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, fromSusan Weddle, TRC community member, regarding comments on the April1990 Draft Remedial Investigation Report; May 15, 1990.

2. Letter to Kenneth Marriott, Department of the Navy, Northern Division, fromMichael Jasinski for David Webster, USEPA, regarding comments on the April1990 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 TedWolfe, Maine DEP, regarding comments on the August 1990 Draft FinalRemedial Investigation Report; October 10, 1990.

4. Letter to James Shafer, Department of the Navy, Northern Division, from MaryJane O'Donnell, USEPA, regarding comments on the August 1990 Draft FinalRemedial Investigation Report; October 17, 1990.

Volume 7: Draft Final Remedial Investigation Report Volume 2: Appendices A-J, preparedby E.C. Jordan Co. [ABB Environmental Services, Inc.]; August 1990 (Sites1,3; 2; 4,11,13; 7; 8; 9).

September 16, 1998



Volume 8: Draft Final Remedial Investigation Report Volume 3: Appendices K-P, preparedby B.C. Jordan Co. [ABB Environmental Services, Inc.]; August 1990 (Sites1,3; 2; 4,11,13; 7; 8; 9).

Volume 9: Draft Final Remedial Investigation Report Volume 4: Appendix Q - RiskAssessment, prepared by B.C. 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, NorthernDivision, from Charlotte Head for David Webster, USEPA, regarding theinclusion of the [Step] 1A Verification Study data in the risk assessment for theair station; September IS, 1988.

2. Letter to T.G. Sheckels, Naval Facilities Engineering Command, NorthernDivision, from David Webster, USEPA, regarding review comments on thePhase I Feasibility Study Preliminary Development of Alternatives, and thePreliminary Risk Assessment; May 5, 1989.

3. Letter to Kenneth Marriott, Department of the Navy, Northern Division, fromTed Wolfe for Deoise Messier, Maine DEP, regarding comments on theFebruary 1989 Preliminary Risk Assessment; February 8, 1990.

4. Letter to Kenneth Marriott, Department of the Navy, Northern Division, fromTed Wolfe, Maine DEP, regarding comments on the April 1990 Draft RemedialInvestigation Report; May 17, 1990.

Volume 10:

Volume 11:

Volume 12:

Volume 13:

Volume 14:

Volume 15:

Not applicable to Site 2.






September 16, 1998


SECTION 5: FEASffilLITY STUDIES

Volume 1: Draft Final Phase I Feasibility Study Development and Screening ofAlternatives, 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, fromDavid Webster, USEPA, regarding comments on the February 1989 Phase IFeasibility Study: Preliminary Development of Alternatives, and February 1989Preliminary Risk Assessment reports; May 5, 1989.

2. Letter to Alan Prysunka, Maine DEP, from T.G. Sheckels, Department of theNavy, Northern Division, regarding Applicable or Relevant and AppropriateRequirements (ARARs) for Remedial Investigation/ Feasibility Study (RI/FS);March 6, 1990.

3. Letter to Kenneth Marriott, Department of the Navy, Northern Division, fromTed Wolfe, Maine DEP, regarding comments on the February 1990 Draft PhaseI Feasibility Study Development and Screening of Alternatives; April 17, 1990.

4. Letter to Kenneth Marriott, Department of the Navy, Northern Division, fromDavid Webster, USEPA, regarding comments on the February 1990 Draft PhaseI Feasibility Study Development and Screening of Alternatives; April 23, 1990.

5. Letter to Kenneth Marriott, Department of the Navy, Northern Division, fromSusan Weddle, TRC community member, regarding comments on the February1990 Draft Phase I Feasibility Study Development and Screening ofAlternatives, and the April 1990 Draft Post-Screening Work Plan; May 23,1990.

6. Letter to James Shafer, Department of the Navy, Northern Division, from TedWolfe, Maine DEP, regarding comments on Draft Final Phase I FeasibilityStudy Development and Screening of Alternatives; September 28, 1990.

7. Letter to James Shafer, Department of the Navy, Northern Division, fromMeghan Cassidy, USEPA, regarding comments on the August 1990 Draft FinalPhase I Feasibility Study Development and Screening of Alternatives; October16, 1990.

Volume 2: Not applicable to Site 2.

Volume 3: Feasibility Study Volume 1, prepared by E.G. Jordan Co. [ABB EnvironmentalServices, Inc.]; March 1992 (Sites 2; 4,11,13; 5,6; 7; 9; 12; 14; EasternPlume).

September 16, 1998


SECTION S (continued)

Correspondence:

1. Letter to Meghan Cassidy, USEPA, from John Lindsay, National Oceanic andAtmospheric Administration, regarding comments on the [July 1991] DraftFeasibility Study Report; August 16, 1991.

2. Letter to James Shafer, Department of the Navy, Northern Division, from TedWolfe, Maine DEP, regarding comments on the July 1991 Draft FeasibilityStudy Report; September 20, 1991.

3. Letter to James Shafer, Department of the Navy, Northern Division, fromMeghan Cassidy, USEPA, regarding comments on the July 1991 DraftFeasibility Study Report; September 23, 1991.

4. Letter to James Shafer, Department of the Navy, Northern Division, fromMeghan Cassidy, USEPA, regarding comments on the November 1991 DraftFinal Feasibility Study; December 26, 1991.

5. Letter to James Shafer, Department of the Navy, Northern Division, from TedWolfe, Maine DEP, regarding comments on the November 1991 Draft FinalFeasibility 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 - O, prepared by E.C. Jordan Co.[ABB Environmental Services, Inc.]; March 1992 (Sites 2; 4,11,13; 5,6; 7; 9;12; 14; Eastern Plume).


SECTION 6: PROPOSED PLANS AND PUBLIC HEARING TRANSCRIPTS



Volume 3: Proposed Plan for Site 2, prepared by ABB Environmental Services, Inc.; May1997.

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

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SECTION 7: RECORDS OF DECISION



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, fromClaudia Sail, MEDEP, regarding comments on the Draft Record of Decision forSite 2; February 12, 1998.

2. Letter to Emil Klawitter, Department of the Navy, Northern Division, fromMichael Barry, USEPA, regarding comments on the Draft Record of Decisionfor Site 2; February 24, 1998.

3. Letter to Loukie Lofchie, BACSE, from Carolyn Lepage, Lepage EnvironmentalServices, 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, fromMichael Barry, USEPA, regarding comments on the Draft Final Record ofDecision for Site 2; July 23, 1998.

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

6. Letter to Emil Klawitter, Department of the Navy, Northern Division, fromClaudia Sail, MEDEP, regarding comments on the Draft Final Record ofDecision for Site 2; August 13, 1998.

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

SECTION 8: POST-RECORD OF DECISION


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

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SECTION 9; COMMUNITY RELATIONS

Volume 1: Community Relations Plan - for NASB NPL Sites prepared jointly by PublicAffairs Office, Navy Northern Division, and E.C Jordan Co. [ABBEnvironmental Services, Inc.]; September 1988

Correspondence:

1. Public notice for the Remedial Investigation and Feasibility Study schedule forBrunswick Naval Air Station Superfund Site published in the Portland PressHerald: February 24, 1988.

2. Memo to Commanding Officer, Naval Air Station Brunswick, from T.F.Rooney, Department of the Navy, Northern Division, regarding communityrelations 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 ofthe Federal Facility Agreement for the Brunswick Naval Air Station; October 6,1989.

4. Letter to Commander Geoffrey Cullison, Naval Air Station Brunswick, fromTed Wolfe, Maine DEP, regarding analytical results from water samplescollected from a Coombs Road residence; December 27, 1989.

5. Letter to Ken Marriott, Naval Facilities Engineering Command, NorthernDivision, from Joshua Katz, Brunswick Area Citizens for a Safe Environment,regarding Freedom of Information Act request; March 6, 1990.

6. Press release regarding an extension of application notification deadline forTechnical Assistance Grant Application to be filed; March 26, 1990.

7. Letter to [Joshua] Katz, from T.J. Purul, Naval Air Station Brunswick,regarding the availability of information requested under the Freedom ofInformation Act; April 6, 1990.

8. Letter to Kenneth Marriott, Naval Facilities Engineering Command, fromJoshua Katz, Brunswick Area Citizens for a Safe Environment, regarding theFreedom of Information Act request; a March 22, 1990 public informationmeeting; and the preliminary response to an April 8, 1990 site visit: April 12,1990.

9. Letter to file from Geoffrey Cullison, Naval Air Station Brunswick, regardingSite 8 and off-site influences; April 23, 1990.

10. Letter to James Shafer, Department of the Navy, Northern Division, from TedWolfe, Maine DEP, regarding data from the sampling at Consolidated Auto, andthe revised May 30, 1990 Maximum Exposure Guidelines; June 22, 1990.

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11. Fact sheet for Naval Air Station Brunswick regarding question and answersabout National Priorities List Sites; August 15, 1990.

12. Press release announcing the public comment period for th& Federal FacilityAgreement for Brunswick Naval Air Station; November 2, 1990.

13. Press release regarding Brunswick citizens receiving a $50,000 federal grant fora Superfund advisor; January 3, 1991.

14. Fact sheet regarding the Sites 1 and 3 Proposed Plan, and the Eastern PlumeProposed Plan; December 1991.

15. Public notice announcing the public meeting/hearing and public comment periodfor 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 3cleanup at Naval Air Station Brunswick; June 1992.

17. Public notice announcing the public meeting/hearing and public comment periodfor cleanup of the Perimeter Road Disposal Area [Site 8] at Naval Air StationBrunswick; October 1992.

18. Fact sheet regarding the Site 8 Proposed Plan; October 1992.

19. Public notice announcing the public meeting/hearing and public comment periodfor removal of Building 95 pesticide shop and surrounding soils; November1992.

20. Fact sheet regarding the proposed removal actions at Building 95; November1992.

21. Public notice announcing the public meeting/hearing and public comment periodfor the revised Proposed Plan for Site 8 that now includes excavation; March1993.

22. Public notice announcing the public meeting/hearing and public comment periodfor the Sites 5 and 6 Proposed Plan; March 1993.

23. Fact sheet regarding the Proposed Plan for Sites 5, the Orion Street AsbestosDisposal 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).

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1. Meeting minutes of December 3, 1987, Technical Review Committee (TRC)meeting to get acquainted, to discuss results of completed and plannedinvestigations, and to establish future review procedures; undated.

2. Meeting minutes of January 11, 1988, TRC meeting to discuss the projectschedule; 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 forthe TRC at Brunswick and a review of the revised April 1988 RI/FS work plan;undated.

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

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

7. Meeting minutes of February 22, 1988, TRC meeting to review validatedanalytical data from the first round of sampling, and to present preliminaryinformation for the forthcoming risk analysis and alternative developmentdeliverables; undated.

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

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

10. Letter to Senator William Cohen from E.B. Darsey, Department of the Navy,Naval Air Station, Brunswick, regarding a copy of the requested TRC meetingminutes, 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 AdditionalSampling Plan, the RI/FS program, and the schedule for its implementation;July 11, 1989.

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

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

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SECTION 9 (continued)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 DraftInitial 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, fromGeoffrey Cullison, Naval Air Station, Brunswick, transmitting the omittedhandout from the previous letter; July 19, 1990.

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

17. Letter to TRC members from James Shafer, Department of the Navy, NorthernDivision, regarding minutes from the January 10, 1991, TRC meeting; January28, 1991.

18. Letter to James Shafer, Department of the Navy, Northern Division, fromMelville Dickenson, ABB Environmental Services, Inc., regarding minutes fromthe October 3, 1991, TRC meeting; January 28, 1991.

19. Meeting minutes of February 20, 1992, TRC meeting to discuss the scheduleand status of the IRP sites; undated.

20. Meeting minutes of May 20, 1992, TRC meeting to discuss schedules for theSites 1 and 3 and Eastern Plume Records of Decision and Remedial Design, thesite inspection work plan for Swampy Road Debris site and MerriconeagExtension Debris site, Site 8 Focused Feasibility Study and Proposed Plan, andthe multi-site Feasibility Study; the minutes also included a discussion of thefuture actions scheduled for other sites; undated.

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

22. Meeting minutes of December 10, 1992, TRC meeting to discuss schedules forthe 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 andremedial design, the remedial designs for Sites 5, 6, 8, 9, and Building 95, andthe site investigation at Swampy Road Debris site and Merriconeag ExtensionDebris 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)

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SECTION 9 (continued)Correspondence:

1. Meeting minutes of March 18, 1993, TRC meeting to discuss the acceleratedschedule, 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 scheduleupdate, undated.

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

5. Meeting minutes of March 17, 1994, technical meeting to discuss the Site 11Time Critical Removal Action; Building 95 construction project; West RunwayStudy 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 TimeCritical Removal Action; Site 9 Interim Groundwater Record of Decision;Remedial Design for Sites 1, 3, 5, 6, 8, Eastern Plume, and Building 95; LongTerm Monitoring for Building 95, Sites 1 and 3 and Eastern Plume; undated.

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

8. Meeting minutes of June 9, 1994, technical meeting to discuss Site 11 TimeCritical Removal Action, and status of the Remedial Action contract for Sites 1and 3, 5, 6, 8, and the Eastern Plume; undated.

9. Meeting minutes of June 23, 1994, TRC meeting to discuss the Site 11 TimeCritical 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 theconstruction status for remediation of Building 95 and Sites 1, 3, 5, 6, 8 andEastern Plume; the Site 11 Removal Action; Site 9 Interim Groundwater RODand Long Term Monitoring Plan, Site 9 Site Investigation Work Plan; migrationof the Eastern Plume; additional sampling at Building 95; undated.

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

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

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

14. Meeting minutes of January 11, 1995, TRC meeting to discuss Proposed Plansand RODs for Sites 2, 7, 12, and 14; the Site 9 Source Investigation Samplingand 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 constructionstatus 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 TermMonitoring; confirmatory sampling at Building 95; undated.

16. Meeting minutes of April 19, 1995, TRC meeting to discuss the Site 9 SourceInvestigation; construction status of remediation of Sites 1, 3, 5, 6, 8, EasternPlume, 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 constructionstatus 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 theconstruction status of the remediation of Sites 1, 3, 5, 6, 8, Eastern Plume, andBuilding 95; Site 9 Source Investigation; basewide long term monitoring; Site11 post-removal action; undated.

19. Meeting minutes of October 25, 1995, RAB meeting to discuss the constructionstatus 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, 19%, RAB meeting to discuss the constructionstatus 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, andSite 14; Site 9 Source Investigation; basewide long term monitoring; undated.

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21. Meeting minutes of May 1, 1996, RAB meeting to discuss the constructionstatus 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 SourceInvestigation; basewide long term monitoring; Pump Test Report/NumericalModeling Report; Building 95 Closure Report; undated.

22. Meeting minutes of August 1, 1996, RAB meeting to discuss Proposed Plansand 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 ProposedPlans and ROD for Sites 4, 11, and 13; basewide long term monitoring;extraction well status; monitoring well MW-311; undated.

24. Meeting minutes of October 31, 1996, RAB meeting to discuss the ROD forSites 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 ProposedPlan and ROD for Site 2; ROD for Sites 4, 11, and 13; basewide long termmonitoring; geostatistical analysis work plan; Site 9 Source InvestigationReport; extraction well issues; treatment plant modifications; undated.

26. Meeting minutes of April 23, 1997, RAB meeting to discuss the ROD for Sites4, 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 Sites4, 11, and 13; basewide long term monitoring; groundwater infiltration study;geostatistical analysis; cessation of Sites 1 and 3 extraction wells; monitoringwell 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 for1998; ROD for Sites 4, 11, and 13; basewide long term monitoring;groundwater infiltration study; geostatistical analysis; installation of extractionwell EW-2A; treatment plant status; status of the IRP sites; undated.

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

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31. Meeting minutes of July 29, 1998, RAB meeting to discuss updates to theschedule; 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. [ABBEnvironmental 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, fromCynthia Bertocci, Maine DEP, regarding the state's interest in the InstallationRestoration 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 Programfor 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 andcontrol of installation pollutants (NACIP) program and guidance involvingfederal and state regulatory agency oversight; March 11, 1986.

4. Letter to Commanding Officer, Naval Air Station Brunswick, fromCommanding Officer, Naval Facilities Engineering Command, NorthernDivision, regarding federal and state environmental agencies oversight authorityof the NACIP program; April 7, 1986.

5. Letter to David Webster, USEPA, from K.J. Vasilik, Naval Air StationBrunswick, regarding the definition of the RI/FS program at the NASBrunswick; January 20, 1987.

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

7. Letter to Charlotte Head, USEPA, from R.L. Gillespie, Naval FacilitiesEngineering Command, Northern Division, regarding the Navy's timetable tocomplete Remedial Investigation Feasibility Study at the Naval Air StationBrunswick, and outlining the Navy's understanding of the responsibilities of thevarious agencies involved in the RI/FS program; October 22, 1987.

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8. Letter to Charlotte Head, USEPA, from Kenneth Finkelstein, National Oceanicand Atmospheric Administration, regarding the June 10, 1987, TrusteeNotification Form for Naval Air Station Brunswick; November 10, 1987.

9. Letter to Charlotte Head, USEPA, from T.G. Sheckels, Department of theNavy, Northern Division, regarding the listing of Naval Air Station Brunswickon the NPL, the establishment of the Administrative Record, and the TechnicalReview Committee for the base; November 16, 1987.

10. Letter to R.L. Gillespie, Naval Facilities Engineering Command, NorthernDivision, from David Webster, USEPA, regarding the schedule to be publishedby February 1988, a mechanism for delineating the roles and responsibilities ofthe agencies, and the USEPA's concerns over the progress to date; November20, 1987.

11. Memo to Charlotte Head, USEPA, from Joan Coyle, USEPA Water MonitoringSection, regarding sampling results from the Jordan Avenue Well Field inBrunswick, 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 DavidWebster, USEPA, regarding the definition of the commencement of the RI/FSunder the Comprehensive Environmental Response, Compensation, and LiabilityAct; December 17, 1987.

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

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

15. Letter to Ronald Springfield, Naval Facilities Engineering Command, NorthernDivision, from David Webster for Charlotte Head, USEPA, regarding theevaluation 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, regardingcomments on the Federal Facility Agreement; November 8, 1989.

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

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SECTION 10 (continued)18. Letter to Meghan Cruise, USEPA, from Jeanne Johnson, Town of Brunswick

Conservation Commission, regarding a request for an extension for review andcomment of [the documents included in the Information Repository for] theBrunswick Naval Air Station; November 17, 1989.

19. Letter to Alan Prysunka, Maine DEP, from Merrill Hohmari, USEPA, regardingthe state's comments on the [Federal Facility] Agreement; December 18, 1989.

20. Letter to William Adams, E.C. Jordan Co. [ABB Environmental Services, Inc.],from R.L. Gillespie, Department of the Navy, Northern Division, regarding aschedule extension for the Draft Initial Screening Report [Feasibility Study];February 1, 1990.

21. Letter to T.G. Sheckels, Department of the Navy, Northern Division, fromMerrill Hohman, USEPA, regarding an amendment to the Federal FacilityAgreement; February 9, 1990.

22. Letter to Alan Prysunka, Maine DEP, from T.G. Sheckels, Department of theNavy, Northern Division, regarding Applicable or Relevant and AppropriateRequirements (ARARs) for Remedial Investigation/ Feasibility Study at NavalAir Station Brunswick; March 6, 1990.

23. Letter to Ken Marriott, Naval Facilities Engineering Command, NorthernDivision, from Meghan Cassidy, USEPA, regarding a request concurrencebetween the agencies for an extension to the Remedial Investigation schedule;March 12, 1990.

24. Letter to Thomas Sheckels, Naval Facilities Engineering Command, NorthernDivision, from Alan Prysunka, Maine DEP, regarding ARARs [Applicable orrelevant and appropriate requirements] for Naval Air Station Brunswick;April 9, 1990.

25. Letter to Meghan Cassidy, USEPA, from K.R. Marriott, Department of theNavy, Northern Division, regarding an extension under the FFA for preparingthe response to comments on the Draft Feasibility Study and Draft RemedialInvestigation reports; May 18, 1990.

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

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

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

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29. Letter to Cmdr. Ron Terry, Naval Air Station Brunswick, from MeghanCassidy, USEPA, regarding sampling of Mere Brook, April 23, 1992.

30. Letter to James Shafer, Naval Facilities Engineering Command, NorthernDivision, from Mary Sanderson, USEPA, regarding the proposed acceleratedschedules for the naval air station; January 11, 1993.

By Reference ONLY with location noted:

U.S. Environmental Protection Agency, 1988. "Guidance for ConductingRemedial Investigations and Feasibility Studies under CERCLA"; Office ofSolid Waste and Emergency Response; OSWER Directive 9335.3-01; InterimFinal; October 1988.

U.S. Environmental Protection Agency, 1988. "Engineering Evaluation/ CostAnalysis"

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< ) ' < li'l " IS |)<| 2' vu , • - j s (. is i

U.S. NAVAL |AIR STATIQNBRUNSWICK MAINE

The U.S. Department of the Navy Announcesthe Availability of a Record of Decision for

Site 2: Orion Street Landfill - Southat NAS Brunswick

OnSeptember29,1998, officials from theU.S. Navy and the U.S. EnvironmentalProtcction Agency (USEP A) jomtl>signed a Record ofDecision (ROD) for Site 2: Orion Street Landfill -South, located at the Naval AirStation (NAS)in Brunswick, Maine. The ROD formally selects the Minimal Action Alternative as the final remedy for tins site.The Navy and the USEPA have determined that the Minimal Action Alternative is appropriate for Site 2 since riskestimates are below federal and state target risk levels In support of the ROD, the Maine Department ofEnvironmental Protection (MEDEP) provided a letter of concurrence to die Nav v express! ng their agreement \\\\\\this decision.

iImplementation of theMinima] Action Alternative will include thefoLlowing activities

• institirtionalcontrols,mcludingniaintenanccofthcexistingfence, installation of warning agnsand land use restrictions;

• removal of surface debris that is visible in the depression immediate ly south and east of thelandfill;

• installation of an additional groundwatcr monitoring well;

• emaronrnentalmonitoring.includingcollectioiiandanalysisofsamplesofgroundwatcr, 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 cither to continue the minimal action activities or to make modi fi cations to the selc ctedremedy. In addition to the five-year reviews, monitoring data will also be evaluated more frequently at quarterlyRestoration Advisory Board meetings, where decisions for more immediate actions can be made, if necessary

The ROD and the documents vvhichformthebasisforthisdecisionarepart of the Administrative Record The recordis a public information file maintained at:

Hours: Monday, Wednesday. 9:30-8 00pmThursday, Friday 9:30 - 6'OOpmSaturday 9.30 - 5 00pm

Curt is Memorial Librarytemporarily housed atOld Brunswick High SchoolMcKcen StreetBrunswick, ME 04011

Questions about this decision or the Installation Restoration Program at NAS Brunswick should be directedJohn James Michael Barry Claudia SailPublic Affairs Office USEPA - Region 1 Maine DEPNaval AirStation Brunswick JFKFederal Building (HBT) State HmiseStation #17Brunswick, ME 04011 Boston, MA 02203-2211 Augusta, ME 04333(207) 921-2527 (617) 223-5579 (207) 287-7713

to'

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