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December 2007

Appendix G ENVIRONMENTAL ANALYSIS

BRUNSWICK NAVAL AIR STATION

BRUNSWICK LOCAL REDEVELOPMENT AUTHORITY BRUNSWICK, MAINE

Environmental Analysis Brunswick Naval Air Station

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LIST OF TABLES ............................................................................................................ ii LIST OF FIGURES .......................................................................................................... ii ACRONYMS .................................................................................................................... iii 1.0 INTRODUCTION................................................................................................. 1

1.1 Limitations .......................................................................................................... 1 1.2 Report Organization............................................................................................ 1

2.0 BACKGROUND ................................................................................................... 3

2.1 Brunswick Naval Air Station.............................................................................. 3 2.2 Reuse Master Plan............................................................................................... 3 2.3 Environmental Investigation, Study, and Cleanup Overview............................. 4

3.0 SUMMARY OF ENVIRONMENTAL CONDITIONS .................................... 7

3.1 Documents Reviewed ......................................................................................... 7 3.2 Known Environmental Sites ............................................................................... 7

3.2.1 IRP Sites ............................................................................................................7 3.2.2 Petroleum, Oil, and Lubricant Sites...................................................................8 3.2.3 Military Munitions Response Program Sites .....................................................8 3.2.4 Land Use Controls and Institutional Controls ...................................................9

3.3 Future Land Use and Proposed Cleanup Standards.......................................... 10 3.3.1 Applicable Cleanup Standards ..........................................................................10 3.3.2 Installation Restoration Program and Petroleum, Oil, and Lubricant Sites ......11

4.0 ENVIRONMENTAL DATA GAPS BY REUSE AREA ................................. 13

4.1 Base-wide Data Gaps........................................................................................ 13 4.1.1 Base-wide Groundwater Model .......................................................................13 4.1.2 Record of Decision Amendment .....................................................................13 4.1.3 Petroleum Hydrocarbons Releases ..................................................................14 4.1.4 Underground Utilities Abandoned in Place.....................................................14 4.1.5 Asbestos Containing Material, Lead Based Paint, and PCB Paint ..................15 4.1.6 Pesticide and Herbicide Storage Areas, Mixing Areas, and Base-wide

Application...................................................................................................... 15 4.1.7 Building Drains, Drywells, and Combined Sewers with Potential Releases...15 4.1.8 Potential Radiological Contamination.............................................................16 4.1.9 Phase I/II Environmental Site Assessments ....................................................16

4.2 Recreation and Open Space Data Gaps ............................................................ 17 4.3 Professional Office Data Gaps.......................................................................... 17 4.4 Natural Areas Data Gaps .................................................................................. 17 4.5 Business and Technology Industries Data Gaps............................................... 18 4.6 Community Mixed Use Data Gaps ................................................................... 18

TABLE OF CONTENTS


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4.7 Airport Operations and Aviation-Related Business Data Gaps........................ 19 4.8 Residential Data Gaps....................................................................................... 19 4.9 Education Data Gaps......................................................................................... 19

5.0 CONCLUSIONS ................................................................................................. 20

LIST OF TABLES Table 1. Documents Reviewed Table 2. Summary of Environmental Conditions for Installation Restoration Program and Military Munitions Response Program Sites Table 3. Known Environmental Issues by Proposed Land Use District Table 4. Maine DEP Petroleum Contamination Decision Tree Table 5. Cleanup Standards for Installation Restoration Program Sites Table 6. Environmental Data Gaps and Constraints by Proposed Land Use District Table 7. Existing Oil Water Separators Table 8. Existing Aboveground Storage Tanks Table 9. Existing Underground Storage Tanks

LIST OF FIGURES Figure 1. Reuse Master Plan with Environmental Installation Restoration Program Sites Figure 2. Reuse Master Plan with Military Munitions Response Program Sites Figure 3. Reuse Master Plan with Potential Environmental Constraints Figure 4. Reuse Master Plan with Existing Land Use Controls


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ACRONYMS ACM Asbestos-containing material AST Aboveground storage tank BACSE Brunswick Area Citizens for a Safe Environment BLRA Brunswick Local Redevelopment Authority BNAS Brunswick Naval Air Station BRAC Base Realignment and Closure BTEX Benzene, toluene, ethylbenzene, and xylenes CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CERFA Community Environmental Response Facilitation Act DLA Defense Logistics Agency DoD Department of Defense DRMO Defense Reutilization and Marketing Office DRO Diesel range organics EBS Environmental Baseline Study ECP Environmental Condition of Property Report EOD Explosive Ordnance Disposal EPA United States Environmental Protection Agency FFA Federal Facilities Agreement FS Feasibility Study GRO Gasoline range organics IC Institutional control IRP Installation Restoration Program LUC Land use control MC Munitions Constituents MCL Maximum Contaminant Level MEC Munitions and Explosives of Concern MEDEP Maine Department of Environmental Protection MEG Maximum Exposure Guidelines MES Matrix Environmental Services, LLC MMRP Military Munitions Response Program Navy United States Navy NCP National Contingency Plan NEX Navy Exchange Service Station NFA No Further Action NPL National Priorities List PA Preliminary Assessment PAH Polynuclear Aromatic Hydrocarbon PCB Polychlorinated biphenyls POL Petroleum, Oil, and Lubricant RAG Risk Assessment Guidance RCRA Resource Conservation and Recovery Act RI Remedial Investigation


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ROD Record of Decision SI Site Investigation TPH Total petroleum hydrocarbons UST Underground storage tank UXO Unexploded Ordnance


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1.0 INTRODUCTION Matrix Environmental Services, LLC, (MES) has prepared this report for the Brunswick Local Redevelopment Authority (BLRA) to identify environmental data gaps, land use controls (LUCs), proposed cleanup standards, and phasing opportunities in redevelopment for the Brunswick Naval Air Station (BNAS), Brunswick, Maine (Site). Building on the BLRA’s reuse plan efforts already underway, MES has identified areas of environmental concern that may directly impact redevelopment. Cultural, natural, and historical resources are not discussed in this appendix. Constraints related to these issues are presented in the main body of the Reuse Plan. The purpose of this effort is to enable the BLRA to successfully complete a consensus reuse plan that takes into account the ten BLRA Guiding Principles, the community goals, and the environmental planning considerations. The information contained in this report is based on MES’ review of over 150 historical documents shown in Table 1. The data gaps and information identified herein are continuously changing based on additional information generated by the United States Department of the Navy (Navy) and the environmental regulatory agencies governing the Site, including the Maine Department of Environmental Protection (MEDEP) and the United States Environmental Protection Agency (EPA). This evaluation has been prepared for the exclusive use of the BLRA in its ongoing reuse planning efforts.

1.1 Limitations MES’ environmental services were conducted in accordance with practices and procedures generally accepted by the environmental consulting industry. The analysis presented herein includes statements of professional opinion and are based on documents and information provided by and produced by others. MES has not performed a site walk or sampling of environmental media of any kind. The potential exists for unreported and unknown environmental issues associated with the Site or surrounding areas that are not identified herein. No warranties, expressed or implied, are presented herein. However, MES has provided its best professional opinion regarding the potential data gaps at the Site. The remainder of this report presents a background of the Site, summary of the various environmental programs in place at the Site, and an analysis of the data gaps by reuse area.

1.2 Report Organization This report is organized into five primary sections, as follows:

• Section 1 presents the objectives for this report, limitations, and report organization.


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• Section 2 provides background information including a brief site history, a discussion of the future land uses planned for the site, and the environmental investigation process that has occurred at BNAS.

• Section 3 presents a summary of environmental conditions on the Site. • Section 4 provides an overview of the environmental data gaps for both known

environmental sites, and those areas or issues that have not yet been investigated at the Site.

• Section 5 presents conclusions for the Site. • Tables and figures, which assist in the interpretation of the narrative information,

are provided at the back of the report.


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2.0 BACKGROUND This section presents a summary of background information on the Site, a brief description of the environmental investigation, study, and cleanup activities that have occurred at the Site, and a summary of land uses presented in the main body of the Reuse Master Plan.

2.1 Brunswick Naval Air Station BNAS is located south of the Androscoggin River and north of Casco Bay. The air station lies within the city limits of Brunswick, Maine. The main station of BNAS encompasses approximately 2,834 acres. BNAS was originally commissioned on April 15, 1943 with a primary mission of training British Naval Command (Royal Canadian Air Force) pilots. After the Air Station was deactivated in October 1946, the land and buildings were leased jointly to the University of Maine and Bowdoin College as annexes to ease the over-crowded conditions. In 1949, both colleges terminated their leases and the Air Station was taken over by the Brunswick Flying Service. In March of 1951, the station was recommissioned as a Naval Air Facility with the mission of supporting three land-plane patrol squadrons and one Fleet Aircraft Service Squadron; and a planned future mission of anti-submarine warfare. At present, three patrol squadrons flying the P3 Orions and two reserve squadrons are stationed at the NAS. In 2005, BNAS was included on the federal government’s Base Realignment and Closure (BRAC) list. The Site is scheduled for closure in 2011. Accordingly, BLRA has prepared a Reuse Master Plan with input from the community to identify reuse of the Site.

2.2 Reuse Master Plan A Preferred Reuse Master Plan has been developed and the following Land Use Districts have been identified in the Plan and are shown on the figures included in this document:

• Recreation and Open Space which will include a new 18-hole golf course in the northeastern portion of the Site and active recreation areas including a community garden

• Professional Office including an office campus at the Site’s “front gate” area • Natural Areas, including passive recreation open spaces • Business and Technology Industries including a potential Alternative Energy

Park • Community Mixed Use including a new Hotel and Conference Center, and

indoor recreation facilities • Aviation Related Businesses including commercial and industrial facilities • Airport Operations including runways and supporting facilities • Residential area consisting of new and existing residences • Educational Facilities including a Lifelong Education Center.


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2.3 Environmental Investigation, Study, and Cleanup Overview BNAS has been the subject of environmental investigations, studies, and cleanup actions since the early 1980s. Aviation activities at BNAS during more than 70 years of operation generated petroleum hydrocarbons, waste oils, paint residues, hydraulic fluid, used batteries, and other wastes. Disposal of some wastes occurred on site. Later, recognition that these wastes might be harmful to human health and the environment resulted in laws and regulations governing their disposal and cleanup (e.g., the Comprehensive Environmental Response, Compensation, and Liability Act [CERCLA] and the Resource Conservation and Recovery Act [RCRA]). The Installation Restoration Program (IRP) was developed by the Department of Defense (DoD) to comply with federal guidelines for managing and controlling past hazardous waste disposal actions. The IRP focuses on cleaning up contamination from past hazardous waste operations and past hazardous material spills (i.e., hazardous substances). However, it is not an all-encompassing program. The IRP is intended to address the cleanup of contamination and damage resulting from past, not current, activities. In 1987, BNAS was placed on the EPA’s National Priority List (NPL). In 1990, the Navy entered into a Federal Facilities Agreement (FFA) with the EPA and MEDEP. Because the IRP Program had already been implemented, the sites identified under the IRP remain in the Superfund Program, and several have been subsequently added to the program. Because the Site is included on the NPL, the EPA is primarily responsible for overseeing the investigation and cleanup of BNAS, with assistance from MEDEP. Underground storage tank (UST) and aboveground storage tank (AST) sites contaminated only with petroleum products are managed by MEDEP. Throughout its history, BNAS stored, trained with, and used various types of Naval munitions including aircraft cannons, depth charges, bombs, rockets, hand grenades, torpedoes, sea mines, small arms, and pyrotechnics. Archival records from 1943 list the explosives magazine storage requirements for the BNAS as follows:

• 10 High explosive magazines – 20’ x 50’ each • 1 Incendiary magazine – 20’ x 50’ • 3 Fuse and detonator magazines – 10’ x 10’ each • 2 Small arms magazines – 20’ x 50’ each • 1 Pyrotechnic magazine – 20’ x 20’ • 6 Inert magazines – 40’ x 100’ each • 1 Torpedo magazine – 25’ x 50’

The Department of Defense established the Military Munitions Response Program (MMRP) to address munitions and explosive of concern (MEC) and munitions constituents at military installations. These MMRP sites at BNAS include non-operational ranges and an active Explosives Ordnance Disposal (EOD) site.


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CERCLA is currently utilized by the Navy for investigation and cleanup of BNAS. Because BNAS was included on the NPL in 1987, EPA is the lead environmental regulatory agency, with input from MEDEP. CERCLA is the process by which the EPA enforces investigation and cleanup of BNAS. Although there may be an opportunity to “streamline” or accelerate the process in the future, currently, there are defined steps for the investigation and remediation process. The basic steps in the CERCLA process are illustrated below, and can summarized as follows:

• Preliminary Assessment/Site Investigation (PA/SI): this is the initial step to determine whether a release has occurred on a site.

• Remedial Investigation (RI): Once contamination has been confirmed, the RI must be conducted to determine the nature and extent of the contamination, and risk to human health and environment from that contamination.

• Feasibility Study (FS): Following definition of the nature and extent of contamination, potential remedial alternatives to address the contamination are evaluated in a feasibility study.

• Record of Decision (ROD): Based on the evaluation of remedial alternatives in the FS, the best alternative is selected and documented in a ROD.

• Remedial Design/Remedial Action (RD/RA): The selected remedy is then designed and implemented.

• No Further Action/Delisting: Once the implemented remedy is proven effective, the EPA/MeDEP will issue a “remedy complete” or “No Further Action” determination, and may delist the property from the NPL.

It is possible under current CERCLA law to delist portions of property from the NPL if the property is clean and suitable for intended reuse. Property that is not on the NPL will be easier to sell and develop.


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CERCLA PROCESS

To date, the Navy’s investigation and remediation program has considered a “like use” scenario; that is, the Navy’s cleanup has reflected future use of BNAS as an industrial military facility. An analysis of the appropriateness of the Navy’s cleanup as it relates to the BLRA’s intended future use is presented in Section 3.3.

Site Discovery

Preliminary Assessment (PA)

Site Inspection (SI)

Hazard Ranking System (HRS)

National Priorities List (NPL)

Remedial Investigation (RI)

Feasibility Study (FS)

Proposed Plan

Record of Decision (ROD)

Remedial Design (RD) Remedial Action (RA)

Five Year Review

Conduct Risk Assessment

Risk Management

Community Interviews

Public Comment


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3.0 SUMMARY OF ENVIRONMENTAL CONDITIONS This section presents a summary of environmental conditions for each known environmental site segregated by future land use as shown in the Preferred Master Reuse Plan. The narrative text in this section should be supplemented by reference to the following figures:

• Figure 1 - Reuse Master Plan with Environmental Installation Restoration Program Sites

• Figure 2 - Reuse Master Plan with Military Munitions Response Program Sites • Figure 3 - Reuse Master Plan with Potential Environmental Constraints • Figure 4 - Reuse Master Plan with Existing Land Use Controls

Tables to be used in conjunction with the narrative text presented in this section are as described throughout text. Tables and figures are located at the end of this report.

3.1 Documents Reviewed Over 150 documents were obtained and reviewed during the creation of this report. These documents were obtained from various sources, including the Navy, Restoration Advisory Board, EPA, and MEDEP. A list of documents reviewed is provided in Table 1.

3.2 Known Environmental Sites Currently, there are known environmental sites in active and inactive phases of investigation and remediation at the Site. These sites are being investigated and/or remediated by the U.S. Navy under the IRP and the MMRP. A summary of known information about these sites is presented in Table 2. A cross reference table that lists each of the known environmental sites by proposed land use is included in Table 3. Figure 1 shows the known IRP sites, Figure 2 presents the MMRP sites, and Figure 4 presents existing Land Use Control areas.

3.2.1 IRP Sites Since 1983, the Navy has identified 18 IRP sites and an extensive groundwater contaminant plume at BNAS. Each of the known IRP sites is shown on Figure 1. There are presently 11 active IRP sites including:

• Site 1/3 – Orion Street Landfill North/Hazardous Waste Burial Area • Site 2 – Orion Street Landfill South • Site 4 – Acid/Caustic Disposal Pit • Site 7 – Old Acid/Caustic Pit • Site 9 – Neptune Drive Disposal Area


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• Site 10 – Harpswell Fuel Line • Site 11 – Fire Training Area • Site 12 – EOD Area • Site 13 – Defense Reutilization and Marketing Office (DRMO) Area • Site 17 – Former Pesticide Shop • Eastern Groundwater Plume.

The seven inactive IRP sites include:

• Site 5 – Orion Street Asbestos Disposal Area • Site 6 – Sandy Road Rubble and Asbestos Disposal Site • Site 8 – Perimeter Road Disposal Site • Site 14 – Old Dump #3 • Site 15 – Merriconeag Extension Debris Site • Site 16 – Swampy Road Debris Site • Site 18 – West Runway Study Area.

EPA RODs for No Further Action (NFA) are in place for soil at Sites 4, 5, 6, 8, 11, and 13. NFA Decisions for Sites 4, 11, and 13 were granted because no direct contact or incidental ingestion pathways currently exist at these sites. A Draft Consensus Statement providing a NFA Decision for Sites 14, 15, 16, and 18 was submitted to the EPA. Although the EPA responded to the Draft Consensus Statement with comments in February 2001, a signed Final Consensus Statement has not yet been located. A summary of work performed, work planned by the Navy, remediation status, and existing LUCs is presented in Table 2.

3.2.2 Petroleum, Oil, and Lubricant Sites The Navy has identified two Petroleum, Oil, and Lubricant (POL) Sites including:

• POL 1 - Old Navy Fuel Farm • POL 2 - Navy Exchange (NEX) Service Station

Ongoing cleanup continues at both POL sites.

3.2.3 Military Munitions Response Program Sites Five sites potentially containing MEC have been identified for investigation under the MMRP:

• UXO-1 – Former Munitions Bunker West Area • UXO-2 – Machine Gun Boresight Range • UXO-3 – Skeet Range • Old Quarry Site


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• Site 12 – EOD Area (This site is currently also under investigation in the IRP listed above)

A Preliminary Assessment (PA) has been conducted for the following identified MMRP sites: UXO-1, UXO-2, and UXO-3. An addendum to the PA is planned for the Old Quarry Site and Site 12 - EOD Area. The Navy is in the process of evaluating information obtained in the PA, and will be assessing which of the identified MMRP sites requires additional investigation. A summary of each of these sites is presented in Table 2, and Figure 2 shows the location of each site, along with the proposed reuse.

3.2.4 Land Use Controls and Institutional Controls Land use controls, also known as Institutional Controls or Activity and Use Limitations, are required whenever environmental contamination exists on a property at a level that is not protective of unrestricted use. The navy has instituted LUCs on numerous parcels at the site. LUCs include any type of physical, legal, or administrative mechanism that restricts the use of, or limits access to, property to reduce risks to human health and the environment. LUCs are designed to limit the types of uses and activities that are permissible and/or restricting access to areas that contain contamination above concentrations that are protective of human health and the environment. LUCs also can impose actions for long term obligations such as operations and maintenance, including inspections, of remedies such as caps for landfills. For LRAs or other property recipients of closed military bases, LUCs are not the preferred alternative, and generally do not meet the needs of the Reuse Plan for being protective of human health and the environment. The following types of LUCs can be implemented:

• Proprietary Controls that include environmental covenants, easements, or restrictions and are binding on future owners and tenants. These are generally listed in the deed that governs property transfer.

• State and local government controls that specify building requirements, zoning, or worker requirements at a site.

• Government orders or permits such as a Consent Agreement that binds the property recipient in the legal document between EPA and/or the state, and the property recipient.

• Administrative mechanisms that can include informational notices to tenants and occupants, ordinances, or construction permitting.

• Engineering Controls or physical barriers such as fences or signs.

The first four LUCs are also institutional controls (ICs), the legal mechanisms as discussed in the National Contingency Plan (NCP). Engineering controls (e.g., vapor barriers or ventilating systems) are not legal instruments, but should be recorded in a legal instrument since they are generally part of a Record of Decision that describes the environmental remedy for a site. LUCs may be recorded in numerous legal documents, including the deed and other property transfer documents. Additionally, these documents generally describe the methodology by which the property recipient will report on the


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land use control effectiveness and any violations or issues related to LUCs. Once cleanup is complete, LUCs may be modified or terminated after consultation with the regulatory agencies, DoD, and documented in amended deeds and Consent Agreements. The DoD has implemented numerous LUCs at BNAS. As shown in the attached Figure 4 – Land Use Controls and further detailed in the Navy’s Base Instruction 5090.1C, significant interim LUCs exist on the parcels occupied by IRP sites. These LUCs will remain in place until the site has been remediated to a level protective of human health and the environment for the proposed land use.

3.3 Future Land Use and Proposed Cleanup Standards

3.3.1 Applicable Cleanup Standards Contaminated environmental media onsite are managed under both EPA Region 1 and Maine Department of Environmental Protection (MEDEP). When the two agencies’ cleanup standards differ, the more protective value is used. Groundwater is regulated under EPA’s chemical-specific Maximum Contaminant Levels (MCLs) and MEDEP’s Maximum Exposure Guidelines (MEGs). Soil is managed under MEDEP’s Remedial Action Guidelines (RAGs), which are chemical-specific guidelines based on direct contact risk. RAGs were developed for three exposure scenarios: residential, trespasser, and adult worker. Both the trespasser and the adult worker are for non-residential exposure scenarios. In addition to RAGs, EPA’s Ecological Soil Screening Levels (SSLs) can influence soil cleanup onsite. Surface water quality is controlled by MEDEP’s Rule Chapter 584, which was approved by the EPA in July 2006. The standards included in Chapter 584 are intended to protect aquatic life and human health by preventing toxic concentrations of pollutants in ambient surface waters as governed in the United States Clean Water Act and State laws. Although no risk-based standards exist for total petroleum hydrocarbons (TPH), MEDEP has produced a decision tree approach that uses site-specific geologic and human exposure related criteria to establish remediation goals for petroleum-contaminated soil and groundwater. The guidelines establish three levels of site-specific remediation goals. The most stringent includes areas of current or potential future groundwater use as drinking water. Areas in close proximity to drinking water supplies or sand and gravel aquifers fall into this “Stringent Standards” group. The second group, “Intermediate Standards,” includes sites where groundwater is less likely to be used as drinking water as a result of its quality or quantity. These “Intermediate Standards” are used in areas to abate ongoing groundwater contamination and to minimize the risk of vapor problems in buildings and utility corridors. Finally, the third tier of “Baseline Standards” applies to all remaining sites, including sites where groundwater has been contaminated beyond use. Baseline Standards are further divided into two groups: one for industrial sites and one for non-industrial urban areas. MEDEP defines that at a minimum all sites must be


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cleaned of petroleum-saturated soil and free product. Specific cleanup goals for each level are shown in Table 4. Several IRP sites have MEDEP-negotiated TPH cleanup goals corresponding to an industrial cleanup standard and developed using “Baseline 2” including:

• Site POL 1 – Old Navy Fuel Farm o 870 mg/kg TPH

• Site POL 2 – Navy Exchange Service Station o 500 mg/kg Gasoline Range Organics (GRO)

3.3.2 Installation Restoration Program and Petroleum, Oil, and Lubricant Sites The IRP and POL sites are at varying stages of investigation, remediation, and closure. The Navy has applied cleanup standards suitable for “like use,” i.e. industrial standards, at most of IRP and POL sites. A summary of present status, Navy-proposed cleanup standards, and likely-required cleanup standards based on the Preferred Reuse Master Plan are presented and compared in Table 5. Several sites, such as the landfills (Sites 1/3 - Orion Street Landfill North/Hazardous Waste Burial Area and Site 2 - Orion Street Landfill South), will require LUCs including engineering controls to protect human health during and following redevelopment. Five sites (Site 5 - Orion Street Asbestos Disposal Area, Site 6 - Sandy Road Rubble and Asbestos Disposal Site, Site 8 - Perimeter Road Disposal Site, Site 14 - Old Dump #3, and Site 18 - West Runway Study Area) have been remediated and closed, with NFA consensus, to standards suitable for the likely reuse scenarios of industrial, residential, or recreational, as detailed in Table 2. Areas such as Site 4 - Acid/Caustic Disposal Pit and Site 13 - Defense Reutilization and Marketing Office (DRMO) Area have been classified as NFA because “no direct contact pathway exists.” It is possible, however, these sites may have contamination concentrations greater than industrial standards that may pose a problem during redevelopment if the barrier layer (asphalt parking lot or building and foundation) is removed, similar to the scenario with the barracks removal at Site 9 - Neptune Drive Disposal Area. Site 11 - Fire Training Area has an NFA recommended following soil removal action in 1995. The report documenting the removal has not been located in the administrative record, and therefore the present cleanup standard status is a data gap. Site 15 - Merriconeag Extension Debris Site and Site 16 - Swampy Road Debris Site are considered to have an unknown present cleanup standards status and may require further investigation due to additional debris discovered during the Community Environmental Response Facilitation Act (CERFA) walkover. Ongoing cleanup continues at Site 7 - Old Acid/Caustic Pit, Site 9 - Neptune Drive Disposal Area, Site 17 - Former Pesticide Shop, POL 1 - Old Navy Fuel Farm, –POL 2 - Navy Exchange Service Station, and the Eastern Plume. Navy-planned cleanup standards for these sites vary from final MEDEP and EPA-negotiated cleanup goals at the two POL sites to Site 17 - Former Pesticide Shop which has yet to have a ROD developed.


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Finally, investigation has not begun at Site 12 EOD Area, therefore current cleanup standard status and Navy-proposed cleanup goals are both unknown.


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4.0 ENVIRONMENTAL DATA GAPS BY REUSE AREA Although much is known about environmental issues at the Site, environmental data gaps exist for both the identified (known) IRP and MMRP sites. Environmental data gaps also exist for sites that have not been formally assessed under any of the Navy’s on-going environmental programs. Although the Navy has conducted some investigation and in some cases, remediation, MES has identified issues at the IRP and MMRP sites that have not been assessed or require reassessment due to the intended reuse of the Site. Table 6 presents identified data gaps in terms of both known and unknown areas. To illustrate the potential impact of data gaps on redevelopment, each land use parcel within the Preferred Master Reuse Plan is evaluated with regard to the Navy IRP sites, MMRP Sites, and uninvestigated potential environmental areas of concern where impacts may have occurred. These sites are shown overlain on the reuse scenario in Figure 3.

4.1 Base-wide Data Gaps

4.1.1 Base-wide Groundwater Model A base-wide groundwater model must be developed utilizing data from existing monitoring wells, as well as from additional wells in areas of potential concern to evaluate base-wide hydrology, contaminant plume nature and extent, and effects of groundwater extraction and re-injection on contaminant migration. This model would be useful in understanding the hydrogeology of the contaminated groundwater from the various IRP sites (or other sites not yet identified) and their relation to the Eastern Plume, and in minimizing the future LUCs that may be necessary to protect human health and the environment and/or minimizing the long-term restrictions on groundwater use. The model could includea risk assessment section so the ptotential effect of the volatile organic compounds on indoor air and future developmenet can be assessed. In addition, parcel delisting from the NPL will not be possible without completion of this groundwater model and close coordination with EPA.

4.1.2 Record of Decision Amendment Several of the Records of Decision currently in place require modification to address additional remediation that has been conducted, and to provide legally enforceable restrictions. Additionally, several sites have a “Consensus Statement” in draft format, but no formal ROD. Signed version(s) of the respective Consensus Statements from EPA have not yet been found. Until a signed Consensus Statement is in place, sites may not be considered officially “closed” and regulatory concurrence is required. Additionally, two of these sites require additional investigation as a result of the site walk recently conducted by EPA, and may not be closed. These are detailed in the specific reuse area sections below.


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4.1.3 Petroleum Hydrocarbons Releases Twenty-four oil/water separators either currently or historically existed at BNAS. Three discharge(d) into the storm sewer system and the remainder discharge(d) into the sanitary sewer system (as shown in Table 7). Documentation regarding integrity testing of the oil/water separator containment systems has not yet been located. Currently, there are 138 active ASTs (as shown in Table 8) and 11 inactive ASTs that contain gasoline, diesel, #1 and #2 fuel oil, JP-8, hydraulic oil, waste oil, cooking grease, waste glycol, ethylene glycol, or lube oil. All ASTs are inspected annually in compliance with the installation’s Spill Prevention, Control, and Countermeasures Plan. Historical releases from ASTs are known to have occurred, but have not been investigated. There are also 17 active USTs (as shown in Table 9), but the UST database indicates at one time there were 525 USTs onsite. Tanks were removed and either replaced with an AST, or removed with no replacement due to building demolition or conversion to natural gas. Specific locations of former tanks are not available in the database, only associated building numbers and street addresses. Most of the tanks were in the residential areas, and contained fuel oil for heating. There are likely releases that have not been investigated that resulted from the former USTs and oil/water separators.

4.1.4 Underground Utilities Abandoned in Place Throughout the Site, several historical underground utilities are no longer in use and have been abandoned in place. IRP Site 10 – Harpswell Fuel Line, runs north-south through the central portion of the Site. The fuel lines have been abandoned in place, and impacts from petroleum releases have not been assessed. The line consists of two asbestos-wrapped pipes which run 13 miles from the US Naval Reserve in Harpswell to the Old Navy Fuel Farm on base. Three miles of pipeline exist on base, 0.5 miles exist in the town of Brunswick, and 8.5 miles exist in the town of Harpswell. The present integrity of the pipeline is also unknown, as it appears that the Transient Quarters were constructed above a section of the fuel line. Additionally, the pipe is wrapped in asbestos containing material (ACM). In the event this line is unearthed during construction activities, the ACM may require special handling and offsite disposal. In November 2007, the Defense Logistics Agency (DLA) transferred $9.4 million to the Navy for the removal of Harpswell Fuel line from the former Navy station in Harpswell to BNAS. However, funding was not provided for the removal of the fuel line section on BNAS property. In addition to the fuel line, approximately 20,504 linear feet of up to 14” diameter asbestos-wrapped steam lines have been left in place in 2’ x 2’ concrete underground trenches throughout the air station. The asbestos insulation around these pipes may require special handling and offsite disposal if redevelopment consists of excavating for building foundations or new utilities where these lines are located. Due to the age of BNAS, a large quantity of the water supply lines are constructed of Transite (an asbestos and concrete composite) pipe. If these pipes are not reused in the redevelopment plan, they may need to be removed and disposed of as asbestos containing material if unearthed during construction.


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Combined sanitary/storm sewers can contaminate sediments within the lines and at discharge points. The integrity of the sewer lines should be assessed prior to reuse, and sampling at outfalls should be considered. Finally, PCB contamination from former transformers or from areas where transformers were historically stored requires assessment to ensure that potential residual contamination does not present a threat to human health and/or the environment.

4.1.5 Asbestos Containing Material, Lead Based Paint, and PCB Paint Due to the age of the buildings at BNAS, a significant amount of asbestos and lead-based paint is likely present in buildings onsite. Comprehensive asbestos and lead-based paint (LBP) surveys suitable for demolition purposes have not been performed, although surveys for ACM and LBP have been conducted in a limited fashion. All buildings on BNAS are assumed to contain ACM and LBP. Existing survey information is available in an inventory maintained by BNAS, and any documentation concerning prior building demolition and the abatement and disposal of ACM or potential ACM should be obtained if available Generally, the Navy does not pay for the abatement of asbestos and lead-based paint in buildings being transferred. The cost of abatement and proper disposal of these materials during redevelopment can be significant, and should be considered during preparation of budgets and for planning purposes. PCB containing paints, which require special handling and disposal, may also be present in some buildings. A survey for PCB containing paints should be conducted.

4.1.6 Pesticide and Herbicide Storage Areas, Mixing Areas, and Base-wide Application Throughout the operational history of BNAS, pesticides and herbicides have been stored, prepared, and applied throughout the base. IRP Site 17, Building 95, is one of these areas and is under active investigation. However, numerous other areas around the base were used as storage and mixing areas. Pesticides are currently mixed and stored in Building 647 for the majority of the main cantonment area, and in Building 39 for the golf course. A base-wide assessment of potential pesticides and herbicides has not been conducted.

4.1.7 Building Drains, Drywells, and Combined Sewers with Potential Releases BNAS does not have industrial operations generating an industrial wastewater stream. Small amounts of industrial type wastes have been generated as off-specification and waste chemicals and solvents. Historically, those wastes were disposed of in landfills, building drains, or transferred to the DRMO. BNAS discharges its sanitary wastes to Brunswick Wastewater Treatment Plant via Brunswick’s partially combined storm and sanitary sewer system. Disposal of waste chemicals down sanitary sewers has the


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potential to contaminate sediment within the sewer and provides a pathway for potential release by sanitary sewer overflow during peak rainfall events. Sanitary sewer overflow can contribute to contamination of environmental media at storm sewer discharge points. Additionally, storm sewers may transport environmental contaminants from their origin during rain events. Storm drainage from the central and southern runways, taxiways, and islands discharge to Mere Brook beaver marsh, while the outlying taxiways north of the operations area drain to the north into tributaries of the Androscoggin River. Storm drainage for the operations area discharges into the unnamed tributary bordering Site 9 that enters the northwestern branch of Picnic Area Pond. Storm sewer discharge points can be collection areas for contaminants and can lead to contaminated sediments and surface waters, which may require investigation before property transfer and redevelopment.

4.1.8 Potential Radiological Contamination The historical presence of nuclear weapons at BNAS is suspected. The EPA and MEDEP have requested that the Navy perform a radiological survey. The most likely areas for radiological contamination are in the Weapons Area Compound and the magazines within the Restricted Weapons Complex. No surveys or assessments have been conducted, and the potential presence of radiological contamination is a data gap.

4.1.9 Phase I/II Environmental Site Assessments A minimum of a Phase I Environmental Site Assessment (ESA) is recommended to identify potential environmental conditions on the base and to satisfy one of the requirements to qualify for the innocent landowner defense, the bona fide prospective purchaser defense, or the contiguous landowner defense to liability under CERCLA and for the purpose of identifying potential development and liability considerations associated with the purchase and development of the base including identification of contaminants that exceed EPA or MEDEP standards. To qualify, the Phase I should be conducted no more than six months prior to property transfer. Additionally, a Phase II investigation at areas identified as possible areas of environmental concern in the Phase I ESA should be conducted prior to property transfer, including areas identified as potential Recognized Environmental Conditions or actual Recognized Environmental Conditions (i.e., areas identified during a Phase I site reconnaissance as areas that are or potentially are impacted by onsite or offsite environmental activities). A Phase I/II ESA is required to establish “baseline” environmental conditions prior to property acquisition by lenders and by regulators to qualify under the All Appropriate Inquiries rule. Therefore, the EPA should be consulted to obtain an opinion on the adequacy of the Navy’s ECP in documenting baseline environmental conditions. It is anticipated that property recipients will be required to document their own baseline conditions.


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4.2 Recreation and Open Space Data Gaps Table 6 presents a detailed description of the identified data gaps for the Recreation and Open Space Reuse Area. The Recreation and Open Space reuse area contains four IRP sites: Site 5 – Orion Street Asbestos Disposal, Site 6 – Sandy Road Rubble and Asbestos Disposal Site, Site 16 – Swampy Road Debris Site, and the Eastern Plume. Site 5 was removed from active site status with an NFA in 1993, but the MEDEP notes the site may require additional sampling and investigation for pesticides. Site 6 was removed from active site status with an NFA in 1993 and is likely suitable for unrestricted reuse. Site 16 was removed from active site status by the Navy in 2001 following a Draft Consensus Statement submitted to the EPA. The EPA responded to the Navy’s draft letter with minor comments on February 5, 2001, but a revised and final Consensus Statement cannot be located. The Eastern Plume currently has restrictions in place that do not allow soil excavation or construction of buildings. The Recreation and Open Space reuse area also contains a portion of the Former Skeet Range which requires a Site Investigation to assess the potential for MEC and the environmental impacts associated with the ranges. Finally, data gaps with potential environmental areas of concern include the golf course shed where pesticides were stored and mixed and the Picnic Ponds area, which will be assessed with the Eastern Plume. Two auxiliary generator USTs have been identified on the Recreation and Open Space parcel. Potential releases associated with these have not been assessed.

4.3 Professional Office Data Gaps The Professional Office parcels contain two IRP sites: Site 7 – Old Acid/Caustic Pit and Site 8 – Perimeter Road Disposal Site; and one Petroleum site: POL 1 – Old Navy Fuel Farm. Site 8 was removed from active site status with an NFA in 1993 and is likely suitable for unrestricted reuse. Site 7 and Site POL 1 both require further action prior to reuse. Environmental data gaps for these sites are specifically outlined in Table 6. Other data gaps include contamination associated with the active fuel farm which may require relocation from the new development’s “front door”, light industrial buildings including the truck wash, contamination in utility trenches, and several oil/water separators, USTs, ASTs.

4.4 Natural Areas Data Gaps The Natural Areas parcels contain three IRP sites: Site 12 – EOD Area, Site 15 – Merriconeag Extension Debris Site, and the Eastern Plume. Site 15 was removed from active site status by the Navy in 2001 following a Draft Consensus Statement submitted to the EPA. The EPA responded to the Navy’s draft letter with minor comments on February 5, 2001, but a revised and final Consensus Statement cannot be located. During the recent site visit by EPA, additional debris was observed at the site and the EPA requests additional investigation. Sites 12 and the Eastern Plume both require further action prior to reuse. Environmental data gaps for these sites are specifically outlined in


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Table 6. Additionally, Site 12 has many data gaps associated with the EOD activities that require a Site Investigation, Remedial Investigation, and Feasibility Study to assess the potential for MEC and the environmental impacts associated with the ordnance demolition activities. Other identified data gaps include potential radiological contamination associated with potentially stored nuclear weapons in the Restricted Weapons Complex and the Weapons Area Compound that have not been assessed at all but include at least 22 magazine storage bunkers that require an assessment of historical use, MEC, and Munitions Compounds (MC).

4.5 Business and Technology Industries Data Gaps The Business and Technology Industries parcels contain seven IRP sites: Sites1/3 – Orion Street Landfill North and Hazardous Waste Burial Area, Site 2 – Orion Street Landfill South, Site 4 – Acid/Caustic Disposal Pit, Site 9 – Neptune Drive Disposal Area, Site 11 – Fire Training Area, Site 13 –DRMO Area, and the Eastern Plume. These seven sites require further action prior to reuse. The existing low permeability caps on the landfills may not currently be suitable for reuse in a Business and Technology Campus. Design review and final parcel use (employee picnic area with walking trails, open parking area, field for solar panel arrays and energy research, etc.) must consider the existing remedy, and a decision regarding upgrading the cap must be evaluated. Environmental data gaps for these sites are specifically outlined in Table 6. The parcels contain a portion of the Former Skeet Range and the Former Machine Gun Boresight Range, and both require a Site Investigation to assess the potential for MEC and environmental impacts associated with the range activities. Finally, data gaps with potential environmental areas of concern within the parcel include the light industrial buildings (transportation maintenance, electric distribution building, and former paint locker and public works building), the former coal pile, contaminants that have preferentially migrated through existing utility trenches, and the abandoned ACM-wrapped steam lines.

4.6 Community Mixed Use Data Gaps The Mixed Use parcels contain three IRP sites: Site 7 - Old Acid/Caustic Pit, Site 9 – Neptune Drive Disposal Area, Site 17 – Former Pesticide Shop; and two Petroleum sites: POL 1 – Old Navy Fuel Farm and POL 2 – NEX Service Station. IRP Sites 7, 9, and 17 and POL Sites 1 and 2 all require further action prior to reuse. Environmental data gaps for these sites are specifically outlined in Table 6. The parcels contain a portion of the Former Skeet Range which needs a Site Investigation to assess the potential for MEC and environmental impacts associated with the range activities. Other data gaps include an assessment of the potential presence of methane gas resulting from the degradation of deicing fluids or releases from glycol tanks, light industrial buildings (auto equipment repair shop, car wash, auto hobby shop, former fire station, truck wash, and fuel farm), contamination in utility trenches, numerous oil/water separators, USTs, and the abandoned ACM-wrapped steam lines.


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4.7 Airport Operations and Aviation-Related Business Data Gaps The Airport Operations and Aviation-Related Business development areas contain two IRP sites. Both Site 14 - Old Dump #3 and Site 18 - West Runway Study Area were removed from active site status by the Navy in 2001 following a Draft Consensus Statement submitted to the Environmental Protection Agency (EPA). The EPA responded to the Navy’s draft letter with minor comments on February 5, 2001, but a revised and final Consensus Statement cannot be located. These two IRP sites are likely suitable for unrestricted reuse following the finalization of the Consensus Statement. This area also contains a portion of the footprint of the Former Munitions Bunker West Area. The potential for the presence of MEC in this area needs to be addressed in a Site Investigation. Finally, uninvestigated potential environmental areas of concern within the airport reuse areas include the runway (potential for contamination by combustion by-products and the potential for glycol deicer spills biodegrading to methane gas in the soil beneath the runway), light industrial buildings (e.g., maintenance hangars), 3 active USTs, and segments of the abandoned asbestos-containing material (ACM)-wrapped steam lines.

4.8 Residential Data Gaps The Residential areas of the main base and McKeen Street Housing do not contain any IRP or MMRP sites; however, there is the potential for unidentified environmental impacts. Environmental data gaps for these parcels include possible petroleum spills from heating oil aboveground storage tanks and underground storage tanks, and the unquantified presence of lead-based paint and ACM within the housing units.

4.9 Education Data Gaps The Education parcels do not contain any IRP sites. The Former Munitions Bunker West Area and the Southwest Old Quarry both have footprints within the boundary of the western Education parcel. Both of these areas require a Site Investigation to assess the potential for MEC and the environmental impacts associated with the storage and the reported ordnance demolition activities. The Education parcels within the cantonment area and west of the runway have data gaps with potential environmental areas of concern including light industrial buildings (generator building, medical/dental clinic, and an ambulance garage) and the abandoned ACM-wrapped steam lines.


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5.0 CONCLUSIONS All of the identified reuse parcels have data gaps associated with known environmental IRP/MMRP sites and/or areas that have not been investigated. The ECP report prepared by the Navy is a good starting point for identification of environmental issues associated with the Site, but does not offer a comprehensive analysis of all issues that could affect redevelopment. The BLRA must have a thorough documentation of the existing environmental conditions on the Site prior to transfer in order to:

• Qualify for the innocent landowner defense, the bona fide prospective purchaser defense, or the contiguous landowner defense under CERCLA.

• Maximize property available for “clean parcel” designation to oobtain delisting status off from the NPL, and maximize land values to developers.

• Assign responsibility for contamination prior to transfer, and avoid future “finger-pointing” exercises with the Navy. For example, if the BLRA accepts existing USTs associated with the NEX service station and the tanks are leaking but this is not known until after the property transfers, the Navy could claim that the BLRA contributed to the contamination by operating the USTs after transfer, and therefore is responsible for cleanup (see first bullet).

• Accurately estimate costs for regulatory closure in the event that the property disposition occurs via a CERCLA Early Transfer mechanism.

• Negotiate reasonable terms for insurance coverage and premium costs. • Understand development schedules and timeframes for remediation. • Understand the regulatory standards that will be applied to the Site after property

transfer. A thorough understanding of regulatory position on each site is critical prior to transfer so that adequate funding can be negotiated with the Navy.

Significant environmental concerns/issues that could affect property values and future reuse/redevelopment plans include:

• The site is currently on the NPL and is a Superfund site. The CERCLA process can be time consuming, and therefore it is imperative that the Navy begin the process as quickly and expeditiously as possible to gain as much information and advance as far through the process as possible before transfer. By having an approved Reuse Plan, future intended use is known, and must be considered in the investigation and remediation process. Discussions must be held early with the EPA and MEDEP, and characterization and remediation completed in order to delist as much property as possible from the NPL. This will improve the marketability of the property for development.

• Inadequate assessment of existing utilities could result in remediation of contamination, removal and replacement of asbestos wrapped or asbestos containing utility lines, or fines associated with discharge of contaminated sediments to outfalls.

• Discovery of MEC or MC could significantly delay development due to the nature and length of time it takes to assess and remediate. Additionally, discovery of


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MEC after development can severely impact existing businesses or airport operations due to the safety arcs that must be imposed during investigation and remediation activities.

• Institutional controls currently in place at the IRP sites are not appropriate for the intended future use. This issue must be discussed with the Navy and regulators so that a thorough understanding of the Navy’s responsibility for cleanup can be made. The Navy’s position has always been that they will clean to a like use, which is not appropriate for the BLRA’s purposes. Institutional controls must be minimized or eliminated so that development can occur at this site.

• Groundwater must be understood through a base-wide modeling effort so that appropriate remedies, ICs, land use controls, treatment, use, and appropriate footprints of impacted areas can be established.

• Migration of contamination offsite must be assessed and addressed. • A base-wide radiological survey must be completed. • Methane assessments around the airport must be conducted to evaluate whether

explosive levels of methane are present. • The BLRA must have detailed cost estimates for what it is and is not responsible

in taking on the existing buildings, including an understanding of potential contamination from floor drains, dry wells, asbestos, lead based paint, PCB paint, and chemical contaminants from past use.

During the development of the Reuse Plan, certain areas have been identified as priorities in redevelopment phasing for the BLRA. The priority areas include property that may be transferred to the BLRA prior to 2011 base closure, areas that will be developed to include special activity centers or economic centers, and areas that will require significant cleanup time or areas that have not yet been investigated and may require a long lead time for investigation and remediation. At this planning stage, possible priority areas include:

1. Currently, groundwater use base-wide is prohibited by EPA unless groundwater modeling is performed. A base-wide groundwater model must be developed utilizing data from existing monitoring wells, as well as from additional wells in areas of potential concern to evaluate base-wide hydrology, contaminant plume nature and extent, and effects of groundwater extraction and re-injection on contaminant migration. This model would be useful in understanding the hydrogeology of the contaminated groundwater from the various IRP sites (or other sites not yet identified) and their relation to the Eastern Plume, and in minimizing the future LUCs that may be necessary to protect human health and the environment and/or minimizing the long-term restrictions on groundwater use. In addition, parcel delisting from the NPL will not be possible without completion of this groundwater model and close coordination with EPA.

2. Property at and adjacent to the new “front door” slated for development as a high end campus-style business park must be investigated so that potential remediation can be estimated and integrated into the development pro forma and schedule. The following sites are included in the “front door” area: Site 7 – Old Acid/Caustic Pit, Site 17 – Former Pesticide Shop, and Site POL 1 – Old Navy Fuel Farm. Since the


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Navy’s existing fuel farm is also located in this area, it is possible the fuel farm may be closed and relocated to a property adjacent to the airfield. Therefore, it is recommended a soil and groundwater contamination study be performed on the area. To date, potential impacts to soil and groundwater in the area surrounding the existing fuel farm have not been assessed and will be required for site closure and redevelopment.

3. Under the MMRP, the Navy intends to evaluate the following munitions sites: the

EOD site (also known as IRP Site 12), the former munitions bunker (west area), the machine gun boresight range, the skeet range, and the quarry on the western perimeter of the base. However, a much larger area was or is currently used for munitions storage, including, but not limited to the munitions compound (adjacent to Sites 1 and 3), and magazine storage bunkers in the Weapons Complex near Site 12. These areas have not been identified by the Navy either under the installation IRP or MMRP program for assessment. The potential for MEC and MC must be assessed prior to base redevelopment.

4. Anecdotal information suggests that the Navy stored and loaded nuclear weapons

onto P3 and C130 aircraft at the base. The transportation and storage of nuclear and/or radioactive material could have resulted in radiological contamination on portions of the base. To help alleviate community, LRA, and regulatory agency concerns, it is recommended that a base-wide radiological survey be performed.

5. A survey and evaluation of the potential glycol contamination on the airfield and

adjacent to former glycol underground storage tanks is also recommended. This soil gas survey would evaluate the potential for presence of explosive levels of methane gas. Historical use of glycol as a deicing fluid for aircraft may have resulted in glycol contamination in soil and groundwater. As glycol degrades, methane gas can be generated as a byproduct and is explosive at concentrations between five and fifteen percent. The methane gas can migrate along utility corridors, which can be very dangerous during base redevelopment as utilities are replaced or relocated.

The ultimate goal prior to transfer is to use the ten BLRA Guiding Principles to characterize contamination throughout the Site and to take the appropriate remedial actions to allow for economically viable and market-based reuse in a manner that is protective of human health and the environment. Investigation and cleanup take time, and the goal is for the Navy to complete as much of the remediation as possible prior to transfer so the property is immediately available to support an appropriate redevelopment plan, on a defined schedule. More robust remedies may need to be considered by the Navy and regulators to meet schedules for transfer. For example, a “dig and haul” remedy to remove source areas is a much more immediate and thorough remedy than is in-situ injections that take much longer, and have limited effectiveness. However, the remedy may be more expensive. These are the types of issues that the BLRA must be involved in from now until property transfer so that as much cleanup can be accomplished as possible prior to transfer, or the BLRA can negotiate with the Navy to privatize a cleanup that is protective of human health and the environment, and meets development schedules and priorities.

TABLES

Table 1. DOCUMENTS REVIEWED

No. Document Description1 Environmental Condition of Property Report for NASB, May 2006.2 Monitored Natural Attenuation Assessment of the Eastern Plume, October 20063 Second Five-Year Review Reoprt of NASB, September 20054 Site Management Plan - A Road Mpa for Environmental Cleanup at NASB, January 20075 Draft Final Suppllemental RI Report for NASB, August 1991

6

EPA Record of Decisions and Explanation of Significant Differences -Site 7 ROD 9/27/2002 -Site 5 ESD 12/27/2000 -Site 6 ROD 9/28/1999 -Site 7 ROD 9/29/1998 -Site 5 ROD 2/10/1998 -Site 6 ROD 9/30/1994 -Site 1 ESD 9/30/1994 -Site 3 ROD 8/31/1993

7 Integrated natural Resources Management Plan, November 2001

8Environmental Baseline Survey for Defense Fuel Support Point - Casco Bay Terminal, Casco Bay-to-Brunswick NASB Pipleine, and South Harpswell, November 1997

9Remedial Investigation/Feasibility Study ProgramDraft Final Phase I Feasibility Study, Development and Screening of Alternatives for NASB, August 1990

10 Final Preliminary Assessment for NASB, February 200611 Map of U.S. Naval Air Station Brunswick, Maine. Map. United States Navy. June 30, 1946.

12Draft Naval Air Station Brunswick Instruction 5090.1C Restriction on Excavation Activities and Groundwater Use. October 2006

13 Final Work Plan and Site Safety and Health Plan Site 9 Ash Landfill/Dump Removal Action, October 2005

14 BRAC Preparedness Strategy for BNAS, May 200515 MEDEP Memorandum Regarding Pre-Draft Condition of Property, November 2005

16Final Draft Hydrologic Study of the Picnic Pond Stormwater Retention System Mare [sic ] Brook Watershed, June 2002

17 April 2006 Technical Meeting Summary/ Agenda18 Building 95, Monitoring Event 22 & Reporting Limits MEDEP Comments19 Draft Technical Meeting Summary 25-26 April 2006 EPA Comments & Review 20 Sites 1, 3 & Eastern Plume-Monitoring Event 26 Review and Comments21 Aug 2006 RAB Technical Conference Notes22 Eastern Plume-Extraction Well Installation Review & Comments23 1, 4 Dioxane Existing and Proposed Sampling Locations24 Site 2, Monitoring Event 1225 Sediment Data for Picnic Pond26 Site 9 debris pile samples taken on May 16th27 Site 7, Work Plan for Installation of Monitoring Wells28 Responses to MEDEP Comments Site 7 Regulator Draft Monitoring Event 1 Report, April 200529 Responses to MEDEP Comments Site 7 Regulator Draft Monitoring Event 2 Report, Sept. 200530 Site 7, Monitoring Event 2-September 2005 Follow-Up Comments31 Building 95-Method Detection Limits and Reporting Limits32 1,4 Dioxane Sampling Locations MEDEP Comments

33Conference Call Notes Oct 4, 2006 w/ Carolyn Lepage, Carol Warren, Catherine Guido, Darren Gainer, Dale Mosher, Lonnie Monaco

34 NAS Report Status of sites Bldg 95, Site 2, Site 9, Site 1 & 3, 35 BACSE Comments on September 2006 “1,4-Dioxane Existing and Proposed Sampling Locations”36 Monitored Natural Attenuation Assessment of the Eastern Plume Naval Air Station, Brunswick, Maine

37 Naval Air Station Brunswick Restoration Advisory Board Oct 25, 2006 Technical Telephone Conference notes38 BACSE Comments on the April 25, 2006 Restoration Advisory Board Meeting Minutes39 Status of Draft/Draft-Final and Other Reports: Nov. 200640 Long Term Monitoring Plan Sites 1 &3 and Eastern Plume Naval Air Station, Brunswick, Maine41 Mere Brook Investigation Workplan42 Technical Meeting Summary Nov. 7, 8, & 9 2006

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No. Document Description

43 Restoration Advisory Board Meeting: Meeting Attendees US Navy, Regulatory Representatives and Consultants

44Addendum to EPA's 1997 Policy Towards Landowners and Transferees of Federal Facilities: Applicability of the Bona Fide Prospective Purchaser Liability Protections to Transferees of Federal Real Property

45 Technical Committee Meetings Summary Nov. 7, 8 & 9 2006 46 Building 95-Workplan47 Site 9, Soil Sampling Corrective Action Plan

48Draft Soil Sampling Corrective Action Plan and Letter Work Plan for Site 9, Ash Landfill/Dump Area, dated December 4, 2006, received December 27, 2006 for the Naval Air Station Brunswick, Maine

49

Remedial Investigation/ Feasibility Study (RI/FS) Schedule for Sites 12 & 17, and the military munitions response program (MMRP) and Quarry Areas of Concern (AOCs) at the Naval Air Station Brunswick/ Topsham, Maine

50Response to Comments from the Maine Department of Environmental Protection Draft Work Plan for Extraction Well Installation Eastern Plume

51 NAS Brunswick's IRP Drawdown Plan52 Eastern Plume Groundwater Sample Plan Results September 2006 Monitoring Plan53 Eastern Plume Groundwater Sample Plan Results Spring 2006 Monitoring Plan54 Technical Meeting Agenda Naval Air Station Brunswick 20, March 200755 CERFA Identification of Uncontaminated Property at the Naval Air Station Brunswick, Maine

56Draft Final Site Inspection (SI) Work Plan for the Military Munitions Response Program at the Naval Air Station Brunswick, Maine dated Feb. 19, 2007

57 Interpreted Basewide Groundwater Elevation Map Naval Air Station 58 Community Environmental Response Facilitation Act (CERFA)59 Community Environmental Response Facilitation Act (CERFA) presentation, March 2007

60 Map of the significant sand and gravel aquifers in Brunswick Quadrangle, Maine: Maine Geological Survey61 Revised Proposed Sampling Locations for 1, 4-dioxane Monitoring Event ECC Project No. 5700.007.015

62 Response to MEDEP Comments Building 95 Regulator Draft Monitoring Event 22 Report, September 200563 Responses to MEDEP Comments Site 9 Regulator Draft Monitoring Event 26 Report, April 200564 Responses to MEDEP Comments Site 9 Regulator Draft Monitoring Event 27 Report, September 200565 Responses to MEDEP Comments Site 1&3 Regulator Draft Monitoring Event 26 Report, April 2005

66BACSE Comments on the January 2007 Draft Final Preliminary Assessment Addendum and Feb 2007 Draft Final Site Inspection Work Plan

67 Draft Site 2 Investigation Work Plan, dated March 2007, Naval Air Station Brunswick

68Revised 1,4-Dioxane Existing and Proposed Sampling Locations, received on March 27, 2007, Naval Air Station Brunswick, Maine

69 Site 9 Ash Landfill; Building 201; and Soccer Field Investigations70 Final Extraction Well Installation Work Plan Eastern Plume

71Letter Work Plan for the Site 9 Neptune Drive Disposal Site Ash Removal, dated February 2007, Naval Air Station Brunswick, Maine

72 Failure to comply-Long Term Monitoring Program-Sites 1 & 3 and Eastern Plume

73Response to Comments from the EPA New England-Region 1 1. On the Draft Remedial Investigation scoping plan for Site 17, Building 95, dated Feb 2007

74Response to Comments from the Brunswick Area Citizens for a Safe Environment (BACSE) on the Draft Remedial Investigation Scoping Plan for Site 17, Building 95, dated February 2007

75Responses to Comments from the MEDEP Bureau of Remediation and Waste Management on the draft Remedial Investigation and Scoping Plan for Site 17, Building 95, dated February 2007

76 March 2007 Draft Work Plan for Investigation Activities at the Former Orion Street Landfill-South

77Sites 1, 3, and Eastern Plume, Monitoring Event 27 (September 2005) Report, dated March 2007, Naval Air Station Brunswick, Main

78 Background Study Work Plan, dated March 2007 EPA Comments79 Draft Background Study Work Plan MEDEP Comments80 Base Instruction, received via e-mail May 10, 2007 EPA Comments81 Site 2,Monitoring Event 13 (June 2006), dated April 2007 EPA Comments82 Naval Exchange (NEX) Round 3 NEX Workplan Addendum

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No. Document Description

83 Responses to EPA Comments Sites 1&3 Eastern Plume Monitoring Event 27 (Sept. 2007) Report, March 200784 Revised Base Operating Instruction MEDEP Comments85 Eastern Plume (OU 5) 1, 4- Dioxane Navy Letter86 EPA Refusal Comments to Navy Letter dated June 5, 2007 concerning 1,4 Dioxane

87Letter regarding Failure to comply- Long Term Monitoring Program Sites 1&3, Eastern Plume MEDEP Comments

88 Stipulated Penalties for Non-Compliance with the Federal Facility Agreement (FFA) from EPA89 2007 Field Work Schedule90 Site 9 Investigation at the NASB

91Response to EPA Comments on the Draft Final Site Inspection (SI) Work Plan for the Military Munitions Response Program at the Naval Air Station Brunswick, Maine, dated May 2007

92Response to EPA Comments on the Draft Final Preliminary Assessment Addendum for the Military Munitions Response Program at the Naval Air Station Brunswick, Maine, dated May 2007

93Navy Letter dated June 20, 2007 re: USEPA New England-Region 1 Letter of June 6, 2007, stipulated penalties for non-compliance with the federal facility agreement (FFA) at NASB

94 March RAB Meeting Notes95 Naval Air Station Brunswick Restoration Advisory Board May 15, 2007 Conference Call Notes96 Old Navy Fuel Farm Sampling MEDEP Comments97 Final Revision 1, Report Site 2 Monitoring Event No. 5 Final Report- April 200298 Sites 1, 3, and Eastern Plume, Monitoring Event 28 (April 2006) Report, dated May 2007 EPA Comments

99 Letter Work Plan for the Site 9 Neptune Drive Disposal Site Ash Removal, dated May 18, 2007 EPA Comments100 NASB Conference Call Notes October 25, 2006101 Military Munitions Sites-Site Investigation Work Plan Response to Comments

1021, 4 dioxane at the NASB; response to EPA letter dated June 6, 2007 concerning 1, 4 dioxane within the Eastern Plume at NASB

103 Navy Letter dated July 27, 2007 subject: 1, 4- Dioxane at the NASB104 NASB JUL 17 07 Technical Conference Call Notes105 Site 9, Monitoring Well Installation MEDEP Comments106 NASB Mere Brook Samples JUL 2007

107 June 12-14, 2007 Technical Meeting notes, dated July 17, 2007, for the Naval Air Station, Brunswick, Maine108 Site 9 Neptune Drive Disposal Site, Well Installation, dated July 2007 EPA Comments109 Site 2, Monitoring Event 14 (September 2006), dated July 2007 EPA Comments110 NASB Split Sampling Results in Eastern Plume Aug 2007

111 Monitoring Events #4&5 for site 7 at the Naval Air Station Brunswick, Maine, dated July 2007 EPA Comments112 Sites 1,3 & Eastern Plume, Monitoring Event 28 MEDEP Comments113 Attachment to MEDEP Comments on Remedial Investigation Work Plan for Site 17114 Site 17, Remedial Investigation Workplan MEDEP Comments115 Site 17 Monitoring Events 24 & 25 MEDEP Comments116 Revised Letter Work Plan – Site 9 Soil Removal Action EPA Comments117 Background Study Workplan MEDEP Comments118 Site 9, Monitoring Event 29-September 2006 MEDEP Comments119 Draft Final Long Term Monitoring Plan for Sites 1 & 3, NASB120 Eastern Plume- Draft Final Long Term Monitoring Plan MEDEP Comments121 Naval Exchange (NEX) Long Term Monitoring-Fall 2007 MEDEP Comments122 Response to Draft Final MEDEP and EPA Comments Site 7 Monitoring Event 1123 Response to Draft Final MEDEP and EPA Comments Site 7 Monitoring Event 2124 Draft NASB Instruction 5090.1C, Restriction on Excavation Activities and Groundwater Use125 Responses to MEDEP Comments Site 2 Regulator Draft Monitoring Event 12 Report, Sept. 2005126 Response to MEDEP Comments Site2 Regulator Draft Monitoring Event 12 Report, Sept. 2005127 Revised Final Report Site 2 Monitoring Event No. 5 Final Report- April 2003 NASB128 Draft Action Items from Dec. 2006 Technical Meeting129 Draft Action Items from January 9, 2007 Technical Meeting130 NASB Conference Call Notes January 9, 2007131 NASB Excavation Clearance Permit updated May 10th, 2007

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No. Document Description132 NAS Brunswick Instruction 5090. 1C (NASBINST 5090.1C)

133Response to Comments from the Brunswick Area Citizens for a Safe Environment Draft Work Plan for Former Orion Street Landfill South (Site 2)

134Response to Comments from the Maine Department of Environmental Protection Draft Work Plan for Former Orion Street Landfill- South (Site 2)

135response to Comments from the united States Environmental Protection Agency Draft Work Plan for Former Orion Street Landfill- South (Site 2)

136Response to Comments from the Brunswick Area Citizens for a Safe Environment (BACSE) on the Draft Remedial Investigation Scoping Plan for Site 9, Building 201 AOC, & Irrigated Playing Fields


138 Figure 5 Sample Locations Bldg 201 Area of Concern NASB139 Figure 4 Sample Locations Site 9/ Neptune Drive Disposal Site NASB


141 Figure 5, Sample Locations Bldg 201 Area of Concern NASB

142Response to Comments from the Brunswick Area Citizens for a Safe Environment (BACSE) Draft Site Management Plan, A Roadmap for Environmental Cleanup

143 Response to Comments from the BACSE Draft Site Management Plan144 Response to Comments from MEDEP Draft Site Management Plan Feb 26 07145 Response to Comments from USEPA Draft Site Management Plan Feb 13 07146 Response to Comments from MEDEP Sites 1 & 3 Landfill Draft Operation and Maintenance Plan147 Response to Comments from USEPA Sites 1 &3 Landfill Draft Operation and Maintenance Plan148 Technical Meetings NASB March 20, 21, 22 2007 Meeting Notes

149 Action Items from 13 Feb 2007 Conference Call- Draft (Reviewed at March Tech Meeting; March 20-22, 2007150 Action Items from March Technical Meetings151 Technical Meetings NASB March 22 2007 Meeting Notes152 Draft Remedial Investigation Work Plan for Site 17, Building 95, dated June 2007 EPA Comments153 Aquatic chemical report from ECOTOX database154 Chemical report from ECOTOX database155 Terrestrial chemical report from ECOTOX database156 Brunswick Naval Air Station Restoration Board Contact List

157Brunswick Naval Air Station Restoration Board 2006 Schedule Conference Calls, Technical Meetings and RAB Meetings

158 Actions Items generated during 14 JUN 2007 Technical Meeting159 Action Items reviewed during 13 JUN 2007 Technical Meeting160 Draft Mere Brook Investigation Workplan Text161 Draft Final Operations and Maintenance Manual for Sites 1 & 3 Landfill dated Aug 27, 2007162 Response to Regulator comments on Draft Work Plan Background Study, NASB163 Final Site 7 Monitoring Event 2 Summary Report September 2005164 Technical Meetings NASB JUN 12, 14 2007 165 RAB Meeting Notes JUN 13 2007 166 JUN 12, 2007 RAB Meeting Notes: Mere Brook Fish Tissue Study Presentation167 Letter Work Plan for Monitoring Well Installation Site 9 168 Technical Meeting Agenda NASB 20 MAR 2007169 Regulator Draft Site 9 Monitoring Event 27 Report Sept. 2005170 Preliminary Draft Sample Figures JAN07171 Site Management Plan A Road Map for Environmental Cleanup JAN 2007: TEXT & FIGURES172 Base Wide Quality Assurance Project Plan for the Long-Term Monitoring Program173 Regulator Draft Building 95 Monitoring Event 22 Summary Report Sept. 2005 doc. Dated April 2005174 Regulator Draft Site 2 Monitoring Event 12 Summary Report Sept. 2005 doc. Dated April 2006175 Regulator Draft Sites 1 & 3 & Eastern Plume Monitoring Event 26 Report April 2005

176Draft Direct -Push Work Plan for Site 9 Ash Delineation and Investigations at Bldg 201 area of concern and irrigated playing fields

177 Proposed Changes to the Final Long Term Monitoring Plan for Site 7

4 of 4

Table 2. SUMMARY OF ENVIRONMENTAL CONDITIONS FOR INSTALLATION RESTORATION PROGRAM AND MILITARY MUNITIONS RESPONSE PROGRAM SITES

Soil Groundwater Landfill Leachate Seep

Surface Water Sediment

1 Orion Street Landfill North 1955-1975

10 acres Sites 1/3 of landfill but "Site" occupies 60 acres

MSW, waste oil, solvents, pesticides, petroleum products, paints, aircraft/auto parts, various other chemicals.

-- VOCs, metals VOCs, DDT, metals Metals

VOCs, SVOCs, PAHs, metals

Pesticides in surface water of Mere Brook

1983 - Initial Assessment Study (IAS)1990 - RI/FS

1992 - ROD1995 - Slurry wall & 2 GW extraction wells installed, installation of a low permeability cap1997 - GW extraction wells deactivated 2005 - Installation of additional 6 wells

LTMFinalize O&M PlanDevelop final LUCsDevelop IC boundary for siteUpdate ARAR tablesSampling to Evaluate Potential Impacts to Mere BrookMonitor landfill cap for subsidence

No further action with respect to soil (1992). Active, Long-term groundwater and soil gas monitoring, long-term operations and maintenance of cap and hydraulic containment

No Soil Excavation on or near Site 1/3, Groundwater Use Restriction

2 Orion Street Landfill South 1945-1955 2 acres

Solvents, paint, oil, toluene, MEK, medical supplies, ash from solid waste incineration

Metals (Hg) VOCsDDT, DDD, metals (As, Cd, Cr, Pb, Hg, Ni)

Metals (Fe, Zn)

Metals (Fe), PAHs (phenanthrene),

dioxins from solvent incineration

1982 - PA1988 - RI/FS

1998 - ROD1998 - Risk Assessment1999 - Removal Actions that included removal of surface debris, installation of a soil cap, installationof fence and signs Implementation of "Minimal Action" remedy 2007 - Second round of fish tissue sampling

LTMDevelop final LUCsDevelop IC boundary for site, Investigate area north of Landfill between Site 2 and Site 1/3

Active, Long-term groundwater, sediment, leachate monitoring, investigation north of landfill ongoing

No Soil Excavation on or near Site 2, Groundwater Use Restriction, maintenance of fencing and warning signs

3 Hazardous Waste Burial Area 1960-1973 10 acres

Sites 1/3Solvents, paints, isopropyl alcohol, PCE

Combined with Site 1





Combined with Site 1 Combined with Site 1 Combined with Site 1 Combined with Site 1 Combined with Site 1

No Soil Excavation on or near Site 1/3, Groundwater Use Restriction

4 Acid/Caustic Pit 1969-1974

Under Building 584, pit 4' x 4' x 3'

Liquid wastes (acids, solvents, transformer oil) disposed in unlined pit

None (though soil samples were not collected directly from the pit area)

TCE, metals (Pb) NA NA NA

PCBs from transformer oil, indoor air assessed?

late 1988 - RI/FS with Risk Assessment 1998 - ROD (Conditional NFA)

Soil - NoneGW - To be addressed under Eastern Plume

Closed (1998) - No further action with respect to soil. Groundwater being addressed with Eastern Plume.

No Excavation beneath Building 584, Consult with Navy before building demolished

5Orion Street Asbestos Disposal Site

1979 0.25 acresAsbestos-lined pipes, construction debris in two trenches

Asbestos None NA NA NA NA1991 - Geophysical Survey and Site Inspection and Sampling

1993 - Debris excavated and removed, ROD issued with NFA (no ICs)

None

Closed (1993) - NFA with no ICs, MEDEP notes site may require additional sampling investigation for pesticides

None

6Sandy Road Rubble and Asbestos Site

Unknown-1970s 1 acre

Asbestos-lined pipes, construction debris, aircraft parts

Asbestos None NA NA NA NA1991 - Geophysical Survey and Site Inspection and Sampling

1993 - Debris excavated and removed, ROD issued with NFA (no ICs)

None Closed (1993) - NFA with no ICs, Suitable for unrestricted reuse None

7 Old Acid/Caustic Pit 1952-1969 1.4 acres

Liquid wastes (transformer oil, battery acid, caustics, solvents, misc. liquids. )

PAHs, pesticidesNote no detects of PCBs

Metals (Cd, Mn) NA NA NA soil pile contaminants

1983 - IAS1990 - RI/FS with Risk Assessment

2000 - GW pump test to assess Cd plume, 400cy of soil excavated (140 cy transported offsite, 260 cy redistributed onsite2002 - ROD2005 - GW LTM Plan finalized 2007 - Reinstalled three MWs damaged during soil removal

Install 3 additional wellsDetermine extent/location of redistributed soilDevelop final LUCsDevelop IC boundary for siteUpdate ARAR tablesAmend ROD for soil contaminationInspect piles of soil in woods between MWs and road

Selected remedy is Institutional Controls and long term groundwater monitoring

No soil excavation, Groundwater Use Restriction

8 Perimeter Road Disposal Area 1964-1974 0.5 acres

Solvents (TCE, MED, toluene), construction debris, asphalt debris

PAHs, DDTNote no detects of PCBs

NA NA NA NA NA 1990 - RI/FS 1993 - Debris excavated and removed, ROD issued with NFA (no ICs)

None Closed (1993) - NFA with no ICs, Suitable for unrestricted reuse None

9 Neptune Drive Disposal Area 1943-1953 20 acres Solvents, paint sludge, metal

shop waste, ash

VOCs (TCE, DCE, VC, toluene), SVOCs (combustion by-products)

VOCs (PCE, TCE, VC, DCA), DRO in one MW

Metals (As, Cr, Pb, Na, Zn), pesticides

PAHs, pesticides

dioxins from solvent incineration, diesel range organics to the west

1983 - IAS1985 - Pollution Abatement Confirmation Study1990 - RI with Risk Assessment1995/96 - Source Investigations1999 - ROD2003/2004 - Add'l Investigation Work including 2 borings, 2007 work plan for additional sampling

1995 - Impoundment ponds construction south, east, and southeast of Bldg 2012005 - Barracks were demolished2006 - Excavation of ash landfill began2007 - Installed MW in southwest corner of site

Finish excavation of ash landfillReplace MWs removed during excavationInvestigate DRO in MW near Bldg 201Direct push soil investigation south of Neptune Dr. LTMDevelop IC boundary for siteUpdate ARAR tablesAmend ROD for contaminated soil removal

Active, Remediation in progressNo soil excavation, Groundwater Use Restriction

10

Harpswell Cove Fuel Depot, easement and 2 fuel lines that run through the base

1956-1991

Easement is 30 feet wide, 2 fuel lines

Petroleum Petroleum Petroleum NA NA NA asbestos 1997 - Environmental Baseline Study (EBS)

1991 - Lines were drained, cleaned, and pressurized with nitrogen1995 - Pipeline valve stems removed when fuel farm was demolished 1999 4 test pits excavated to assess condition of pipeline and soil, no impacts identified

None Lines onsite - none none

Navy-Identified Contaminants of ConcernIRP/POL/MMRP

SiteDescription Dates of

Operation Size Wastes Disposed/Used at Site Remediation Status Existing Land Use

Controls

Additional Potential

Contaminants of Concern (GAPS)

Previous Studies Previous Actions Planned Actions

Page 1 of 4







Controls




11 Fire Training Area 1950s-1990Approximately 3 acres

Liquid wastes (fuels, oils, solvents). Fires burned directly on the ground.

Solvents (TCE, TCA), PAHs

Solvents (TCE, TCA) NA NA NA dioxins from solvent

incineration1990 - RI/FS

1994 - Buried drums and debris excavated and removed1995 - Concrete pad and 6-10' of underlying soil excavated and removed (no disposal docs), TCE remained in subsurface soil1998 ROD


Closed (1998) - NFA for soils, Groundwater addressed under Eastern Plume. Infiltration Gallery in use on this site.

No soil excavation, Groundwater Use Restriction, no disturbance of infiltration gallery

12 EOD Area 1981-2004 14 acres Explosives

Metals (Al, Hg, Pb), nitrates/nitrites, explosives compounds not detected

Metals (Al, Hg, Pb), perchlorate, nitrates/nitrites

NA NA NAperchlorate, unexploded ordnance

1983 - IAS1989/1991 - Supplemental RI2006 - Preliminary Assessment (PA)

NoneDevelop Supplemental PA, SI, RI, FS, and ROD Investigation status current. No

remediation conducted to date

No soil excavation, groundwater use restriction

13 DRMO Area 1970s-1980s 280' x 300' Leaking USTs (diesel, waste oil, solvents)

Pesticides, SVOCs VOCs NA NA NA -- 1988 - Site Characterization

1986 - 1 UST removed, 1 UST replaced with AST1989 - 1 UST removed


Closed (1998) - Soil NFA because site is paved and soils not accessible. Groundwater is assessed under Eastern Plume.

No soil excavation, groundwater use restriction

14 Old Dump Number 3 Late 1940s

under existing runway

Construction debris No sampling conducted None None None None --

Supplemental Remedial Investigation (including magnetometer survey)

None None Closed (2001*), Likely suitable for unrestricted reuse None

15Merriconeag Extension Debris Site

Unknown

Concrete rubble and debris dam that created a 0.75 acre pond

Construction debris, asbestos cement pipe

Sampling belowstate and federal standards

None NA

Sampling below state and federal standards


--

1992 - Site Inspection (including magnetometer survey, soil/sediment/surface water samples)1999 - Confirmation magnetometer survey

1999 - Asbestos cement pipe and scrap metal debris removed from site

None, however EPA requested additional investigation

Closed (2001*), additional investigation requested None

16 Swampy Road Debris Site Unknown

Debris across 1,700' section of stream

Debris


None NA



--

1992 - Site Investigation (magnetometer survey, soil/sediment/surface water samples)

1999 - Debris items removed None, however EPA requested additional investigation

Closed (2001*), Likely suitable for unrestricted reuse None

17Building 95, Former Pesticides Shop

1955-1985 1 acre Pesticides, herbicidesDDT, other pesticides and herbicides

DDE, DDT, endrin, alpha chlordane, gamma chlordane, heptachlor epoxide

NA NA NA --1983 - IAS1992 - Site Evaluation

1994 - Oct. soil excavation (45 cy removed), Dec. soil excavation (5 cy removed)1996 - Building demolition and soil excavation (1260cy removed)

LTMDevelop Work Plan, Develop RI/FS and RODLocate, excavate, dispose of impacted soil that was placed south of Ave B in 1994Develop LUCsDevelop IC boundary for site

Active, investigation in progress, nature and extent not defined, no ROD

No soil excavation, groundwater use restricted

18 West Runway Study Area Unknown

Approximately 2 acres

Fill material and metallic debris


NoneSampling below state and federal standards



--

1993 - Site Investigation (including magnetometer and GPR survey, soil/sediment/GW/surface water samples for VOCs, and test pits)

1993 - Fill material and metallic debris were removed1994 - Additional water sampling event at citizens' group request

None Closed (2001*), Likely suitable for unrestricted reuse None

Page 2 of 4







Controls




POL 1 POL1: Old Navy Fuel Farm 1943-1993

Approximately 10 acres

Leaking tanks, Petroleum, ethylene glycol GRO, DRO GRO, DRO,

BTEX, MTBE NA NA NA

Methane (degradation product of ethylene glycol)

1990/92 - Studies performed on 2 distinct hydrocarbon plumes

1993 - Tanks and piping removed during decommissioning1996 - SVE/biosparge system installed1998 - Biosparging system converted to dual-phase extraction system2000 - Unsuccessful DPE resulted in 15,000 cy soil removal action2000 - GW monitoring program implemented

LTMDevelop soil LUCs, GW is close to meeting MEGs

Active, Long-term monitoringNo soil excavation, groundwater use restriction

POL 2POL2: Navy Exchange Service Station (NEX)

1957-PresentApproximately 2 acres

Leaking tanks and lines, Petroleum, releases to utility trenches and along utility lines.

GRO GRO NA NA NA --2004 - Feasibility Study2003 - Baseline biodegradation evaluation

1974 - USTs replaced (single wall steel)1985 - Groundwater recovery system (for odor mitigation)1992 - Soil excavation (440 tons)1993 - USTs replaced (double wall fiberglass; SVE/Air sparging system installed1995 - Stage II vapor recovery system installed1996 - All 3 piping sumps replaced1999 - Upgrade repairs to USTs2002 - Insitu chemical oxidation pilot study (ineffective)2003 - SVE/Air sparging system deactivated2005 - Denitrification-based biodegredation pilot study

EPA and DEP unsatisfied with effectiveness & request alternative technology to DBBDevelop final LUCsDevelop IC boundary for site

Active, Additional biodegredation pilot studies planned, regulators request source area treatment and potential soil excavation because in situ treatment is not effective.

No soil excavation, groundwater use restriction, worker safety precautions for soil excavation work on utility lines "in the area"

-- Eastern Plume --

North south at least 0.6 miles

Contamination from Sites 4, 11, and 13 (4 and 13 no longer considered by Navy to be contributing as sources)

-- VOCs, 1,4-dioxane -- VOCs --

Navy not treating effluent for 1,4-dioxane, arsenic, or manganese.

1990 - RI1991 - Supplemental RI1992 - FS and ROD issued2007 - Mere Brook fish tissue sampling2007 - Groundwater sampling near Mere Brook

1995 - GW treatment system with 5 extraction wells and UV oxidation[date unknown] - 6th extraction wellinstalled2001 - UV oxidation upgraded to air stripper with carbon polishing2001 - Direct push investigations in southern boundary of plume and Site 112003 - Analysis of MNA parameters in select GW wells2004 - Direct push investigation near MW-3132007 - Installed additional extraction well

Analyze 2007 Surface Water Investigations along segments of Mere Brook and near MW-313Develop Eastern Plume Groundwater ModelFinalize LTMPDevelop final LUCsDevelop IC boundary for siteContinue assessment of 1,4-dioxaneContinue sample collection for MNA Install new extraction wells to replace/augment existing wellsInvestigate causes of plume shiftUpdate ARAR tablesDevelop LUCs for infiltration galleryDiscuss alternative remedies for plume containment

Active, Investigation and Remediation in progress with operation of groundwater extraction and treatment system

Groundwater use restriction, no building above Eastern Plume allowed. Soil excavation restrictions under consideration

Page 3 of 4







Controls




MMRP UXO 001

Former Munitions Bunker West Area

1980 - 2000 for munitions

training29 acres

Munitions and Explosives of Concern, including small arms ammunitions, practice grenades, and limited pyrotechnics

No sampling conducted


No Sampling Conducted



MEC, metals, explosives, perchlorate

1991 - Supplemental FS2006 - Final Prelim Assessment None Navy in the process of determining

what actions to takeInvestigation status current. No remediation conducted to date

No soil excavation or groundwater use

MMRP UXO 002

Machine Gun Bore Sight Range

1980 - 2000 for munitions

training0.3 acres

Machine gun and pistol ammunitions, no unexploded ordnance suspected, but Munitions Constituents likely





No sampling conducted lead 1991 - Supplemental FS

2006 - Final Prelim Assessment None Navy in the process of determining what actions to take

Investigation status current. No remediation conducted to date


MMRP UXO 003 Skeet Range 1980 - 2000 73.2 acres Lead shot from expended

shotgun ammunitionNo sampling conducted





antimony, arsenic, nickel, and lead azide




-- Quarry Site approx 1950s 4 acres

Undocumented reports of Munitions and Explosives of Concern disposal.Reports of surface spreading of TPH-contaminated soil.






TPH, MEC, metals, explosives, perchlorate




+Dioxins are produced during the combustion/incineration of chlorinated solvents. Due to historical site activities, Dioxins may be present at these sites.*Draft Consensus Statement submitted and EPA responded to it with comments February 5, 2001. Unable to locate a Final EPA-Signed Consensus Statement, which is required for closure. ARAR - Applicable or Relevant and Appropriate RequirementsBNAS - Brunswick Naval Air StationBTEX - Benzene, Tolune, Ethylbenzene, and Xylenecy - cubic yardDCA - DichloroethaneDCE - DichloroetheneDRO - Diesel Range OrganicsICs - Institutional ControlsGRO - Gasoline Range OrganicsGW - GroundwaterLTM - Long Term MonitoringLUC - Land Use ControlMEDEP - Maine Department of Environmental ProtectionMMRP - Military Munitions Response ProgramMTBE - Methyl Tertiary-Butyl EtherMW - Monitoring WellNFA - No Further ActionO&M - Operation and MaintenancePAH - Polynuclear Aromatic HydrocarbonPCB - Polychlorinated BiphenylPCE - TetrachloroetheneRI/FS - Remedial Investigation/Feasibility StudyROD - Record of DecisionSVOC - Semi-Volatile Organic CompoundsTCE - TrichloroetheneTPH - Total Petroleum HydrocarbonsVC - Vinyl ChlorideVOC - Volatile Organic Compounds

NFA - Likely suitable for unrestricted redevelopmentNFA - Conditional, not protective for redevelopmentNo Color - Site in active investigation and/or remediation phase

Page 4 of 4

Table 3. KNOWN ENVIRONMENTAL ISSUES BY PROPOSED LAND USE DISTRICT

Planned Land Use District Reuse Features MMRP Sites IRP SitesAviation Related Business Aviation Related Industry None None

Airport Operations Aviation Related Industry One (1) MMRP Site:-Former Munitions Bunker West Area

Two (2) IRP Sites:-Site 14: Old Dump #3-Site 18: West Runway Study Area

Professional Office Office Campus None Three (3) IRP Sites:-Site POL1: Old Navy Fuel Farm-Site 7: Old Acid/Caustic Pit-Site 8: Perimeter Road Disposal Site

Community Mixed Use Hotel/Conference CenterIndoor Recreation Center

One (1) MMRP Site:-Former Skeet Range

Five (5) IRP Sites:-Site POL1: Old Navy Fuel Farm-Site POL2: NEX Service Station-Site 7: Old Acid/Caustic Pit-Site 9: Neptune Drive Disposal Area-Site 17: Building 95/Former Pesticide Shop

Business & Technology Industries

Alternative Energy Research Park

Two (2) MMRP Site:-Former Skeet Range-Former Machine Gun Boresight Range

Seven (7) IRP Sites:-Site 1/3: Orion Street Landfill North/HW Burial Area-Site 2: Orion Street Landfill South-Site 4: Acid/Caustic Disposal Pit-Site 11: Fire Training Area-Site 13: DRMO Area-Portion of Site 9: Neptune Drive Disposal Area-Portion of Eastern Plume

Education Bowdoin CollegeSouthern Maine Community CollegeEmbry-Riddle University

Two (2) MMRP Site:-Former Munitions Bunker West Area-Southwest Old Quarry

None

Residential Residential None None

Recreation / Open Space New 18-hole Golf Course One (1) MMRP Site:-Former Skeet Range

Four (4) IRP Sites:-Site 5: Orion Street Asbestos Disposal Site-Site 6: Sandy Road Rubble & Asbestos Disposal Site-Site 16: Swampy Road Debris Site-Eastern Plume

Natural Areas Community GardensNature Center with Walking Trails

One (1) MMRP Site:-Site 12 EOD Area

Three (3) IRP Sites:-Site 12: EOD Area-Site 15: Merriconeag Extension Debris Site-Portion of Eastern Plume

Page 1 of 1

Table 4. MAINE DEPARTMENT OF ENVIRONMENTAL PROTECTION PETROLEUM CONTAMINATION DECISION TREE

GRO DRO

Stringent (ST) 5 10

Remove all free product.Remove or remediate contaminated soil greater than 5 mg/kg GRO and 10 mg/kg DRO.Remediate groundwater containing greater than 50 ug/L GRO or DRO, 5 ug/L benzene, and 35 ug/L MTBE.

Intermediate (IN) 5 10Remove all free product.Remove or remediate contaminated soil greater than 5 mg/kg GRO and 10 mg/kg DRO.

Baseline 1 (BL1) NA NA Remove all free product.Remove or remediate soil saturated with gasoline, kerosene, or fuel oil.

Baseline 2 (BL2) 500 - 1,000 200 - 400Remove all free product.Remove or remediate contaminated soil to: 500 to 1,000 mg/kg GRO and 200 to 400 mg/kg DRO.

Notes:GRO - Gasoline Range OrganicsDRO - Diesel Range OrganicsMTBE - Methyl tert-butyl ether NA - No Applicable Standard

Soil Standards (mg/kg)Cleanup Level Cleanup Goals

Page 1 of 1

Table 5. CLEANUP STANDARDS FOR INSTALLATION RESTORATION PROGRAM SITES

Site DescriptionRelevant Admin

Record Documents

Dates of Operation Present Cleanup Standards Status Navy-Proposed Cleanup Standards Required Cleanup Standards for

Reuse Plan Will Navy Plan fulfill LRA Plan

1 Orion Street Landfill North 294 1955-1975 Restricted groundwater and soil Restricted groundwater and soil Unrestricted (Commercial

Standards)LUCs, including engineering controls, likely needed for landfills

2 Orion Street Landfill South 388 1945-1955 Restricted groundwater and soil Restricted groundwater and soil Unrestricted (Commercial

Standards)LUCs, including engineering controls, likely needed for landfills

3 Hazardous Waste Burial Area 294 1960-1973

4 Acid/Caustic Pit 387 1969-1974

Building 584 prevents "indirect or incidental ingestion" contact with contaminated soil beneath the foundation. Soil beneath building has not been sampled, it possibly exceeds Industrial standards.

No further action planned due to "no direct contact pathway."

Unrestricted (Commercial Standards)

No

5 Orion Street Asbestos Disposal Site 357 1979

Residential Residential Recreation Yes

6 Sandy Road Rubble and Asbestos Site 357 Unknown-1970s Residential Residential Recreation Yes

7 Old Acid/Caustic Pit 913 1952-1969

No soil standards established in ROD - soil may exceed industrial standards. Groundwater standards are Federal MCLs and State MEGs.

Industrial Mixed use (Residential Standards) No

8 Perimeter Road Disposal Area 358 1964-1974 Residential Residential Unrestricted (Commercial

Standards)Yes

9 Neptune Drive Disposal Area 935, 975 1943-1953

No soil standards established in ROD - soil exceeds industrial standards.

Ash Landfill Removal Work Plan states under Statement of Work, "ensure that cleanup standards have been attained for unrestricted reuse."

Mixed use (Residential Standards) No, unless unrestricted reuse goal of Work Plan is achieved and meets residential cleanup standards.

10 Harpswell Cove Fuel Depot ECP 1956-1991

11 Fire Training Area 387, ECP 1950s-1990Unknown - Soil removal/disposal in 1995 was not documented, further investigation is planned.

Unknown Unrestricted (Commercial Standards)

No

12 EOD Training Area ECP, SMP 1981-2004

Investigation planned. Unknown Recreation No

13 DRMO Area 387 1970s-1980s

Paved parking lot prevents "indirect or incidental ingestion" contact with contaminated soil beneath the pavement. Soil beneath pavement has not been sampled. Soil possibly exceeds industrial standards.

No further action planned due to "no direct contact pathway."

Unrestricted (Commercial Standards)

No

Transferred to DESC


Page 1 of 2

Table 5. CLEANUP STANDARDS FOR INSTALLATION RESTORATION PROGRAM SITES

Site DescriptionRelevant Admin

Record Documents

Dates of Operation Present Cleanup Standards Status Navy-Proposed Cleanup Standards Required Cleanup Standards for

Reuse Plan Will Navy Plan fulfill LRA Plan

14 Old Dump Number 3 701 Late 1940s

Industrial. Investigation did not reveal existence of site; likely removed during runway construction. Draft Consensus Statement recommends no further action.

Industrial Industrial Yes

15 Merriconeag Extension Debris Site 701 Unknown

Draft Consensus Statement recommends no further action. Previous removal action cleaned to residential standards, but EPA notes additional debris found during CERFA walkover and requires additional investigation.

Uncommitted to additional investigation.

Recreation No, additional investigation necessary to determine the present cleanup standards status.

16 Swampy Road Debris Site 701 Unknown

Draft Consensus Statement recommends no further action. Previous removal action cleaned to residential standards, but EPA notes additional debris found during CERFA walkover and requires additional investigation.

Uncommitted to additional investigation.

Recreation No, additional investigation necessary to determine the present cleanup standards status.

17 Building 95, Former Pesticides Shop 1955-1985

Exceeds industrial standards, investigation is ongoing.

Unknown, likely industrial.No ROD has been developed.

Mixed use (Residential Standards) No

18 West Runway Study Area 701 Unknown Draft Consensus Statement

recommends no further action. Industrial Industrial Yes

-- POL1: Old Navy Fuel Farm SMP 1943-1993

Report documenting 2000 soil removal action not included in admin record. Soil may be industrial or Residential.

Industrial Mixed use (Residential Standards) No

--POL2: Navy Exchange Service Station (NEX)

June Tech Mtg. Notes 1957-Present

Total Petroleum Hydrocarbons (Gasoline Range) - greater than 5,000 mg/kg.

Negotiated concentration (not risk-based) of Total Petroleum Hydrocarbons (Gasoline Range) - 500 mg/kg.

Mixed use (Residential Standards) No

-- Eastern Plume ECP, SMP -- Exceeds Drinking Water Standards Exceeds Drinking Water Standards Potable drinking waterNo

BTEX - Benzene, toluene, ethyl-benzene, xyleneCERFA - Community Environmental Response Facilitation Act DESC - Defense Energy Support CenterECP - Environmental Condition of Property ReportEPA - United States Environmental Protection AgencyLUC - Land Use ControlMEG - Maximum Exposure Guideline MCL - Maximum Contaminant Levelmg/kg - milligrams per kilogramROD - Record of DecisionSMP - Site Management Plan

Page 2 of 2

Table 6. ENVIRONMENTAL DATA GAPS AND CONSTRAINTS BY PROPOSED LAND USE DISTRICT

Planned Land Use District

• Potential glycol , petroleum hydrocarbon, metals, and solvent contamination from active operations such as maintenance, painting, repairs, laboratories, etc., in hangars.

• 2 Glycol USTs and a UST at the Hangar 5 have not been assessed.

•o Potential MEC, metals, explosives and perchlorate contamination from small arms

ammunition, practice grenades & pyrotechnics.o Area requires investigation.

o Removed from Active Site list in 2001; Draft Consensus Statement submitted and EPA responded to it with comments February 5, 2001. Final EPA-signed Consensus Statement (required for closure) cannot be located.

o Likely suitable for unrestricted reuse, but regulatory concurrence must be obtained for NFA with no ICs.


o Likely suitable for unrestricted reuse, but regulatory agency concurrence must be received for NFA with no ICs.

Professional Office •

o Elevated levels of petroleum hydrocarbons remain in site soils and groundwater.o Nature and extent of contamination not defined. •

o Remedy in place not appropriate for mixed use redevelopment.o Ethylene Glycol was stored onsite and leaks may lead to anaerobic degradation in the

subsurface, which can produce methane gas and present an explosive hazard.o LUCs need to be developed for soil; groundwater is close to meeting the present

MEGs.

o Lead may require additional assessment. • Truck Wash should be investigated for releases to the environment prior to redevelopment.

o May need further investigation to define downgradient extent of contamination.

o Selected remedy is Institutional Controls and LTM which is not appropriate for mixed use areas.

Other Potential Environmental Data Gaps/Constraints on Redevelopment

Aviation Related Business None identified

Airport Operations • Munitions Bunker West Deicing areas are commonly contaminated with ethylene and propylene glycol, either from storage areas, or directly spraying onto airplanes and dripping onto the ground. Ethylene and propylene glycols are not extremely toxic and have relatively high action levels, and degrade quickly in soils. However, anaerobic degradation of glycol produces methane, a gas that can be explosive at concentrations between 5 – 15 %. Methane can travel through areas of higher permeability such as utility trenches. The presence of methane needs to be investigated at the airport, deicing areas, and near glycol storage area.

Potential petroleum hydrocarbon, BTEX, and SVOC contamination from active Fuel Farm.

• Site 7: Old Acid/Caustic Pit.

• POL1: Old Navy Fuel Farm.

The active fuel farm may require relocation to the airport parcelsto remove from the area of mixed use and the new “Front Door” of the development. Investigation and remediation likely required in this area prior to redevelopment as mixed use facility. Additionally, if not relocated, set backs and buffer zoneswill be required around this active fuel facility, limiting developable property.

Known IRP/MMRP Site Data Gaps/Constraints on Redevelopment

• Site 14: Old Dump #3

• Site 18: West Runway Study Area

Page 1 of 12


Planned Land Use District Other Potential Environmental Data Gaps/Constraints on Redevelopment


o Remedy will require modification for site to be protective of Human Health and the Environment, including removal of contaminated soils.

o Soil piles adjacent to this site have been identified but have not been sampled for contaminants.

o Need to install 2 piezometers for quarterly groundwater elevation gauging to determine groundwater flow direction.

o Determine whether an additional remedy is needed to treat low pH groundwater.o Use those wells with existing wells to sample for dissolved-phase metal contamination

to delineate extent of groundwater plume.o Need to identify the area where the 260 cubic yards of excavated soil was spread

onsite and determine if that can be left in place pending the reuse scenario.o Amend ROD for soil contamination.o Develop LUCs and ICs.

•o Selected remedy is Institutional Controls and LTM which is not appropriate for mixed

use areas.o Remedy will require modification for site to be protective of Human Health and the

Environment, including removal of contaminated soils.•

o Soil piles adjacent to this site have been identified but have not been sampled for contaminants.

o Need to install 2 piezometers for quarterly groundwater elevation gauging to determine groundwater flow direction.

• Potential additional petroleum hydrocarbon contamination from active NEX Service Station.

o New monitoring wells need to be installed to replace the ones removed during the soil removal action.

•

o Use those wells with existing wells to sample for dissolved-phase metal contamination to delineate extent of groundwater plume.

o Need to identify the area where the 260 cubic yards of excavated soil was spread onsite and determine if that can be left in place pending the reuse scenario.

o Amend ROD for soil contamination. • o Develop LUCs and ICs.

o Nature and extent of contamination is not defined.o Navy is conducting additional investigation. • Oil/water separators have not been assessed.o ICs and existing LUCs not appropriate remedy for mixed use community. • 7 USTs have not been assessed.o Final remedy must be protective of human health and environment for intended reuse

as a mixed use community.• NEX active USTs may require a reassessment in this Planned

Land Use District.o Potential dioxin and PAH contamination from solvent incineration has not been

assessed at this site.o Diesel range organics have been detected and require characterization to the west.

Community Mixed Use

• Site 9: Neptune Drive Disposal Area.

Utility trenches can provide preferential flow pathways for contaminants released, such as methane gas or petroleum hydrocarbons from the NEX Service Station. These will require remediation if encountered during construction activities.

Potential petroleum hydrocarbon, metals, and solvent contamination from active Auto Equipment Repair Shops & Maintenance Buildings.

Abandoned utilities such as asbestos wrapped steam lines run throughout this area. In general, pipe wrapping is friable, and will require special handling and disposal if encountered during construction activities. If a release occurs, assessment of surrounding soils will be required for asbestos.

• Site 7: Old Acid/Caustic Pit. Methane assessment should be conducted via a soil gas survey prior to development in this area due to glycol storage areas.

Page 2 of 12




o 2, 3, or 7 wells (pending monitoring event) have been excluded from sampling in LTMP without regulatory approval.

o 3 Areas of the site (former incinerator location, reported disposal area behind Building 201, 2 streams/impoundment ponds) have not been adequately investigated to define the nature and extent of contamination.

o Ponds have detections of acetone and MEK, an intermittent sheen, a petroleum odor coming from the concrete control riser, and evidence of iron oxide staining (a characteristic of leachate); an investigation of this area needs to be performed.

o Building 201 is a potential source of the petroleum in groundwater; an investigation of the area needs to be performed.

o Discrepancy on the number of cubic yards of soil removed from the site (12,000 vs. 1,500 have both been reported).

o Source area for chlorinated solvents in groundwater has not been identified.o MEDEP has noted sampling SOPs have not been followed during soil/ash removal;

therefore results may not be representative of the conditions onsite.o Soil stockpiles 7 and 8 are classified as special waste and have been placed on top of a

hazardous waste soil stockpile with a plastic sheeting barrier separating them; MEDEP suspects the two piles may now be commingled and has stated all 3 piles must now be handled as hazardous waste until the Navy has proven otherwise.

o ROD requires revision to detail the ash removal activities.o Need to finalize/update LTMP and IC Boundary.o Implement direct push technology investigation of area south of Neptune Drive to

determine extent of ash landfill south of Neptune Drive.o Buildings in area should be assessed for indoor air quality.

o Extent of soil contamination needs to be defined.o Soil removal needs to be performed on soil moved to the south of the road during 1994 -

this area may require soil investigation sampling to delineate the target area.o May need to sample around dog kennel.o Need to perform an RI/FS.o ROD needs to be developed and site included in Federal Facilities Agreement.o Mixed use redevelopment must include remedy protective of residential reuse.

o Elevated levels of petroleum hydrocarbons remain in site soils and groundwater.o Nature and extent of contamination not defined.o Remedy in place not appropriate for mixed use redevelopment.o Ethylene Glycol was stored onsite and leaks may lead to anaerobic degradation in the

subsurface, which can produce methane gas and present an explosive hazard.

• Site 17: Building 95, Former Pesticide Shop

• POL1: Old Navy Fuel Farm.

Page 3 of 12




o LUCs need to be developed for soil; groundwater is close to meeting the present MEGs.

o Lead may require additional assessment.o May need further investigation to define downgradient extent of contamination.

o Source area remains and requires removal.o Existing LUCs and ICs not appropriate for mixed use redevelopment.o Potential impacts to utility corridors and trenches leading away from Site should be

assessed and remediated during utility upgrades.o In situ treatment consisting of Denitrification-Based Bioremediation (DBB) has not

produced data that shows significant decreases occurring in the source area within a reasonable timeframe.

o MEDEP has denied Navy's request for an expansion of the DBB program based on the current data and therefore an alternative remedy must be selected.

o The Corrective Action Plan outlines quarterly monitoring of 22 existing monitoring wells, but this data has not been provided. This data would help delineate the extent of the plume downgradient of the source.

o Downgradient extent of plume may not be well enough defined for development of an effective treatment.

o Navy, EPA, and MEDEP will likely revisit the remedial technology selected for this site and choose an alternate technology.

o Potential antimony, arsenic, nickel and lead azide contamination. o Area requires invesitgation.

•o Existing remedy of low permeability cap may not support intended reuse.o Existing Institutional Controls and Land Use Restrictions will require modification for

proposed land use.o Potential pesticide and metal contamination in surface water and fish of Mere Brook.o Leachate concentrations from landfills to Mere Brook are not decreasing and may

require additional remediation.• Potential PAH and metals contamination from former coal pile.

o Some wells were excluded from sampling via unapproved changes to Long Term Monitoring Plan (LTMP) (4-7 wells depending on monitoring event).

• Potential PCB contamination from electrical distribution building.

o Navy is not treating groundwater for arsenic, manganese, and 1,4-dioxane until after performing a background study (See Eastern Plume).

• Potential pesticide and herbicide contamination from storage areas and mixing areas

o Final land use controls (LUCs) will need to be developed.o Institutional Control (IC) checklist needs to be expanded to include construction

activities/ground disturbance within weapons compound.

• POL2: NEX Service Station

• Former Skeet Range.

Potential petroleum hydrocarbon, metals, SVOCs, and VOC contamination from Transportation Maintenance Building, paint and oil storehouse, paint locker, former garage, auto repair shops, and fire station.

• Site 1/3: Orion Street Landfill North/Hazardous Waste Burial Area . Business & Technology Industries

Page 4 of 12




o Boundaries of Site 3 may be improperly depicted on Navy maps and requires revisions. •

o Monitor landfill cap for subsidence.

• Oil/water separators not assessed.•

o Nature and extent of contamination not defined at area north of Site 2.

o Existing ICs, LUCs, and remedy of a soil cap may not be appropriate to protect human health to remove fence and allow passive recreation.

o Potential dioxins and PAHs from solvent incineration have not been investigated and should be incorporated into sampling plan for northern area, and LTMP for Site 2.

• The Weapons Compound Area is not in the MMRP program, and investigation and assessment has not begun in this area.

o 2 wells were excluded for sampling via unapproved changes to LTMP. • Need to understand scope and schedule for Weapons Compound Area investigations.

o

Current LUCs are for a restricted area; for reuse additional measures (i.e. redesigned cap, etc.) may need to be considered pending redevelopment plan and zoning use. Present cap is an earthen cover.

o During additional measure implementation, final LUCs will need to be developed.o Need to complete report on second round of fish tissue sampling in Mere Brook.o Need to install shallow wells and evaluate elevated turbidity in leachate samples.

o Ash from solid waste (which may have included chlorinated solvents) incineration may contain dioxins, which have not been analyzed for at this site.

o Conditional NFA and ICs not appropriate for reuse as Business and Technology Park if building 584 is demolished.

o Remedy must be re-evaluated for reuse.o Potential PCB contamination from transformer oil not evaluated during previous soil

investigation.o Indoor air assessment should be conducted.o Groundwater being evaluated with Eastern Plume (see data gaps associated with

Eastern Plume).

o Nature and extent of contamination is not defined.o Navy is conducting additional investigation.o ICs and existing LUCs not appropriate remedy for mixed use community.

Utility trenches can provide preferential flow pathways for contaminants released, such as methane gas or petroleum hydrocarbons from the NEX Service Station. These will require remediation if encountered during construction activities.

Abandoned utilities such as asbestos wrapped steam lines run throughout this area. In general, pipe wrapping is friable, and will require special handling and disposal if encountered during construction activities. If a release occurs, assessment of

• Site 9: Neptune Drive Disposal Area.

• Site 4: Acid/Caustic Pit.

• Site 2: Orion Street Landfill South.

Page 5 of 12




o Final remedy must be protective of human health and environment for intended reuse as a mixed use community.

o Potential dioxin and PAH contamination from solvent incineration has not been assessed at this site.

o Diesel range organics have been detected and require characterization to the west.

o 2, 3, or 7 wells (pending monitoring event) have been excluded from sampling in LTMP without regulatory approval.

o 3 Areas of the site (former incinerator location, reported disposal area behind Building 201, 2 streams/impoundment ponds) have not been adequately investigated to define the nature and extent of contamination.

o Ponds have detections of acetone and MEK, an intermittent sheen, a petroleum odor coming from the concrete control riser, and evidence of iron oxide staining (a characteristic of leachate); an investigation of this area needs to be performed.

o Building 201 is a potential source of the petroleum in groundwater; an investigation of the area needs to be performed.

o Discrepancy on the number of cubic yards of soil removed from the site (12,000 vs. 1,500 have both been reported).

o Source area for chlorinated solvents in groundwater has not been identified.o MEDEP has noted sampling SOPs have not been followed during soil/ash removal;

therefore results may not be representative of the conditions onsite.o Soil stockpiles 7 and 8 are classified as special waste and have been placed on top of a

hazardous waste soil stockpile with a plastic sheeting barrier separating them; MEDEP suspects the two piles may now be commingled and has stated all 3 piles must now be handled as hazardous waste until the Navy has proven otherwise.

o ROD requires revision to detail the ash removal activities.o Need to finalize/update LTMP and IC Boundary.o Need to finalize Draft Direct Push Technology investigation [2003/2004].o Need to install additional well in southwest corner of site.o Buildings in area should be assessed for indoor air quality.

o Removed from Active Site list in 1998; Conditional Soil NFA not protective for long-term when land use changes.

o Existing ICs and LUCs for this site are not appropriate for reuse as a business park. There is currently a no dig restriction.

o Potential dioxin and PAH contamination from solvent incineration has not been assessed for soils.

o Soil beneath water table may be contaminated.o Currently, an infiltration gallery is located over this site. Treated groundwater is

discharged to the infiltration gallery, and migrates through contaminated soils.

• Site 11: Fire Training Area.

Page 6 of 12




o Infiltration gallery may require relocation out of business park, or may require redesign to accommodate development.

o This area is still acknowledged as a source area for the Eastern Plume.o Groundwater from this site is included in the Eastern Plume site, and all the data gaps

for Eastern Plume are listed below.

o Removed from Active Site list in 1998; Soil NFA not protective for long-term if parking lot is demolished.

o Site is fully paved; if asphalt is removed, additional soil investigation and possibly remedial activities may be needed pending reuse scenario.

o Existing ICs and LUCs must be modified for intended land use. o Groundwater not being treated for 1,4-dioxane, arsenic, or manganese.o Human health exposure to VOCs migrating from the plume to indoor and outdoor air

must be evaluated to assess potential engineering controls that may be necessary for structures built over the plume.

o Navy is attempting to remove 1,4-dioxane from list of contaminants to treat. EPA rejected Navy's request for a new risk assessment and background study.

o 13-18 wells (depending on monitoring event) have been excluded from sampling in LTMP without approval of regulators.

o Need to define nature and extent of plume.o Offsite migration of plume may result in Natural Resource Damages Assessment o Need to finalize/issue updated LTMP and IC Boundaries.o Need to install 1 replacement extraction wells and optimize extraction well network.o Need to evaluate MNA data.o Need to optimize LTMP for hydraulic containment and mass removal. Treat for 1,4-

dioxane, arsenic, and manganese prior to discharge. New remedy may need to be considered.

o Need additional surface water sampling in Mere Brook to assess plume impacts. A soil/groundwater investigation of the Mere Brook area is planned for 2007.

o Need additional investigation near monitoring well MW-313.o Groundwater samples from MW-308 show contamination in the bedrock. Vertical

extent of contamination needs to be reassessed.o Need to complete groundwater model for Eastern Plume.

o Potential antimony, arsenic, nickel and lead azide contamination. o MMRP Sites require investigation

• Eastern Plume Site.


• Site 13: DRMO

Page 7 of 12




o Potential lead contamination. o Area requires investigation.

• Potential fuel oil contamination from generator buildingo Potential MEC, metals, explosives and perchlorate contamination from small arms

ammunition, practice grenades & pyrotechnics.•

o Area requires investigation

o Potential MEC, metals, explosives and perchlorate contamination from small arms o Area requires investigation due to reports of observed land spread TPH-contaminated

soil and of miscellaneous municipal trash.• Potential residual fuel oil contamination from heating oil

ASTs/USTs and ancillary lines.• Tanks removed but not documented.• Potential asbestos containing materials and lead based paints

in/on buildings.• Two auxillary generator USTs that have not been assessed for

o Existing ICs and LUCs will require modification to support reuse as golf course. • Eastern Plume may have migrated and contaminated the Picnic Ponds.

o Groundwater not being treated for 1,4-dioxane, arsenic, or manganese. • Potential pesticide & herbicide contamination from pesticide storage & mixing at former golf course.

o Eastern Plume and sitewide groundwater model required to assess migration and areas where groundwater restrictions should apply.

o Human health exposure to VOCs migrating from the plume to indoor and outdoor air must be evaluated to assess potential engineering controls that may be necessary for



o Need to define nature and extent of plume.o Offsite migration of plume may result in Natural Resource Damages Assessment o Need to finalize/issue updated LTMP and IC Boundaries.o Need to install 1 replacement extraction wells and optimize extraction well network.o Need to evaluate MNA data.o Need to optimize LTMP for hydraulic containment and mass removal. Treat for 1,4-o Need additional surface water sampling in Mere Brook to assess plume impacts. A

soil/groundwater investigation of the Mere Brook area is planned for 2007.o Need additional investigation near monitoring well MW-313.

Education

• Eastern Plume

• Southwest Old Quarry

• Munitions Bunker West.

Recreation / Open Space

Medical/dental building should be assessed for potential dental amalgams/metals, discharge to floor drains, or storage of other chemicals.

• Former Machine Gun Boresight Range.

None identifiedResidential

Page 8 of 12




o Groundwater samples from MW-308 show contamination in the bedrock. Vertical extent of contamination needs to be reassessed.

o Need to complete groundwater model for Eastern Plume.

o Removed from Active Site list in 1993; NFA with no ICs.o Area likely suitable for unrestricted reuse; however, recently the MEDEP has noted

area may require additional sampling and investigation for pesticides.o Requires agency coordination regarding additional sampling requirements.


o Signed document and regulatory concurrence required.o EPA notes additional debris was found during CERFA walkover and requests additional

investigation.o Additional investigation requirements due to debris must be coordinated with regulators.

o Potential antimony, arsenic, nickel and lead azide contamination. o MMRP Sites require investigation.

Natural Areas •o Potential Perchlorate and munitions and explosives of concern (MEC) contamination,

including potential for unexploded ordnance.o Need to perform MMRP: Supplemental Preliminary Assessment, Site Investigation,

Remedial Investigation/Feasibility Study (RI/FS), ROD.• Potential MEC/MC contamination due to presence of 22

weapons/magazine storage bunkers.o Evaluation of potential unexploded ordnance required prior to assessment of munitions

constituents.• The Restricted Weapons Complex is not in the MMRP program,

and investigation and assessment has not begun in this area.

• Need to understand scope and schedule for Restricted • Little to no information regarding past use, storage, and


o EPA notes additional debris was found during CERFA walkover and requests additional investigation.

• Site 12: EOD Area.

• Site 15: Merriconeag Extension Debris Site


Potential radiological contamination due to stored nuclear weapons.

• Site 5: Orion Street Asbestos Disposal Site

• Site 16: Swampy Road Debris Site

Page 9 of 12




o Asbestos containing debris was discovered during walkover. Asbestos regulations are continuing to evolve throughout the country with regard to ACM in soils. At a minimum, surface ACM will require removal and offsite disposal.

o Coordination and confirmation with regulatory agencies required for this site to confirm NFA with no ICs or additional investigation required for debris area. Additionally, the mechanism for removal and documentation for the ACM must be coordinated with the regulators.

o Existing ICs and LUCs must be modified for intended land use. o Groundwater not being treated for 1,4-dioxane, arsenic, or manganese.o Human health exposure to VOCs migrating from the plume to indoor and outdoor air

must be evaluated to assess potential engineering controls that may be necessary for structures built over the plume.



o Need to define nature and extent of plume.o Offsite migration of plume may result in Natural Resource Damages Assessment o Need to finalize/issue updated LTMP and IC Boundaries.o Need to install 1 replacement extraction wells and optimize extraction well network.o Need to evaluate MNA data.o Need to optimize LTMP for hydraulic containment and mass removal. Treat for 1,4-

dioxane, arsenic, and manganese prior to discharge. New remedy may need to be considerd.

o Need additional surface water sampling in Mere Brook to assess plume impacts. A soil/groundwater investigation of the Mere Brook area is planned for 2007.

o Need additional investigation near monitoring well MW-313.o Groundwater samples from MW-308 show contamination in the bedrock. Vertical

extent of contamination needs to be reassessed.o Need to complete groundwater model for Eastern Plume.

•o Possible petroleum releases from leaks along the length of the pipeline presents an

uninvestigated data gap.o If pipelines are removed, they will require special handling and disposal due to the

asbestos/tar coating. Additionally, if removed sampling for petroleum will also be needed.

• LUCIP needs to be developed and include non-CERCLA sites.

• Eastern Plume Site.

Sitewide or Multiple Parcels

Need to delineate the superfund sites (IC boundaries) to allow for deed restrictions/parcelization for specific areas.

• Site 10 Harpswell Fuel Pipeline

Page 10 of 12




• EPA/MEDEP requests groundwater management plan and site wide groundwater modeling. Presently the extent of groundwater contamination has not been defined for any of the sites and regulators consider all groundwater at base to be contaminated

• Unofficial groundwater use restriction site-wide problematic for remote areas of the site where public utilities are not in place, nor are planned. For example, the natural areas may require water for ranger stations or trail head facilities. If aquifer water cannot be used then cost prohibitive to install utilities.

• Groundwater use restriction areas can only be developed after a comprehensive site wide model, and a thorough understanding of plume size, migration, and interactions between surface water and groundwater is achieved.

• EPA/MEDEP request the agreements on remedies for soil contamination to be included for each site in the RODs, and that they be amended to make the restrictions legally enforceable.

• Site Management Plan needs to be revised to include the Additional Work Schedule of activities planned for NASB.

• Potential residual contamination from asbestos wrapped steam lines

• Potential residual petroleum hydrocarbon contamination from active, closed-in-place, and removed ASTs/USTs and ancillary piping

• Potential residual PCB contamination from transformers• Storm/sanitary combined sewers can contaminate sediments

within the lines and at discharge points. Sediments at outfall locations should be investigated.

• Asbestos wrapped steam lines will require special handling and disposal if encountered during construction

• Transite utility lines (asbestos material) will require special handling and disposal if encountered during construction.

• 24 oil/water separators are or have been in use at BNAS. Integrity testing and/or sampling should be conducted to evaluate potential releases from these Oil/Water separators.

• 138 active ASTs and 11 inactive ASTs require assessment of potential leaks

• 17 active USTs require assessment for potential leaks

Page 11 of 12




• 525 USTs were formerly on base and have not been assessed for contamination.

• It is unknown which buildings have or had building drains or drywells. Buildings with historical chemical use or storage should be assessed for releases from drains or dry wells, concurrently with soil and groundwater assessments.

• Radiological contamination possible throughout site.

Page 12 of 12

Table 7. EXISTING OIL WATER SEPARATORS

OWS Number Location Type Discharge Point Volume Source Description

1 Building 590 Steel Tank Sanitary 550 Floor Drains2 Building 553 Steel Tank Sanitary 1000 Floor Drains3 Hangar 6 - East Steel Tank Sanitary 1000 Interior Floor Drains4 Hangar 1 Orion St.Northside Concrete Manhole Sanitary 350 Interior Floor Drains5 Hangar 1 Orion St. Southside Concrete Manhole Sanitary 315 Interior Floor Drains

6 Bldg. 250 Orion St. Fiberglass Chamber with Storage Tank Sanitary 5000 Interior Floor Drains

7 Hangar 5 Orion St. Concrete Chamber Sanitary 5600 Interior Floor Drains8 Building 611 Test Cell Concrete Chamber Sanitary 1000 Interior Floor Drains9 Bldg. 555 Sonobouy Locker Steel Box in Floor Sanitary 150 Floor Drains10 Hangar 6 - West Steel Tank Sanitary 1000 Interior Floor Drains

11 Bldg. 660 Heavy Equipment Washrack Concrete Chamber Sanitary 550 Heavy Equipment Washrack

12 Bldg 211Boiler Room Steel Box in Floor Sanitary 270 Floor Drains13 Bldg 635 Seabee Compound Concrete Chamber Sanitary 150 Repair Bay Floor Drains

14 Bldg. 29 Hobby Shop Steel Box in Floor Sanitary 225 Repair Bay Floor Drains/Car Wash

15 Bldg 292 Fire Station Concrete Manhole Sanitary 400 Repair Bay Floor

Drains/Car Wash

16 Bldg. 23 Car Wash Modified Floor Trench Sanitary 63 Commercial Car Wash

17 Bldg. 23 Car Wash Modified Floor Trench Sanitary 63 Commercial Car Wash

18 JFSI Steel Tank Storm 5000 Tank Containment19 Bldg. 39 Steel Tank Storm 2000 Fuel/Maintenance Area20 Hangar 4 Concrete Tank Sanitary 7500 Floor Drains21 Taxiway “G” Washrack Concrete Chamber Storm 12000 Aircraft Rinse Facility

22 Bldg. 86 GSE Concrete Manhole Sanitary 675 Floor Drains from Repair Bays

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Table 8. EXISTING ABOVEGROUND STORAGE TANKS

Building Number Location Size

(Gallons) Contents Year of Installation

A5.0 HANGAR 5 SO 500 WASTE OIL 1996A5.1 HANGAR 5 SO 250 WASTE OIL 1996A5.2 HANGAR 5 NO 500 WASTE OIL 1996A5.3 HANGAR 5 NO 500 WASTE OIL 1996A5.4 HANGAR 5 NO 20000 #1 OIL 1999A5.5 HANGAR 5 NO 20000 #1 OIL 1999A5.6 HANGAR 5 EAST 1000 DIESEL 1999A5.7 HANGAR 5 EAST 100 DIESEL 2005A6.0 HANGAR SIX (I) 125 HYD OIL 2004A6.1 HANGAR SIX EAST 250 WASTE OIL 2004A6.2 HANGAR SIX EAST 500 WASTE OIL 2004A6.3 HANGAR SIX WEST 500 WASTE OIL 2005A6.4 HANGAR SIX WEST 250 WASTE OIL 2005A6.5 HANGAR SIX WEST 500 WASTE OIL 2005A6.6 HANGAR SIX WEST 250 WASTE OIL 2005A6.7 HANGAR SIX WEST 250 WASTE OIL 2005A9.0 VPU-1/OLD HSG OFFICE (I) 275 #1 OIL 1999A11.0 NEX 3000 #1 OIL 1999A11.1 NEX 250 COOKING GR 2002A19.1 PW (SHOPS) 275 #1 OIL 1999A19.2 PW (SHOPS) 275 #1 OIL 1999A20.0 N.H. COLL/HRO 3000 #1 OIL 1999A25.0 GYM 3000 #1 OIL 1995A27.0 FSC 1000 #1 OIL 1999A29.3 HOBBY SHOP 500 WASTE OIL 1996A29.4 H0BBY SHOP 2000 #1 OIL 1999A35.0 MAIN GATE 100 DIESEL 2004A36.0 DYERS GATE 100 DIESEL 2004A37.0 NIS OFFICE (I) 275 #1 OIL NKA39.1 GOLF COURSE (i) 275 OIL NKA39.2 GOLF COURSE 250 GASOLINE 1995A39.3 GOLF COURSE 250 DIESEL 1995A39.4 GOLF COURSE STORAGE 250 WASTE OIL 2001A45.1 HAZ WASTE STORAGE 1000 WASTE OIL 1996A45.2 HAZ WASTE STORAGE 1000 WASTE OIL 1996A45.3 HAZ WASTE STORAGE 500 #1 OIL 1999A45.4 HAZ WASTE STORAGE 250 WASTE OIL 2001A50.0 TREATMENT PLANT 2000 #1 OIL 1995A50.1 TREATMENT PLANT 138 DIESEL 1999A50.2 TREATMENT PLANT (EA) 100 DIESEL 1998A54.0 FASO 12000 #1 OIL 1996A55.0 SECURITY 250 #1 OIL 2006A57.0 AIRCRAFT BEACON LIGHT 100 DIESEL 2004A58.0 TACAN 100 DIESEL 2004A77.0 MAG AREA (V) 500 #1 OIL 1997A78.0 GOLF COURSE 500 #1 OIL 1995A81.0 HAZMAT STORAGE 2500 #1 OIL 1999A86.1 GSE (I) 70 LUBE/HYD 1992A86.10 GSE 250 WASTE OIL 1996A86.11 GSE 4000 #1 OIL 1999

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A86.12 GSE A/C DEICING FACILITY 90000 PROPYLENE GLYCOL 2001A86.2 GSE (I) 70 LUBE/HYD 1992A86.3 GSE (I) 70 LUBE/HYD 1992A86.4 GSE (I) 70 LUBE/HYD 1992A86.5 GSE (I) 70 LUBE/HYD 1992A86.6 GSE (I) 70 LUBE/HYD 1992A86.7 GSE (I) 70 LUBE/HYD 1992A86.8 GSE (I) 70 LUBE/HYD 1992A86.9 GSE 100 DIESEL 1992A000.1 DOSS REFUELLERS 250 #1 OIL 1996A153.0 RECYCLING BUILDING 550 #1 OIL 2004A153.1 RECYCLING BUILDING 550 #1 OIL 2004A153.3 RECYCLING BUILDING 250 WASTE OIL 2004A153.4 RECYCLING BUILDING 275 WASTE OIL 2004A200.0 AIROPS 550 DIESEL 1992A200.1 AIROPS 3000 #1 OIL 1999A201.0 NEW GALLEY 250 COOKING GR NKA201.3 NEW GALLEY 2000 #1 OIL 1999A201.4 NEW GALLEY 100 DIESEL 2006A209.0 RIGGERS SHOP (GEN) 550 DIESEL 1992A221.0 THRIFT SHOP (I) 275 #1 OIL 1999A227.0 ANT SITE #1 550 DIESEL 1990A229.1 GCA HARDSTAND 250 DIESEL 1996A231.0 NEW CONTROL TOWER 100 HYD OIL 2005A250.0 AIMD (PWR PLANTS) (I) 250 WASTE OIL 1993A250.1 BLDG 250 VR-62 250 WASTE OIL 1996A250.2 BLDG 250 VR-62 250 WASTE OIL 1996A250.3 BLDG 250 20000 #1 OIL 1999A250.4 BLDG 250 1000 DIESEL 2002A250.5 ADMIN ENTRANCE 125 HYD OIL 2001A292.1 FIRE DEPT (I) 200 DIESEL 1998A292.2 FIRE DEPT 2000 #1 OIL 1999A294.0 SUPPLY WAREHOUSE 6000 #1 OIL 1999A295.0 H2O PUMP HOUSE(I) 275 DIESEL NKA295.1 H20 PUMP HOUSE(I) 275 DIESEL NKA295.2 H20 PUMP HOUSE(I) 275 DIESEL NKA295.3 H20 PUMP HOUSE(I) 275 DIESEL NKA295.4 H20 PUMP HOUSE(I) 25 DIESEL NKA296.0 VORTAC (ANT) (GEN) 550 DIESEL 1992A512.1 BOQ 10000 #1 OIL 1998A516.1 NITEFLITE 6000 #1 OIL 1995A517.0 BOQ 125 HYD OIL NKA518.0 ANT SITE #2 550 DIESEL 1990A537.0 SEWAGE PUMP HSE 550 DIESEL 1990A538.0 NEX - SERVICE STATION 550 #1 OIL 1991A553.1 AIRFIELD SUPPORT BLDG 15000 POTASSIUM ACETATE 2006A554.0 P-3 SUPPORT FACILITY 100 DIESEL 2003A583.0 BOWLING ALLEY 250 COOKING GR NKA583.1 BOWLING ALLEY 2500 #1 OIL 1999A585.0 CHAPEL 1000 #1 OIL 1999

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A590.0 TRANS GARAGE 250 WASTE OIL 1996A590.1 PW TRANSPORTATION 60 LUBE OIL 2004A590.2 PW TRANSPORTATION 60 ATF 2004A590.3 PW TRANSPORTATION 60 WIND WASH 2004A590.4 PW TRANSPORTATION 60 ANTI-FREEZE 2004A590.5 PW TRANSPORTATION 60 SOAP 2004A590.6 PW TRANSPORTATION 60 EMPTY 2004A590.7 PW TRANSPORTATION 60 DIESEL 2004A590.8 PW TRANSPORTATION 60 ANTI-FREEZE 2004A594.0 ASWOC TOWER 4000 DIESEL 1996A594.1 ASWOC TOWER 4000 #1 OIL 1999A611.0 TEST CELL - T-56 Engine 1000 JP8 1967A611.1 TEST CELL 185 WASTE OIL 1994A611.3 TEST CELL-APU 100 JP8 UKA635.1 RNMCB-27 (I) 70 LUBE/HYD NKA635.14 RNMCB-27 250 WASTE OIL 1996A635.2 RNMCB-27 (I) 70 LUBE/HYD NKA635.3 RNMCB-27 (I) 70 LUBE/HYD NKA635.4 RNMCB-27 (I) 70 LUBE/HYD NKA635.5 RNMCB-27 (I) 70 LUBE/HYD NKA635.6 RNMCB-27 (I) 70 GLYCOL NKA644.1 OP TRAINER (I) 150 HYD OIL UKA644.2 OP TRAINER 6000 #1 OIL 1996A645.0 BRANCH CLINIC 550 DIESEL 1992A645.1 BRANCH CLINIC 2000 #1 OIL 1999A646.0 ASR-8 ANT SITE 550 DIESEL 1992A647.0 PEST CONTROL BLDG (I) 275 #1 OIL 1999A650.0 FUEL FARM 845000 JP8 1992A651.0 FUEL FARM 845000 JP8 1992A654.0 FUEL FARM (I) 250 DIESEL 1992A658.0 FUEL FARM MAINT (I) 330 #1 OIL 1997A658.1 FUEL FARM MAINT (I) 330 #1 OIL 1997A660.0 VEHICLE WASH RACK (I) 500 #1 OIL 1996A750.0 COMBINED BACHELOR QTR 100 DIESEL 2004AT1.0 AIRCRAFT ARRESTOR 10 GASOLINE NKAT1.1 AIRCRAFT ARRESTOR 300 ETHYLENE GLYCOL NKAT2.0 AIRCRAFT ARRESTOR 10 GASOLINE NKAT2.1 AIRCRAFT ARRESTOR 300 ETHYLENE GLYCOL NK

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Table 9. EXISTING UNDERGROUND STORAGE TANKS



5.0 (1) HANGAR FIVE (GEN) 1,000 DIESEL 1999

77.0 (1) WEAPONS MAGAZINE AREA 500 FUEL OIL # 1 199786.0 GSE (DE-ICE) 10,000 PROP GLYCOL 199386.1 GSE (DE-ICE) 10,000 PROP GLYCOL 1993117.5 FUEL FARM 20,000 NO-LEAD 1990117.6 FUEL FARM 20,000 NO-LEAD 1990117.7 FUEL FARM 10,000 DIESEL 1992211.4 FIELD HOUSE 20,000 FUEL OIL #1 1990211.5 FIELD HOUSE 20,000 FUEL OIL #1 1990

538.4 NEX GAS STATION 10,000UNLEADED PREMIUM 1993

538.5 NEX GAS STATION 10,000UNLEADED PREMIUM 1993

538.6 NEX GAS STATION 10,000 UNLEADED 1993

539.2WEAPONS MAGAZINE AREA (GEN) 2,000 DIESEL 1990

594.0 (1) ASWOC (GEN) 4,000 DIESEL 1996594.1 (1) ASWOC HEATING 4,000 FUEL OIL # 1 1999

642.1WEAPONS MAGAZINE AREA (GEN) 1,000 FUEL OIL #1 1992

654 JET FUEL FARM 3,000 JP8 1992

Notes:(1) Aboveground storage tank with underground piping and therefore require registration as underground storage tank.

1 of 1

FIGURES