MEMORANDUM

DATE:

BREAK: _

OTHfcR:

U.S. ENVIRONMENTAL PROTECTION AGENCY

REGION I

1 CONGRESS STREET, SUITE 1100, BOSTON, MA 02114-2023

June 20, 2000

Superfund Record^ Center

SITE: EqyitoM

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TO:

SUBJ: ACTION MEMORANDUM - Request for a ceiling increase for the Non-Time Critical Removal Action at

the Eastland Woolen Mill Superfund Site, Corinna^Maine

;x:

FROM: Edward M. Hathaway, Remedial Project Manager

ME/VT/CT Superfund Section

THRU: Don Berger, Chi

OSRRII Bran.

Richard Cavagnero, Chief

Emergency Planning and R 'anch

Patricia L. Meaney, Director

Office of Site Remediation and Restoration

Site ID# 01T6

I. PURPOSE

This Action Memorandum requests and documents your approval of a ceiling increase for the

non-time-critical removal action (NTCRA) described herein for the Eastland Woolen Mill

Superfund Site, located on Route 7 in Corinna, Maine.

The July 22, 1999 Action Memorandum approved a consistency exemption from the $2 million

and 12 month statutory limits on fund lead removal actions. The same basis for a statutory

exemption applies to this ceiling increase.

The July 22, 1999 Action Memorandum approved a removal ceiling of $9.7 million. Based upon

additional costs related to:(l) the increased volumes of contamination identified during the

NTCRA pre-design activities; (2) the need for extensive pretreatment of certain soils prior to

excavation; (3) the need for a pilot study involving in-situ pretreatment of certain soils prior to

excavation; (4) re-location of a building as required by the National Historic Preservation Act;

and (5) cost increases relating to actual cost estimates in comparison to the initial estimates.

As stated in the July 22, 1999 Action Memorandum, the overall objective of the NTCRA is to

eliminate the source of the soil, groundwater, and sediment contamination in order to protect
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

current and future users of groundwater at or near the Site, future users of the Site property, and

ecological receptors. In general terms, the NTCRA consists of the excavation of soils with

concentrations of monochlorobenzene, benzene, (1,2; 1,3; and 1,4) dichlorobenzene, and (1,2,3

and 1,2,4) trichlorobenzene above the soil cleanup levels established in the July 22, 1999 Action

Memorandum. This NTCRA will be performed by EPA using fund money as no PRP is available

to implement the response action in a timely manner. This Action Memorandum does not

include any activities that would require Post-Removal Site Control (PRSC).

This NTCRA will ensure that EPA can provide a timely response to effectively minimize threats

to public health or welfare or the environment which may result from the continuing release

and/or threat of release of hazardous substances at and from the Site, and is consistent with

EPA's Superfund Accelerated Cleanup Model (SACM).

II. SITE CONDITIONS AND BACKGROUND

A. Site Description

CERCLIS ID No.: MED980915474

Site ID. No.: 01T6

Category Non-time-critical

The Site includes the former Eastland Woolen Mill and the local areas contaminated by the

release of hazardous substances from the Eastland Woolen Mill. Eastland Woolen Mill was a

textile mill that began operation in approximately 1909. The Eastland Woolen Mill ceased

operation in 1996 and the majority of the Mill property is now owned by the Town of Corinna.

1. Removal Site Evaluation

See July 22, 1999 Action Memorandum for this information, except that the former mill

buildings have now been removed as part of the on-going EPA response action.

2. Physical Location

The Eastland Woolen Mill Site is located in the Town of Corinna, Penobscot County,

Maine. The Town of Corinna is located approximately 25 miles northwest of Bangor,

Maine. Approximately 800 persons live within 1 mile of the Site and 2,500 with 4 miles.

The Site was originally dominated by the 250,000 square foot Eastland Woolen Mill.

The former mill has been removed. Three dams are found in the vicinity of the Site. One

dam is approximately 500 feet north (upstream) of the Eastland Woolen Mill and serves
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

as the outlet for Corrundel Lake. A second dam is located beneath the Eastland Woolen

Mill and serves as the outlet for the Mill Pond. The third dam is located approximately

0.5 miles down river of the Eastland Woolen Mill.

The Site has been used as industrial property since at least 1912. The Eastland Woolen

Mill building may have been constructed as early as the late 1800's. The Eastland

Woolen Mill Company owned and operated the mill from 1936 until 1996. The company

assets were sold at a real estate foreclosure auction in 1997. In 1997, the Town of

Corinna took title to the parcel on which the majority of the Eastland Woolen Mill

buildings are located. The Eastland Woolen Mill and its associated side buildings are

currently abandoned.

3. Site Characteristics: See July 22, 1999 Action Memorandum for this information,

except that the former mill buildings have now been removed as part of the ongoing EPA response action.

4. Release or Threatened Release: See July 22,1999 Action Memorandum for this

information, except that the former mill buildings have now been removed as part

of the on-going EPA response action.

5. NPL Status: The Site was placed on the NPL in July 1999.

6. Maps, pictures, and other graphic representations: See July 22, 1999 Action

Memorandum for this information, except that the former mill buildings have now

been removed as part of the on-going EPA response action.

7. Current Status of NTCRA

The NTCRA was initiated with the signing of the Action Memorandum in July 1999.

During fall 1999, EPA began the design for the excavation and treatment activities and

the demolition of the former Eastland Woolen Mill. The Mill building demolition was

completed in May 2000. The design of the NTCRA is expected to be complete in June

2000. A pre-design effort to better define the extent of the contamination requiring

excavation was performed in fall 1999 and a second delineation program will be

performed in May/June 2000. Mobilization for the excavation activities should occur in

June 2000. The NTCRA is expected to be completed by December 2001.
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

8. Basis for Ceiling Increase

The initial $9.7 million dollar estimate for the NTCRA that was presented in the

Engineering Evaluation and Cost Analysis (EE/CA) and July 1999 Action Memorandum

was based upon the information known at the time and using EPA and US Army Corp

cost estimates for the work to be performed. This ceiling increase is based upon an

number of factors:

(1) an additional 10,000 cubic yards of material are estimated to require excavation and

treatment with an anticipated cost of $1.8 million. This increase is due to the detection of

additional contamination above cleanup levels beyond the railroad bridge as well as an

increase in the estimated volume within the original areas of contamination. The

complexity of the excavation has also increased as the depth of contamination in certain

areas approached 40 feet. Increased pre-design costs are due to an extensive boring

program to map the contamination with an anticipated additional cost of $1 million. A

comprehensive soil boring program was implemented in fall 1999 to delineate the areas

above cleanup levels. This data was then evaluated and incorporated into a data base that

was used to confirm that no additional contaminants of concern were present in the

excavation areas.

(2) pre-treatment of the soil to reduce water content and volatile emissions are estimated

to cost $0.8 million. Much of the contaminated soil is below the water table. Also,

DNAPL is present in a large area within one of the excavation areas. To reduce the

potential for DNAPL mobilization during excavation and to prevent the creation of an

ambient air hazard, a DNAPL recovery and vapor reduction pre-treatment program will

be implemented. Available DNAPL will be removed from the soil using pumps. The

water level in the soil will be lowered and a vapor extraction system will be employed to

remove the volatile fraction from the contaminated soil.

(3) a $1.2 million dollar cost to pilot test an in-situ treatment technology as part of the

design to determine if full scale implementation of this technology should be proposed to

the public. There is an area where the contamination is located in a narrow zone that is

beneath 25- 35 feet of clean soil. The cost to remove the clean soil has caused EPA to reevaluate the best cleanup approach for these soils. A pilot test for in-situ treatment would

use either a fenton like process or a potassium permanganate. An Action Memorandum

and public comment period would be required prior to full scale implementation of the

in-situ treatment. See table 1 for a line item comparison of the EE/C A and current design

cost estimates.
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

(4) Re-location of a building pursuant to the National Historic Preservation Act (NHPA).

One structure that is located within the area of excavation has been determined to be

eligible for the National Register of Historic Places. As required by the NHPA, EPA

must minimize the adverse impact on a historic property. To accomplish this, EPA will

re-locate this structure during excavation. The owner of the structure will own the land

upon which the structure will be placed. This will allow the structure to remain at this

location and reduce the costs to EPA by not requiring a second re-location.

(5) Costs have increase in a number of other items: (1) the highway bridge was originally

estimated at $237,000 and is now estimated at $550,000; (2) the road detour estimate has

increased from $250,000 to $400,000; and (3) the re-location of the historic building has

increased from $50,000 to $300,000. These new estimates are based upon draft final

design packages and preliminary contractor estimates and represents an additional

$713,000 in cost.

In addition, the complexity of the design will result in a $0.5 million increase in design

costs. The design will require the integration of multiple state, local, and federal agencies

to resolve issues regarding traffic flow, utilities, building demolition, river re-location and

restoration, and air quality. The result has been a much longer and more detailed design

than anticipated, and

While the costs have increased, all of the activities are consistent with the original scope

of the NTCRA. The additional volume is based upon a better understanding of the

contaminant distribution. The additional costs for the bridge, road, and relocation are

based upon the more specific estimate that can be prepared at the draft final design stage.

In addition, the complexity of this project has necessitated a significant increase in the

pre-design and design activities required to assure that the NTCRA will be implemented

in a manner that does not create unacceptable impacts to air quality, traffic flow, or utility

services.
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

NTCRA COST TABLE

Task Description

Pre-Design Investigations

Estimated

Cost

$260,541

Current

Cost

$1,338,730

Difference

$1,078,189

Design/Work Plans

Building Demolition

Site Preparation

Soil Excavation

Area 1

Area 2

Area 3

Area 4

Area 5

River Diversion

Road Detour

$115,200

$3,828,000

$80,200

$790,571*

No Cost

$168,198

No Cost

$325,900

$37,800

Bridge J $237,200

Building Relocation (Oddfellows) | $50,000

L $517,880

$3,635,600

$150,000

$1,250,000

$120,000

$110,000

$476,050**

$500,000

$325,900

$400,000

$550,000

$325,000

$402,680

($192,400)

$69,800

$459,571

$120,000

$110,000

$307,852

500,000

0

362,200

312,800 |

275,000

On-Site Soil Treatment

Soil Screening/Washing

Pilot Scale

Full Scale

$55,700

$84,600

$728,730

$55,700

$84,600

$1,000,000

0

0

271,270

Backfill and Restoration $771,558 | $771,5581 0

Soil Pre-Treatment

DNAPL Recovery

Multi-Phase Extraction

No Cost

No Cost

$300,000

$500,000

$300,000

$500,000

I In-Situ Treatment No Cost | $1,200,000| $1,200,000

Other Costs (PM, Con. S&A, EDC

ontmgency (approx. 5%)

TOTAL: $9,700,000 $14,611,018 $4,911,018

*Note that this cost includes Area 2, which was originally thought to be part of Area 1.

**Note that this cost includes removal of several chemical UST's associated with the mill that

were originally costed into the building demo task and represent roughly $150,000 of the

difference between the two costs.
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT.

AND STATUTORY AND REGULATORY AUTHORITIES

Section 300.415(b)(2) of the National Contingency Plan (NCP) lists a number of factors for EPA

to consider in determining whether a removal action is appropriate, including:

(i) Actual or potential exposure to nearby human populations, animals, or the food

chain from hazardous substances or pollutants or contaminants;

(ii) Actual or potential contamination of drinking water supplies or sensitive

ecosystems;

(iii) Hazardous substances or pollutants or contaminants in drums, barrels, tanks,

or other bulk storage containers, that may pose a threat of release;

(iv) High levels of hazardous substances or pollutants or contaminants in soils

largely at or near the surface, that may migrate;

(v) Weather conditions that may cause hazardous substances or pollutants or

contaminants to migrate or be released;

(vi) Threat of fire or explosion;

(vii) The availability of other appropriate federal or state response mechanisms to

respond to the release; and

(viii) Other situations or factors that may pose threats to public health or welfare

of the United States or the environment.

This Action Memorandum is based upon the same factors as the July 22, 1999 Action

Memorandum. The pre-design investigations have confirmed that substantial concentrations of

chlorobenzenes present in the soil and groundwater at the Site. This contamination is having an

impact on the ecological community and threatens local water supplies^
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

IV. ENDANGERMENT DETERMINATION

Actual or threatened releases of hazardous substances, pollutants, or contaminants, from this Site,

if not addressed by implementing the response action selected in this Action Memorandum, may

present an imminent and substantial endangerment to public health, or welfare, or the

environment.

V. EXEMPTION FROM STATUTORY LIMITS

This ceiling increase will require additional funding above the statutory ceiling of $2 million

dollars and may require more than 1 year to implement. As documented in the July 22, 1999

Action Memorandum, this NTCRA will require funding above the statutory ceiling of $2

million dollars and will require more than 1 year to implement. The July 22, 1999 Action

Memorandum projected costs of $9.7 million and a time frame of 18-24 months to complete.

The revised ceiling for the NTCRA will be $15 million with a projected time frame of 24 -30

months to complete. The same basis for the statutory requirements apply to this Action

Memorandum. This Action Memorandum re-affirms the finding that a "consistency" exemption

is appropriate in order to implement the NTCRA proposed in this Action Memorandum.

The proposed response action described in the July 22, 1999 Action Memorandum and this

Action Memorandum, are otherwise appropriate and consistent with the remedial action to be

taken. The NTCRA included in this Action Memorandum will remove the source of

contamination to the bedrock aquifer and the East Branch of the Sebasticook River. Excavation

and on-site treatment is a response action that would be consistent with the type of actions that

would be considered as part of the expected remedial response and do not preclude any future

remedial response that may be necessary.

The implementation of the NTCRA is necessary to prevent the further migration of the

contamination in the soils. Authorization is, therefore, hereby requested for a "consistency"

exemption to exceed the statutory limits of $2 million and 1 year on removal actions in order to

implement the NTCRA as described in this Action Memorandum.
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

VI. PROPOSED ACTIONS AND ESTIMATED COSTS

The following removal action objectives have been developed for the Site:

* Prevent, to the extent practicable, direct contact with and ingestion of surface and

subsurface soils that represent an unacceptable health risk;

* Prevent, to the extent practicable, the migration of chlorinated benzenes (and

other contaminants) in soils to the groundwater and surface water; and

* Prevent, to the extent practicable, the release of contamination believed to be

within the building to the environment through flooding and further degradation

of the structure from fire.

To meet the removal action objectives, EPA selected in the July 22, 1999 Action

Memorandum, a NTCRA to remove the source of the soil and groundwater

contamination. This alternative was referred to as Alternative 2 in the EE/CA. The scope

of the NTCRA has not significantly changed since the July 22, 1999 Action

Memorandum..

1. Proposed Action Description (See July 22, 1999 Action Memorandum)

The actions proposed in the July 22, 1999 Action Memorandum remain the same. However,

design activities conducted since July 22, 1999 have clarified some of the details of the actions

previously proposed:

(1) Excavation extent and volume: The excavation of contaminated soils is likely

to extend to the former Moosehead Mill complex. Pre-design activities have

identified additional contaminated above cleanup levels extending at least to the

former Moosehead Mill.

(2) Pretreatment of soils: Pre-excavation activities in the soil will include DNAPL

recovery, de-watering, and vapor recovery to decrease air emissions during

excavation. Water collected as part of the NTCRA will be treated and discharged

to the East Branch of the Sebasticook River.

(3)'In-situ Pilot: A full scale pilot of in-situ treatment technologies will be

implemented to determine if in-situ technologies are capable of treating the deep

contaminated soils to the cleanup levels.
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

(4) Additional pre-design work was required to evaluate the National Historic

Preservation Act requirements regarding the Odd Fellows building. A structure

determined to be eligible for listing on the National Register of Historic Places.

Also, additional design work regarding air emissions during excavation, water

treatment, DNAPL in the subsurface, and treatment options for deep soil

contamination were necessary to complete the design of the NTCRA.

(5) Surface Water Management: The surface water of the East Branch of the

Sebasticook River will be managed by re-locating the river to a new permanent

location. This decision was determined to be the most cost effective approach.

EPA will leave the re-location in place pursuant to the restoration requests of the

anticipated landowners of the parcels containing both the current and future

locations of the river (both are governmental entities, Town of Corinna and State

of Maine). The Mill Pond will cease to exist as a result of design requirement

regarding floodplain elevations and restoration of the exposed sections of Mill

Pond will also be part of the NTCRA.

(6) Traffic Management: The final location of the traffic detour that will re-route

traffic to allow for the excavation of Main Street has been established pursuant to

discussions between EPA, State of Maine, and the local community. EPA will

install the detour and after completion, the ME DOT will convert the detour into a

permanent re-alignment of the highway pursuant to the restoration requests of the

owners of the parcels containing both the current and future locations of Main

Street. The State of Maine has requested, and EPA agrees, that the replacement

of the Main Street bridge will occur along the detour and new road alignment.

2. Contribution to Remedial Performance

The NTCRA proposed in this document in combination with the July 22, 1999 Action

Memorandum is expected to contribute significantly to the long-term remedial action.

The remedial goal for this Site is to protect public health and the environment. More

specifically, the remedial response will seek to restore the Site to a condition that will

allow for future Site use and minimize any long term threats to the East Branch of the

Sebasticook River and the associated ecosystems and to protect private water supplies.

The removal of the source of the contamination is entirely consistent with all potential

future remedial responses.

The RI/FS is expected to identify any further cleanup actions necessary at the Site. Longterm groundwater restoration, downstream sediment contamination, and the former dump

for the Eastland Woolen Mill are all issues that will be addressed by the RI/FS.

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ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

B. Estimated Costs

Extramural Costs

Regional Allowance Costs $ 15,000,000

(Money from national cleanup fund with contingency)

Other extramural costs

CLP $80,000

State of Maine Cooperative Agreement $20,000

Sub-Total Extramural Costs $ 15,100,000

Total Extramural $ 15,100,000

Intramural Cost

Intramural Direct $50,000

Intramural Indirect $100,000

Total Intramural $ 150,000

Total Estimated Removal Ceiling $ 15,400,000

Original Removal Projected Ceiling

based upon July 22, 1999 Action Memorandum $9,700,000

Additional Ceiling Increase requested: $5,700,000

VII. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED

OR NOT TAKEN

If the NTCRA is not implemented, the contaminants will continue to leach from the soils into

the groundwater further contributing to the groundwater contamination and causing impacts to

the East Branch of the Sebasticook River. Some of the local water supplies that are not on the

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ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

water supply line have concentrations of chlorobenzenes that are increasing. Failure to

implement the NTCRA means that the source of the groundwater contamination has not

beencontrolled.

X. RECOMMENDATION

This decision document represents a ceiling increase and re-affirmation of the statutory basis

and consistency exemption for the selected removal action for the Eastland Woolen Mill

Superfund Site, in Corinna, Penobscot County, Maine, developed in accordance with CERCLA

as amended, and is not inconsistent with the NCP. This decision is based upon the

Administrative Record for the Site.

Conditions at the Site continue to meet the NCP criteria for a removal action as specified at 40

C.F.R. § 300.415(b)(2) and the CERCLA section 104(c) consistency exemption. I recommend

your approval of the proposed project ceiling increase of $5,700,000. The total project ceiling

for the NTCRA, if approved, will be $15,400,000. I also recommend and request your approval

of a "consistency" exemption to the statutory limits of $2 million and one year on removal

actions.

Approve Disapprove

Patricia L. Meaney, Director

Office of Site Remediation and Restoration

12