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NEW ENGLAND OTHER:

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

MEMORANDUM

DATE: May 31, 2001

SUBJ: ACTION MEMORANDUM - Request for a Ceiling Increase for the Non-Time Critical Removal Action at

the Eastland Woolen Mill Superfund Site, Corinna, Maine

FROM: Edward M. Hathaway. Remedial Project Manager

ME/VT/CT Superfund Section

THRU: Don Berger, ChieC-p/

OSRR II Branch /I/

Dennisses Valdes. Chief -C/f

Emergency Planning and Response Branch

TO: uPatricia L. Meaney. Director

11 Office of Site Remediation and Restoration

(/

SiteID#01T6

I. PURPOSE

This Action Memorandum requests and documents your approval of a third 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 ceiling for the NTCRA will be

increased by $33,770,811 to $57,724,811 with this Action Memoranda.

The July 1999, June 2000 and September 2000 Action Memoranda 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 1999 Action Memorandum approved a removal ceiling of $9.7 million. Subsequently,

two ceiling increase Action Memoranda were approved in June and September 2000. The June

2000 and September 2000 ceiling increases were 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. This ceiling increase is based upon further

updated estimates of the volume of contaminated soil and actual bid costs of the activities.
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

As stated in the July 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

current and future users of groundwater at or near the Site, future users of the Site propert}. 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 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 the original information relating to the

removal site evaluation. Since the signing of the July 1999 Action Memorandum. EPA

has performed a significant portion of the work identified in the Action Memorandum.

The former mill buildings and all but one of the buildings along Main Street in downtown

Corinna have now been removed. A historic structure was re-located to avoid

destruction. A portion of the contaminated soil (22,000 cubic yards) has been removed

and the road detour/bridge and river diversion are under construction. In addition. EPA

will excavate the remaining areas of contaminated soil during 2001 as part of the funding

authorized by the September 2000 Action Memorandum. EPA has also completed the

majority of the remedial investigation for the site. The feasibility study for all of the areas
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

of concern not included in the NTCRA will be completed in 2001. These investigations

have further confirmed that the area subject to the NTCRA is the primary source of the

contamination at the site.

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 location of the former Eastland

Woolen Mill and serves as the outlet for Corrundel Lake. A second dam is located in a

position which was beneath the Eastland Woolen Mill when the Mill buildings were still

standing and serves as the outlet for the Mill Pond. This dam is scheduled for removal as

part of the 2001 NTCRA activities. 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.

3. Site Characteristics: See July 22, 1999 Action Memorandum for the site

characteristics that were the basis for the NTCRA. As stated above, the former

mill buildings as well as the other building along Main Street have now been

removed. A portion of the contaminated soil has been excavated and the road

detour/bridge and river diversion are under construction. The remedial

investigation field programs are nearing completion. The remedial investigation

has confirmed that the NTCRA has targeted the soils that represent the source of

the groundwater contamination.

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

release or threatened release information that were the basis for the NTCRA. The

partial completion of the removal has addressed the release and threatened release

from the contaminated soils within the areas subject to excavation in 2000. The

remedial investigations performed since the July 1999 Action Memorandum have

further confirmed that the contamination beneath the river, Main Street, and

former fill represent a substantial threat to groundwater
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

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. A figure of the areas subject to excavation in

2000 and 2001 as well as a figure showing the overall areas of activity for the

NTCRA are included as attachments to this Action Memorandum.

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 was completed in August 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 was performed in May/June

2000. Mobilization for the excavation activities occurred in June 2000. The five

additional structures along Main Street that were within the area of the Site work have

been removed. The relocation of the Odd Fellows building pursuant to the National

Historic Preservation Act was completed in November 2000. EPA removed

approximately 22.000 cubic yards of contaminated soil from beneath the East Branch of

the Sebasticook River as well as from several isolated locations on the Mill property.

Air monitoring has been performed to confirm that the ambient air is of acceptable

quality. EPA has also completed the installation of the new bridge and performing the

installation of the detour road to allow for the remaining excavation activities. The

NTCRA is expected to be completed by December 2003.

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 is also true for the $14.6 million

estimate that was presented in the June 2000 ceiling increase and the $23.3 million

estimate that was presented in the September 2000 ceiling increase. This ceiling increase

is based upon an number of factors:

(1) volumes of contaminated soil in excess of the first, second and third estimates have

been removed from the first two areas of excavation. The initial estimate for the first two

areas was 6,000 cubic yards of material. The actual volume excavated from the first two

areas is approximately 22,000 cubic yards of material. This additional material in areas

one and two plus the additional quantities of contaminated soil that are expected to be
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

removed in the remaining excavation areas increase the total quantity of contaminated

soil from an original estimate of 22,000 cubic yards to approximately 70.000 cubic yards.

The increased quantities of contaminated soil that are anticipated to be excavated during

2001 will result in an increase in this cost by approximately $2,000,000.

(2) the original cost for site preparation did not anticipate several of the costs that were

necessary to set up the site facilities, including decontamination areas, haul roads,

intensive traffic control, along with the cost of the removal of the additional structures. In

addition EPA has an on-site mobile laboratory with three gas chromatograms to monitor

the air, soil, and water quality during the NTCRA. The additional cost for the various site

management activities is $6,000,000 greater than originally anticipated.

(3) the cost for the road detour, new bridge, and river diversion has increased by

$1,000,000 as a result of the awarded amount as compared to the design cost estimate.

The majority of the increase relates to basic market factors, increased complexity due to

updating the existing configuration to current codes; and restoration requirements.

(4) the estimated cost for treatment has been increased by $13 million based upon the

additional volumes of soil and the possibility that a thermal desorption treatment unit will

likely be required as opposed to the soil pile thermal treatment that was the basis for the

original soil treatment cost estimate. The processing requirement (moisture content and

particle size) are much more substantial for the standard low temperature thermal

desorption approach. Both approaches are within the scope of the Action Memorandum.

The thermal piles become more challenging as the volume of soil increases since there

may not be sufficient space to allow for the treatment of all soil in 2001. The cost to

backfill all of the treated soil has also increased by $700.000 due to the increase in soil

volume.

The total amount of contractor related NTCRA costs above the September 2000 Action

Memorandum are $22.700,000. The net increase is approximately $21,000,000 as the

multi-phase extraction and in-situ treatment costs are not anticipated to be incurred within

the excavation area due to the technical infeasibility of these technologies. In addition, the

revised EPA indirect rate adds $12,279,000 in cost to the NTCRA.

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

Design/Work Plans

Building Demolition

Miscellaneous

Site Preparation/Site

Management

Soil Excavation

Area 1

Area 2

Area 3

Area 4

Area 5

River Diversion

Road Detour

8/1999

Estimated

Cost

$260,541

$115,200

S3,828,000

$80,200

$790,571*

No Cost

$168,198

No Cost

$325,900

$37,800

6/2000

Design Cost

Estimate

$1,338,730

$517,880

$3,635,600

$150,000

$1,250,000

$120,000

$110,000

$476,050

$500,000

$325,900

$400,000

9/2000

$1,339,000

$618,000

$3,750,000

$900,000

$1,250,000

$1,850,000

$500,000

5/2001

Estimate

$1,339,000

$918,000

$3,726,300

$7,396,200

$1,420,000

$2,868,400

$782,500

0

$600,000

Building Relocation

(Oddfellows)

On-Site Soil Treatment

Soil Screening/Washing

Pilot Scale

Full Scale

Backfill and Restoration

Soil Pre-Treatment

DNAPL Recovery

Multi-Phase Extraction

| In-Situ Treatment

Other Costs (PM, Con. S&A,

EDC)

$50,000

$55,700

$84,600

$728,730

$771,558

No Cost

No Cost

No Cost

$1,630,100

$325,000

$55,700

$84,600

$1,000,000

$771,558

$300,000

$500,000

$507,000

$56,000

$200,000

$3,500,000

$1,772,000

eliminated

$500,000

$1,200,000 | $1,200,000

$1,500,000 $1,600,000

$507,000

$1,286,250

$150,000

$14,291,000/

$2,421,200/

0

0

0

$2,500,000

Contingency (approx. 5%)

Incremental Funding

Adjustment

TOTAL:

$535,702 | 0 [

$9,700,000 $14,611,018 $23,354,000 $43,845,950
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 ceiling increase is based upon the same factors as the July 22. 1999

Action Memorandum. The draft final design activities have confirmed that substantial

concentrations of chlorobenzenes present in the soil and groundwater at the Site. The

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 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 ceiling for the NTCRA was increased to $15.4 million in June 2000 and to $23,954,000 in

the September 2000 Action Memo. This Action Memo will increase the ceiling to $57,724,811

(including EPA's indirect costs). The duration of the removal has been revised to an expected

time frame of 3-5 years. 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 1999. June 2000, and September 2000

Action Memoranda and this Action Memorandum, are otherwise appropriate and consistent

with the remedial action to be taken. The NTCRA activities 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 is

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 1999. June 2000, and September 2000

Action Memoranda)

The actions proposed in the July 1999, June 2000, and September 2000 Action

Memoranda remain the same.

2. Contribution to Remedial Performance

The NTCRA proposed in this document in combination with the July 1999, June 2000,

and September 2000 Action Memoranda 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 prhate

water supplies. The removal of the source of the contamination is entirely consistent \\ith

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.
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

B. Estimated Costs

Extramural Costs

Regional Allowance Costs $43.845,450

(Money from national cleanup fund with contingency)

Other extramural costs

CLP $1,000,000

State of Maine Cooperative Agreement $ 100,000

Extramural Direct Costs $44,945,450

Extramural Indirect Costs $12,144.261

Total Extramural $57,089.711

Intramural Cost

Intramural Direct $500,000

Intramural Indirect $135,100

Total Intramural $635,100

Total Estimated Removal Ceiling $57.724,811

Notes:

Existing Removal Projected Ceiling

based upon September 2000 Action Memorandum: $23,954,000

Additional Ceiling Increase requested: $33,770,811

10
ACTION MEMORANDUM FOR THE EASTLAND WOOLEN MILL SITE

VII. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED

OR NOT TAKEN

If the NTCRA is not completed, 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 water

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

NTCRA means that the source of the groundwater contamination has not been controlled. In

addition, without the additional funding requested under this ceiling increase, the contaminated

soil that will be excavated by the end of 2001 (approximately 70,000 cubic yards) will remain

on site until funding is available for the treatment of this material. The re-development and reuse of downtown Corinna cannot occur until the NTCRA is completed.

VIII. 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 $33,770,811. The total project ceiling

for the NTCRA, if approved, will be $57,724,811.

Approve Disapprove

L. Meaney, Director

/Office of Site Remediation and Restoration

11