HRS DOCUMENTATION RECORD COVER SHEET

Name of Site: Leeds Metal

EPA ID No.: MEN000103584

Contact Persons

Site Investigation: Weston Solutions, Inc. (WESTON ® )/ (978) 552-2100 Superfund Technical Assessment and Response Team III (START)
3 Riverside Drive Andover, MA 01810 (Mr. Gerald A. Hornok and Mr. John F. Kelly)

Documentation Record: U.S. Environmental Protection Agency (617) 918-1436 (EPA) Region I 5 Post Office Square, Suite 100 Boston, MA 02109-3912 (Ms. Nancy Smith)

Pathways, Components, or Threats Not Scored

The surface water migration, soil exposure and air mi gration pathways were not scored in this HRS documentation record because the ground water pathway is sufficient to qualify the site for the National Priority List (NPL).

Surface Water Migration Pathway

Three HRS watersheds have been identified for the L eeds Metal property: a stream flowing northerly away from the Leeds Metal property; a stream flowing southerly away from the Leeds Metal property; and an isolated wetland on the northwestern portion of the Leeds Metal property. Sampling from these HRS
watersheds documented an Observed Release of metals to the on-property wetland.

Soil Exposure Pathway

Sampling has documented the presence of significant su rface soil contamination on the Leeds Metal property. However, there is no resident population, and no nearby residences are suspected to be contaminated by site

wastes.

Air Migration Pathway

To date, a release of hazardous substances to air from on-site sources has not been documented.

Leeds Metal HRS Documentation Record

MEN000103584 September 2011Leeds Metal 1 HRS Documentation Record

MEN000103584 R evised July 9, 2012 HRS DOCUMENTATION RECORD

N ame of Site: Leeds Metal Date Prepared: September 2011 Date Revised: July 9, 2012 EPA Region: Region I

Street Address of Site*: Off of Blue R ock Road

City, County, State, Zip Code: Leeds, An droscoggin County, Maine, 04263

General Location in the State: Southwestern Maine

Topographic Map: U.S. Geological Survey, Monmouth, Maine 7.5

- minute series Topographical Map. 1979 [7].

Latitude**: 44° 14 ′ 13.5 ′′ North

Longitude**: 70° 04 ′ 48.9 ′′ West

Scores

Air Pathway NS Ground Water Pathway 65.512 Soil Exposure Pathway NS Surface Water Pathway NS

HRS SITE SCORE 32.25

NS = Not Scored

* The street address, coordinates, and contaminant locations presented in this Hazard Ranking System ( HRS ) documentation record identify the general area the site is loc ated. They represent one or more locations U.S. Environmental Protection Agency ( EPA ) considers to be part of the site based on the screening information
EPA used to evaluate the site for Nati onal Priorities List ( NPL ) listing. EPA lists natio nal priorities among the
known “releases or threatened releases” of hazardous substances; thus, the focus is on the release, not pr ecisely
delineated boundaries. A site is defined as where a hazardous substance has been “deposited, stored, placed,

o r otherwise come to be located.” Generally, HRS scoring and the subsequent listing of a release merely represent the initial determination that a certain area may need to be addressed under Comprehensive
Envir onmental Response, Compensation , and Liability Act (CERCLA). Accordingly, EPA contemplates that the preliminary description of facility boundaries at the time of scoring will be refined as more information is developed as to where the contamination has come to be located.

** The geographic coordinates of the site were measured from its approximate center [ 4 , p. 1]. See Figure 2
for the location of the latit ude and longitude measurement point.S S 2

1. Ground Water Migration Pathway Score (S gw )

2. Surface Water Overland/Flood Migration Component 64.512 4161.798

(from Table 4-1, line 30)

3. Soil Exposure Pathway Score (S

s ) NS

--

(from Table 5-1, line 22)

4. Air Migration Pathway Score (S

a ) (from Table 6-1, line 12)

2 5. Total of S gw 2 + S

sw 2 + S

s 2 + S

a

6. HRS Site Score Divide the value on line 5 by 4 and take the square root NS

NS --

--

4161.798

32.25 WORKSHEET FOR COMPUTING HRS SITE SCORE

Leeds Metal 2 HRS Documentation Record

MEN000103584 Revised July 9, 2012HRS Table 3-1 – Ground Water Migration Pathway Scoresheet

Factor Categories and Factors Maximum

Value Value Assigned
Likelihood of Release to an Aquifer:

1. Observed Release 550 550

2. Potential to Release:

2a. Containment 10 NS 2b. Net Precipitation 10 NS 2c. Depth to Aquifer 5 NS

2d. Travel Time 35 NS 2e. Potential to Release [lines 2a x (2b + 2c + 2d)] 500 NS

3. Likelihood of Release (higher of lines 1 and 2e) 550 550

Waste Characteristics: 4. Toxicity/Mobility (a) 1,000 5. Hazardous Waste Quantity (a) 10,000

6. Waste Characteristics 100 56
Targets :
7. Nearest Well 50 50 8. Population:

8a. Level I Concentrations (b) 50

8b. Level II Concentrations (b) 12

8c. Potential Contamination (b) 60.8 8d. Population (lines 8a + 8b + 8c) (b) 122.8

9. Resources 5 NS

10. Wellhead Protection Area 20 NS 11. Targets (lines 7 + 8d + 9 + 10) (b) 172.8
Ground Water Migration Score For An Aquifer: 12. Aquifer Score [(lines 3 x 6 x 11)/82,500] (c) 100 64.512
Ground Water Migration Pathway Score:

13. Pathway Score (S gw ), (highest value from line 12 for all aquifers evaluated) c 100 64.512

(a) Maximum value applies to waste characteristics category. (b) Maximum value not applicable. (c) Do not round to nearest integer.

Leeds Metal 3 HRS Documentation Record

MEN000103584 September 2011ACRONYM/ABBREVIATION LIST

% Percent 1,1-DCE 1,1-Dichloroethene bgs Below Ground Surface

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of

1980
CERCLIS Comprehensive Environmental Response, Compensation, and Liability Information System Cis-1,2-DCE Cis-1,2-dichloroethene

CLP Contract Laboratory Program

Co. Company
COC Chain of Custody
Cm/s Centimeters per second CRQL Contract Required Quantitation Limit

DNAPL Dense Non-Aqueous Phase Liquid

DRO Diesel Range Organics

EPA U.S. Environmental Protection Agency

ERM Environmental Resource Management

GPS Global Positioning System

GRO Gasoline Range Organics

HAE Height Above Ellipsoid

HRS Hazardous Ranking System

ICP Inductively Coupled Plasma

MA Massachusetts

MCL Maximum Contaminant Level

MDL Method Detection Limit

ME Maine

ME DEP Maine Department of Environmental Protection

ME DHS Maine Department of Human Services

MEG Maximum Exposure Guidelines

MEK Methyl Ethyl Ketone μg/Kg Micrograms Per Kilogram μg/L Micrograms Per Liter mg/Kg Milligrams Per Kilogram mg/L Milligrams Per Liter

MTBE Methyl Tert-Butyl Ether

No. Number

NPL National Priorities List

OEME Office of Environmental Measurement and Evaluation

PCB Polychlorinated Biphenyl

PCE Tetrachloroethene

PID Photoionization Detector
Pine & Swallow Pine & Swallow Associates, Inc.

ppm Parts Per Million

PVC Poly Vinyl Chloride QAPP Quality Assurance Project Plan

RCRA Resource Conservation and Recovery Act

RL Reporting Limit
Roux Associates Roux Associates, Inc.

Leeds Metal 4 HRS Documentation Record

MEN000103584 September 2011ACRONYM/ABBREVIATION LIST

SCDM Superfund Chemical Data Matrix

SI Site Inspection

START Superfund Technical Assessment and Response Team III

SVOC Semivolatile Organic Compounds

TCE Trichloroethene

TPH Total Petroleum Hydrocarbons

Trans-DCE Trans-dichloroethene

USGS United States Geological Survey

VOA Volatile Organic Analytes

VOC Volatile Organic Compound

WESTON ® Weston Solutions, Inc.

XRF X-Ray Fluorescence
Yd 3 Cubic Yards

Leeds Metal 5 HRS Documentation Record

MEN000103584 September 2011

# I

0 1 0.5

Miles 0 1 0.5

Kilometers Leeds Metal property

Nearest Residence
Nearest Private Drinki ng Water Supply Well 1 Mile Radius

Maine Route 106 Blue Rock Road Plains Road

Figure 1

Leeds Metal Along Blue Rock Road Leeds, Maine Property Location Map

Leeds Metal

MEN000103584 10-03-0002

G. Hornok

16 August 2010 EPA Region I Superfund Technical Assessment and Response Team (START) III
Contract No. EP-W-05-042

TDD Number:

Created by:

Created on:

Modified by:

Modified on: Topos: MicroPath/USGS Quadrangle Name(s): Wayne and Monmouth, ME
All other data: START GPS Data Collected as part of EPA Site Inspection, References 14, 15, 16, and 17 Data Sources:

G. Hornok

13 July 2011



### 6 HRS Documentation Record September 2011!>!>!>!>!>!>!>Container Disposal AreaLagoonsProperty BoundaryDebris Pile BDebris Pile DDebris Pile CDebris Pile ABattery Drop AreaME Route 106Blue Rock RoadPondNearest Residence andPrivate Drinking Water Supply WellConcrete Disposal AreaAccess RoadConcrete Pad/BuildingERM-5SRailroad TracksERM-2S/2DERM-1S/1DERM-3S/3DERM-4S/4DExtent of OperationsRX-2SRX-3SOn-site WetlandFormer Operations Area(Leeds Metal Site Location)Figure 2Leeds MetalAlong Blue Rock RoadLeeds, MaineProperty Map10-03-0002G. Hornok16 August 2010EPA Region ISuperfund Technical Assessment andResponse Team (START) IIIContract No. EP-W-05-042TDD Number:Created by:Created on:Modified by:Modified on:G. Hornok13 July 20110 100 200 300 400 500 60050FeetILEGENDProperty!>Monitoring WellsAccess RoadFormer Operations AreaDrum Disposal AreaExtent of OperationsDebris PileContainer Disposal AreaConcrete Disposal AreaLagoonsBattery Drop AreaWetlandImagery: Me GIS Spring 2003 OrthoimageryAll other data: START GPS Data Collectedas part of EPA Site Inspection,References 14, 15, 16, and 17Data Sources:HRS Documentation RecordLeeds Metal7September 2011MEN000103584Figure 3aSS-01/SB-01SS-02/SB-02(Collected Northwest, see Figure 3b)SS-06Leeds MetalAlong Blue Rock RoadLeeds, MaineSurface and SubsurfaceSoil/Source SampleLocation MapSS-41EPA Region ISuperfund Technical Assessment andResponse Team (START) IIISS-08/SB-08Contract No. EP-W-05-042TDD Number:10-03-0002SS-09/SB-09Created by:G. Hornok"/"/"/"/"/"/"/"/"/"/"/"/SS-10/SB-10SS-52SS-15/SB-15SS-53SS-42/SB-42SS-16"/SS-35/SB-35SS-07SS-11/SB-11Created on:23 July 2010Modified by:G. HornokSS-12/SB-12Modified on:13 July 2011Concrete PadLEGENDSS-13/SB-13Soil/Source Sample"/SS-14/SB-14A"/Access Road"/"/"/SS-34/SB-34SS-50Debris PileSS-17/SB-17Extent of OperationsSS-32/SB-32"/B"/"/"/SS-18/SB-18Drum Disposal AreaCSS-33/SB-33"/"/"/Property BoundarySS-40/SB-40"/"/"/"/"/"/"/"/"/"/Former Operations AreaSS-19"/D"/"/"/"/"""///SS-37/SB-37SS-03SS-05/SS-43SS-39BDebris Pile DesignationSS-04I"/SS-27/SB-27/SS-36/SB-36SB-44SB-43SS-23SS-22/SS-25SS-38/SB-38SB-220 50 100 200 300 400FeetSS-24SS-26Data Sources:Imagery:Me GIS Spring 2003 OrthoimagerySS-21"/"/"/"/"/"/"/"/"/SS-20/SS-44All other data: START GPS Data Collectedas part of EPA Site Inspection,References 14, 15, 16, and 17"/DSS-31/SB-31"/SS-28/SB-28"/SS-30/SB-30SS-29/SB-29Leeds MetalMEN0001035848HRS Documentation RecordSeptember 2011"/SS-01/SB-01SS-02/SB-02AFigure 3bLeeds MetalAlong Blue Rock RoadLeeds, MaineBackground Surface andSubsurface SoilSample Location Map10-03-0002G. Hornok23 July 2010EPA Region ISuperfund Technical Assessment andResponse Team (START) IIIContract No. EP-W-05-042TDD Number:Created by:Created on:Modified by:Modified on:G. Hornok13 July 20110 100 200 300 40050FeetILEGEND"/Background SampleFormer Operations AreaProperty BoundaryExtent of OperationsAccess RoadDebris PileBDebris Pile DesignationImagery: Me GIS Spring 2003 OrthoimageryAll other data: START GPS Data Collectedas part of EPA Site Inspection,References 14, 15, 16, and 17Data Sources:Leeds MetalHRS Documentation Record9MEN000103584September2011!>!>!>!>!>!>!>GW-01 (ERM-5S)GW-06 (ERM-4S)GW-07/GW-10 (ERM-4D)GW-02 (ERM-2S)GW-03 (ERM-2D)GW-04 (ERM-1S)GW-05 (ERM-1D)GW-08 (ERM-3S)GW-09 (ERM-3D)GW-11 (RX-3S)GW-12 (RX-2S)Figure 4Leeds MetalAlong Blue Rock RoadLeeds, MaineGround Water SampleLocation Map10-03-0002G. Hornok19 October 2010EPA Region ISuperfund Technical Assessment andResponse Team (START) IIIContract No. EP-W-05-042TDD Number:Created by:Created on:Modified by:Modified on:D. Brammer13 July 201100.0625MilesILEGENDLeeds Metal Property!>Ground Water SampleGround Water monitoring wellcouplets represented by singlesymbol.'S' designates shallow ground watermonitoring well, while 'D' designatesthe accompanying deep well.Imagery: Me GIS Spring 2003 OrthoimageryAll other data: START GPS Data Collectedas part of EPA Site Inspection,References 14, 15, 16, and 17Data Sources:Leeds MetalHRS Documentation Record10MEN000103584September2011hghghghghghghghghghghghghghghghghghghghghghghghghghghghghgDW-03DW-01DW-02DW-05DW-06DW-09DW-10DW-18DW-12DW-13DW-14/DW-33DW-23DW-24DW-25DW-31DW-29DW-30DW-15/DW-34DW-16DW-11DW-19DW-27DW-26DW-28DW-20DW-22DW-21DW-08DW-04Figure 5Leeds MetalAlong Blue Rock RoadLeeds, MaineDrinking Water SampleLocation Map10-03-0002G. Hornok19 October 2010EPA Region ISuperfund Technical Assessment andResponse Team (START) IIIContract No. EP-W-05-042TDD Number:Created by:Created on:Modified by:Modified on:G. Hornok13 July 201100.250.125MilesILEGENDLeeds Metal PropertyhgDrinking Water SampleImagery: Me GIS Spring 2003 OrthoimageryAll other data: START GPS Data Collected aspart of EPA Site Inspection, Town of Leeds, METax Assessors Maps, References 14, 15, 16, and 17Data Sources:HRS Documentation RecordLeeds Metal11September2011MEN000103584

# I

0 1 2 3 0.5

Miles 0 1 2 3 4 5 0.5

Kilometers Leeds Metal property

4 Mile Radius

Maine Route 106 2 Mile Radius

Figure 6

Leeds Metal Along Blue Rock Road Leeds, Maine 4 Mile Target Distance Limit Map

Leeds Metal

MEN000103584 10-03-0002

G. Hornok

16 August 2010 EPA Region I Superfund Technical Assessment and Response Team (START) III
Contract No. EP-W-05-042

TDD Number:

Created by:

Created on:

Modified by:

Modified on: Topos: MicroPath/USGS Quadrangle Name(s): Wayne, Monmouth, Purgatory, Lake Auburn East, and Turner Center, ME All other data: START GPS Data Collected as part of EPA Site Inspection, References 14, 15, 16, and 17 Data Sources:

G. Hornok

13 July 2011



### 12 HRS Documentation Record September 2011REFERENCES

Ref.

No. Description of the Reference

[1] U.S. Environmental Protection Agency (EPA). 1990. Hazard Ranking System; Final Rule

, 40 CFR Part 300, Appendix A. The complete Hazard Ranking System; Final Rule is
available from http://www.epa.gov/superfund/sites/ npl/hrsres/index.htm#HRS%20 Rule . 14 December. Excerpt. 32 pages.

[2] U.S. Environmental Protection Agency (EPA). 2004. Superfund Chemical Data Matrix (SCDM). Available from http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm

. January. Excerpt. 107 pages.

[3] Reference Reserved.

[4] Hornok, G. Weston Solutions, Inc. 2010. Project Note, Leeds Metal, RE: Latitude/Longitude Calculations. TDD No. 09-05-0004. 25 January. 1 page.

[5] U.S. Environmental Protection Agency (EPA). 2011. Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) Superfund Program, Region 1, RE: Leeds Metal. Available from http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0103584 . Printout dated 3 March. 2 pages.

[6] Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START).

2010. Site Assessment Program Site-Specific Q uality Assurance Project Plan for Surface and Subsurface Soil/Source, Groundwater, Drinking Water, and Sediment Sampling , Leeds Metal, Site Inspection, Leeds, Maine. TDD No. 09-05-0004. 26 October. 104 pages.

[7] U.S. Geological Survey (USGS). 1979. Monmouth, Maine (7.5-minute series topographic map). 1 page.

[8] U.S. Geological Survey (USGS). 1966. Wayne, Maine (7.5-minute series topographic map). 1 page.

[9] James W. Sewall Company. 2009. Property Map Number 4, Town of Leeds, Androscoggin County, Maine. 1 April. 1 page.

[10] James W. Sewall Company. 2009. Property Map Number 1, Town of Leeds, Androscoggin County, Maine. 1 April. 1 page.

[11] Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START).

2011. Final Site Inspection Report for Leeds Metal , Leeds, Maine. TDD No. 09-05-0004. 19 August. 321 pages.

[12] Town of Leeds, Maine. 2010. Property Card for Map Number 4 Lot Number 38. 2 September. 2 pages.

Leeds Metal 13 HRS Documentation Record

MEN000103584 Revised July 9, 2012REFERENCES

Ref.

No. Description of the Reference

[13] U.S. Environmental Protection Agency (EPA). 2010. Consent for Access to Property Re: Leeds Metal property. 20 January. 1 page.

[14] Weston Solutions, Inc., Superfund Techni cal Assessment and Response Team III (START). 2010. Field Logbook for the Leeds Metal Combined Preliminary Assessment/Site Inspection Volume I. No. 01419-S. TDD No. 09-05-0004. 48 pages.

[15] Weston Solutions, Inc., Superfund Techni cal Assessment and Response Team III (START). 2011. Field Logbook for the Leeds Metal Combined Preliminary Assessment/Site Inspection Volume II. No. 01428-S. TDD No. 09-05-0004. 48 pages.

[16] Weston Solutions, Inc., Superfund Techni cal Assessment and Response Team III (START). 2011. Field Logbook for the Leeds Metal Combined Preliminary Assessment/Site Inspection Volume III. No. 01429-S. TDD No. 09-05-0004. 48 pages.

[17] Weston Solutions, Inc., Superfund Techni cal Assessment and Response Team III (START). 2011. Field Logbook for the Leeds Metal Combined Preliminary Assessment/Site Inspection Volume IV. No. 01430-S. TDD No. 09-05-0004. 12 pages.

[18] Harnish, D. (Assistant Attorney General, State of Maine). 2001. Notice of Potential Liability and Request for Participation in Cleanup Ac tivities and Request for Information Letter addressed to Harold Siagel. 23 April. 10 pages.

[19] Beneski, B. State of Maine, Department of Environmental Protection. 1998. Site Discovery Report for Leeds Metal, Leeds, Maine. 21 May. 63 pages.

[20] Barrows, J. Vice President, Bancroft & Ma rtin, Inc. 1999. Letter to Ms. Lynne Cayting, Maine Department of Environmental Protecti on, Re: Leeds Metal Scrapyard, Bancroft & Martin, Inc.’s Supplemental Response to Requ est for Information. 10 March. 21 pages.

[21] Roux Associates, Inc. 2004. Targeted Environmental Investigation, Northwest Portion of Guilford Rail Property, Blue Rock Road, Leeds, Maine . 17 June. 98 pages.

[22] Cogburn, P. Maine Department of Environmental Protection. 1983. Oil & Hazardous Materials Report Form, Spill Number P/10/83 . 15 pages.

[23] Maine Department of Environmental Protection. 1987. Oil & Hazardous Materials Report Form, Spill Number A/158/87 . 2 pages.

[24] Drobinski, J. Environmental Resources Management. 1999. Letter Report to Ms. Cynthia Scarano, Maine Central Railroad, Re: Results of Groundwater Sampling, Leeds Metal Site – Leeds, Maine. 2 March. 74 pages.

[25] Drobinski, J. Environmental Resources Management. 2000. Letter Report to Ms. Cynthia Scarano, Maine Central Railroad, Re: R esults of Monitoring Well Installation & Groundwater Sampling, Leeds Metal Site – Leeds, Maine. 20 January. 92 pages.

Leeds Metal 14 HRS Documentation Record

MEN000103584 September 2011REFERENCES

Ref.

No. Description of the Reference

[26] Cayting, L. 2000. Memorandum to the File, Subject: Interview with Francis Andre, Leed’s Former Fire Chief. 3 March. 1 page.

[27] Kirkpatrick, M. Maine Department of Environmental Protection. 2000. Leeds Metal Site, Designation of Uncontrolled Hazardous Subs tance Site. 28 September. 10 pages.

[28] Drobinski, J. Environmental Resources Management. 2001. Letter Report to Ms. Cynthia Scarano, Maine Central Railroad, Re: Nove mber 2000 Shallow Groundwater Investigation, Leeds Metal Site – Leeds, Maine. 27 March. 88 pages.

[29] Environmental Resources Management. 2006. Maine Central Railroad, Debris Pile Evaluation Report, Leeds, Maine . March. 350 pages.

[30] Beneski, B. Maine Department of Environmental Protection. 2008. Letter to Mrs. AmyJean McKeown, USEPA Region 1, Re: Leeds Meta l, Leeds, Maine. 23 January. 2 pages.

[31] Smith, T. Maine Department of Environmental Protection. 2009. Site Assessment and Support Services Trip Report, Leeds Metal, Leeds . 1 June. 15 pages.

[32] Weston Solutions, Inc., Superfund Techni cal Assessment and Response Team III (START).

2010. Removal Program Preliminary Assessment/S ite Investigation Report for the Leeds Metal Site, Leeds Androscoggin County, Maine, 1 June 2009 and 15 through 19 June 2009

. TDD No. 08-11-0003. February. 480 pages.

[33] Maine Department of Environmental Pr otection. 2009. Leeds Metal Residential Drinking Water Well SAP. June. 9 pages.

[34] Weston Solutions, Inc., Superfund Techni cal Assessment and Response Team III (START).

2011. Trip Report for the Leeds Metal Site Inspection, Leeds, Maine . TDD No. 09-05-0004. 18 March. 154 pages.

[35] Burton, J. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Letter to N. Smith (EPA Region 1 – New England), RE: Case No. 40791. SDG No. A3SS9. Leeds Metal Site. TDD No. 09-05-0004. 22 February. 80 pages.

[36] Burton, J. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Letter to N. Smith (EPA Region 1 – New England), RE: Case No. 40791. SDG No. A3ST4. Leeds Metal Site. TDD No. 09-05-0004. 16 February. 82 pages.

[37] Burton, J. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Letter to N. Smith (EPA Region 1 – New England), RE: Case No. 40791. SDG No. A3ST5. Leeds Metal Site. TDD No. 09-05-0004. 24 February. 68 pages.

[38] Burton, J. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Letter to N. Smith (EPA Region 1 – New England), RE: Case No. 40791. SDG No. A3ST6. Leeds Metal Site. TDD No. 09-05-0004. 16 February. 86 pages.

Leeds Metal 15 HRS Documentation Record

MEN000103584 September 2011REFERENCES

Ref.

No. Description of the Reference

[39] Burton, J. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Letter to N. Smith (EPA Region 1 – New England), RE: Case No. 40791. SDG No. A3SW8. Leeds Metal Site. TDD No. 09-05-0004. 21 February. 82 pages.

[40] Burton, J. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Letter to N. Smith (EPA Region 1 – New England), RE: Case No. 40791. SDG No. MA3SS9. Leeds Metal Site. TDD No. 09-05-0004. 3 February. 46 pages.

[41] Burton, J. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Letter to N. Smith (EPA Region 1 – New England), RE: Case No. 40791. SDG No. MA3ST4. Leeds Metal Site. TDD No. 09-05-0004. 17 February. 72 pages.

[42] Burton, J. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Letter to N. Smith (EPA Region 1 – New England), RE: Case No. 40791. SDG No. MA3ST5. Leeds Metal Site. TDD No. 09-05-0004. 21 February. 46 pages.

[43] Burton, J. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Letter to N. Smith (EPA Region 1 – New England), RE: Case No. 40791. SDG No. MA3ST6. Leeds Metal Site. TDD No. 09-05-0004. 8 February. 44 pages.

[44] Burton, J. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Letter to N. Smith (EPA Region 1 – New England), RE: Case No. 40791. SDG No. MA3SW8. Leeds Metal Site. TDD No. 09-05-0004. 17 February. 49 pages.

[45] Burton, J. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2010. Letter to N. Smith (EPA Region 1 – New England), RE: Case No. 40791. SDG No. A3T23. Leeds Metal Site. TDD No. 09-05-0004. 23 December. 53 pages.

[46] Burton, J. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2010. Letter to N. Smith (EPA Region 1 – New England), RE: Case No. 40791. SDG No. A3T24. Leeds Metal Site. TDD No. 09-05-0004. 30 December. 54 pages.

[47] Burton, J. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2010. Letter to N. Smith (EPA Region 1 – New England), RE: Case No. 40791. SDG No. A3T26. Leeds Metal Site. TDD No. 09-05-0004. 30 December. 76 pages.

[48] Reference Reserved.

[49] U.S. Department of Health and Human Serv ices, Public Health Serv ice, Agency for Toxic Substances and Disease Registry. 1997. Toxicological Profile for Tetrachloroethylene

. September. 318 pages.

[50] U.S. Department of Health and Human Serv ices, Public Health Serv ice, Agency for Toxic Substances and Disease Registry. 1997. Toxicological Profile for Trichloroethylene

. September. 335 pages.

Leeds Metal 16 HRS Documentation Record

MEN000103584 September 2011REFERENCES

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[51] Parsons Corporation. 2004. Final Principles and Practices of Enhanced Anaerobic Bioremediation of Chlorinated Solvents . August. Excerpt from Section 1, Section 2. 457

pages.

[52] Trains Magazine. 2011. Pan Am Railways merger family tree. Available at http://trn.trains.com/en/sitecore/content/Hom e/Railroad%20Reference/Railroad%20History/ 2006/06/Pan%20Am%20Railways%20merger%20family%20tree.aspx . Internet accessed 18 March. 1 page.

[53] Brammer, D. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Project Note, Leeds Metal, RE: Adjusted Values for PCB Data, Case 40791; SDG A3SS9. TDD No. 10-03-0002. 16 March. 132 pages.

[54] Brammer, D. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Project Note, Leeds Metal, RE: Adjusted Values for PCB Data, Case 40791; SDG A3ST4. TDD No. 10-03-0002. 16 March. 134 pages.

[55] Brammer, D. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Project Note, Leeds Metal, RE: Adjusted Values for PCB Data, Case 40791; SDG A3ST5. TDD No. 10-03-0002. 11 March. 138 pages.

[56] Brammer, D. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Project Note, Leeds Metal, RE: Adjusted Values for PCB Data, Case 40791; SDG A3ST6. TDD No. 10-03-0002. 16 March. 138 pages.

[57] Brammer, D. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Project Note, Leeds Metal, RE: Adjusted Values for PCB Data, Case 40791; SDG A3SW8. TDD No. 10-03-0002. 16 March. 144 pages.

[58] Brammer, D. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Project Note, Leeds Metal, RE: Adjusted Values for Total Metals Data, Case 40791; SDG MA3SS9. 15 March. TDD No. 10-03-0002. 104 pages.

[59] Brammer, D. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Project Note, Leeds Metal, RE: Adjusted Values for Total Metals Data, Case 40791; SDG MA3ST4. TDD No. 10-03-0002. 15 March. 129 pages.

[60] Brammer, D. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Project Note, Leeds Metal, RE: Adjusted Values for Total Metals Data, Case 40791; SDG MA3ST5. TDD No. 10-03-0002. 14 March. 118 pages.

[61] Brammer, D. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Project Note, Leeds Metal, RE: Adjusted Values for Total Metals Data, Case 40791; SDG MA3ST6. TDD No. 10-03-0002. 14 March. 110 pages.

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[97] Reference Reserved.

[98] Reference Reserved.

[99] Reference Reserved.

[100] Reference Reserved.

[101] Reference Reserved.

[102] Reference Reserved.

Leeds Metal 20 HRS Documentation Record

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[103] U.S. Environmental Protection Agency Contract Laboratory Program. 2005. Statement of Work for Organic Analysis, Multi-Media, Multi- Concentration, SOM01.1. May. 130 pages.

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[113] U.S. Environmental Protection Agency. 1996. Using Qualified Data to Document an
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[114] Hornok, G. Weston Solutions, Inc., Superfund Technical Assessment and Res ponse Team III (START). 2011. Phone Conversation Record, Re: Well Information for Town of Leeds, ME Tax Assessor’s Map No. 4, Lot No. 46. 11 February. 1 page.

[115] Leeds. 2010. Property Card for Map Number 1 Lot Number 67-1. 2 September. 2 pages.

[116] U.S. Environmental Protection Agency. 2010. Consent for Access to Property, 4 Youngs Drive, Lot #1. 26 September. 4 pages.

[117] Hornok, G. Weston Solutions, Inc., Superfund Technical Assessment and Res ponse Team III (START). 2011. Phone Conversation Record, Re: Well Information for Town of Leeds, ME Tax Assessor’s Map No. 1, Lot No. 67-1. 23 February. 1 page.

Leeds Metal 21 HRS Documentation Record

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[118] Leeds. 2010. Property Card for Map Number 1 Lot Number 67-A. 2 September. 2 pages.

[119] Hornok, G. Weston Solutions, Inc., Superfund Technical Assessment and Res ponse Team III (START). 2011. Phone Conversation Record, Re: Well Information for Town of Leeds, ME Tax Assessor’s Map No. 1, Lot No. 67-A. 11 February. 1 page.

[120] Leeds. 2010. Property Card for Map Number 1 Lot Number 58-7. 2 September. 2 pages.

[121] U.S. Envi ronmental Protection Agency. 2010. Consent for Access to Property, 91 Route 106, Leeds, ME, Block/Lot 58/7. 3 September. 2 pages.

[122] Hornok, G. Weston Solutions, Inc., Superfund Technical Assessment and Res ponse Team III (START). 2011. Phone Conversation Record, Re: Well Information for Town of Leeds, ME Tax Assessor’s Map No. 1, Lot No. 58-7. 15 February. 1 page.

[123] Leeds. 2010. Property Card for Map Number 1 Lot Number 58-5. 2 September. 2 pages.

[124] U.S. Envi ronmental Protection Agency. 2010. Consent for Access to Property, 83 Route 106, Leeds, ME, Block/Lot 5. 14 September. 4 pages.

[125] Leeds. 2010. Property Card for Map Number 1 Lot Number 63. 2 September. 2 pages.

[126] U.S. Envi ronmental Protection Agency. 2010. Consent for Access to Property, 66 Route 106, Leeds, ME. 4 September. 4 pages.

[127] Hornok, G. Weston Solutions, Inc., Superfund Technical Assessment and Res ponse Team III (START). 2011. Phone Conversation Record, Re: Well Information for Town of Leeds, ME Tax Assessor’s Map No. 1, Lot No. 63. 11 February. 1 page.

[128] Leeds. 2010. Property Card for Map Number 1 Lot Number 63-2. 2 September. 2 pages.

[129] Hornok, G. Weston Solutions, Inc., Superfund Technical Assessment and Res ponse Team III (START). 2011. Phone Conversation Record, Re: Well Information for Town of Leeds, ME Tax Assessor’s Map No. 1, Lot No. 63-2. 14 February. 1 page.

[130] Leeds. 2010. Property Card for Map Number 1 Lot Number 63-1. 2 September. 2 pages.

[131] Hornok, G. Weston Solutions, Inc., Superfund Technical Assessment and Res ponse Team III (START). 2011. Phone Conversation Record, Re: Well Information for Town of Leeds, ME Tax Assessor’s Map No. 1, Lot No. 63-1. 11 February. 1 page.

[132] Affordable Well Drilling. 2010. Invoice for drilled well at 52 Route 106. 27 October. 1 page.

[133] Hornok, G. Weston Solutions, Inc. 2011. Project Note, Leeds Metal Site, RE: Source Area Calculations. TDD No. 10-03-0002. 11 July. 1 page.

[134] Reference Reserved.

Leeds Metal 22 HRS Documentation Record

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[135] Howatt, K. (Maine Department of E nvironmental Protection). 2011. Email correspondence with Gerald Hornok, Re: Leeds. 2 0 June . 1 page.

[136] Hamilton, P.A. (Eaton, Peabody, Bradford & Veague, P.A., Attorneys at Law). 2000. Letter to Ms. Lynne Cayting, Environmental Specia list, Maine Department of Environmental Protection, Re: Leeds Metal/Maine Ce ntral Railroad. 3 March. 5 pages.

[137] Hamilton, P.A. (Eaton, Peabody, Bradford & Veague, P.A., Attorneys at Law). 1999. Letter to Ms. Lynne Cayting, Environmental Specia list, Maine Department of Environmental Protection, Re: Maine Central Railroad/Leeds. 18 May. 7 pages.

[138] Maine Department of Environmental Pr otection, Bureau of Remediation and Waste Management. 2010. Maine Remedial Action Guidelines (RAGs) for Soil Contaminated with Hazardous Substances. 13 January. 24 pages.

[139] U.S. Environmental Protection Agency (EPA). 2009. National Primary Drinking Water Regulations. May. 6 pages.

[140] Maine CDC (Center for Disease Control and Prevention). 2010. Maximum Exposure Guidelines (MEGs) for Drinking Water. 14 December. 6 pages.

[141] Smith, T. Maine Department of Environmental Protection, Division of Technical Services.

2000. Memorandum Re: Review Comments on Ja nuary 20, 2000 report on the Results of Monitoring Well Installation and Groundwater Sa mpling, Leeds Metal Site, Leeds, Maine. Submitted by ERM for MCRR. 31 January. 6 pages.

[142] Smith, T. Maine Department of Environmental Protection, Division of Technical Services.

2001. Memorandum Re: Review Comments on November 2000 Shallow Groundwater Investigation, Leeds Metal Site, Leeds, Ma ine. Submitted by ERM on March, 27, 2001. 21 March. 6 pages.

[143] Lambert, T. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III (START). 2011. Project Note, Leeds Metal Hazard Ranking System Project File, RE: Adjusted Values for VOC Data, Case 40791; SDG A3ST6. TDD No. 09-05-0004. 21 March. 162 pages.

[144] Hornok, G. Weston Solutions, Inc. 2011. Project Note, Leeds Metal, RE: Private Drinking Water Supply Well Depth to Bedrock. TDD No. 10-03-0002. 24 March. 2 pages.

[145] U.S. Envir onmental Protection Agency (EPA). 2004. Site Characterization Technologies for DNAPL Investigations Office of Solid Waste and EPA 542-R-04-017 Emergency Response (5102G) September 2004

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[146] U.S. Department of Health and Human Services, Agency for Toxic Substances and Disease Registry. 1997. Tetrachloroethylene, CA S # 127-18-4. September. 2 pages.

[147] U.S. Department of Health and Human Services, Agency for Toxic Substances and Disease Registry. 2003. Trichloroethylene, CAS # 79-01-6. July. 2 pages.

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[148] Washoe County Department of Water Resources Water Service. 2011. Central Truckee

Meadows Remediation District: What is PCE? Available at www.co.washoe.nv.us/water/PCE_background.htm

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[149] Environment Agency. 2003. An illustrate d handbook of DNAPL transport and fate in the subsurface. June. 67 pages.

[150] U.S. Geological Survey (USGS). 1980. Purgatory, Maine (7.5-minute series topographic map). 1 page.

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[152] U.S. Geological Survey (USGS). 1967. Turner Center, Maine (7.5-minute series t opographic map). 1 page.

[153] Hornok, G. Weston Solutions, Inc. 2011. Project Note, Leeds Metal, RE: Ground Water and Drinking Water Form Is. TDD No. 10-03-0002. 15 July. 33 pages.

[154] Hornok, G. Weston Solutions, Inc. 2011. Project Note, Leeds Metal, RE: Private Drinking Water Supply Well Elevation. TDD No. 10-03-0002. 13 July. 1 page.

[155] Hornok, G. Weston Solutions, Inc. 2011. Project Note, Leeds Metal, RE: Groundwater Well Elevation. TDD No. 10-03-0002. 13 July. 1 page.

[156] U.S. Department of Health and Human Services. 2011. Household Products Database: Auto Products excerpt Available at http://householdproducts.nlm.nih.gov/index.htm . 15 July. 7

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[157] Hornok, G. Weston Solutions, Inc. 2011. Project Note, Leeds Metal, RE: Reference 73 Crosswalk/Key. TDD No. 10-03-0002. 18 July. 1 page.

[158] Hornok, G. Weston Solutions, Inc. 2011. Project Note, Leeds Metal, RE: Potential

Residential Sources of PCE and/or TC E. TDD No. 10-03-0002. 19 July. 1 page.

[159] U.S. Environmental Protection Agency (EPA). 2011. Resource Conservation and Recovery Act Information (RCRAInfo) database RE: Leeds, ME. Available from http://www.epa.gov/enviro/facts/rcrainfo/search.html . Printout dated 19 July. 2 pages.

[160] U.S. Environmental Protection Agency (EPA). 2011. Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) Superfund Program, Region 1, RE: Leeds, ME. Available from http://cumulis.epa.gov/supercpad/cursites/csitinfo.cfm?id=0103584 . Printout dated 18 July. 2 pages.

[161] Maine Department of Environmental Protection, Bureau of Remediation & Waste Management. 2011. Hazardous & Oil Spill System, Re: Leeds, ME and Monmouth, ME.

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[162] Jones, J.M. 2005. RCRA Corrective Action, Safety-Kleen Systems, Inc., 86 Highway 202 Leeds, ME, MED 980 667 810. 30 September. 16 pages.

[163] Smith, T. Maine Department of Environmental Protection, Division of Technical Services. 2011. Memorandum Re: Water Supply Sampling U pdate, Leeds Metals, Leeds. 7 April. 5

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[164] Hornok, G. Weston Solutions, Inc. 2011. Phone Conversation Record, Re: Clarification of 7 April 2011 Memorandum. 26 July. 1 page.

[165] Smith, T. Maine Department of Environmental Protection, Division of Technical Services. 2011. Memorandum Re: May 17, 2011, Letter Correspondence, RE: Leeds Metal Site, Leeds, ME, prepared by Environmental Resources Management. 19 May. 7 pages.

[166] Wang Engineering, Inc. 1987. Hydrogeological Assessment of the Leeds Service Center, Safety-Kleen Corporation, Leeds, Maine. 9 September. 147 pages.

[167] Wang Engineering, Inc. 1989. Report, Co mprehensive Hydrogeological Study at SafetyKleen Corp Service Center, Leeds, Maine. 4 April. 230 pages.

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[170] Barton & Loguidice, P.C. 1999. Quarterly Groundwater Sampling Results, Safety-Kleen Leeds, Maine Service Center, Hazardous Fac ility License No. 0-28-95-A-N, Leeds, Maine. December. 109 pages.

[171] Barton & Loguidice, P.C. 2000. Quarterly Groundwater Sampling Results, Safety-Kleen Leeds, Maine Service Center, Hazardous Fac ility License No. 0-28-95-A-N, Leeds, Maine. December. 25 pages.

[172] Messmer, M., Barton & Loguidice. 2007. Letter RE: Safety-Kleen, Leeds, Maine Service Center Off-Site Groundwater Sampling Letter St amped Transmittal. 2 March. 63 pages.

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[174] Ekedahl, J. Woodward & Curran. 2011. Hazardous Waste Closure Certification of SafetyKleen Service Center, Leeds, Maine, Volume 1. January. 2,560 pages.

[175] Maine Department of Environmental Protection. 2004. Board Order In the Matter of SafetyKleen Systems Inc., Leeds, Androscoggin County, Maine. 5 February. 68 pages.

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[176] U.S. Environmental Protection Agency (EPA). 2012. Superfund Chemical Data Matrix (SCDM) – Interim Report for Trichloroethylene (TCE), Appendix A. Available from http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm

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[177] U.S. Environmental Protection Agency (EPA). 2012. Superfund Chemical Data Matrix (SCDM). Available from http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm

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[178] U.S. Environmental Protection Agency (EPA). 2012 Methodology for Determining Chemical and Physical Properties Factor Valu es and Screening Concentration Benchmarks for Volatile Substances Listed in the U.S. EPA’s Superfund Chemical Data Matrix . Available
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[179] U.S. Environmental Protection Agency (EPA). 2012. SUBSET of SCDM Volatile Substances and Corresponding Factor Values and Supporting Data. . Available from http://www.epa.gov/superfund/sites/npl/hrsres/t ools/volatile-substances-factor-values.pdf. 31 March. 8 pages.

[180] Hornok, G. and Kelly, J. Weston Solutions, Inc. 2012. Project Note, Re: Summary of
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Leeds Metal 2 5a HRS Documentation Record

MEN000103584 Revised July 9, 2012SITE SUMMARY – Leeds Metal

The Leeds Metal property is located along Blue Rock Ro ad in Leeds, Androscoggi n County, Maine (ME) [5,

p. 1]. The geographic coordinates of the property, as measured from its approximate center, are 44° 14 ′ 13.5 ′′

north latitude and 70° 04 ′ 48.9 ′′ west longitude (see Figure 1) [4, p. 1; 7]. The Leeds Metal property is depicted on the Town of Leeds Tax Assessor’s Map Number (No.) 4, as Lot No. 38 [9; 12, p. 1]. According

to the Town of Leeds Tax Assessor’ s records, the 36-acre property is currently owned by Maine Central Railroad Guilford Transportation Industries, Inc., which was rebranded under the name of Pan AM Railways in March 2006 [9; 12, p. 1; 13; 18, pp. 1-3; 52]. Acco rding to information compiled by the State of Maine, from approximately 1969 to 1984, scrap metal recovery processes were conducted on the property by various entities [18, pp. 1-2; 19, p. 1, Figure 2]. In addition, available file information indicates that cast concrete manufacturing and disposal took place on the northwest ern portion of the property, and on an adjacent property, during a period from approximately 1956 through the 1990s [20, pp. 2-3; 21, pp. 3-4].

The Leeds Metal site consists of five sources [f our pile sources (Debris Piles A through D) and one contaminated soil source (Former Operations Area)], wh ich were documented and sampled as part of the 2010 EPA Site Inspection (SI), and are located on the centr al-southeastern portion of the property (see Figure 2) [see Source Characterization sections of this HRS Docu mentation Record]. These on-site sources have been documented to contain one volatile organic compound (VOC) [tetrachloroethene (PCE)], two polychlorinated biphenyls (PCBs) (Aroclor-1254 and Aroc lor-1260), and three total metals (arsenic, chromium, and lead) [see

Source Characterization sections of this HRS Documenta tion Record]. As part of this HRS Documentation Record, a release of PCE from on-site sources to ground water monitoring wells located on the property has been documented [see Ground Water Migration Pathway sec tion of this HRS Documentation Record]. In addition, a release of PCE, and its breakdown product tr ichloroethene (TCE), to downgradient residential drinking water supply wells was docum ented in seven drinking water wells affecting 17 residents [see Ground Water Migration Pathway section of th is HRS Documentation Record].

Prior to 1969, the Leeds Metal property, then known as Libby’s Pit, was mined for sand and gravel [18, p. 1]. According to records summarized by a lawyer representing Maine Central Railroad, National Metal Converters, Inc. leased the Leeds Metal property in 1969, to conduct a metal shredding operation at the property [136, pp. 1-2; 137, pp. 1-7]. In addition, in a 1968 internal letter between railroad employees, Saco Steel Company (Co.) (believed by the lawyer representi ng the railroad to be the predecessor of National Metal Converters, Inc.) proposed the use of a machine known as a ‘fragmentizer’ to demolish junked cars [136, pp. 1-2]. The material would then be separated into ferrous and non-ferrous ma terial, and the non-ferrous

material would be discarded as waste suitable to be used as fill material [136, pp. 1-2]. A newspaper article published in April 1970 stated that operations at the L eeds Metal property had recently been initiated [136, p. 4]. In February 1976, National Metal Converters, In c. sought and obtained consent from the railroad to transfer their 10-year lease at the Leeds Metal property to Michael Schiavone & Sons, Inc. [136, pp. 2, 4].

Available records indicate that Michael Schiavone & Sons, Inc. operated an automobile shredding plant on the property until 1978 [18, p. 2]. From 1978 to 1980, Lucas Salvage Company operated a scrap metal recovery facility as a tenant of Michael Schiavone & Sons , Inc. [18, p. 2]. In 1980, Leeds Metal acquired the assets of Michael Schiavone & Sons, Inc., and operated a scrap metal recovery operation on the property until 1982 [18, p. 2]. Available file information indicates that the last operations on the Leeds Metal property were conducted by a private individual, who operated a scrap metal recovery facility on the property for a portion of 1984 [18, p. 2].

On 2 June 1983, Maine Department of Environmen tal Protection (ME DEP) personnel responded to a complaint of a leaking transformer at the Leeds Metal property (Spill No. P-10-83) [22, pp. 1-3]. ME DEP personnel performed a reconnaissance of the property, noting the presence of five transformers and 27 drums, some of which were leaking [22, p. 3]. In addition, as part of the investigation, ME DEP personnel collected

Leeds Metal 26 HRS Documentation Record

MEN000103584 September 2011two soil samples, one from around a leaking transformer and one from around leaking drums, which were submitted to the ME DEP Laboratory Services section for P CB analysis [22, pp. 3, 9-10]. Analytical results of the soil samples indicated the presence of two PCBs (Aroclor-1248 and Aroclor-1260) in both of the soil samples [22, pp. 9-10].

On 30 June 1983, in response to Sp ill No. P-10-83, ME DEP personnel mobilized to the Leeds Metal property to collect 13 drum samples, and one sludge sample from a lagoon located on the property [22, pp. 3-4, 6, 11­ 14]. Analytical results of the 13 drum samples did not indicate the presence of PCBs above the analytical detection limit of 50 milligrams per kilogram (mg/Kg) following a 100-fold dilution [22, pp. 11-12]. Analytical results of the sludge sample indicated the presence of Aroclor-1260 at an estimated concentration of 3.6 mg/Kg [22, pp. 13-14].

On 30 April 1987, ME DEP personnel responded to a repor t of abandoned drums at the Leeds Metal property (Spill No. A/158/87) [23, pp. 1-2]. The ME DEP i nvestigator, who was also involved in the June 1983 complaint, indicated that the drums on the property had not been disposed of, although the property owner had stated that the drum disposal had been complete d [23, pp. 1-2]. In response to Spill No. A/158/87, the property owner contracted Seacoast Ocean Services to remove 1,045 gallons of drum contents as well as an additional 19 drums from the property [23, pp. 1-2].

On 21 May 1998, ME DEP completed a Site Discovery fo r the Leeds Metal property [19, pp. 1-3]. On 24 October 1997, as part of the Site Discovery, ME DEP personnel collected 15 surface soil samples (sampling interval of 2 to 8 inches below the soil surface) to de termine if a release of hazardous substances to soils had occurred [19, p. 2, Figures 2 and 3]. The 15 soil sam ples were collected from the following locations on the property: near the suspected loading dock and incinerator; near a foundation of a bu ilding located adjacent to the railroad tracks on the southeastern portion of the pr operty; in the wooded area located on the southern portion of the property; and an area of drainage into the pond on the property [19, p. 2, Figures 2 and 3]. ME DEP personnel determined the sampling locations based on analysis of aerial photographs taken when metal reclamation activities were conducted on the propert y, as well as on conditions during the October 1997 sampling event [19, p. 2]. The soil samples were subm itted to the Maine Department of Human Services (ME DHS) Health and Environmental Testing Laboratory for PCB, Resource Conservation and Recovery Act (RCRA) 8 metals, and Fuel Oil analyses [19, Appendix A (pp. 1-3, 8-23)]. PCB analytical results of the surface soil samples indicated the presence of two PCB Aroclors, Aroclor-1248 and -1260, above laboratory reporting limits (RLs) [19, p. 3, A ppendix A (pp. 8-21)]. Each of the RCRA 8 metals, including arsenic, cadmium, chromium, and lead was detected above laborator y RLs [19, p. 3, Appendix A (pp. 4-7)]. Fuel Oil analysis indicated the samples contained diesel range organics (DRO) and total petroleum hydrocarbons (TPH) [19, p. 3, Appendix A (pp. 24-53)].

On 16 and 17 September 1998, Environmental Resources Management (ERM), on behalf of Maine Central Railroad, installed 11 temporary ground water monitori ng wells at various locations throughout the Leeds Metal property [24, pp. 1-2, 7, 11]. Temporary gr ound water monitoring wells were installed, based on consultation with ME DEP, to evaluate ground wate r flow direction beneath the property as well as ground water quality in relation to documented soil contamin ation [24, pp. 2-3]. The temporary ground water monitoring wells were installed to a maximum depth of 28 feet below ground surface (bgs) using a directpush system, and were allowed to equilibrate prior to depth sounding [24, p. 2]. The ground water elevation survey performed on the installed wells indicated th at the depth to ground water on the property ranged from between 5.5 and 22.0 feet bgs, and that ground water fl ow beneath the property was generally from north to south [24, pp. 3, 12]. In addition, on 16 and 17 September 1998, 11 ground water samples were collected from the temporary ground water monitoring wells, after stagnant water was purged [24, pp. 2-3, 13-14]. The ground water samples were collected in laboratory-prepar ed containers and shipped to Alpha Analytical Laboratories for VOC, PCB, total RCRA 8 metals, and TPH analyses [24, p. 3]. Analytical results of the

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MEN000103584 September 2011ground water samples indicated the presence of one VOC (PCE) above method detection limits (MDLs), at concentrations of 0.27 milligrams per Liter (mg/L) in sample MW-8 and 0.13 mg/L in sample MW-9 [24, pp. 4, 11, 16-48]. These two temporary monitoring wells were located along the sout heastern property boundary [24, p. 12]. Analytical results of the ground water samples also indicated the presence of four RCRA 8 metals, including arsenic, chromium, and lead, at con centrations above MDLs [24, pp. 4, 11, 16-48].

On 1 through 3 November 1999, on beha lf of Maine Central Railroad, ER M installed nine overburden ground water monitoring wells on the Leeds Metal property [25, pp. 2-3, 12]. Eight of the ground water monitoring wells (ERM-1S, ERM-1D, ERM-2S, ERM-2D, ERM-3S , ERM-3D, ERM-4S, and ERM-4D) were installed as shallow and deep couplets on the southern portion of the Leeds Metal property [25, pp. 2-3, 12]. One ground water monitoring well (ERM-5S) was installed on the central portion of the Leeds Metal property [25, pp. 2-3, 12]. The shallow ground water monitoring wells (ERM-1S, ERM-2S, ERM-3S, ERM-4S, and ERM5S) were installed to a maximum depth of 22 feet bgs, with 10-foot slotted well screens set at the bottom of the wells to intersect the ground water table [25, pp. 2-3, 12, 14-26]. The deep overburden ground water monitoring wells (ERM-1D, ERM-2D, ERM-3D, and ERM-4D ) were installed to a maximum depth of 47 feet bgs, with 5-foot slotted well screens set at the bottom of the wells [25, pp. 2-3, 12, 14-26]. On 18 November 1999, ERM conducted a ground water elevation survey of the newly installed wells, and noted that ground water in the shallow overburden was predominately fro m the southeast to the northwest across the property [25, pp. 3-5, 13]. On 18 and 19 November 1999, ERM collected 10 ground water samples, including one field duplicate, from the nine wells installed on the pr operty [25, pp. 3-4, 12, 27-28, 43]. The ground water samples were collected using low-flow techniques, and were submitted to Alpha Analytical Laboratories for VOC analysis by Method 8260 and dissolved and total RCRA 8 metals analysis by Method 3015; and were submitted to the Binax+nel laboratory for DRO analysis by Maine Method 4.1.25 [25, pp. 3-4, 12, 27-28, 43]. Analytical results of the ground water samples indicated the presence of two VOCs, 1,1,1-trichloroethane and PCE, above laboratory RLs, at concentrations of 2. 6 micrograms per liter (μg/L) and 140 μg/L, respectively [25, pp. 6, 11-12, 44-77]. One dissolved RCRA 8 metal (barium) and one total RCRA 8 metal (barium) were detected in ground water samples above the laboratory RLs [25, pp. 6, 11-12, 44-76].

Due to ground water sampling results from the previous investigations, which indicated the presence of chlorinated solvents in ground water on the Leeds Me tal property, ME DEP initiated an inventory of downgradient local drinking water supply wells in anticipation of collecting drinking water samples [135]. Between February 2000 and December 2005, ME DEP personnel collected drinking water samples from residential drinking water supply wells located south a nd southwest of the Leeds Metal property [135]. The drinking water samples were submitted to the State of Maine Health and Environmental Testing Laboratory for VOC analysis [135]. Analytical results of the ME DEP drinking water samples collected during this time period indicated the presence of several VOCs above MD Ls, including cis-1,2-dichloroethene (cis-1,2-DCE), PCE, and TCE [135]. None of the VOCs detected in ME DEP drinking water samples were detected at concentrations above ME DEP Maximum Exposure Guidelines (MEGs) or EPA Maximum Contaminant Levels (MCLs) for drinking water [135; 139; 140].

On 2 March 2000, as part of the investigation of past industrial practices at the Leeds Metal property, ME DEP personnel interviewed the former assistant fire chie f of the Town of Leeds, ME, who stated that cars were transported to the property via truck for “shredding” [26]. He also stated that within a cement building on the property, lead batteries and other auto parts were cleaned for resale [26]. The former assistant fire

chief stated that metal from the shredded cars was salvaged (sent off the property via railroad), while upholstery was piled in former gravel excavation pits [26] . He also stated that such materials as “gasoline, diesel, transformer oil, brake fluid, oils, battery acid, and antifreeze” were dumped on the ground and that approximately 100 “barrels” were staged along the southe rn property boundary [26]. The former assistant fire chief recalled that the Leeds and Monmouth Fire Depart ments responded to fires at the property, and that gasoline tanks would ignite and cause oil-saturated soil to burn [26].

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MEN000103584 September 2011On 28 September 2000, ME DEP designated the L eeds Metal property as an Uncontrolled Hazardous Substance Site based on previous investigati ons and known operational hi story [27, pp. 1-10].

From 27 through 29 November 2000, on behalf of Maine Central Railroa d, ERM oversaw a shallow ground water investigation at the Leeds Metal property, whic h was completed by Pine & Swallow Associates, Inc. (Pine & Swallow) [28, pp. 1-4]. As part of the investigation, Pine & Swallow installed temporary well points at locations throughout the property, and collected ground water samples to further delineate VOC contamination in the overburden ground water [28, pp. 1-4]. A total of 12 temporary monitoring well points were installed from 8 to 24 feet bgs, at locations near existing permanent and temporary ground water monitoring wells on the property where PCE had previous ly been detected in ground water samples [28, pp. 1-4, 10, 16-25]. As part of the ERM investiga tion, 13 ground water samples were collected from the 12 newly installed temporary ground water monitoring wells , and five samples were collected from previously installed ground water monitoring wells [28, p. 19]. All 18 ground water samples were collected using a peristaltic pump and dedicated tubing, and were submitted to Pine & Swa llow personnel for field analysis of target compounds [1,1-dichloroethene (1,1-DCE), cis-1,2- DCE, trans-dichloroethene (trans-DCE), PCE, TCE, and vinyl chloride) using a gas chromatograph [28, pp. 3-4, 19-20]. In addition, ME DEP submitted the five ground water samples collected from the previously in stalled ground water monitoring wells to the Maine Health and Environmental Testing Laboratory for VOC analysis by Method 8260 [28, pp. 4, 31-88]. Field screening analytical results of the samples collect ed from the newly installed temporary ground water monitoring wells indicated the presence of PCE in four of the wells, at a maximum concentration of 4.3 μg/L [28, pp. 4-6, 10, 12-13, 30]. In addition, field screening indicated the presence of PCE in three of the ground water samples collected from the previously installed monitoring wells, at a maximum concentration of 46 μg/L [28, pp. 4-6, 10-13, 30]. Laboratory analytical results of ground water samples collected from the previously installed monitoring wells indicated the presence of PCE and 1,1,1-trichloroethane at maximum concentrations of 120 μg/L and 2.8 μg/L, respectively [28, pp. 4-6, 12-13, 31-47].

On 27 November 2000, as part of the shallow ground water investigation, ERM collected sediment and surface water samples from three locations on and around the Leeds Metal property [28, pp. 4-5, 10, 14-15, 48-88]. Sediment and surface water samples were coll ected from the following locations [sediment (SS-#) and surface water (SW-#) sample locations in parent heses]: the lagoon/trench areas located on the western portion of the property (SS-1 and SW-1); the wetland ar ea located south of the property (SS-2 and SW-2); and the pond located in the central portion of the property (SS-3 and SW-3) [28, pp. 4-5, 10, 14-15, 48-88]. The sediment and surface water samples were submitted to Alpha Analytical Laboratories for analysis of VOCs by EPA Method 8260b, PCBs by EPA Met hod 8082, total RCRA 8 metals by EPA Method 6010B/7470A, and DRO by Maine Method 4.1.25 [28, pp. 5, 10, 14-15, 48-88]. Analytical results of the sediment samples indicated the presence of two VOCs (acetone and PCE), one PCB (Aroclor-1260), five RCRA 8 total metals (arsenic, barium, cadmium, ch romium, and lead), and DRO above the reporting detection limit [28, pp. 5, 10, 14, 61-69]. Analytical results of the surface water samples indicated the presence of one VOC (toluene) and five RCRA 8 tota l metals (barium, cadmium, chromium, lead, and mercury) above the reporting detecti on limit [28, pp. 5, 10, 15, 48-60].

On 10 November 2003, on behalf of Maine Central Railr oad, ERM began the evaluation of the four debris piles (Debris Piles A through D) located on the Leeds Metal property [29, pp. 1-4]. As part of the Debris Pile Evaluation, ERM conducted test pitting activities in each of the four debris piles to determine the type and chemical composition of the material contained within the piles [29, pp. 4-5]. Test pits were excavated to a maximum depth of 13 feet bgs, and the material enc ountered within the test pit was documented by ERM personnel [29, pp. 4-5, Appendix B]. Soil samples were collected from the excavat or bucket used in test pitting activities, and each sample was comprised of soil not in contact with the bucket [29, p. 6]. One composite soil sample was collected fro m each of the test pits and screened in the field for PCBs and total

Leeds Metal 29 HRS Documentation Record

MEN000103584 September 2011metals, and two grab samples were collected from east test pit and screened in the field for VOCs [29, p.5]. VOC field screening was performed using two separate photoionization detectors (PIDs); PCB field screening was performed with D-tech field test kits; and total me tals field screening was performed using a Niton X-ray fluorescence (XRF) unit [29, pp. 5-6]. In addition, 49 soil samples were submitted to Alpha Analytical Laboratories for VOC analysis by EPA Method 8260, semivolatile organic compounds (SVOC) analysis by EPA Method 8270, PCB analysis by EPA Method 8080, a nd total RCRA 8 metals analysis by EPA Methods 6010A and 7471 [29, p. 7, Appendix D (pp. 155-159)].

As part of the Debris Pile Evaluation, ERM personne l described Debris Pile A as being “vegetated with invasive vegetation up to 1.5 ′′ in diameter in a relatively dry matrix of sand with minor silt, metal pieces (up to 3' long), rubber, plastic, plant matter, fabric, and metal oxides” [29, pp. 9-10]. A total of 30 test pits were excavated in Debris Pile A [29, p. 4, 70-71]. Screen ing results of soil samples indicated the presence of total VOCs at a concentration of 54.1 parts per million (ppm) a nd total PCBs at concentrations greater than 25 ppm [29, 12-15, 70-71]. In addition, metals screening analysis of soil samples indicated the presence of 12 total metals, including arsenic and lead [29, pp. 2-15, 70-71]. Eight test pit soil samples collected from Debris Pile A were submitted to Alpha Analytical Laboratories for the laboratory analyses described above [29, pp. 65, 70-71, Appendix D (pp. 155-159). Laboratory analytical results indicated the presence of four SVOCs, three PCBs, and six total metals above laboratory reporting detection lim its, including Aroclor-1260, cadmium, chromium, and lead [29, pp. 65, 70-71, Appendix D (pp. 1-154)].

ERM personnel described Debris Pile B as being “heavily vegetated with trees up to 3 ′′ in diameter in a moist matrix of silt with minor sand and clay, plant matter, me tal, rubber, plastic, fabric, and metal oxides” [29, pp. 9-10]. A total of 100 test pits were excavated in Debris Pile B [29, pp. 4, 70, 72]. Screening results of soil samples indicated concentrations of total VOCs at 20.3 ppm and total PCBs greater than 25 ppm [29, pp. 16­ 35, 70, 72]. In addition, metals screening analysis indicated the presence of 10 total metals including arsenic and lead [29, pp. 16-35, 70, 72]. Fifteen test pit soil samples collected from Debris Pile B were submitted to Alpha Analytical Laboratories for the laboratory analys es described above [29, pp. 65-66, 70, 72, Appendix D (pp. 155-159)]. Laboratory analytical results indicated the presence of 13 VOCs, four SVOCs, four PCBs,

and six total metals above laborat ory reporting detection limits, including Aroclor-1260, arsenic, cadmium, chromium, and lead [29, pp. 65-66, 70, 72, Appendix D (pp. 1-154)].

ERM described Debris Pile C as being “heavily vegetated with trees up to 3 ′′ in diameter in a moist matrix of silt and minor sand, plant matter, oxidized metal, o ccasional metal pieces, metal oxides, rubber, and plastic” [29, pp. 9-10]. A total of 20 test pits were excavated in Debris Pile C [29, pp. 4, 36-38, 70, 73]. Screening results of soil samples indicated the presence of total VOC s at a concentration of 12 ppm and total PCBs at concentrations ranging between 4.1 and 15 ppm [29, pp. 36-38, 70, 73]. In addition, metals screening analysis indicated the presence of nine total metals, incl uding lead [29, pp. 36-38, 70, 73]. Four test pit soil samples collected from Debris Pile C were submitted to Alpha Analytical Laboratories for the laboratory analyses described above [29, pp. 66-67, 70, 73, Appe ndix D (pp. 155-159)]. Laboratory analytical results indicated the presence of 11 VOCs, three SVOCs, two P CBs, and six total metals above laboratory reporting detection limits, including Aroclor-1260, arsenic, cadmi um, chromium, and lead [29, pp. 66-67, 70, 73, Appendix D (pp. 1-154)].

ERM described Debris Pile D as being an “unvegetated, relatively dry pile with minor sand, silt and clay, metal oxides, oxidized metal, rubber, plastic, and fabric” [29, pp. 9-10]. A total of 100 test pits were excavated in Debris Pile D [29, pp. 4, 39-60, 70, 74]. Screening results of soil samples indicated the presence of total VOCs at a maximum concentration of 17.4 ppm a nd total PCBs at concentrations greater than 25 ppm [29, pp. 39-60, 70, 74]. In addition, metals screeni ng analysis indicated the presence of 10 total metals, including arsenic and lead [29, pp. 39-60, 70, 74]. A total of 20 test pit soil samples collected from Debris Pile D were submitted to Alpha Analytical Laboratories for the laboratory analyses described above [29, pp.

Leeds Metal 30 HRS Documentation Record

MEN000103584 September 201167-68, 70, 74, Appendix D (pp. 155-159)]. Laboratory analytical results indicated the presence of 13 VOCs, three SVOCs, two PCBs, and six total metals above laboratory reporting detection limits, including PCE, Aroclor-1254, Aroclor-1260, arsenic, cadmium, chromium, and lead [29, pp. 67-68, 70, 74, Appendix D (pp. 1-154)].

As part of the Debris Pile Evaluation completed in March 2006, ERM also investigated an area designated as Area E (referred to in tables as Debris Pile E) [29, pp. 4, 61-64]. According to ME DEP representative Kathy Howatt, Debris Pile E was designated as an area lo cated along the southeastern property boundary, and is equivalent to the area referred to as the Former Op erations Area during sampling conducted as part of the EPA Site Assessment Site Inspection [11, pp. 24-25; 17, p. 12]. Two test pits were excavated in the area of Debris Pile E [29, pp. 61-64]. Screening results of soil samples indicated the presence of total VOCs at a maximum concentration of 0.1 ppm and total PCBs at concentrations ranging from 4.1 to 15 ppm [29, pp. 61­ 64]. In addition, total metals screening analysis indicat ed the presence of six total metals, including lead [29, pp. 61-64]. In addition, two soil samples were submitted to Alpha Analytical Laboratories for the laboratory analyses described above [29, pp. 68, Appendix D (pp. 155-159)]. Analytical results indicated the presence of three SVOCs, two PCBs, and six total metals above laboratory reporting detection limits, including Aroclor1254, Aroclor-1260, arsenic, cadmium, chromium, and l ead [29, pp. 68, Appendix D (pp. 1-154)].

As part of the Debris Pile Evaluation, ERM utilized survey data of the four debris piles, collected by Maine Central Railroad personnel in late Fall 2003, to further refine volume estimates [29, pp. 4-5]. ERM’s original volume estimates of the debris piles were 16,700 cubic yards (yd 3 ), 55,600 yd 3 , 10,400 yd 3 , and 55,500 yd 3

, for Debris Piles A, B, C, and D, respectively [29, p. 4]. Following the Maine Central Railroad survey of the Debris Piles, and area calculations of cross sections, ERM’s volume estimates of the piles were refined to 6,413 yd 3 , 20,566 yd 3 , 1,727 yd 3 , and 11,280 yd 3 , for Debris Piles A, B, C, a nd D, respectively [29, Appendix A].

On 17 June 2004, Roux Associates, Inc. (Roux Associat es), on behalf of Guilford Rail System, completed a Targeted Environmental Investigation of the northwest portion of the Leeds Metal property [21, pp. 1-4]. The purpose of the investigation was to determine if hazardous substances were present on the northwestern portion of the property due to filling activities allegedl y conducted by an adjacent business, Rinker Industries (located at 173 State Route 106 in Leeds, ME) [21, pp. 1-2, Figure 2]. On 10 May 2004, as part of the investigation, Roux Associates completed three soil borings (RX-1S, RX-2S, and RX-3S) as ground water monitoring wells, at locations along the northwest propert y boundary and adjacent to concrete waste [21, p. 7, Figure 2]. On 11 May 2004, Roux Associates gauged the existing permanent ground water monitoring wells, in addition to the wells installed on 10 May 2004 [21, p. 8]. According to Roux Associates, gauging of the ground water wells indicated that ground water flow in the shallow overburden was in a north to northwesterly direction [21, p. 16, Figure 3]. Also on 11 May 2004, Roux Associates personnel collected ground water samples from the newly installed ground wa ter monitoring wells RX-1S, RX-2S, and RX-3S [21, p. 8]. The ground water samples were collected using low-flow techniques and were submitted to Resource Laboratories for the following analyses: VOCs by EPA Method 8260B, SVOCs by EPA Method 8270B, PCBs by EPA Method 8082B, dissolved RCRA 8 metals by EPA Methods 6010B and 7470A, DRO by EPA Method 8015B, and gasoline ra nge organics (GRO) by EPA Method 8015B [21, pp. 8-9, Table 2, Appendix I]. Analytical results of the ground water samples indicated the presence of DRO in ground water monitoring wells RX-1S and RX-3S [21, p. 14, Table 2, Appendix I].

On 10 May 2004, as part of the Targeted Environmental Investigation of the northwest portion of the Leeds Metal property, Roux Associates collected three co mposite soil samples (CS-1, CS-2, and CS-3) from locations adjacent to the three newly installed mon itoring wells, and two composite soil samples (CS-4 and CS-5) from locations between the three monitoring wells [ 21, p. 7, Figure 2, Table 1]. The five soil samples were collected from a depth of approximately 1 foot bgs and submitted to Resource Laboratories for the

Leeds Metal 31 HRS Documentation Record

MEN000103584 September 2011following analyses: VOCs by EPA Method 8260B, S VOCs by EPA Method 8270B, PCBs by EPA Method 8082B, RCRA metals by EPA Met hods 6010B and 7470A, DRO by EPA Method 8015B, and GRO by EPA Method 8015B [21, p. 8, Table 1, Appendix H]. Analytical results of the surface soil samples indicated the presence of 10 SVOCs, seven RCRA 8 metals (including arsenic, cadmium, chromium, and lead), and DRO at concentrations above laboratory RLs [ 21, pp. 10-14, Table 1, Appendix H].

On 8 August 2004, the Leeds Metal property was liste d in the Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) database [CERCLIS No. MEN000103584] [5, pp. 1-2].

On 23 January 2008, ME DEP wrote to EPA and requ ested assistance in investigating the Leeds Metal property due to lack of cooperation from the property owner [30, pp. 1-2].

On 1 June 2009, as part of an EPA Removal Program Preliminary Assessment/Site Investigation, ME DEP personnel collected ten ground water samples, includi ng one field duplicate, from the nine ground water monitoring wells installed on the Leeds Metal propert y by ERM in November 1999 [31, pp. 1-15]. The ground water samples were relinquished to Weston So lutions, Inc. Superfund Technical Assessment and Response Team III (START) personnel and submitted to the EPA Office of Environmental Measurement and Evaluation (OEME) laboratory located in North Ch elmsford, Massachusetts (MA) for VOC, RCRA metals, and cyanide analyses [31, p. 2; 32, p. 24]. Analyti cal results of the ground water samples collected by ME DEP indicated the presence of one VOC (PCE), at a ma ximum concentration of 15 μg/L in samples ERM-4S and field duplicate ERM-6S [32, pp. 61, 158-200]. In addition, four total recoverable metals were detected at concentrations above laboratory RLs [32, pp. 62-63, 391-410].

On 15 through 18 June 2009, as part of the EPA Removal Program Preliminary Assessment/Site Investigation, START collected a total of 196 surf ace and subsurface soil samples from locations throughout the Leeds Metal property [32, pp. 24-26, 39, 44-49]. Of the 196 surface and subsurface soil samples collected, 177 samples were screened in the field for VOCs, and 152 samples were screened in the field for metals [32, pp. 27, 50-55, 118-136]. In addition, fo r confirmatory results, 24 of the soil samples were submitted to the EPA OEME laboratory for VOCs in so il (high level method) analysis, and 20 of the soil samples were submitted to the EPA OEME laboratory fo r metals in soil (medium level) analysis by inductively coupled plasma (ICP) [32, pp. 27-28, 40-41, 57-60, 233-284, 333-378, 411-453]. VOC screening results indicated the presence of PCE in 30 surface and subsurface soil samples at a maximum concentration of 4,140 micrograms per Kilogram (μg/Kg) [32, pp. 40, 50-52, 77, 118-136]. Metals screening analysis indicated the presence of four total metals above the sample reporting limit, including arsenic, cadmium, and lead [32, pp. 41, 53-55, 77, 118-136]. Laboratory confirmation analysis indicated the presence of 14 VOCs

and 17 total metals above laborator y reporting limits, including PCE, arsenic, cadmium, chromium, and lead [32, pp. 27-28, 40-41, 57-60, 233-284, 333-378, 411-453].

On 17 and 18 June 2009, as part of the EPA Removal Program Preliminary Assessment/Site Investigation, eight temporary well points were installed at locations throughout the Leeds Metal property [32, pp. 26, 39]. Six of the temporary well points (WP-01 through WP-06) were installed in areas west and north of Debris Pile D, while two temporary well points (WP-07 and WP -08) were installed along the southeastern property boundary [32, pp. 26, 39]. A total of 19 ground water sam ples were collected, using a peristaltic pump, from various depth intervals within the temporary mon itoring well points, and submitted to the EPA Mobile Laboratory for VOC field screening [32, pp. 26-28, 39, 56, 118-136]. In addition, two ground water samples were collected, using a peristaltic pump, from two gr ound water monitoring wells previously installed on the property (ERM-4S and ERM-4D), and submitted to the EP A Mobile Laboratory for VOC field screening [32, pp. 26-28, 39, 56, 118-136]. Analytical results of the ground water samples indicated the presence of PCE in all of the samples, at a maximum concentration of 86 μg/L, and the presence of 1,1,1-trichloroethane in one

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MEN000103584 September 2011sample at a concentration of 1.0 μg/L [32, pp. 26-28, 39, 56, 118-136].

On 18 June 2009, as part of the EPA Removal Program Preliminary Assessment/Site Investigation, ME DEP personnel collected nine drinking water samples, including one field duplicate, from eight residences located south and southwest of the Leeds Metal property [32, p. 26; 33, pp. 1-3]. ME DEP relinquished the drinking water samples to EPA OEME Mobile Laboratory pe rsonnel for VOC field screening, and to START personnel for submittal to the EPA OEME Laboratory for volatile organic analytes (VOAs) in drinking water, total metals, cyanide, and sulfate analy ses [32, pp. 26-29, 56, 61-63, 106-116, 118-136, 201-232, 285­ 332, 379-390, 454-480; 33, pp. 1-3, Chain of Custody (C OC) attachment]. Screening results of drinking water samples indicated the presence of PCE in four samples, at a maximum concentration of 0.67 μg/L, and TCE in five samples, at a maximum concentration of 1.5 μg/L [32, pp. 27, 56, 118-136; 33, pp. 1-3, COC attachment]. Laboratory analysis indicated the presence of five VOCs, six metals, and sulfate at concentrations above analytical RLs, including cis- 1,2-DCE, PCE, and TCE [32, pp. 26-29, 61, 64-66, 201­ 232, 285-332, 379-390, 454-480; 33, pp. 1-3, COC attachment].

On 16 March 2010, as part of the EPA Site Assessment Preliminary Assessment/Site Inspection, EPA and START personnel performed a reconnaissance of the Leeds Metal property [14, pp. 2-14]. As part of the reconnaissance, START personnel observed conditions on the Leeds Metal property, and identified potential source areas both on and adjacent to the property [14, pp. 2-14]. Observations and sampling conducted as part of the EPA Site Assessment Site Inspection, as we ll as sample results from previous investigations, have identified the following nine source areas on and adjacent to the Leeds Metal property: Debris Pile A, located on the eastern-central portion of the property, west of the concrete pad; Debris Pile B, located on the southeastern portion of the property, directly south of Debris Pile A; Debris Pile C, located on the southcentral portion of the property, directly west of Debris Pile B; Debris Pile D, located on the southern portion of the property, southwest of Debris Pile B; the Abandoned Drum Area, located along the southern property boundary and extending south onto Lot No. 40, depicted on the Town of Leeds, ME Tax Assessor’s Map No. 4; the Battery Drop Area, located on the northern por tion of the property, adjacent to the access road and railroad; the Former Operations Area, encompassing approximately the western half of the property; the Concrete Storage Area, located along the northwester n property boundary, adjacent to the property depicted on the Town of Leeds, ME Tax Assessor’s Map No. 4, as Lot No. 37; and the Container Disposal Area, located along the western property boundary, adjacent to Maine Route 106 [9; 11, pp. 21-110, Attachments A and C].

On 8 through 11, 15 through 18, and 30 November 2010, START conducted sampling activities on the Leeds Metal property and at nearby propertie s as part of the EPA Site Assessment Site Inspection [14, pp. 21-48; 15, pp. 2-26, 29-48; 16, pp. 2-40, 46-48; 17, pp. 2-6; 34]. A total of 47 surface soil/source, 29 subsurface soil/source, 12 ground water, 31 drinking water, and 34 sediment samples were collected to identify source areas on the property, and determine potential impacts to local ground water and sediments [6; 11, pp. 25, 79, 123, 133, 173; 14, pp. 21-48; 15, pp. 2-26, 29-48; 16, pp. 2-40, 46-48; 17, pp. 2-6; 34, pp. 50-97]. Source samples were not collected from the Battery Drop Area a nd the Concrete Disposal Area as part of the EPA Site Assessment Site Inspection, as these two source areas were characterized during the EPA Removal Program Preliminary Assessment/Site Investigation and Roux Associates Targeted Environmental Investigations [11, pp. 26-40, 80-89; 14, pp. 21-48; 15, pp. 2-26, 29-48; 16, pp. 2-40, 46-48; 17, pp. 2-6].

Analytical results of one surface soil/source sample (SS-07) collected from Debris Pile A during the EPA Site Assessment Site Inspection indicated a source containi ng the following two VOCs, three PCBs, and 13 total

metals at concentrations above background: 2-butanone [also known as me thyl ethyl ketone (MEK)], 1,2,3­ trichlorobenzene, Aroclor-1242, Aroclor-1254, Aroclor-1260, antimony, arsenic, barium, cadmium, calcium, chromium, cobalt, copper, iron, lead, mercury, nickel, and zinc [11, pp. 42-43, Attachment A [Table 1 (p. 1 of

Leeds Metal 33 HRS Documentation Record

MEN000103584 September 20117), Table 2 (p. 1 of 7), Table 3 (p. 1 of 7)]; 17, pp. 3-4; 34, p. 30, Table 1; 37, Table 2 (p. 1 of 3); 42, Table 1 (p. of 3)].

Analytical results of seven surface and subsurface soil/source samples (SS-34, SS-35, SS-36, SB-34, SB-35, SB-36, and SB-43) collected from Debris Pile B duri ng the EPA Site Assessment Site Inspection indicated a source containing the following 15 VOCs, four PCBs, and 20 total metals at concentrations above background: acetone, 2-butanone, carbon disulfide, chlorofo rm, 1,2-dichlorobenzene, 1,3-dichlorobenzene, 1,4-dichlorobenzene, ethylbenzene, isopropylbenzene, methyl acetate, 4-methyl-2-pentanone, toluene, TCE, m,p-xylene, o-xylene, Aroclor-1248, Aroclor-1254, Aroclor-1260, Aroclor-1268, antimony, arsenic, barium, beryllium, cadmium, calcium, chromium, copper, iron, lead, magnesium, manganese, mercury, nickel, potassium, silver, sodium, thallium, va nadium, and zinc [11, pp. 67-70, 101-107, Attachment A [Table 1 (p. 5 of 7), Table 2 (p. 5 of 7), Table 3 (pp. 5-6 of 7)], Attach ment C [Table 1 (pp. 3-4 of 4), Table 2 (pp. 3-4 of 4), Table 3 (pp. 3-4 of 5)]; 16, pp. 33-35; 34, pp. 27-28; 38, Ta ble 2 (pp. 1-2 of 2); 43, Table 1 (pp. 1-2 of 2)].

Analytical results of four surface and subsurface soil/source samples (SS-32, SS-33, SB-32, and SB-33) collected from Debris Pile C during the EPA Site A ssessment Site Inspection indicated a source containing the following four VOCs, two PCBs, and five total metals at concentrations above background: acetone, bromomethane, 2-butanone, chloromethane, Aroclor- 1254, Aroclor-1260, cadmium, copper, lead, mercury, and zinc [11, pp. 66, 100-101, Attachment A [Table 1 (p. 5 of 7), Table 2 (p. 5 of 7), Table 3 (p. 5 of 7)], Attachment C [Table 1 (p. 3 of 4), Table 2 (p. 3 of 4), Ta ble 3 (p. 3 of 5)]; 15, p. 48; 16, p. 2; 34, p. 21; 35, Table 2 (pp. 1-2 of 3); 40, Table 1 (p. 3 of 3)].

Analytical results of eight surface and subsurface soil/source samples (SS-28, SS-29, SS-30, SS-31, SB-28, SB-29, SB-30, SB-31) collected from Debris Pile D dur ing the EPA Site Assessment Site Inspection indicated a source containing the following nine VOCs, four P CBs, and 16 total metals at concentrations abovebackground: acetone, 2-butanone, bromomethane, ethylbenzene, methyl acetate, styrene, PCE, m,p-xylene, oxylene, Aroclor-1248, Aroclor-1254, Aroclor-1260, Aroclor-1268, antimony, arsenic, barium, cadmium, calcium, chromium, cobalt, copper, iron, lead, magnesium , manganese, mercury, nickel, silver, and zinc [11, pp. 61-66, 95-99, Attachment A [Table 1 (pp. 4-5 of 7) , Table 2 (pp. 4-5 of 7), Table 3 (pp. 4-5 of 7)], Attachment C [Table 1 (pp. 2-3 of 4), Table 2 (pp. 2-3 of 4), Table 3 (p. 3 of 5)]; 14, pp. 46-48; 15, pp. 2-3; 34, pp. 12-13; 39, Table 1 (pp. 1-2 of 3), Table 2 ( pp. 1-2 of 2); 44, Table 1 (pp. 1-2 of 2)].

Analytical results of five surface and subsurface soil/source samples (SS-37, SS-38, SS-39, SB-37, SB-38) collected from the Abandoned Drum Source Area during th e EPA Site Assessment Site Inspection indicated a source containing the following two VOCs, two PCBs, and 13 total metals at concentrations above background: acetone, 2-butanone, Aroclor-1254, Aroclor-1260, aluminum, barium, cadmium, calcium, chromium, copper, iron, lead, magnesium, manganese, mercury, nickel, and zinc [11, pp. 38, 71-72, 88, Attachment A [Table 1 (p. 6 of 7), Table 2 (p. 6 of 7), Table 3 (p. 6 of 7)], Attachment C [Table 1 (p. 4 of 4), Table 2 (p. 4 of 4), Table 3 (p. 4 of 4)]; 16, pp. 14-16; 17, p. 12; 34, pp. 23-24; 35, Table 1 (pp. 2-3 of 3), Table 2 (pp. 2-3 of 3); 40, Table 1 (pp. 2-3 of 3)].

Analytical results of six surface soil samples collect ed from the Battery Drop Area as part of the EPA Removal Program Preliminary Assessment/Site Investigation indicated a source containing the following three metals above screening detection limits: antimony, ar senic, and lead [Figure 2; 11, p. 4 (Figure 2); 32, pp. 27-28, 40-41, 55, 122].

Analytical results of surface and subsurface soil/s ource samples (SS-09, SS-13, SS-17, SS-20 through SS-27, SS-44, SB-09, SB-17, SB-22, SB-27 and SB-44) collected from the Former Operations Area during the EPA Site Assessment Site Inspection indicated a source containing the following 10 VOCs, four PCBs, and 23

total metals at concentrations a bove background: bromomethane, 2-butanone, chloromethane, ethylbenzene,

Leeds Metal 34 HRS Documentation Record

MEN000103584 September 2011methyl acetate, methyl tert-butyl ether (MTBE), styrene, PCE, m,p-xy lene, o-xylene, Aroclor-1248, Aroclor1254, Aroclor-1260, Aroclor-1268, aluminum, antimony, arsenic, barium, beryllium, cadmium, calcium, chromium, cobalt, copper, iron, lead, magnesium, manganese, mercury, nickel, potassium, selenium, silver, sodium, thallium, vanadium, and zinc [11, pp. 44-61, 73-78, 91-95, 108, Attachment A [Table 1 (pp. 2-4, 7 of 7), Table 2 (pp. 2-4, 7 of 7), Table 3 (pp. 2-4, 7 of 7)], Attachment C [Table 1 (pp. 1-2 of 4), Table 2 (pp. 1-2 of 4), Table 3 (pp. 1-2 of 5)]; 15, pp. 18-19; 16, pp. 28-31, 38-39; 17, p. 6; 34, pp. 13, 16, 26-28, 31].

Analytical results of four surface soil/source samples (SS-03, SS-04, SS-05, and SS-43) collected from the Container Disposal Source Area during the EPA Site Assessment Site Inspection indicated a source containing the following VOC and six total metals at concentrations above background: methyl acetate, barium, cadmium, copper, lead, potassium, and zinc [11, pp. 26-27, 39, 42, 73, Attachment A [Table 1 (pp. 1, 6 of 7), Table 2 (pp. 1, 6 of 7), Table 3 (pp. 1, 7 of 7)]; 16, pp. 2-4; 34, p. 21; 35, Table 1 (pp. 1-2 of 3), Table 2 (pp. 1-2 of 3); 40, Table 1 (pp. 1-2 of 2)].

Surface soil samples collected from the Concrete Dispo sal Area as part of the Roux Associates Targeted Environmental Investigation indicated a source c ontaining DRO and the following ten SVOCs and seven RCRA 8 metals at concentrations above laboratory de tection limits: benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i) perylene, benzo(k)fluoranthene, chrysene, fluoranthene, indeno(1,2,3­ cd)pyrene, phenanthrene, pyrene, arsenic, barium, cadmium, chromium, lead, selenium, and silver [21, pp. 10­ 14, Table 1, Appendix H].

For the purposes of this HRS documentation record, the following will be evaluated: six hazardous substances (PCE, Aroclor-1254, Aroclor-1260, arsenic, chromium, a nd lead) detected in source samples collected from five source areas located on the Leeds Metal property; and two hazardous substances (PCE and TCE) detected in ground water and/or drinking water samples.

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MEN000103584 September 2011Source Characterization

Source No. 1

2.2 SOURCE CHARACTERIZATION

2.2.1 SOURCE IDENTIFICATION

Name of Source : Debris Pile A

Number of Source : Source No. 1

Source Type : Pile

Description and Location of Source :

Debris Pile A (Pile - Source No. 1) is located on the undeveloped property identified as the Leeds Metal property, depicted on the Town of Leeds, ME Tax Assesso r’s Map No. 4, as Lot No. 38 [5; 9; 12, pp. 1-2; 19,

p. 1, Fig. 1]. Source No. 1 is located adjacent to (southwest, north, and south o f) the concrete building and pad on the east-central portion of the Leeds Metal property (see Figure 2) [14, pp. 10-11; 29, p. 70]. The geographic coordinates of Debris Pile A, as measured from its approximate center, are 44° 14 ′ 15.2 ′′ north

latitude and 70° 04 ′ 46.8 ′′ west longitude (see Figures 1 and 2) [7].

Between 1969 and 1984, scrap metal recovery processes were conducted on the Leeds Metal property by various entities [18, pp. 1- 2]. The former assistant fire chief of the Town of Leeds, ME stated that cars were transported to the property via trucks for “shredding” [ 26]. He also stated that within a cement building on the property, lead batteries and other auto parts were cl eaned for resale [26]. The former assistant fire chief noted that metal from the shredded cars was salvaged (s ent off the property via railroad), while the upholstery was piled in former gravel excavation pits [26]. He further stated that such materials as “gasoline, diesel, transformer oil, brake fluid, oils, battery aci d, and antifreeze” were dumped on the ground and that approximately 100 ‘barrels’ were staged along the southern property boundary [26]. The former assistant fire chief recalled that the Leeds and Monmouth Fire Depart ments responded to fires at the property, and that gasoline tanks would ignite causing oil-saturated soil to burn [26]. The eastern and southern portions of the Leeds Metal property contained car shredding waste bot h on the ground surface and in piles, including Source No. 1 (Debris Pile A) [14, pp. 9-11]. Debris Pile A is not elevated, but rather appears to be a filled-in portion of a depression that extends west toward the property access road (see Figure 2) [14, pp. 10-11; 29, Figure 2]. The material which comprises Debris Pile A was observed to be consistent with that of several other debris piles on the property, and included rubber, plastic, and metal debris [14, pp. 10-11].

In November 2003, ERM personnel, wo rking on behalf of the property ow ner, completed an evaluation of four on-site debris piles (Debris Piles A through D) [29, pp. 1-4]. As part of this evaluation, ERM representatives conducted extensiv e test pitting, sampling, and a volume estimation of each pile [29, pp. 1-10, 12-60, 70-74, Appendices A, B, and D]. ERM described Debris Pile A as being “vegetated with invasive vegetation up to 1.5 ′′ in diameter in a relatively dry matrix of sand with minor silt, metal pieces (up to 3' long), rubber, plastic, plant matter, fabric, and meta l oxides” [29, pp. 9-10]. Screening and laboratory analyses of test pit samples collected from Debris Pile A, on behalf of the property owner, indicated the presence of three PCBs (Aroclor-1248, Aroclor-1254, and Aroclor-1260) and six total metals (antimony, arsenic, cadmium, copper, lead, and nickel) at concentr ations exceeding state standards [29, pp. 12-15, 65, 70­ 71; 138, Appendix 1]. ERM estimated the approxi mate volume of Debris Pile A to be 16,700 yd 3 [29, p. 4].

In late fall of 2003, Maine Central Railroad personnel conducted a survey of the four on-site debris piles (Debris Piles A through D) to further refine volume estimates presented earlier by ERM [29, pp. 4-5]. Following the Maine Central Railroad survey of Debris Pile A, the volume estimate of Debris Pile A was adjusted by ERM to 6,413 yd 3 [29, Appendix A (pp. 1-2, 6-7)].

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MEN000103584 September 2011Source Characterization

Source No. 1

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

- Background Concentrations:

Debris Pile A (Source No. 1) is a pile source type; therefore, no background samples are required. However, since the debris pile materials were mixed with local soil material, background surface and subsurface soil samples were collected as part of the EPA Site Assessment Site Inspection [15, pp. 44- 46; 17, pp. 3-4; 34, pp. 20, 30; 75, p. 1; 76, p. 1]. On 16 November 2010, as part of the EPA Site Assessment Site Inspection, background soil sampling activities were conducted [15, pp. 44-46; 34, p. 20]. The background surface and subsurface soil samples were collected in accordance w ith the EPA-approved Site-Specific Quality Assurance Project Plan (QAPP), dated 26 October 2010 [6; 34, pp. 19-20]. Two background surface soil samples (SS-01 and SS-02) and two background subsurface soil samples (S B-01 and SB-02) were collected from a residential property located northwest of the Leeds Metal property [9; 12; 15, pp. 44-46; 34, p. 20; 106, pp. 1-2]. The residential property is located in Leeds, ME, and is depicted on the Town of Leeds, ME Tax Assessor’s Map No. 4 as Lot No. 55 (see Figure 3b) [9; 106, pp. 1-2]. The background samples were collected from the same 0- to 2-foot depth interval and during the same time period as the source samples presented as part of the Source No. 1 Characterization, and the background and s ource samples contained similar native materials [15, pp. 44-46; 75, pp. 1, 6, 9, 11, 13-15, 42; 76, pp. 1, 4, 6, 8, 9]. Background soil samples SS-01 and SB-01 were submitted to Contract Laboratory Program (CLP) Laboratories for VOC and PCB analyses following SOM01.2 and total metals analysis following ISM01.2, while background soil samples SS-02 and SB-02 were submitted to a CLP Laboratory for total metals analysis fo llowing ISM01.2 [15, pp. 44-46; 34, p. 20; 35, p. 1; 40, p. 1; 79, pp. 1-2; 84, pp. 1-2; 89, pp. 1-2]. As part of this HRS documentation record and the evaluation of background concentrations, the fo llowing hazardous substances in b ackground samples are presented: two PCB aroclors (Aroclor-1254 and Aroclor-1260), and thr ee total metals (arsenic, chromium, and lead).

Table 1 - Hazardous Substances Asso ciated with Background Samples

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-01 Soil 16 Nov. 2010 Aroclor-1254 42 U μg/Kg 42 μg/Kg 15, p. 44; 34, p. 20; 35, Table 2 ( p. 1 of 3); 53, Attachment B (p. 1)

SS-01 Soil 16 Nov. 2010 Aroclor-1260 42 U μg/Kg 42 μg/Kg 15, p. 44; 34, p. 20; 35, Table 2 ( p. 1 of 3); 53, Attachment B (p. 1)

SS-02 Soil 16 Nov. 2010 Chromium 1 23.1 (17.9 J) mg/Kg 1.1 mg/Kg 15, pp. 44-45; 34, p. 20; 40, Table 1 (p. 1 of 3); 58, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 2)

SS-02 Soil 16 Nov. 2010 Lead 1 5.1 (5.1 JEB) mg/Kg 1.1 mg/Kg 15, pp. 44-45; 34, p. 20; 40, Table 1 (p. 1 of 3); 58, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 2)

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MEN000103584 September 2011Source Characterization

Source No. 1

Table 1 - Hazardous Substances Associated with Background Samples (Continued)

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SB-01 Soil 16 Nov. 2010 Aroclor-1254 36 U μg/Kg 36 μg/Kg 15, p. 45; 34, p. 20; 35, Table 2 (p. 2 of 3); 53, Attachment B (p. 7)

SB-01 Soil 16 Nov. 2010 Aroclor-1260 36 U μg/Kg 36 μg/Kg 15, p. 45; 34, p. 20; 35, Table 2 (p. 2 of 3); 53, Attachment B (p. 7)

SB-02 Soil 16 Nov. 2010 Arsenic 8.4 mg/Kg 1.4 mg/Kg 15, pp. 45-46; 34, p. 20; 40, Table 1 (p. 2 of 3); 58, pp. 8 (Table 2), 10 (Table 3), Attachment B (p. 4)

SB-02 Soil 16 Nov. 2010 Chromium 1 35.9 (27.8 J) mg/Kg 1.4 mg/Kg 15, pp. 45-46; 34, p. 20; 40, Table 1 (p. 2 of 3); 58, pp. 8 (Table 2), 10 (Table 3), Attachment B (p. 4)

SB-02 Soil 16 Nov. 2010 Lead 1 5.2
(5.2 JEB) mg/Kg 1.4 mg/Kg 15, pp. 45-46; 34, p. 20; 40, Table 1 (p. 2 of 3); 58, pp. 8 (Table 2), 10 (Table 3), Attachment B (p. 4)

Nov. = November. CRQL = Contract Required Quantitation Limit. μg/Kg = Micrograms per kilogram. mg/Kg = Milligrams per kilogram. U = The compound or element was analyzed for, but not detected. The associated numerical value is the sample-adjusted CRQL [103, p. B-47].J = The associated numerical value is an estimated quantity [40, Table 1 (pp. 1-2 of 3); 103, p. B47]. EB = The compound was also detected in an associated equipment rinsate blank [40, Table 1 (pp. 1­ 2 of 3)]. ( ) = For hazardous substance concentrations, denotes concentration of the compound or element prior to adjustment.

1 Chromium and lead results were qualified as estimated following data review. Chromium had a low bias (serial dilution results exceeded percent difference criteria) and was adjusted by multiplying by the adjustment factor of 1.29 [40, p. 5; 58, pp. 2, 3 (Exhibit 3), 10 (Table 3)]. Lead had a high bias [equipment (rinsate) blank contamination] and was not numerically ad justed [40, p. 4; 58, pp. 2, 3 (Exhibit 3), 10 (Table 3)].

- Source Samples:

On 30 November 2010, as part of the EPA Site Assessm ent Site Inspection, soil/s ource sampling activities of Debris Pile A were conducted [17, pp. 3-4; 34, p. 30]. The surface and subsurface source samples were

collected in accordance with the EPA -approved Site-Specific QAPP, dated 26 October 2010 [6]. As part of the Debris Pile A characterization, eight surface soil/source samples (SS-07, SS-10, SS-12, SS-14 through SSLeeds Metal 38 HRS Documentation Record

MEN000103584 September 2011Source Characterization

Source No. 1

16, SS-50, and SS-53) and four subsurface soil/source samples (SB-10, SB-12, SB-14, and SB-15) were collected from various locations throughout the pile (see Figure 3a) [16, pp. 31, 38-39, 46-48; 17, pp. 2-5; 34, pp. 51-53, 61-64; Figure 3]. All surface soil samples collected from Debris Pile A as part of the EPA Site Assessment Site Inspection were collected from depths of up to 2 feet bgs [Figure 3a; 75, pp. 6, 9, 11, 13-15, 42]. Surface soil/source sample SS-07 was described as dark brown, sandy silt, abundant debris (foam, wire coating, plastic, rubber, and tile), trace fine gravel, and trace clay [75, p. 6]. Surface soil/source sample SS-10 was described as medium-to-dark brown, fine-to-coarse sand, some silt, little fine-to-medium gravel, trace clay, trace debris (metal shavings), and trace organics [75, p. 9]. Surface soil/source sample SS-12 was described as medium-to-dark brown, silty sand, some de bris (rubber, metal, metal slag), little fine-to-medium gravel, trace clay and trace organics [75, p. 11]. Surface soil/source sample SS-14 was described as medium brown-to-red brown, fine-to-coarse sand, some silt, trace fine-to-medium gravel, trace organics, and trace debris (rubber, plastic) [75, p. 13]. Surface soil/source sample SS-15 and field duplicate SS-53 were described as olive green-to-medium grey, silt, little clay, trace fine sand and trace organics [75, p. 14]. Surface soil/source sample SS-16 was described as dark brow n, fine sandy silt, major debris (wire, slag, plastic, metal), little medium-to-coarse sand, little fine-t o-medium gravel, trace organics [75, p. 15]. Surface soil/source sample SS-50 was described as black, silty fine sand, some debris (metal, wire, plastic), little medium-to-coarse sand, little fine gravel, and trace clay [75, p. 42]. Subsurface soil/source sample SB-10 was described as medium brown, silty sand, trace fine-to-medi um gravel, trace debris (plastic), and trace organics [76, p. 4]. Subsurface soil/source sample SB-12 was descri bed as dark brown, sandy silt, some debris (rubber, metal, metal slag, glass), trace fine gravel, and trace cl ay [76, p. 6]. Subsurface soil/source sample SB-14 was described as medium brown, fine-to-coarse sand, little silt, trace fine-to-medium gravel, trace clay, and trace organics [76, p. 8]. Subsurface soil/source sample SB-15 was described as medium brown-to-light brown, sand, little silt, little fine-to-medium gravel, trace clay, trace debris (wire coating), and trace organics [76, p. 9].

The eight surface soil/source samples (SS-07, SS-10, SS-12, SS-14 through SS-16, SS-50, and SS-53) and four subsurface soil/source samples (SB-10, SB-12, SB-14, and SB-15) were submitted to CLP Laboratories for VOC and PCB analyses following SOM01.2, and total metals analysis following ISM01.2 [37, p. 1; 34, pp. 51-53, 61-64; 38, p. 1; 42, p. 1; 43, p. 1; 81, pp. 1-3; 82, pp. 1-2; 86, p. 1; 87, p. 1; 91, p. 1; 92, p. 1]. The analytical data were validated according to EPA New England Regional Functional Guidelines Tier II requirements (for VOCs, PCBs, and total metals analyses) [ 37, p. 1; 38, p. 1; 42, p. 1; 43, p. 1]. For the purposes of the Source No. 1 evaluation and the HRS documentation record, analytical results of 12 soil/source samples (SS-07, SS-10, SS-12, SS-14 through SS- 16, SS-50, SS-53, SB-10, SB-12, SB-14, and SB-15) confirm the presence of the following hazardous substances: two PCB Aroclors (Aroclor-1254 and Aroclor-1260) and three total metals (arsenic, chro mium, and lead) as presented in the following table.

Among the 12 selected soil/source samples, Aroclor-1254 was detected at a maximum concentration of11,000 μg/Kg in surface soil/source sample SS-07, located on the western portion of Source No. 1; Aroclor1260 was detected at a maximum concentration of 12, 000 μg/Kg in surface soil/source sample SS-07; arsenic was detected at a maximum concentration of 46.2J mg /Kg in subsurface soil/source sample SB-12, located on the northeastern portion of Source No. 1; chromium was detected at a maximum c oncentration of 819 mg/Kg in surface soil/source sample SS-50, located on the sout heastern portion of Source No. 1; and lead was detected at a maximum concentration of 20,900J mg /Kg in surface soil/source sample SS-50, located on the southeastern portion of Source No. 1 [Figure 3a; 16, pp. 38-39; 17, pp. 3-4; 34, pp. 28, 30; 37, Table 2 (p. 1 of 3); 42, Table 1 (p. 2 of 3); 43, Table 1 (p. 2 of 2); 55, pp. 7 (Table 2), 10 (Table 3); 60, p. 8 (Table 2), 12 (Table 3); 61, pp. 7 (Table 2), 10 (Table 3)].

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MEN000103584 September 2011Source Characterization

Source No. 1

Table 2 - Hazardous Substances Associated with Source No. 1

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-07 Soil/

Source 30 Nov. 2010

Aroclor-1254 11,000 μg/Kg 2,200 μg/Kg 17, pp. 3-4; 34, p. 30; 37, Table 2 (p. 1 of 3); 55, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 2)

Aroclor-1260 12,000 μg/Kg 2,200 μg/Kg 17, pp. 3-4; 34, p. 30; 37, Table 2 (p. 1 of 3); 55, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 2)

Chromium 325 mg/Kg 61.9 mg/Kg 17, pp. 3-4; 34, p. 30; 42, Table 1 (p. 1 of 3); 60, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 1)

Lead 3,630 mg/Kg 61.9 mg/Kg 17, pp. 3-4; 34, p. 30; 42, Table 1 (p. 1 of 3); 60, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 1)

SS-10 Soil/

Source 30 Nov. 2010

Aroclor-1254 340 μg/Kg 35 μg/Kg 16, pp. 46-47; 34, p. 29; 37, Table 2 (p. 1 of 3); 55, pp. 7 (Table 2), 10 (Table 3), Attachment B (pp. 7-8)

Aroclor-1260 440 μg/Kg 35 μg/Kg 16, pp. 46-47; 34, p. 29; 37, Table 2 (p. 1 of 3); 55, pp. 7 (Table 2), 10 (Table 3), Attachment B (pp. 7-8)

Lead 304 mg/Kg 1.1 mg/Kg 16, pp. 46-47; 34, p. 29; 42, Table 1 (p. 1 of 3); 60, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 2)

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MEN000103584 September 2011Source Characterization

Source No. 1

Table 2 - Hazardous Substances Associated with Source No. 1 (Continued)

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-12 Soil/

Source 30 Nov. 2010 Aroclor-1254 1,700 μg/Kg 180 μg/Kg 16, pp. 47-48; 34, p. 30; 37, Table 2 (p. 1 of 3); 55, pp. 7 (Table 2), 10 (Table 3), Attachment B (pp. 15-16)

Aroclor-1260 1,000 μg/Kg 180 μg/Kg 16, pp. 47-48; 34, p. 30; 37, Table 2 (p. 1 of 3); 55, pp. 7 (Table 2), 10 (Table 3), Attachment B (pp. 15-16)

Chromium 96.5 mg/Kg 1.1 mg/Kg 16, pp. 47-48; 34, p. 30; 42, Table 1 (p. 1 of 3); 60, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 4)

Lead 656 mg/Kg 1.1 mg/Kg 16, pp. 47-48; 34, p. 30; 42, Table 1 (p. 1 of 3); 60, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 4)

SS-14 Soil/

Source 30 Nov. 2010 Aroclor-1254 390 μg/Kg 36 μg/Kg 17, pp. 2-3; 34, p. 30; 37, Table 2 (p. 1 of 3); 55, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 19)

Aroclor-1260 510 μg/Kg 36 μg/Kg 17, pp. 2-3; 34, p. 30; 37, Table 2 (p. 1 of 3); 55, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 19)

Lead 250 mg/Kg 1.1 mg/Kg 17, pp. 2-3; 34, p. 30; 42, Table 1 (p. 1 of 3); 60, pp. 7 (Table 2), 11 (Table 3), Attachment B (p. 6)

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Source No. 1

Table 2 - Hazardous Substances Associated with Source No. 1 (Continued)

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-15 Soil/

Source 30 Nov. 2010 Aroclor-1254 89 μg/Kg 39 μg/Kg 17, pp. 4-5; 34, p. 30; 37, Table 2 (p. 1 of 3); 55, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 77)

Aroclor-1260 84 μg/Kg 39 μg/Kg 17, pp. 4-5; 34, p. 30; 37, Table 2 (p. 1 of 3); 55, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 77)

Chromium 81.1 mg/Kg 1.2 mg/Kg 17, pp. 4-5; 34, p. 30; 42, Table 1 (p. 1 of 3); 60, pp. 7 (Table 2), 11 (Table 3), Attachment B (p. 7)

Lead 155 mg/Kg 1.2 mg/Kg 17, pp. 4-5; 34, p. 30; 42, Table 1 (p. 1 of 3); 60, pp. 7 (Table 2), 11 (Table 3), Attachment B (p. 7)

SS-16 Soil/

Source 18 Nov. 2010 Aroclor-1254 900 μg/Kg 190 μg/Kg 16, p. 31; 34, p. 27; 38, Table 2 (p. 1 of 2); 56, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 3­ 4)

Aroclor-1260 1 1,600 (1,600 J) μg/Kg 190 μg/Kg 16, p. 31; 34, p. 27; 38, Table 2 (p. 1 of 2); 56, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 3­ 4)

Chromium 245 mg/Kg 238 mg/Kg 16, p. 31; 34, p. 27; 43, Table 1 (p. 1 of 2); 61, pp. 6 (Table 2), 8 (Table 3), Attachment B (p. 3)

Lead 2 1,264 (1,820 J) mg/Kg 238 mg/Kg 16, p. 31; 34, p. 27; 43, Table 1 (p. 1 of 2); 61, pp. 6 (Table 2), 8 (Table 3), Attachment B (p. 3)

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Source No. 1

Table 2 - Hazardous Substances Associated with Source No. 1 (Continued)

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-50 Soil/

Source 18 Nov. 2010 Aroclor-1254 240 μg/Kg 46 μg/Kg 16, pp. 38-39; 34, p. 28; 38, Table 2 (p. 2 of 2); 56, pp. 7 (Table 2), 9 (Table 3), Attachment B (p. 13)

Chromium 819 mg/Kg 273 mg/Kg 16, pp. 38-39; 34, p. 28; 43, Table 1 (p. 2 of 2); 61, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 9)

Lead 2 14,514
(20,900 J) mg/Kg 273 mg/Kg 16, pp. 38-39; 34, p. 28; 43, Table 1 (p. 2 of 2); 61, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 9)

SS-53 Soil/

Source 30 Nov. 2010 Aroclor-1254 71 μg/Kg 39 μg/Kg 17, pp. 4-5; 34, p. 30; 37, Table 2 (p. 3 of 3); 55, pp. 9 (Table 2), 11 (Table 3), Attachment B (p. 86)

Chromium 79.5 mg/Kg 1.2 mg/Kg 17, pp. 4-5; 34, p. 30; 42, Table 1 (p. 3 of 3); 60, pp. 9 (Table 2), 13 (Table 3), Attachment B (p. 15)

Lead 119 mg/Kg 1.2 mg/Kg 17, pp. 4-5; 34, p. 30; 42, Table 1 (p. 3 of 3); 60, pp. 9 (Table 2), 13 (Table 3), Attachment B (p. 15)

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Source No. 1

Table 2 - Hazardous Substances Associated with Source No. 1 (Continued)

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SB-10 Soil/

Source 30 Nov. 2010 Aroclor-1254 200 μg/Kg 35 μg/Kg 16, p. 47; 34, p. 29; 37, Table 2 (p. 2 of 3); 55, pp. 8 (Table 2), 10 (Table 3), Attachment B (p. 78)

Aroclor-1260 130 μg/Kg 35 μg/Kg 16, p. 47; 34, p. 29; 37, Table 2 (p. 2 of 3); 55, pp. 8 (Table 2), 10 (Table 3), Attachment B (p. 78)

Lead 121 mg/Kg 1.1 mg/Kg 16, p. 47; 34, p. 29; 42, Table 1 (p. 2 of 3); 60, pp. 8 (Table 2), 11 (Table 3), Attachment B (p. 8)

SB-12 Soil/

Source 30 Nov. 2010 Aroclor-1254 430 μg/Kg 37 μg/Kg 17, p. 3; 34, p. 30; 37, Table 2 (p. 2 of 3); 55, pp. 8 (Table 2), 11 (Table 3), Attachment B (pp. 80-81)

Aroclor-1260 710 μg/Kg 110 μg/Kg 17, p. 3; 34, p. 30; 37, Table 2 (p. 2 of 3); 55, pp. 8 (Table 2), 11 (Table 3), Attachment B (pp. 80-81)

Arsenic 3 26.6 (46.2 J) mg/Kg 1.1 mg/Kg 17, p. 3; 34, p. 30; 42, Table 1 (p. 2 of 3); 60, pp. 8 (Table 2), 12 (Table 3), Attachment B (p. 10)

Chromium 80.8 mg/Kg 1.1 mg/Kg 17, p. 3; 34, p. 30; 42, Table 1 (p. 2 of 3); 60, pp. 8 (Table 2), 12 (Table 3), Attachment B (p. 10)

Lead 662 mg/Kg 1.1 mg/Kg 17, p. 3; 34, p. 30; 42, Table 1 (p. 2 of 3); 60, pp. 8 (Table 2), 12 (Table 3), Attachment B (p. 10)

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Source No. 1

Table 2 - Hazardous Substances Associated with Source No. 1 (Concluded)

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SB-14 Soil/

Source 30 Nov. 2010 Aroclor-1254 210 μg/Kg 34 μg/Kg 17, p. 4; 34, p. 30; 37, Table 2 (p. 2 of 3); 55, pp. 8 (Table 2), 11 (Table 3), Attachment B (p. 83)

Aroclor-1260 150 μg/Kg 34 μg/Kg 17, p. 4; 34, p. 30; 37, Table 2 (p. 2 of 3); 55, pp. 8 (Table 2), 11 (Table 3), Attachment B (p. 83)

Lead 51.8 mg/Kg 1.0 mg/Kg 17, p. 4; 34, p. 30; 42, Table 1 (p. 2 of 3); 60, pp. 8 (Table 2), 12 (Table 3), Attachment B (p. 12)

SB-15 Soil/

Source 30 Nov. 2010 Lead 26.4 mg/Kg 1.1 mg/Kg 17, p. 5; 34, p. 30; 42, Table 1 (p. 2 of 3); 60, pp. 8 (Table 2), 13 (Table 3), Attachment B (p. 13)

Nov. = November. CRQL = Contract Required Quantitation Limit. μg/Kg = Micrograms per kilogram. mg/Kg = Milligrams per kilogram. J = The associated numerical value is an estimated qua ntity [42, Table 1 (p. 2 of 3); 43, Table 1 (pp. 1­ 2 of 2); 103, p. B-47]. ( ) = For hazardous substance concentrations, denot es concentration of the compound or element prior to adjustment. Based on the EPA Fact Sheet, Using Qualified Data to Document an Observed
Release and Observed Contamination , for HRS purposes it is not required to adjust qualified source data. Although the fact sheet was not inte nded for application to source data, it has been applied as a conservative measure in this situ ation to demonstrate the relative increase in contamination in the source samples over background levels [113].

1 Aroclor-1260 had a low bias (compound did not meet percent difference criteria in the instrument continuing calibration) in surface soil/source sample SS-16 and was not numerically adjusted [38, pp. 3-4; 56, pp. 2, 3 (Exhibit 3), 8-9 (Table 3)].

2 Lead had a high bias (serial dilution results exceed ed percent difference criteria) in surface soil/source samples SS-16 and SS-50, and was adjusted by dividing by the adjustment factor of 1.44 [43, p. 5; 61, pp. 2, 3 (Exhibit 3), 8 (Table 3), 11].

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Source No. 1

3 Arsenic had a high bias (matrix spike analytes did not meet percent recovery criteria) in subsurface soil/source sample SB-12 and was adjusted by dividing by the adjustment factor of 1.74 [42, p. 5; 60, pp. 2, 3 (Exhibit 3), 12 (Table 3), 13].

List of Hazardous Substances Associated with Source

Based on samples collected as part of the EPA Site Assessment Site Inspection, Source No. 1 has been documented to contain two PCB Aroclors (Aroclor-1254 and Aroclor-1260) and three total metals (arsenic, chromium, and lead) [16, pp. 31, 38-39, 46-48; 17, pp. 2-5; 34, pp. 27-30; 37, Table 2 (pp. 1-3 of 3); 38, Table 2 (pp. 1-2 of 2); 42, Table 1 (p. 1-3 of 3); 43, Ta ble 1 (pp. 1-2 of 2); 55, pp. 7-9 (Table 2), 10-11 (Table 3); 56, pp. 6-7 (Table 2), 8-9 (Table 3); 60, pp. 7-9 (Tab le 2); 10-13 (Table 3); 61, pp. 6-7 (Table 2), 8 (Table 3), 10 (Table 3)]. Therefore, the substances Aroc lor-1254, Aroclor-1260, arsenic, chromium, and lead are

considered to be associated with the Debris Pile A source [1, p. 51588, Section 2.2.2]. These hazardous substances are consistent among the on-site sources ( see Source Characterization for Sources 2 through 5). Based on a survey completed by the property owner, the volume of Debris Pile A (Source No. 1) was determined to be approximately 6,413 yd 3 [29, Appendix A (pp. 1 and 2)].

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

On-site observations indicate that no portion of Source No . 1 has a maintained engineered cover or complete runoff control management systems [17, p. 11]. No report of a natural or man-made liner was documented during source sampling activities [17, p. 11]. Therefore, Source No. 1 does not have full containment, and the source yields a containment value of 10 [1, p. 51596 (Table 3-2)].

Table 3 - Hazardous Substances Available to Pathways

Containment Description Containment Factor References

Gas release to air : NS

Particulate release to air : NS

Release to ground water : Based on the lack of liner, a maintained engineered cover, and any complete run-on control and runoff management systems, a Containment Factor Value of 10 has been assigned for release to ground water for Source

No. 1. 10 1, p. 51596, Table 3-2; 17, p. 11

Release via overland migration and/or flood : NS

NS = Not Scored.

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Source No. 1

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1 Hazardous Waste Quantity

The Hazardous Waste Quantity for Source No. 1 was assigne d based on the Volume Factor Value of a “pile” source type [1, p. 51591, Table 2-5, Section 2.4.2. 1.3]. The Hazardous Constituent Quantity and Hazardous Wastestream Quantity Values were not evaluated fo r Source No. 1 because insufficient information was available [1, pp. 51590-51591 (Sections 2.4.2. 1.1 and 2.4.2.1.2, Table 2-5)].

2.4.2.1.1 Hazardous Constituent Quantity

Description

There is insufficient information to evaluate Source No. 1 for Hazardous Constituent Quantity.

Table 4 – Hazardous Constituent Quantity

Hazardous Substance Constituen t Quantity (pounds) References

NS (insufficient information)

Sum (pounds):

Hazardous Constituent Quantity Assigned Value: NS

2.4.2.1.2 Hazardous Wastestream Quantity

Description

There is insufficient information to evaluate Source No. 1 for Hazardous Wastestream Quantity.

Table 5 – Hazardous Wastestream Quantity

Hazardous Wastestream Wastestrea m Quantity (pounds) References

NS (insufficient information)

Sum (pounds):

Sum of Wastestream Quantity/5,000 (1, p. 51591, Table 2-5):

Hazardous Wastestream Quantity Assigned Value : NS

2.4.2.1.3 Volume

Description

Based on sampling results and observations of the material contained within Source No. 1 (Debris Pile A), the areal extent of the source defined as part of this s ource characterization fully encompasses and is larger than

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Source No. 1

the source extent presented in the ERM Debris Pile Eval uation [Figure 2; 29, 70-71, Appendix A (pp. 1-2)]. There, for the purposes of this HRS documentation r ecord, the volume estimate presented for Source No. 1 (Debris Pile A) by ERM in their Debris Pile Evaluation Report is utilized [29, pp. 4-5, Appendix A (pp. 1-2)]. Based on a survey completed by the property owner, the volume of Debris Pile A (Source No. 1) was determined to be approximately 6,413 yd 3 [29, Appendix A (pp. 1-2)].

Table 6 – Volume

Source

Type Description (# drums or dimensions) Units (yd 3 ) References

Pile Debris Pile 6,413 29, 70, Appendix A (pp. 1-2)

The volume of a “pile” source, in yd 3 , is divided by 2.5 to assign a Hazardous Waste Quantity to the source [1, p. 51591, Table 2-5].

Sum (yd 3 ): 6,413

Equation for Assigning Value (1, p. 51591, Table 2-5): 6,413 yd 3 ÷ 2.5 = 2,565.2

Volume Assigned Value: 2,565.2

2.4.2.1.4 Area

Description

The area of Source No. 1 was not scored.

Table 7 – Area

Source Type Units (ft 2 ) References

NS

The area of a “pile” source, in ft 2 , is divided by 13 to assign a Hazardous Waste Quantity to the source [1, p. 51591, Table 2-5].

Area Assigned Value: 0

2.4.2.1.5 Source Hazardous Waste Quantity Value

The Hazardous Waste Quantity Value for Source No. 1 was assigned based on the Volume Factor Value (2,565.2) [1, p. 51591, Table 2-5]. The Hazardous Constituent Quantity and Hazardous Wastestream Quantity Factor Values were not evaluated for Source No. 1 because insufficient in formation was available [1, pp. 51590-51591, Sections 2.4.2.1.1, 2.4.2.1.2].

Highest HWQ value assigned from Ref. 1, Table 2-5: 2,565.2

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Source No. 2

2.2 SOURCE CHARACTERIZATION

2.2.1 SOURCE IDENTIFICATION

Name of Source : Debris Pile B

Number of Source : Source No. 2

Source Type : Pile

Description and Location of Source :

Debris Pile B (Pile - Source No. 2) is located on the undeveloped property identified as the Leeds Metal property, depicted on the Town of Leeds, ME Tax Assesso r’s Map No. 4, as Lot No. 38 [5; 9; 12, pp. 1-2; 19,

p. 1, Fig. 1]. Source No. 2 is located adjacent to the southeastern property boundary (see Figure 2) [14, pp. 5­ 6; 29, p. 70]. The geographic coordinates of Debris Pile B, as measured from its approximate center, are 44°

14 ′ 12.6 ′′ north latitude and 70° 04 ′ 46.6 ′′ west longitude (see Figures 1 and 2) [7].

Between 1969 and 1984, scrap metal recovery processes were conducted on the Leeds Metal property by various entities [18, pp. 1- 2]. The former assistant fire chief of the Town of Leeds, ME stated that cars were transported to the property via trucks for “shredding” [ 26]. He also stated that within a cement building on the property, lead batteries and other auto parts were cl eaned for resale [26]. The former assistant fire chief noted that metal from the shredded cars was salvaged (s ent off the property via railroad), while the upholstery was piled in former gravel excavation pits [26]. He further stated that such materials as “gasoline, diesel, transformer oil, brake fluid, oils, battery aci d, and antifreeze” were dumped on the ground and that approximately 100 ‘barrels’ were staged along the southern property boundary [26]. The former assistant fire chief recalled that the Leeds and Monmouth Fire Depart ments responded to fires at the property, and that gasoline tanks would ignite causing oil-saturated soil to burn [26]. The eastern and southern portions of the Leeds Metal property contained car shredding waste bot h on the ground surface and in piles, including Source No. 2 (Debris Pile B) [14, pp. 2-15]. Debris Pile B is sloped gently east to west from the elevated land surface located west of the railroad tracks (see Figure 2) [14, pp. 5-6]. Debris Pile B is approximately 28 feet high with a flat top portion [14, pp. 5-6]. The top of Debris Pile B contains trees and small bushes [14, pp. 5-6]. The material which comprises Debris Pile B was observed to be consistent with that of several other debris piles on the property, and included rubber, pl astic, and metal debris [14, p. 6].

In November 2003, ERM personnel, wo rking on behalf of the property ow ner, completed an evaluation of four on-site debris piles (Debris Piles A through D) [29, pp. 1-4]. As part of this evaluation, ERM representatives conducted extensiv e test pitting, sampling, and a volume estimation of each pile [29, pp. 1-10, 12-60, 70-74, Appendices A, B, and D]. ERM described De bris Pile B as being “heavily vegetated with trees up to 3 ′′ in diameter in a moist matrix of silt with minor sand and clay, plant matter, metal, rubber, plastic, fabric, and metal oxides” [29, pp. 9-10] . Screening and laboratory analyses of test pit samples collected from Debris Pile B, on behalf of the property owner, i ndicated the presence of four PCBs (Aroclor-1016/Aroclor1242, Aroclor-1248, Aroclor-1254, and Aroclor-1260) and nine total meta ls (antimony, arsenic, cadmium, cobalt, copper, iron, lead, manganese, and nickel) at c oncentrations exceeding state standards [29, pp. 16-35, 65-66, 70, 72; 138, Appendix 1]. ERM estimated the a pproximate volume of Debris Pile B to be 55,600 yd 3
[29, p. 4].

In late fall of 2003, Maine Central Railroad personnel conducted a survey of the four on-site debris piles (Debris Piles A through D) to further refine volume estimates presented earlier by ERM [29, pp. 4-5, 70,

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Source No. 2

Appendix A (p. 3)]. Following the Maine Central Railroa d survey of Debris Pile B, the volume estimate of Debris Pile B was adjusted by ERM to 20,566 yd 3 [29, Appendix A (p. 3)].

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

- Background Concentrations:

Debris Pile B (Source No. 2) is a pile source type; therefore, no background samples are required. However, since the debris pile materials were mixed with local soil material, background surface and subsurface soil samples were collected as part of the EPA Site Assessment Site Inspection [15, pp. 44- 46; 17, pp. 3-4; 34, pp. 20, 30; 75, p.1; 76, p. 1]. On 16 November 2010, as part of the EPA Site Assessment Site Inspection, background soil sampling activities were conducted [15, pp. 44-46; 34, p. 20]. The background surface and subsurface soil samples were collect ed in accordance with the EPA-approved Site-Specific QAPP, dated 26 October 2010 [6; 34, pp. 19-20]. Two background surface soil samples (SS-01 and SS-02) and two background subsurface soil samples (SB-01 and SB-02) we re collected from a residential property located northwest of the Leeds Metal property [9; 12; 15, pp. 44- 46; 34, p. 20; 106, pp. 1-2]. The residential property is located in Leeds, ME, and is depicted on the To wn of Leeds, ME Tax Assessor’s Map No. 4 as Lot No. 55 (see Figure 3b) [9; 106, pp. 1-2]. The background samples were collected from the same 0- to 2-foot depth interval and during the same time period as the source samples presented as part of the Source No. 2 Characterization, and the background and source samples contained similar native materials [15, pp. 44-46; 75, pp. 1, 33-35; 76, pp. 1, 20-22]. Background soil samples SS-01 and SB-01 were submitted to CLP Laboratories for VOC and PCB analyses following SOM01.2 and total metals analysis following ISM01.2, while background soil samples SS-02 and SB-02 were submitted to a CLP Laboratory for total metals analysis following ISM01.2 [15, pp. 44-46; 34, p. 20; 35, p. 1; 40, p. 1; 79, pp. 1-2; 84, pp. 1-2; 89, pp. 1-2]. As part of this HRS documentation record and the evaluation of b ackground concentrations, the following hazardous substances in background samples are presente d: two PCB aroclors (Aroclor-1254 and Aroclor1260), and two total metals (chromium and lead).

Table 8 - Hazardous Substances Asso ciated with Background Samples

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-01 Soil 16 Nov. 2010 Aroclor-1254 42 U μg/Kg 42 μg/Kg 15, p. 44; 34, p. 20; 35, Table 2 (p. 1 of 3); 53, Attachment B (p. 1)

SS-01 Soil 16 Nov. 2010 Aroclor-1260 42 U μg/Kg 42 μg/Kg 15, p. 44; 34, p. 20; 35, Table 2 (p. 1 of 3); 53, Attachment B (p. 1)

SS-02 Soil 16 Nov. 2010 Chromium 1 23.1 (17.9 J) mg/Kg 1.1 mg/Kg 15, pp. 44-45; 34, p. 20; 40, Table 1 (p. 1 of 3); 58, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 2)

SS-02 Soil 16 Nov. 2010 Lead 1 5.1 (5.1 JEB) mg/Kg 1.1 mg/Kg 15, pp. 44-45; 34, p. 20; 40, Table 1 (p. 1 of 3); 58, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 2)

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Source No. 2

Table 8 - Hazardous Substances Associated with Background Samples (Continued)

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SB-01 Soil 16 Nov. 2010 Aroclor-1254 36 U μg/Kg 36 μg/Kg 15, p. 45; 34, p. 20; 35, Table 2 (p. 2 of 3); 53, Attachment B (p. 7)

SB-01 Soil 16 Nov. 2010 Aroclor-1260 36 U μg/Kg 36 μg/Kg 15, p. 45; 34, p. 20; 35, Table 2 (p. 2 of 3); 53, Attachment B (p. 7)

SB-02 Soil 16 Nov. 2010 Chromium 1 35.9 (27.8 J) mg/Kg 1.4 mg/Kg 15, pp. 45-46; 34, p. 20; 40, Table 1 (p. 2 of 3); 58, pp. 8 (Table 2), 10 (Table 3), Attachment B (p. 4)

SB-02 Soil 16 Nov. 2010 Lead 1 5.2
(5.2 JEB) mg/Kg 1.4 mg/Kg 15, pp. 45-46; 34, p. 20; 40, Table 1 (p. 2 of 3); 58, pp. 8 (Table 2), 10 (Table 3), Attachment B (p. 4)

Nov. = November. CRQL = Contract Required Quantitation Limit. μg/Kg = Micrograms per kilogram. mg/Kg = Milligrams per kilogram. U = The compound or element was analyzed for, but not detected. The associated numerical value is the sample-adjusted CRQL [103, p. B-47].J = The associated numerical value is an estimated quantity [40, Table 1 (pp. 1-2 of 3); 103, p. B47]. EB = The compound was also detected in an associated equipment rinsate blank [40, Table 1 (pp. 1­ 2 of 3)]. ( ) = For hazardous substance concentrations, denotes concentration of the compound or element prior to adjustment.

1 Chromium and lead results were qualified as estimated following data review. Chromium had a low bias (serial dilution results exceeded percent difference criteria) and was adjusted by multiplying by the adjustment factor of 1.29 [40, p. 5; 58, pp. 2, 3 (Exhibit 3), 10 (Table 3)]. Lead had a high bias [equipment (rinsate) blank contamination] and was not numerically ad justed [40, p. 4; 58, pp. 2, 3 (Exhibit 3), 10 (Table 3)].

- Source Samples:

On 18 November 2010, as part of the EPA Site Assessm ent Site Inspection, soil/s ource sampling activities of Debris Pile B were conducted [16, pp. 33-35; 34, pp. 27-28]. The surface and subsurface source samples were collected in accordance with the EPA-approved Site -Specific QAPP, dated 26 October 2010 [6]. As part of the Debris Pile B characterization, three surface soil/source samples (SS-34, SS-35, and SS-36) and four subsurface soil/source samples (SB-34, SB-35, SB-36, and field duplicate SB-43) were collected from various places throughout the pile (see Figure 3a) [16, pp. 33-35; 34, pp. 27-28, 58-59, 66-68]. All surface soil samples collected from Debris Pile B as part of the EPA Site Assessment Site Inspection were collected from depths of up to 2 feet bgs [16, pp. 33-35; 34, pp. 27-28; 75, pp. 33-35]. Surface soil/source sample SS-34 was

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Source No. 2

described as dark brown, silty sand, some debris (foam, rubber, metal, fibrous material, and woven material), trace clay, trace organics, and containing a “septic” odor [75, p. 33]. Surface soil/source sample SS-35 was described as dark brown-to-black, silt, major debris (r ubber, fabric/cloth), little fine-to-coarse sand, little clay, trace gravel, trace organics, and containing a “petrole um” odor [75, p. 34]. Su rface soil/source sample SS-36 was described as dark brown, silt, little debris (woven fa bric, metal, and wire), little fine sand, trace mediumto-coarse sand, trace clay, and trace organics [75, p. 35]. Subsurface soil/source sample SB-34 was described as black, silt, little fine sand, little clay, and little debris (rubber, foam, and plastic) [76, p. 20]. Subsurface soil/source sample SB-35 was described as black silt, trace clay, and containing abundant [30 to 40 percent (%)] debris (plastic and foam) [76, p. 21]. S ubsurface soil/source sample SB-36 and field duplicate SB-43 were described as dark brown-to-black, silt, some debr is (metal, foam, cloth, plastic, wire), little clay, trace fine-to-coarse sand, trace organics, and containing a “petroleum” odor [76, p. 22].

Soil/source samples (SS-34, SS-35, SS-36, SB-34, SB- 35, SB-36, and SB-43) were submitted to CLP Laboratories for VOC and PCB analyses following SOM01.2, and total metals analysis following ISM01.2 [16, pp. 33-35; 34, pp. 27-28, 58-59, 66-68; 38, p. 1; 43, p. 1; 82, pp. 1-3; 87, p. 1; 92, p. 1]. The analytical data were validated according to EPA New England Regional Functional Guidelines Tier II requirements (for VOCs, PCBs, and total metals analyses) [38, p. 1; 43, p. 1]. For the purposes of Source No. 2 evaluation and the HRS documentation record, analytical results of three surface soil/source samples (SS-34 through SS-36) and four subsurface soil/source samples (SB-34 through SB-36, and SB-43) confirm the presence of the following hazardous substances: two PCB Aroclors (A roclor-1254 and Aroclor-1260) and two total metals (chromium and lead).

Among the seven selected soil/source samples: Aroclor-1254 was detected at a maximum concentration of 9,300 μg/Kg in surface soil/source sample SS-35, located on the northwestern portion of Source No. 2; Aroclor-1260 was detected at a maximum concentration of 38,000 μg/Kg in subsurface soil/source sample SB-36, located on the southern portion of Source No. 2; chromium was detected at a maximum concentration of 882 mg/Kg in subsurface soil/source sample SB-43, lo cated on the southern portion of Source No. 2; and lead was detected at a maximum concentration of 4, 104 mg/Kg in subsurface soil/source sample SB-43 [16, p. 33-34; 34, pp. 27-28; 38, Table 2 (pp. 1-2 of 2); 43, Tabl e 1 (pp. 1-2 of 2); 56, pp. 6-7 (Table 2), 8-9 (Table 3); 61, pp. 7 (Table 2), 11 (Table 3); Figure 3a].

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Source No. 2

Table 9 - Hazardous Substances Associated with Source No. 2

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-34 Soil/

Source 18 Nov. 2010 Aroclor-1254 1,800 μg/Kg 260 μg/Kg 16, pp. 33-34; 34, p. 27; 38, Table 2 (p. 1 of 2); 56, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 5-6)

Aroclor-1260 2 2,700 (2,700 J) μg/Kg 260 μg/Kg 16, pp. 33-34; 34, p. 27; 38, Table 2 (p. 1 of 2); 56, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 5-6)

Chromium 620 mg/Kg 311 mg/Kg 16, pp. 33-34; 34, p. 27; 43, Table 1 (p. 1 of 2); 61, pp. 6 (Table 2), 8 (Table 3), Attachment B (p. 4)

Lead 1 2,514 (3,620 J) mg/Kg 311 mg/Kg 16, pp. 33-34; 34, p. 27; 43, Table 1 (p. 1 of 2); 61, pp. 6 (Table 2), 8 (Table 3), Attachment B (p. 4)

SS-35 Soil/

Source 18 Nov. 2010 Aroclor-1254 9,300 μg/Kg 930 μg/Kg 16, p. 33; 34, p. 27; 38, Table 2 (p. 1 of 2); 56, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 7­ 8)

Aroclor-1260 2 7,300 (7,300 J) μg/Kg 930 μg/Kg 16, p. 33; 34, p. 27; 38, Table 2 (p. 1 of 2); 56, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 7­ 8)

Chromium 643 mg/Kg 308 mg/Kg 16, p. 33; 34, p. 27; 43, Table 1 (p. 1 of 2); 61, pp. 6 (Table 2), 9 (Table 3), Attachment B (p. 5)

Lead 1 3,458 (4,980 J) mg/Kg 308 mg/Kg 16, p. 33; 34, p. 27; 43, Table 1 (p. 1 of 2); 61, pp. 6 (Table 2), 9 (Table 3), Attachment B (p. 5)

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Source No. 2

Table 9 - Hazardous Substances Associated with Source No. 2 (Continued)

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-36 Soil/

Source 18 Nov. 2010 Aroclor-1254 4,400 μg/Kg 460 μg/Kg 16, p. 33; 34, p. 27; 38, Table 2 (p. 1 of 2); 56, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 9­ 10)

Aroclor-1260 2 3,900 (3,900 J) μg/Kg 460 μg/Kg 16, p. 33; 34, p. 27; 38, Table 2 (p. 1 of 2); 56, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 9­ 10)

Chromium 521 mg/Kg 283 mg/Kg 16, p. 33; 34, p. 27; 43, Table 1 (p. 1 of 2); 61, pp. 6 (Table 2), 9 (Table 3), Attachment B (p. 6)

Lead 2 3,778 (5,440 J) mg/Kg 283 mg/Kg 16, p. 33; 34, p. 27; 43, Table 1 (p. 1 of 2); 61, pp. 6 (Table 2), 9 (Table 3), Attachment B (p. 6)

SB-34 Soil/

Source 18 Nov. 2010 Aroclor-1260 2 3,200 (3,200 J) μg/Kg 490 μg/Kg 16, p. 35; 34, p. 28; 38, Table 2 (p. 2 of 2); 56, pp. 7 (Table 2), 9 (Table 3), Attachment B (pp. 14-15)

Chromium 610 mg/Kg 302 mg/Kg 16, p. 35; 34, p. 28; 43, Table 1 (p. 2 of 2); 61, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 10)

Lead 1 3,528 (5,080 J) mg/Kg 302 mg/Kg 16, p. 35; 34, p. 28; 43, Table 1 (p. 2 of 2); 61, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 10)

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Source No. 2

Table 9 - Hazardous Substances Associated with Source No. 2 (Continued)

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SB-35 Soil/

Source 18 Nov. 2010 Aroclor-1254 2 4,300
(4,300 J) μg/Kg 510 μg/Kg 16, pp. 34-35; 34, p. 28; 38, Table 2 (p. 2 of 2); 56, pp. 7 (Table 2), 9 (Table 3), Attachment B (pp. 16-17)

Aroclor-1260 2 370 (370 J) μg/Kg 51 μg/Kg 16, pp. 34-35; 34, p. 28; 38, Table 2 (p. 2 of 2); 56, pp. 7 (Table 2), 9 (Table 3), Attachment B (pp. 16-17)

Chromium 631 mg/Kg 311 mg/Kg 16, pp. 34-35; 34, p. 28; 43, Table 1 (p. 2 of 2); 61, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 11)

Lead 1 2,694 (3,880 J) mg/Kg 311 mg/Kg 16, pp. 34-35; 34, p. 28; 43, Table 1 (p. 2 of 2); 61, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 11)

SB-36 Soil/

Source 18 Nov. 2010 Aroclor-1254 2,600 μg/Kg 510 μg/Kg 16, p. 34; 34, p. 28; 38, Table 2 (p. 2 of 2); 56, pp. 7 (Table 2), 9 (Table 3), Attachment B (pp. 18-19)

Aroclor-1260 2 38,000 (38,000 J) μg/Kg 5,100 μg/Kg 16, p. 34; 34, p. 28; 38, Table 2 (p. 2 of 2); 56, pp. 7 (Table 2), 9 (Table 3), Attachment B (pp. 18-19)

Chromium 762 mg/Kg 313 mg/Kg 16, p. 34; 34, p. 28; 43, Table 1 (p. 2 of 2); 61, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 12)

Lead 1 3,299 (4,750 J) mg/Kg 313 mg/Kg 16, p. 34; 34, p. 28; 43, Table 1 (p. 2 of 2); 61, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 12)

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Source No. 2

Table 9 - Hazardous Substances Associated with Source No. 2 (Concluded)

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SB-43 Soil/

Source 18 Nov. 2010 Aroclor-1254 2,200 μg/Kg 510 μg/Kg 16, p. 34; 34, p. 28; 38, Table 2 (p. 2 of 2); 56, pp. 7 (Table 2), 9 (Table 3), Attachment B (pp. 20-21)

Aroclor-1260 2 32,000 (32,000 J) μg/Kg 5,100 μg/Kg 16, p. 34; 34, p. 28; 38, Table 2 (p. 2 of 2); 56, pp. 7 (Table 2), 9 (Table 3), Attachment B (pp. 20-21)

Chromium 882 mg/Kg 303 mg/Kg 16, p. 34; 34, p. 28; 43, Table 1 (p. 2 of 2); 61, pp. 7 (Table 2), 11 (Table 3), Attachment B (p. 13)

Lead 1 4,104 (5,910 J) mg/Kg 303 mg/Kg 16, p. 34; 34, p. 28; 43, Table 1 (p. 2 of 2); 61, pp. 7 (Table 2), 11 (Table 3), Attachment B (p. 13)

Nov. = November. CRQL = Contract Required Quantitation Limit. μg/Kg = Micrograms per kilogram. mg/Kg = Milligrams per kilogram.J = The associated numerical value is an estimated quantity [43, Table 1 (pp. 1-2 of 2); 103, p. B47]. ( ) = For hazardous substance concentrations, denot es concentration of the compound or element prior to adjustment. Based on the EPA Fact Sheet, Using Qualified Data to Document an Observed
Release and Observed Contamination , for HRS purposes it is not required to adjust qualified source data. Although the fact sheet was not inte nded for application to source data, it has been applied as a conservative measure in this situ ation to demonstrate the relative increase in contamination in the source samples over background levels [113].

1 Lead results were qualified as estimated following data review. Lead had a high bias (serial dilution results exceeded percent difference criteria) a nd was adjusted by dividing by the adjustment factor of 1.44 [43, pp. 4­ 5; 61, pp. 2-3 (Exhibit 3), 9-11 (Table 3)].

2 Aroclor-1260 was biased low (compound did not meet percent difference criteria in the instrument continuing calibration), and was not adjusted [38, pp. 3-4; 56, pp. 2, 3 (Exhibit 3), 8-9 (Table 3)]. Aroclor1254 was biased low (surrogate spike compounds did not meet recovery criteria) in subsurface soil/source sample SB-35, and was not adjusted [38, pp. 7-8; 56, pp. 2, 3 (Exhibit 3), 10 (Table 3)].

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Source No. 2

Note: Trichloroethene was detected in one subsurf ace soil/source sample (SB-35) at concentrations above CLP reporting limits but below the CRQL [38, Table 1 (p. 1 of 2); 103, Exhibit C (p. C-5), Exhibit D Trace VOA (Section 11.1.4); 104, pp. 1-10; 143, pp. 7 (Table 2), 9 (Table 3)]. Trichloroethene is a common breakdown product of tetrachloroethene [49, pp. 189- 190; 50, pp. 197, 202-203; 51, Section 1 (pp. 8-12, Table 1.1, Figure 1.4), Section 2 (pp. 1-16, Figure 2.2, Figure 2.3, Figure 2.4)].

List of Hazardous Substances Associated with Source

Based on samples collected as part of the EPA Site Assessment Site Inspection, Source No. 2 has been documented to contain two PCB Aroclors (Aroclor-1254 and Aroclor-1260) and two total metals (chromium and lead) [16, pp. 33-35; 34, pp. 27-28; 38, Table 2 (pp. 1-2 of 2); 43, Table 1 (pp. 1-2 of 2); 56, pp. 6-7 (Table 2), 8-9 (Table 3); 61, pp. 6-7 (Table 2), 8- 11 (Table 3)]. Therefore the substances Aroclor-1254, Aroclor-1260, chromium, and lead are considered to be associated with the Debris Pile B source [1, p. 51588, Section 2.2.2]. These hazardous substances are c onsistent among all the on-site sources (see Source Characterization for Sources 1, and 3 through 5). Based on a survey completed by the property owner, the volume of Debris Pile B (Source No. 2) w as determined to be approximately 20,566 yd 3 [29, Appendix A (p. 3)]. As part of the EPA Site Assessment Site In spection, seven surface and subsurface soil/source samples were collected from Debris Pile B [16, pp. 33-35; 34, pp. 27-28].

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

On-site observations indicate that no portion of Source No . 2 has a maintained engineered cover or complete runoff control management systems [17, p. 11]. No report of a natural or man-made liner was documented during source sampling activities [17, p. 11]. Therefore, Source No. 2 does not have full containment, and the source yields a containment value of 10 [1, p. 51596 (Table 3-2)].

Table 10 - Hazardous Substances Available to Pathways

Containment Description Containment Factor References

Gas release to air : NS

Particulate release to air : NS

Release to ground water : Based on the lack of a liner, a maintained engineered cover, and any complete run-on control and runoff management systems, a Containment Factor Value of 10 has been assigned for release to ground water for Source

No. 2. 10 1, p. 51596, Table 3-2; 17, p. 11

Release via overland migration and/or flood : NS

NS = Not Scored.

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Source No. 2

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1 Hazardous Waste Quantity

The Hazardous Waste Quantity for Source No. 2 was assigne d based on the Volume Factor Value of a “pile” source type [1, p. 51591 (Table 2-5, Section 2.4.2.1. 3)]. The Hazardous Constituent Quantity and Hazardous Wastestream Quantity Values were not evaluated fo r Source No. 2 because insufficient information was available [1, pp. 51590-51591 (Sections 2.4.2. 1.1 and 2.4.2.1.2, Table 2-5)].

2.4.2.1.1 Hazardous Constituent Quantity

Description

There is insufficient information to evaluate Source No. 2 for Hazardous Constituent Quantity.

Table 11 – Hazardous Constituent Quantity

Hazardous Substance Constituen t Quantity (pounds) References

NS (insufficient information)

Sum (pounds):

Hazardous Constituent Quantity Assigned Value: NS

2.4.2.1.2 Hazardous Wastestream Quantity

Description

There is insufficient information to evaluate Source No. 2 for Hazardous Wastestream Quantity.

Table 12 – Hazardous Wastestream Quantity

Hazardous Wastestream Wastestrea m Quantity (pounds) References

NS (insufficient information)

Sum (pounds):

Sum of Wastestream Quantity/5,000 (1, p. 51591, Table 2-5):

Hazardous Wastestream Quantity Assigned Value : NS

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Source No. 2

2.4.2.1.3 Volume

Description

For the purposes of this HRS documentation record, th e volume estimate presented for Source No. 2 (Debris Pile B) by ERM in their Debris Pile Evaluation Report is utilized [29, pp. 4-5, Appendix A (p. 3)]. Based on a survey completed by the property owner, the volume of Debris Pile B (Source No. 2) was determined to be approximately 20,566 yd 3 [29, Appendix A (p. 3)].

Table 13 – Volume

Source

Type Description (# drums or dimensions) Units (yd 3 ) References

Pile Debris Pile 20,566 29, Appendix A (p. 3)

The volume of a “pile” source, in yd 3 , is divided by 2.5 to assign a Hazardous Waste Quantity to the source [1, p. 51591, Table 2-5].

Sum (yd 3 ): 20,566

Equation for Assigning Value (1, p. 51591, Table 2-5): 20,566 yd 3 ÷ 2.5 = 8,226.4

Volume Assigned Value: 8,226.4

2.4.2.1.4 Area

Description

The area of Source No. 2 was not scored.

Table 14 – Area

Source Type Units (ft 2 ) References

NS

The area of a “pile” source, in ft 2 , is divided by 13 to assign a Hazardous Waste Quantity to the source [1, pp. 51590-51591, Table 2-5].

Area Assigned Value: 0

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Source No. 2

2.4.2.1.5 Source Hazardous Waste Quantity Value

The Hazardous Waste Quantity Value for Source No. 2 was assigned based on the Volume Factor Value (8,226.4) [1, p. 51591, Table 2-5]. The Hazardous Constituent Quantity and Hazardous Wastestream Quantity Factor Values were not evaluated for Source No. 2 because insufficient in formation was available [1, p. 51591, Sections 2.4.2.1.1, 2.4.2.1.2].

Highest HWQ value assigned from Ref. 1, Table 2-5: 8,226.4

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Source No. 3

2.2 SOURCE CHARACTERIZATION

2.2.1 SOURCE IDENTIFICATION

Name of Source : Debris Pile C

Number of Source : Source No. 3

Source Type : Pile

Description and Location of Source (with reference to a map of the site) :

Debris Pile C (Pile - Source No. 3) is located on the undeveloped property identified as the Leeds Metal property, depicted on the Town of Leeds, ME Tax Assesso r’s Map No. 4, as Lot No. 38 [5; 9; 12, pp. 1-2; 19,

p. 1, Fig. 1]. Source No. 3 is located south of the pond, west of Debris Pile B (see Figure 2) [14, p. 6; 29, p. 70]. The geographic coordinates of Debris Pile C, as measured from its approximate center, are 44° 14 ′ 12.5 ′′

north latitude and 70° 04 ′ 50.4 ′′ west longitude (see Figures 1 and 2) [7].

Between 1969 and 1984, scrap metal recovery processes were conducted on the Leeds Metal property by various entities [18, pp. 1- 2]. The former assistant fire chief of the Town of Leeds, ME stated that cars were transported to the property via trucks for “shredding” [ 26]. He also stated that within a cement building on the property, lead batteries and other auto parts were cl eaned for resale [26]. The former assistant fire chief noted that metal from the shredded cars was salvaged (s ent off the property via railroad), while the upholstery was piled in former gravel excavation pits [26]. He further stated that such materials as “gasoline, diesel, transformer oils, brake fluid, oils, battery aci d, and antifreeze” were dumped on the ground and that approximately 100 ‘barrels’ were staged along the southern property boundary [26]. The former assistant fire chief recalled that the Leeds and Monmouth Fire Depart ments responded to fires at the property, and that gasoline tanks would ignite causing oil-saturated soil to burn [26]. The eastern and southern portions of the Leeds Metal property contained car shredding waste bot h on the ground surface and in piles, including Source No. 3 (Debris Pile C) (see Figure 2) [14, pp. 2-15]. Debr is Pile C is smaller than Debris Pile B and is topped by small trees [14, p. 6]. The top of Debris Pile C is sloped more steeply, and is approximately 20 feet high at its highest point (western side) [14, p. 6]. The materi al which comprises Debris Pile C was observed to be

consistent with that of several othe r debris piles on the property, and incl uded rubber, plastic, and metal debris [14, p. 6].

In November 2003, ERM personnel, wo rking on behalf of the property ow ner, completed an evaluation of four on-site debris piles (Debris Piles A through D) [29, pp. 1-4]. As part of this evaluation, ERM representatives conducted extensiv e test pitting, sampling, and a volume estimation of each pile [29, pp. 1-10, 12-60, 70-74, Appendices A, B, and D]. ERM described De bris Pile C as being “heavily vegetated with trees up to 3 ′′ in diameter in a moist matrix of silt and minor sand, plant matter, oxidized metal, occasional metal pieces, metal oxides, rubber, a nd plastic” [29, pp. 9-10]. Screening and laboratory analyses of test pit samples collected from Debris Pile C, on behalf of the propert y owner, indicated the presence of two PCBs (Aroclor1254 and Aroclor-1260) and seven metals (arsenic, cadmi um, copper, iron, lead, manganese, and nickel) at concentrations exceeding state standards [29, pp. 36-38, 66-67, 70, 73; 138, Appendix 1]. ERM estimated the approximate volume of Debris Pile C to be 10,400 yd 3 [29, p. 4].

In late fall of 2003, Maine Central Railroad personnel conducted a survey of the four on-site debris piles (Debris Piles A through D) to further refine volume estimates presented earlier by ERM [29, pp. 4-5]. Following the Maine Central Railroad survey of Debris Pile C, the volume estimate of Debris Pile C was adjusted by ERM to 1,727 yd 3 [29, Appendix A (p. 4)].

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Source No. 3

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

- Background Concentrations:

Debris Pile C (Source No. 3) is a pile source type; therefore, no background samples are required. However, since the debris pile materials were mixed with local soil material, background surface and subsurface soil samples were collected as part of the EPA Site Assessment Site Inspection [15, pp. 44- 46; 17, pp. 3-4; 34, pp. 20, 30; 75, p. 1; 76, p.1]. On 16 November 2010, as part of the EPA Site Assessment Site Inspection, background soil sampling activities were conducted [15, pp. 44-46; 34, p. 20]. The background surface and subsurface soil samples were collect ed in accordance with the EPA-approved Site-Specific QAPP, dated 26 October 2010 [6; 34, pp. 19-20]. Two background surface soil samples (SS-01 and SS-02) and two background subsurface soil samples (SB-01 and SB-02) we re collected from a residential property located northwest of the Leeds Metal property [9; 12; 15, pp. 44- 46; 34, p. 20; 106, pp. 1-2]. The residential property is located in Leeds, ME, and is depicted on the To wn of Leeds, ME Tax Assessor’s Map No. 4 as Lot No. 55 (see Figure 3b) [9; 106, pp. 1-2]. The background samples were collected from a similar depth and during the same time period as the source samples presented as part of the Source No. 3 Characterization, and the background and source samples contained similar native mate rials [15, pp. 44-46; 75, pp. 1, 31-32; 76, pp. 1, 18-19]. Background soil samples SS-01 and SB-01 were submitted to CLP Laboratories for VOC and PCB analyses following SOM01.2 and total metals analysis following ISM01.2, while background soil samples SS-02 and SB-02 were submitted to a CLP Laboratory for total metals analysis following ISM01.2 [15, pp. 44-46; 34, p. 20; 35, p. 1; 40, p. 1; 79, pp. 1-2; 84, pp. 1-2; 89, pp. 1-2]. As part of this HRS documentation record and the evaluation of background concentrations, the following hazardous substances in background samples are presented: two PCB aroclors (Aroclor- 1254 and Aroclor-1260), and one total metal (lead).

Table 15 - Hazardous Substances Asso ciated with Background Samples

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-01 Soil 16 Nov. 2010 Aroclor-1254 42 U μg/Kg 42 μg/Kg 15, p. 44; 34, p. 20; 35, Table 2 (p. 1 of 3); 53, Attachment B (p. 1)

SS-01 Soil 16 Nov. 2010 Aroclor-1260 42 U μg/Kg 42 μg/Kg 15, p. 44; 34, p. 20; 35, Table 2 (p. 1 of 3); 53, Attachment B (p. 1)

SB-01 Soil 16 Nov. 2010 Aroclor-1254 36 U μg/Kg 36 μg/Kg 15, p. 45; 34, p. 20; 35, Table 2 (p. 2 of 3); 53, Attachment B (p. 7)

SB-01 Soil 16 Nov. 2010 Aroclor-1260 36 U μg/Kg 36 μg/Kg 15, p. 45; 34, p. 20; 35, Table 2 (p. 2 of 3); 53, Attachment B (p. 7)

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Source No. 3

Table 15 - Hazardous Substances Associated with Background Samples (Continued)

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SB-02 Soil 16 Nov. 2010 Lead 1 5.2 (5.2 JEB) mg/Kg 1.4 mg/Kg 15, pp. 45-46; 34, p. 20; 40, Table 1 (p. 2 of 3); 58, pp. 8 (Table 2), 10 (Table 3), Attachment B (p. 4)

Nov. = November. CRQL = Contract Required Quantitation Limit. μg/Kg = Micrograms per kilogram. mg/Kg = Milligrams per kilogram. U = The compound or element was analyzed for, but not detected. The associated numerical value is the sample-adjusted CRQL [103, p. B-47].J = The associated numerical value is an estimated quantity [40, Table 1 (pp. 1-2 of 3); 103, p. B47]. EB = The compound was also detected in an associat ed equipment rinsate blank [40, Table 1 (p. 2 of 3)]. ( ) = For hazardous substance concentrations, denotes concentration of the compound or element prior to adjustment.

1 Lead results were qualified as estimated following data review. Lead had a high bias [equipment (rinsate) blank contamination] and was not numerically adjusted [40, p. 4; 58, pp. 2, 3 (Exhibit 3), 10 (Table 3)].

- Source Samples:

On 16 November 2010, as part of the EPA Site Assessm ent Site Inspection, soil/s ource sampling activities of Debris Pile C were conducted [15, p. 48; 16, p. 2; 34, p. 21]. Th e surface and subsurface source samples were

collected in accordance with the EPA -approved Site-Specific QAPP, dated 26 October 2010 [6]. As part of the Debris Pile C characterization, two surface so il/source (SS-32 and SS-33) and two subsurface soil/source (SB-32 and SB-33) samples were collected from two locations on Source No. 3 (see Figure 3a) [15, p. 48; 16,

p. 2; 34, pp. 21, 58, 66]. Surface soil samples collected from Debris Pile C as part of the EPA SI were collected from depths of up to 2 feet bgs [75, pp. 31-32]. Surface soil/source sample SS-32 is described as dark brown-to-black, fine sand, some debris (metal, pl astic, wire coating, rubber, and chrome), little silt, trace medium-to-coarse sand, trace clay, and trace organics [75, p. 31]. Surface soil/source sample SS-33 is described as dark brown-to-black, silty sand, some de bris (plastic, rubber, metal), trace fine gravel, trace organics [75, p. 32]. Subsurface soil/source sample SB -32 was described as dark brown-to-black, fine-tomedium sand, some silt, some debris (wire coating, woven fabric, metal, rubber, wire, foam, plastic, and linoleum), trace coarse sand, trace fine gravel, trace cl ay [76, p. 18]. Subsurface soil/source sample SB-33 was described as dark brown-to-black, silty sand, some debris (wire, rubber, foam, metal, and plastic), and trace clay [76, p. 19].

Soil/source samples (SS-32, SS-33, SB-32, and SB-33) were submitted to CLP Laboratories for VOC and PCB analyses following SOM01.2, and total metals analys is following ISM01.2 [15, p. 48; 16, p. 2; 34, pp. 58, 66; 35, p. 1; 40, p.1; 79, pp. 1-4; 84, pp. 1-2; 89, pp. 1-2]. The analytical data were validated according to EPA New England Regional Functional Guidelines Tier II requirements (for VOCs, PCBs, and total metals analyses) [35, p. 1; 40, p.1]. For the purposes of Source No. 3 evaluation and the HRS documentation record, analytical results of two surface soil/source samples (SS-32 and SS-33) and two subsurface soil/source

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samples (SB-32 and SB-33) confirm the presence of the following hazardous substances: two PCB Aroclors (Aroclor-1254 and Aroclor-1260) and one total metal (lead).

Among the four selected source samples: Aroclor-1254 was detected at a maximum concentration of 5,700 μg/Kg in surface source sample SS-32, located on the northern portion of Source No. 3; Aroclor-1260 was detected at a maximum concentration of 2,700 μg/K g in subsurface source sample SB-33, located on the southern portion of Source No. 3; and lead was detected at a maximum concentration of 48.1 mg/Kg in surface source sample SS-33, located on the southern portion of Source No. 3 [15, p. 48; 16, p. 2; 34, p. 21; 35, Table 2 (pp. 1-2 of 3); 40, Table 1 (pp. 2-3 of 3); 53, pp. 7-8 (Table 2), 11 (Table 3); 58, pp. 8-9 (Table 2), 11 (Table 3)].

Table 16 - Hazardous Substances Associated with Source No. 3

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-32 Soil/

Source 16 Nov. 2010

Aroclor-1254 5,700 μg/Kg 420 μg/Kg 15, p. 48; 16, p. 2; 34, p. 21; 35, Table 2 (p. 1 of 3); 53, pp. 7 (Table 2), 11 (Table 3), Attachment B (pp. 3-4)

Aroclor-1260 2 450 (4,500 J) μg/Kg 420 μg/Kg 15, p. 48; 16, p. 2; 34, p. 21; 35, Table 2 (p. 1 of 3); 53, pp. 7 (Table 2), 11 (Table 3), Attachment B (pp. 3-4)

SS-33 Soil/

Source 16 Nov. 2010

Aroclor-1254 2,200 μg/Kg 410 μg/Kg 15, p. 48; 34, p. 21; 35, Table 2 (p. 1 of 3); 53, pp. 7 (Table 2), 11 (Table 3), Attachment B (pp. 5-6)

Aroclor-1260 2,500 μg/Kg 410 μg/Kg 15, p. 48; 34, p. 21; 35, Table 2 (p. 1 of 3); 53, pp. 7 (Table 2), 11 (Table 3), Attachment B (pp. 5-6)

Lead 1 48.1 (69.2 JEB) mg/Kg 1.4 mg/Kg 15, p. 48; 34, p. 21; 40, Table 1 (p. 2 of 3); 58, pp. 8 (Table 2), 11 (Table 3), Attachment B (p. 7)

SB-32 Soil/

Source 16 Nov. 2010

Aroclor-1254 3,600 μg/Kg 860 μg/Kg 16, p. 2; 34, p. 21; 35, Table 2 (p. 2 of 3); 53, pp. 8 (Table 2), 11 (Table 3), Attachment B (pp. 8-9)

Lead 1 29.7 (42.8 JEB) mg/Kg 1.3 mg/Kg 16, p. 2; 34, p. 21; 40, Table 1 (p. 3 of 3); 58, pp. 9 (Table 2), 11 (Table 3), Attachment B (p. 8)

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Source No. 3

Table 16 - Hazardous Substances Associated with Source No. 3 (Concluded)

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SB-33 Soil/

Source 16 Nov. 2010

Aroclor-1254 2,700 μg/Kg 860 μg/Kg 16, p. 2; 34, p. 21; 35, Table 2 (p. 2 of 3); 53, pp. 8 (Table 2), 11 (Table 3), Attachment B (pp. 10-11)

Aroclor-1260 2,700 μg/Kg 860 μg/Kg 16, p. 2; 34, p. 21; 35, Table 2 (p. 2 of 3); 53, pp. 8 (Table 2), 11 (Table 3), Attachment B (pp. 10-11)

Nov. = November. CRQL = Contract Required Quantitation Limit. μg/Kg = Micrograms per kilogram. mg/Kg = Milligrams per kilogram.J = The associated numerical value is an estimated quantity [40, Table 1 (pp. 2-3 of 3); 103, p. B47]. EB = The compound was also detected in an associated equipment rinsate blank [40, Table 1 (pp. 2­ 3 of 3)]. ( ) = For hazardous substance concentrations, de notes concentration of the compound or element prior to adjustment. Based on the EPA Fact Sheet, Using Qualified Data to Document an Observed
Release and Observed Contamination , for HRS purposes it is not required to adjust qualified source data. Although the fact sheet was not inte nded for application to source data, it has been applied as a conservative measure in this situation to demonstrate the relative increase in contamination in the source samples over background levels [113].

1 Lead had a high bias [equipment (rinsate) blank contamination] in soil/source samples SS-33 and SB-32, and was adjusted by dividing by the adjustment factor of 1.44 [40, p. 4; 58, pp. 2, 3 (Exhibit 3), 11-12 (Table 3)].

2 Aroclor-1260 had an unknown bias (dual column correlati on did not meet percent difference criteria) in surface soil/source sample SS-32 and was adjusted by dividing by the adjustment factor of 10 [35, p. 11; 53, pp. 2, 3 (Exhibit 3), p. 11 (Table 3)].

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Source No. 3

List of Hazardous Substances Associated with Source

Based on samples collected as part of the EPA Site Assessment Site Inspection, Source No. 3 has been documented to contain two PCB Aroclors (Aroclor-1254 and Aroclor-1260) and one total metal (lead) [15, p. 48; 16, p. 2; 34, p. 21; 35, Table 2 (pp. 1-2 of 3); 40, Table 1 (pp. 2-3 of 3); 53, pp. 7-8 (Table 2), 11 (Table 3); 58, pp. 8-9 (Table 2), 11 (Table 3)]. Therefor e the substances Aroclor-1254, Aroclor-1260, and lead are

considered to be associated with the Debris Pile C source [1, p. 51588, Section 2.2.2]. These hazardous substances are consistent among all the on-site sources (see Source Characterization for Sources 1, 2, 4, and 5). Based on a survey completed by the property owner, the volume of Debris Pile C (Source No. 3) was determined to be approximately 1,727 yd 3 [29, Appendix A (p. 4)]. As part of the EPA Site Assessment Site Inspection, four surface and subsurface soil/source samples we re collected from Debris Pile C [15, p. 48; 16,

p. 2; 34, p. 21].

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

On-site observations indicate that no portion of Source No . 3 has a maintained engineered cover or complete runoff control management systems [17, p. 11]. No report of a natural or man-made liner was documented during source sampling activities [17, p. 11]. Therefore, Source No. 3 does not have full containment, and the source yields a containment value of 10 [1, p. 51596 (Table 3-2)].

Table 17 - Hazardous Substances Available to Pathways

Containment Description Containment Factor References

Gas release to air : NS

Particulate release to air : NS

Release to ground water : Based on the lack of a liner, a maintained engineered cover, and any complete run-on control and runoff management systems, a Containment Factor Value of 10 has been assigned for release to ground water for Source

No. 3. 10 1, p. 51596, Table 3-2; 17, p. 11

Release via overland migration and/or flood : NS

NS = Not Scored.

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Source No. 3

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1 Hazardous Waste Quantity

The Hazardous Waste Quantity for Source No. 3 was assigne d based on the Volume Factor Value of a “pile” source type [1, p. 51591, Table 2-5, Section 2.4.2. 1.3]. The Hazardous Constituent Quantity and Hazardous Wastestream Quantity Values were not evaluated fo r Source No. 3 because insufficient information was available [1, pp.51590-51591 (Sections 2.4.2.1.1 and 2.4.2.1.2, Table 2-5)].

2.4.2.1.1 Hazardous Constituent Quantity

Description

There is insufficient information to evaluate Source No. 3 for Hazardous Constituent Quantity.

Table 18 – Hazardous Constituent Quantity

Hazardous Substance Constituen t Quantity (pounds) References

NS (insufficient information)

Sum (pounds):

Hazardous Constituent Quantity Assigned Value: NS

2.4.2.1.2 Hazardous Wastestream Quantity

Description

There is insufficient information to evaluate Source No. 3 for Hazardous Wastestream Quantity.

Table 19 – Hazardous Wastestream Quantity

Hazardous Wastestream Wastestrea m Quantity (pounds) References

NS (insufficient information)

Sum (pounds):

Sum of Wastestream Quantity/5,000 (1, p. 51591, Table 2-5):

Hazardous Wastestream Quantity Assigned Value : NS

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2.4.2.1.3 Volume

Description

For the purposes of this HRS documentation record, th e volume estimate presented for Source No. 3 (Debris Pile C) by ERM in their Debris Pile Evaluation Report is utilized [29, pp. 4-5, Appendix A (p. 4)]. Based on a survey completed by the property owner, the volume of Debris Pile C (Source No. 3) was determined to be approximately 1,727 yd 3 [29, Appendix A (p. 4)].

Table 20 – Volume

Source

Type Description (# drums or dimensions) Units (yd 3 ) References

Pile Debris Pile 1,727 29, Appendix A (p. 4)

The volume of a “pile” source, in yd 3 , is divided by 2.5 to assign a Hazardous Waste Quantity to the source [1, p. 51591, Table 2-5].

Sum (yd 3 ): 1,727

Equation for Assigning Value (1, p. 51591, Table 2-5): 1,727 yd 3 ÷ 2.5 = 690.8

Volume Assigned Value: 690.8

2.4.2.1.4 Area

Description

The area of Source No. 3 was not scored.

Table 21 – Area

Source Type Units (ft 2 ) References

NS

The area of a “pile” source, in ft 2 , is divided by 13 to assign a Hazardous Waste Quantity to the source [1,

p. 51591, Table 2-5]. Area Assigned Value: 0

2.4.2.1.5 Source Hazardous Waste Quantity Value

The Hazardous Waste Quantity Value for Source No. 3 was assigned based on the Volume Factor Value (690.8) [1, p. 51591, Table 2-5]. The Hazardous C onstituent Quantity and Hazardous Wastestream Quantity

Factor Values were not evaluated for Source No. 3 b ecause insufficient information was available [1, p. 51591, Sections 2.4.2.1.1, 2.4.2.1.2].

Highest HWQ value assigned from Ref. 1, Table 2-5: 690.8

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Source No. 4

2.2 SOURCE CHARACTERIZATION

2.2.1 SOURCE IDENTIFICATION

Name of Source : Debris Pile D

Number of Source : Source No. 4

Source Type : Pile

Description and Location of Source :

Debris Pile D (Pile - Source No. 4) is located on the undeveloped property identified as the Leeds Metal property, depicted on the Town of Leeds, ME Tax Assesso r’s Map No. 4, as Lot No. 38 [5; 9; 12, pp. 1-2; 19,

p. 1, Fig. 1]. Source No. 4 is located south of De bris Pile C near the south-central property boundary (see Figure 2) [14, pp. 6-7; 29, p. 70]. The geographic coordinates of Debris Pile D, as measured from its approximate center, are 44° 14 ′ 09.9 ′′ north latitude and 70° 04 ′ 50.3 ′′ west longitude (see Figures 1 and 2) [7].

Between 1969 and 1984, scrap metal recovery processes were conducted on the Leeds Metal property by various entities [18, pp. 1- 2]. The former assistant fire chief of the Town of Leeds, ME stated that cars were transported to the property via trucks for “shredding” [ 26]. He also stated that within a cement building on the property, lead batteries and other auto parts were cl eaned for resale [26]. The former assistant fire chief noted that metal from the shredded cars was salvaged (s ent off the property via railroad), while the upholstery was piled in former gravel excavation pits [26]. He further stated that such materials as “gasoline, diesel, transformer oil, brake fluid, oils, battery aci d, and antifreeze” were dumped on the ground and that approximately 100 ‘barrels’ were staged along the southern property boundary [26]. The former assistant fire chief recalled that the Leeds and Monmouth Fire Depart ments responded to fires at the property, and that gasoline tanks would ignite causing oil-saturated soil to burn [26]. The eastern and southern portions of the Leeds Metal property contained car shredding waste bot h on the ground surface and in piles, including Source No. 4 (Debris Pile D) [14, pp. 2-15]. Debris Pile D is oriented east to west, with steeply sloped faces on the northern, southern, and western sides of the pile [14, pp. 6-7]. Debris Pile D is approximately 44 feet above the ground surface along the western edge of the pile , and approximately 29 feet above the ground surface along the eastern edge of the pile [14, pp. 6-7]. The material which comprised Debris Pile D was observed to be consistent with several other debris piles on the property, and included rubber, plastic, and metal debris [14, p. 7].

In November 2003, ERM personnel, wo rking on behalf of the property ow ner, completed an evaluation of four on-site debris piles (Debris Piles A through D) [29, pp. 1-4]. As part of this evaluation, ERM representatives conducted extensiv e test pitting, sampling, and a volume estimation of each pile [29, pp. 1-10, 12-60, 70-74, Appendices A, B, and D]. ERM described D as being “unvegetated, relatively dry pile with minor sand, silt and clay, metal oxides, oxidized metal, rubber, plastic, and fabric” [29, pp. 9-10]. Screening and laboratory analyses of test pit samples collected from Debris Pile D, on behalf of the property owner, indicated the presence of two PCB aroclors (Arocl or-1254 and Aroclor-1260) a nd six metals (arsenic, cadmium, cobalt, copper, lead, and nickel) at concentr ations exceeding state standards [29, pp. 39-60, 67-68, 70, 74; 138, Appendix 1]. ERM estimated the appr oximate volume of Debris Pile D to be 55,500 yd 3 [29, pp. 4].

In late fall of 2003, Maine Central Railroad personnel conducted a survey of the four on-site debris piles (Debris Piles A through D) to further refine volume estimates presented earlier by ERM [29, pp. 4-5, 70,

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Source No. 4

Appendix A (p. 5)]. Following the Maine Central Railroa d survey of Debris Pile D, the volume estimate of Debris Pile D was adjusted by ERM to 11,280 yd 3 [29, Appendix A (p. 5)].

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

- Background Concentrations:

Debris Pile D (Source No. 4) is a pile source type; therefore, no background samples are required. However, since the debris pile materials were mixed with local soil material, background surface and subsurface soil samples were collected as part of the EPA Site Assessment Site Inspection [15, pp. 44- 46; 17, pp. 3-4; 34, pp. 20, 30; 75, p. 1; 76, p.1]. On 16 November 2010, as part of the EPA Site Assessment Site Inspection, background soil sampling activities were conducted [15, pp. 44-46; 34, p. 20]. The background surface and subsurface soil samples were collect ed in accordance with the EPA-approved Site-Specific QAPP, dated 26 October 2010 [6; 34, pp. 19-20]. Two background surface soil samples (SS-01 and SS-02) and two background subsurface soil samples (SB-01 and SB-02) we re collected from a residential property located northwest of the Leeds Metal property [9; 12; 15, pp. 44- 46; 34, p. 20; 106, pp. 1-2]. The residential property is located in Leeds, ME, and is depicted on the To wn of Leeds, ME Tax Assessor’s Map No. 4 as Lot No. 55 (see Figure 3b) [9; 106, pp. 1-2]. The background samples were collected from a similar depth and during the same time period as the source samples presented as part of the Source No. 4 Characterization, and the background and source samples contained similar native mate rials [15, pp. 44-46; 75, pp. 1, 27-30; 76, pp. 1, 14-17]. Background soil samples SS-01 and SB-01 were submitted to CLP Laboratories for VOC and PCB analyses following SOM01.2 and total metals analysis following ISM01.2, while background soil samples SS-02 and SB-02 were submitted to a CLP Laboratory for total metals analysis following ISM01.2 [15, pp. 44-46; 34, p. 20; 35, p. 1; 40, p. 1; 79, pp. 1-2; 84, pp. 1-2; 89, pp. 1-2]. As part of this HRS documentation record and the evaluation of background concentrations, the following hazardous substances in background samples are presented: one VOC (PCE), two PCB aroclo rs (Aroclor-1254 and Aroclor-1260), and three total metals (arsenic, chromium, and lead).

Table 22 - Hazardous Substances Asso ciated with Background Samples

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-01 Soil 16 Nov. 2010 PCE 4.9 U μg/Kg 4.9 μg/Kg 15, p. 44; 34, p. 20; 35, Table 1 (p. 1 of 3); 112, p. 3 (Table 1), Attachment A (p. 2)

SS-01 Soil 16 Nov. 2010 Aroclor-1254 42 U μg/Kg 42 μg/Kg 15, p. 44; 34, p. 20; 35, Table 2 ( p. 1 of 3); 53, Attachment B (p. 1)

SS-01 Soil 16 Nov. 2010 Aroclor-1260 42 U μg/Kg 42 μg/Kg 15, p. 44; 34, p. 20; 35, Table 2 ( p. 1 of 3); 53, Attachment B (p. 1)

SS-02 Soil 16 Nov. 2010 Arsenic 4.4 mg/Kg 1.1 mg/Kg 15, p. 44; 34, p. 20; 40, Table 1 (p. 1 of 3); 58, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 1)

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Table 22 - Hazardous Substances Associated with Background Samples (Continued)

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-02 Soil 16 Nov. 2010 Chromium 1 23.1 (17.9 J) mg/Kg 1.1 mg/Kg 15, pp. 44-45; 34, p. 20; 40, Table 1 (p. 1 of 3); 58, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 2)

SS-02 Soil 16 Nov. 2010 Lead 1 5.1 (5.1 JEB) mg/Kg 1.1 mg/Kg 15, pp. 44-45; 34, p. 20; 40, Table 1 (p. 1 of 3); 58, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 2)

SB-01 Soil 16 Nov. 2010 PCE 3.6 U μg/Kg 3.6 μg/Kg 15, p. 45; 34, p. 20; 35, Table 1 (p. 2 of 3); 112, p. 4 (Table 1), Attachment A (p. 18)

SB-01 Soil 16 Nov. 2010 Aroclor-1254 36 U μg/Kg 36 μg/Kg 15, p. 45; 34, p. 20; 35, Table 2 (p. 2 of 3); 53, Attachment B (p. 7)

SB-01 Soil 16 Nov. 2010 Aroclor-1260 36 U μg/Kg 36 μg/Kg 15, p. 45; 34, p. 20; 35, Table 2 (p. 2 of 3); 53, Attachment B (p. 7)

SB-02 Soil 16 Nov. 2010 Arsenic 8.4 mg/Kg 1.4 mg/Kg 15, pp. 45-46; 34, p. 20; 40, Table 1 (p. 2 of 3); 58, pp. 8 (Table 2), 10 (Table 3), Attachment B (p. 4)

SB-02 Soil 16 Nov. 2010 Chromium 1 35.9 (27.8 J) mg/Kg 1.4 mg/Kg 15, pp. 45-46; 34, p. 20; 40, Table 1 (p. 2 of 3); 58, pp. 8 (Table 2), 10 (Table 3), Attachment B (p. 4)

SB-02 Soil 16 Nov. 2010 Lead 1 5.2
(5.2 JEB) mg/Kg 1.4 mg/Kg 15, pp. 45-46; 34, p. 20; 40, Table 1 (p. 2 of 3); 58, pp. 8 (Table 2), 10 (Table 3), Attachment B (p. 4)

PCE = Tetrachloroethene.

Nov. = November. CRQL = Contract Required Quantitation Limit. μg/Kg = Micrograms per kilogram. mg/Kg = Milligrams per kilogram.

U = The compound or element was analyzed for, but not detected. The associated numerical value is the sample-adjusted CRQL [103, p. B-47].

J = The associated numerical value is an estimated quantity [40, Table 1 (pp. 1-2 of 3); 103, p. B47].

EB = The compound was also detected in an associated equipment rinsate blank [40, Table 1 (pp. 1­ 2 of 3)]. ( ) = For hazardous substance concentrations, denotes concentration of the compound or element prior to adjustment.

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1 Chromium and lead results were qualified as estimated following data review. Chromium had a low bias (serial dilution results exceeded percent difference criteria) and was adjusted by multiplying by the adjustment factor of 1.29 [40, p. 5; 58, pp. 2, 3 (Exhibit 3), 10 (Table 3)]. Lead had a high bias [equipment (rinsate) blank contamination] and was not numerically ad justed [40, p. 4; 58, pp. 2, 3 (Exhibit 3), 10 (Table 3)].

- Source Samples:

On 9 November 2010, as part of the EPA Site Assessm ent Site Inspection, soil/source sampling activities of Debris Pile D were conducted [14, pp. 46-48; 15, pp. 2-3; 34, pp. 12-13]. The surface and subsurface soil/source samples were collected in accordance with the EPA-approved Site-Specific QAPP, dated 26 October 2010 [6]. As part of the Debris Pile D characterization, four surface soil/source samples (SS-28, SS29, SS-30, and SS-31) and four subsurface soil/source samples (SB-28, SB-29, SB-30, and SB-31) were collected from various places throughout Source No. 4 (see Figure 3a) [14, pp. 46-48; 15, pp. 2-3; 34, pp. 12­ 13, 57-58, 65-66]. Surface soil/source sample SS-28 was desc ribed as medium brown-to-yellow brown, silty sand, major debris (metal, rubber, foam, plastic, wires, wire coating, and slag), trace clay, and trace organics [75, p. 27]. Surface soil/source sample SS-29 was described as medium brown, silty sand, abundant/major debris (plastic, wire, metal, rubber, foam, wire coa ting, and slag), trace fine gravel, trace clay, and trace organics [75, p. 28]. Surface soil/source sample SS-30 was described as dark brown, silty sand, abundant debris (plastic, paper, foam, metal, rubber, wood, a nd wire coating), and trace clay [75, p. 29]. Surface soil/source samples SS-31 was described as dark-brown, s ilty-sand, containing abundant debris (plastic, rubber, metal, chrome, foam, wire, melted metal, and wire coating), trace fine gravel, trace clay, and trace organics [75, p. 30]. Subsurface soil/source sample SB- 28 was described as dark brown, sandy silt, major debris (wire, metal, rubber, foam, and plastic), trace fine gravel, trace clay, and trace organics [76, p. 14]. Subsurface soil/source sample SB-29 was described as sa turated medium-to-rusty br own, silt, abundant/major debris, trace sand, and trace clay [76, p. 15]. Subsurface soil/source sample SB-30 was described as dark brown, fine sandy silt, some debris (rubber, plastic, metal, and fibrous material), trace medium-to-coarse sand, and trace clay [76, p. 16]. Subsurface soil/source sampl e SB-31 was described as dark-brown, silt, abundant debris (plastic, metal, rubber, linoleum, foam, tile, and wire) little sand, trace clay [76, p. 17].

Soil/source samples (SS-28, SS-29, SS-30, SS-31, SB-28, SB -29, SB-30, and SB-31) were submitted to CLP Laboratories for VOC and PCB analyses following SOM01.2, and total metals analysis following ISM01.2 [14, pp. 46-48; 15, pp. 2-3; 34, pp. 12-13, 57-58, 65-66; 39, p. 1; 44; p. 1; 83, pp. 1-3; 88, p. 1; 93, p. 1]. The analytical data were validated according to EPA New England Regional Functional Guidelines Tier II requirements (for VOCs, PCBs, and total metals analyses) [39, p. 1; 44; p. 1]. For the purposes of the Source No. 4 evaluation and the HRS documentation record, four surface soil/source samples (SS-28 through SS-31) and four subsurface soil/source samples (SB-28 through SB-31) confirm the presence of the following hazardous substances: one VOC (PCE), two PCB Aroclo rs (Aroclor-1254 and Aroclor-1260) and three total metals (arsenic, chromium, and lead).

PCE was detected in surface and subsurface soil/s ource samples SS-31 and SB-31, collected from the northern portion of Source No. 4, at a maximum concentration of 3,900 μg/Kg in subsurface soil/source sample SB-31 [15, p. 3; 34, p. 13; 39, Table 1 (pp. 1-2 of 3)]. Among the eight selected source samples,

Aroclor-1254 was detected at a maximum concentrati on of 27,000 μg/Kg in surface soil/source sample SS-28, located on the eastern portion of Source No. 4; Aroclor-1260 was detected at a maximum concentration of 11,000 μg/Kg in subsurface soil/source sample SB-28, located on the eastern portion of Source No. 4; arsenic was detected at a maximum concentration of 48.1 mg /Kg in subsurface soil/source sample SB-31; chromium was detected at a maximum concentration of 2,186 mg /Kg in subsurface soil/source sample SB-29, located on the southern portion of Source No. 4; and lead was de tected at a maximum concentration of 17,361 mg/Kg in subsurface soil/source sample SB-31 (see Figure 3a) [14, pp. 46-48; 15, pp. 2-3; 34, pp. 12-13; 39, Table 1

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(pp. 1-2 of 3), Table 2 (pp. 1-2 of 2); 44, Table 1 (p. 2 of 2); 57, pp. 6-7 (Table 2), pp. 8-9 (Table 3); 62, pp. 7 (Table 2), 10-11 (Table 3)].

Table 23 - Hazardous Substances Associated with Source No. 4

Sample

ID Sample Type Date Hazardous
Substance Hazardous Substance

Concentration SampleAdjusted

CRQL Reference

SS-28 Soil/

Source 9 Nov. 2010

Aroclor-1254 27,000 μg/Kg 2,200 μg/Kg 14, pp. 46-47; 34, p. 12; 39, Table 2 (p. 1 of 2); 57, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 7­ 8)

Aroclor-1260 6,600 μg/Kg 2,200 μg/Kg 14, pp. 46-47; 34, p. 12; 39, Table 2 (p. 1 of 2); 57, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 7­ 8)

Arsenic 1 16.3 (28.4 J) mg/Kg 1.2 mg/Kg 14, pp. 46-47; 34, p. 12; 44, Table 1 (p. 1 of 2); 62, pp. 6 (Table 2), 8 (Table 3), Attachment B (p. 4)

Chromium 1 111 (143 J) mg/Kg 1.2 mg/Kg 14, pp. 46-47; 34, p. 12; 44, Table 1 (p. 1 of 2); 62, pp. 6 (Table 2), 8 (Table 3), Attachment B (p. 4)

Lead 1 4,194 (6,040 JEB) mg/Kg 244 mg/Kg 14, pp. 46-47; 34, p. 12; 44, Table 1 (p. 1 of 2); 62, pp. 6 (Table 2), 8 (Table 3), Attachment B (p. 4)

SS-29 Soil/

Source 9 Nov. 2010

Aroclor-1254 3,600 μg/Kg 870 μg/Kg 14, p. 48; 34, p. 13; 39, Table 2 (p. 1 of 2); 57, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 9­ 10)

Aroclor-1260 5,000 μg/Kg 870 μg/Kg 14, p. 48; 34, p. 13; 39, Table 2 (p. 1 of 2); 57, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 9­ 10)

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Source No. 4

Arsenic 1 18.6 (32.4 J) mg/Kg 1.3 mg/Kg 14, p. 48; 34, p. 13; 44, Table 1 (p. 1 of 2); 62, pp. 6 (Table 2), 9 (Table 3), Attachment B (p. 5)

Chromium 1 512 (661 J) mg/Kg 254 mg/Kg 14, p. 48; 34, p. 13; 44, Table 1 (p. 1 of 2); 62, pp. 6 (Table 2), 9 (Table 3), Attachment B (p. 5)

Lead 1 3,896 (5,610 JEB) mg/Kg 254 mg/Kg 14, p. 48; 34, p. 13; 44, Table 1 (p. 1 of 2); 62, pp. 6 (Table 2), 9 (Table 3), Attachment B (p. 5)

SS-30 Soil/ 9 Nov. 2010 14, p. 48; 15, p. 2; 34,

Source

Aroclor-1254 6,400 μg/Kg 940 μg/Kg p. 13; 39, Table 2 (p. 1 of 2); 57, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 11­ 12)
14, p. 48; 15, p. 2; 34,

Aroclor-1260 6,000 μg/Kg 940 μg/Kg p. 13; 39, Table 2 (p. 1 of 2); 57, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 11­ 12)

Arsenic 1 16.6 (28.9 J) mg/Kg 1.3 mg/Kg 14, p. 48; 15, p. 2; 34, p. 13; 44, Table 1 (p. 1 of 2); 62, pp. 6 (Table 2), 9 (Table 3), Attachment B (p. 6)

Chromium 1 154 (199 J) mg/Kg 1 mg/Kg 14, p. 48; 15, p. 2; 34, p. 13; 44, Table 1 (p. 1 of 2); 62, pp. 6 (Table 2), 9 (Table 3), Attachment B (p. 6)

Lead 1 3,653 (5,260 JEB) mg/Kg 256 mg/Kg 14, p. 48; 15, p. 2; 34, p. 13; 44, Table 1 (p. 1 of 2); 62, pp. 6 (Table 2), 9 (Table 3), Attachment B (p. 6)

SS-31 Soil/

Source 9 Nov. 2010

PCE 1,600 μg/Kg 450 μg/Kg 14, p. 48; 34, p. 13; 39, Table 1 (p. 1 of 3); 112, p. 3 (Table 1), Attachment A (p. 14)

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Source No. 4

Aroclor-1254 23,000 μg/Kg 2,100 μg/Kg 14, p. 48; 34, p. 13; 39, Table 2 (p. 1 of 2); 57, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 13­ 14)
14, p. 48; 34, p. 13;

Aroclor-1260 8,800 μg/Kg 2,100 μg/Kg 39, Table 2 (p. 1 of 2); 57, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 13­ 14)

Arsenic 1 25.6 (44.5 J) mg/Kg 1.3 mg/Kg 14, p. 48; 34, p. 13; 44, Table 1 (p. 1 of 2); 62, pp. 6 (Table 2), 9 (Table 3), Attachment B (p. 7)

Chromium 1 106 (137 J) mg/Kg 1 mg/Kg 14, p. 48; 34, p. 13; 44, Table 1 (p. 1 of 2); 62, pp. 6 (Table 2), 9 (Table 3), Attachment B (p. 7)

Lead 1 3,174 (4,570 JEB) mg/Kg 260 mg/Kg 14, p. 48; 34, p. 13; 44, Table 1 (p. 1 of 2); 62, pp. 6 (Table 2), 9 (Table 3), Attachment B (p. 7)

SB-28 Soil/

Source 9 Nov. 2010

Aroclor-1254 19,000 μg/Kg 1,900 μg/Kg 15, p. 2; 34, p. 13; 39, Table 2 (p. 2 of 2); 57, pp. 7 (Table 2), 9 (Table 3), Attachment B (pp. 17-18)

Aroclor-1260 11,000 μg/Kg 1,900 μg/Kg 15, p. 2; 34, p. 13; 39, Table 2 (p. 2 of 2); 57, pp. 7 (Table 2), 9 (Table 3), Attachment B (pp. 17-18)

Chromium 1 145 (187 J) mg/Kg 1.4 mg/Kg 15, p. 2; 34, p. 13; 44, Table 1 (p. 2 of 2); 62, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 9)

Lead 1 4,569 (6,580 JEB) mg/Kg 272 mg/Kg 15, p. 2; 34, p. 13; 44, Table 1 (p. 2 of 2); 62, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 9)

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SB-29 Soil/

Source 9 Nov. 2010

Aroclor-1254 520 μg/Kg 180 μg/Kg 15, p. 2; 34, p. 13; 39, Table 2 (p. 2 of 2); 57, pp. 7 (Table 2), 9 (Table 3), Attachment B (pp. 19-20)

Aroclor-1260 560 μg/Kg 180 μg/Kg 15, p. 2; 34, p. 13; 39, Table 2 (p. 2 of 2); 57, pp. 7 (Table 2), 9 (Table 3), Attachment B (pp. 19-20)

Chromium 1 2,186 (2,820 J) mg/Kg 223 mg/Kg 15, p. 2; 34, p. 13; 44, Table 1 (p. 2 of 2); 62, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 10)

Lead 1 4,951 (7,130 JEB) mg/Kg 223 mg/Kg 15, p. 2; 34, p. 13; 44, Table 1 (p. 2 of 2); 62, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 10)

SB-30 Soil/

Source 9 Nov. 2010

Aroclor-1254 3,600 μg/Kg 450 μg/Kg 15, p. 3; 34, p. 13; 39, Table 2 (p. 2 of 2); 57, pp. 7 (Table 2), 9 (Table 3), Attachment B (pp. 21-22)

Aroclor-1260 3,700 μg/Kg 450 μg/Kg 15, p. 3; 34, p. 13; 39, Table 2 (p. 2 of 2); 57, pp. 7 (Table 2), 9 (Table 3), Attachment B (pp. 21-22)

Arsenic 1 27.1 (47.1 J) mg/Kg 1.4 mg/Kg 15, p. 3; 34, p. 13; 44, Table 1 (p. 2 of 2); 62, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 11)

Chromium 1 157 (202 J) mg/Kg 1.4 mg/Kg 15, p. 3; 34, p. 13; 44, Table 1 (p. 2 of 2); 62, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 11)

Lead 2 6,944 (10,000 JEB) mg/Kg 272 mg/Kg 15, p. 3; 34, p. 13; 44, Table 1 (p. 2 of 2); 62, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 11)

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SB-31 Soil/

Source 9 Nov. 2010

PCE 3,900 μg/Kg 510 μg/Kg 15, p. 3; 34, p. 13; 39, Table 1 (p. 2 of 3); 112, p. 4 (Table 1), Attachment A (p. 24)
15, p. 3; 34, p. 13; 39,

Aroclor-1254 24,000 μg/Kg 2,400 μg/Kg Table 2 (p. 2 of 2); 57, pp. 7 (Table 2), 9 (Table 3), Attachment B (pp. 23-24)
15, p. 3; 34, p. 13; 39,

Aroclor-1260 6,000 μ g /Kg 2,400 μ g /Kg Table 2 (p. 2 of 2); 57, pp. 7 (Table 2), 9 (Table 3), Attachm ent B (pp. 23-24)

Arsenic 1 48.1 (83.7 J) mg/Kg 1.5 mg/Kg 15, p. 3; 34, p. 13; 44, Table 1 (p. 2 of 2); 62, pp. 7 (Table 2), 11 (Table 3), Attachment B (p. 12)

Chromium 1 209 (269 J) mg/Kg 1.5 mg/Kg 15, p. 3; 34, p. 13; 44, Table 1 (p. 2 of 2); 62, pp. 7 (Table 2), 11 (Table 3), Attachment B (p. 12)

Lead 1 17,361 (25,000 JEB) mg/Kg 298 mg/Kg 15, p. 3; 34, p. 13; 44, Table 1 (p. 2 of 2); 62, pp. 7 (Table 2), 11 (Table 3), Attachment B (p. 12)

PCE = Tetrachloroethene.

Nov. = November. CRQL = Contract Required Quantitation Limit. μg/Kg = Micrograms per kilogram. mg/Kg = Milligrams per kilogram. J = The associated numerical value is an estimated quantity [44, Table 1 (pp. 1-2 of 2)]. EB = The compound was also detected in an associated equipment rinsate blank [44, Table 1 (pp. 1­ 2 of 2)]. ( ) = For hazardous substance concentrations, de notes concentration of the compound or element prior to adjustment. Based on the EPA Fact Sheet, Using Qualified Data to Document an Observed
Release and Observed Contamination , for HRS purposes it is not required to adjust qualified source data. Although the fact sheet was not inte nded for application to source data, it has been applied as a conservative measure in this situation to demonstrate the relative increase in contamination in the source samples over background levels [113].

1 Arsenic, chromium, and lead results were qualified as estimated following data review. Arsenic had an unknown bias (poor laboratory duplicate precision) and was adjusted by dividing by the adjustment factor of

1.74 [44, p. 5; 62, pp. 2, 3 (Exhibit 3), 8-11 (Table 3)]. Chromium had a high bias (matrix spike analytes did not meet percent recovery criteria) and was adjusted by di viding by the adjustment factor of 1.29 [44, p. 5; 62,

p. 2, 3 (Exhibit 3), 8-11 (Table 3)]. Lead had a hi gh bias [equipment (rinsate) blank contamination] and was adjusted by dividing by the adjustment factor of 1.44 [44, p. 3; 62, p. 2, 3 (Exhibit 3), 8-11 (Table 3)].

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Source No. 4

List of Hazardous Substances Associated with Source

Based on samples collected as part of the EPA Site Assessment Site Inspection, Source No. 4 has been documented to contain PCE [14, p. 48; 15, p. 3; 34, p. 13; 39, Table 1 (pp. 1-2 of 3)]. In addition, Source No.

4 has been documented to contain two PCB aroclors (Aroclor-1254 and Aroclor-1260) and three total metals (arsenic, chromium, and lead) [14, pp. 46-48; 15, pp. 2-3; 34, pp. 12-13; 39, Table 2 (pp. 1-2 of 2); 44, Table 1 (pp. 1-2 of 2); 57, pp. 6-7 (Table 2), 8-9 (Table 3); 62, pp. 6-7 (Table 2), 8-11 (Table 3)]. Therefore the substances PCE, Aroclor-1254, Aroclor-1260, arsenic, chro mium, and lead are considered to be associated with the Debris Pile D source [1, p. 51588, Section 2.2.2]. These hazardous substances are consistent among the on-site sources (see Source Characterization for Sources 1 through 3, and 5). Based on a survey completed by the property owner, the volume of Debr is Pile D (Source No. 4) was determined to be approximately 11,280 yd 3 [29, Appendix A]. As part of the EPA Site Assessment Site Inspection, eight surface and subsurface soil/source samples were collected fro m Debris Pile D [14, pp. 46-48; 15, pp. 2-3; 34, pp. 12-13].

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

On-site observations indicate that no portion of Source No . 4 has a maintained engineered cover or complete runoff control management systems [17, p. 11]. No report of a natural or man-made liner was documented during source sampling activities [17, p. 11]. Therefore, Source No. 4 does not have full containment, and the source yields a containment value of 10 [1, p. 51596 (Table 3-2)].

Table 24 - Hazardous Substances Available to Pathways

Containment Description Containment Factor References

Gas release to air : NS

Particulate release to air : NS

Release to ground water : Based on the lack of a liner, a maintained engineered cover, and any complete run-on control and runoff management systems, a Containment Factor Value of 10 has been assigned for release to ground water for Source

No. 4. 10 1, p. 51596, Table 3-2; 17, p. 11

Release via overland migration and/or flood : NS

NS = Not Scored.

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Source No. 4

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1 Hazardous Waste Quantity

The Hazardous Waste Quantity for Source No. 4 was assi gned based on the Volume Factor Value of a “pile” source type [1, p. 51591 (Table 2-5, Section 2.4.2.1. 3)]. The Hazardous Constituent Quantity and Hazardous Wastestream Quantity Values were not evaluated fo r Source No. 4 because insufficient information was available [1, pp. 51590-51591 (Sections 2.4.2. 1.1 and 2.4.2.1.2, Table 2-5)].

2.4.2.1.1 Hazardous Constituent Quantity

Description

There is insufficient information to evaluate Source No. 4 for Hazardous Constituent Quantity.

Table 25 – Hazardous Constituent Quantity

Hazardous Substance Constituen t Quantity (pounds) References

NS (insufficient information)

Sum (pounds):

Hazardous Constituent Quantity Assigned Value: NS

2.4.2.1.2 Hazardous Wastestream Quantity

Description

There is insufficient information to evaluate Source No. 4 for Hazardous Wastestream Quantity.

Table 26 – Hazardous Wastestream Quantity

Hazardous Wastestream Wastestrea m Quantity (pounds) References

NS (insufficient information)

Sum (pounds):

Sum of Wastestream Quantity/5,000 (1, p. 51591, Table 2-5):

Hazardous Wastestream Quantity Assigned Value : NS

2.4.2.1.3 Volume

Description

For the purposes of this HRS documentation record, th e volume estimate presented for Source No. 4 (Debris Pile D) by ERM in their Debris Pile Evaluation Report is utilized [29, pp. 4-5, Appendix A (p. 5)]. Based on

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Source No. 4

a survey completed by the property owner, the volume of Debris Pile D (Source No. 4) was determined to be approximately 11,280 yd 3 [29, Appendix A (p. 5)].

Table 27 – Volume

Source

Type Description (# drums or dimensions) Units (yd 3 ) References

Pile Debris Pile 11,280 29, Appendix A (p. 5)

The volume of a “pile” source, in yd 3 , is divided by 2.5 to assign a Hazardous Waste Quantity to the source [1, p. 51591, Table 2-5].

Sum (yd 3 ): 11,280

Equation for Assigning Value (1, p. 51591, Table 2-5): 11,280 yd 3 ÷ 2.5 = 4,512.0

Volume Assigned Value: 4,512.0

2.4.2.1.4 Area

Description

The area of Source No. 4 was not scored.

Table 28 – Area

Source Type Units (ft 2 ) References

NS

The area of a “pile” source, in ft 2 , is divided by 13 to assign a Hazardous Waste Quantity to the source [1, p. 51591, Table 2-5].

Area Assigned Value: 0

2.4.2.1.5 Source Hazardous Waste Quantity Value

The Hazardous Waste Quantity Value for Source No. 4 was assigned based on the Volume Factor Value (4,512.0) [1, p. 51591, Table 2-5]. The Hazardous Constituent Quantity and Hazardous Wastestream Quantity Factor Values were not evaluated for Source No. 4 because insufficient in formation was available [1, p. 51591, Sections 2.4.2.1.1, 2.4.2.1.2].

Highest HWQ value assigned from Ref. 1, Table 2-5: 4,512.0

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Source No. 5

2.2 SOURCE CHARACTERIZATION

2.2.1 SOURCE IDENTIFICATION

Name of Source : Former Operations Area

Number of Source : Source No. 5

Source Type : Contaminated Soil

Description and Location of Source :

The Former Operations Area (Contaminated Soil - Source No. 5) is located on the undeveloped property identified as the Leeds Metal property, depicted on the Town of Leeds, ME Tax Assessor’s Map No. 4, as Lot No. 38 [5; 9; 12, pp. 1-2; 19, p. 1, Fig. 1]. Source No. 5 is located on the approximate eastern half of the Leeds Metal property (see Figure 2) [14, pp. 8-11; 17, pp. 10-11; 19, p. 1, Figure 2; 21, pp. 1, 3-4]. The geographic coordinates of the Former Operations Ar ea, as measured from its approximate center, are 44° 14 ′

14.1 ′′ north latitude and 70° 04 ′ 48.3 ′′ west longitude (see Figures 1 and 2) [7].

Between 1969 and 1984, scrap metal recovery processes were conducted on the Leeds Metal property by various entities [18, pp. 1- 2]. The former assistant fire chief of the Town of Leeds, ME stated that cars were transported to the property via trucks for “shredding” [ 26]. He also stated that within a cement building on the property, lead batteries and other auto parts were cl eaned for resale [26]. The former assistant fire chief noted that metal from the shredded cars was salvaged (s ent off the property via railroad), while the upholstery was piled in former gravel excavation pits [26]. He further stated that such materials as “gasoline, diesel, transformer oil, brake fluid, oils, battery aci d, and antifreeze” were dumped on the ground and that approximately 100 “barrels” were staged along the southe rn property boundary [26]. The former assistant fire chief recalled that the Leeds and Monmouth Fire Depart ments responded to fires at the property, and that gasoline tanks would ignite causing oil-saturated soil to burn [26]. The eastern and southern portions of the Leeds Metal property contained car shredding waste bot h on the ground surface and in piles, including Source No. 5 (Former Operations Area) [14, pp. 2-15]. The w estern extent of operations on the property is generally defined as the tree-line that runs north-south on the prope rty, while the eastern extent of operations is the railroad bed [14, pp. 8-11; 17, pp. 10-11; 19, p. 1, Figur e 2; 21, p. 3]. The southern extent of operations on the property is generally defined by the tree-line that runs east-west just north of the southern property boundary [Figure 2; 9; 14, pp. 8-11; 17, pp. 10-11; 19, p. 1, Figure 2; 21, p. 3]. The extent of operations on the property is considered to be the area where au tomobile reclamation activities once occurred, and is illustrated in an aerial photograph included in the ME DEP Site Discovery Report [14, pp. 8-11; 17, pp. 10­ 11; 19, p. 1, Figure 2; 21, p. 3].

Analysis of aerial photographs, and GPS data collected by START as part of the EPA Site Assessment Site Inspection, indicate that the Former Operations Area encompasses an area of approximately 190,558 ft 2
[Figure 2; 133, p. 1].

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

- Background Concentrations:

The Former Operations Area (Source No. 5) is a cont aminated soil source type; therefore, background soil samples have been utilized for comparison purposes. On 16 November 2010, as part of the EPA Site Assessment Site Inspection, background soil sampling activ ities were conducted [15, pp. 44-46; 34, p. 20].

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Source No. 5

The background surface and subsurface soil samples were collected in accordance with the EPA-approved Site-Specific QAPP, dated 26 October 2010 [6; 34, pp. 19-20]. Two background surface soil samples (SS-01 and SS-02) and two background subsurface soil samples (S B-01 and SB-02) were collected from a residential property located northwest of the Leeds Metal property [9; 12; 15, pp. 44-46; 34, p. 20; 106, pp. 1-2]. The residential property is located in Leeds, ME, and is depicted on the Town of Leeds, ME Tax Assessor’s Map No. 4 as Lot No. 55 (see Figure 3b) [9; 106, pp. 1-2]. The background samples were collected from the same 0- to 2-foot depth interval and during the same time period as the source samples presented as part of the Source No. 5 Characterization, and the background and s ource samples contained similar native materials [15, pp. 44-46; 75, pp. 1, 8, 12, 16, 19-26, 40; 76, pp. 1, 3, 10, 12-13]. Background soil samples SS-01 and SB-01 were submitted to CLP Laboratories for VOC and PCB analyses following SOM01.2 and total metals analysis following ISM01.2, while background soil samples SS-02 and SB-02 were submitted to a CLP Laboratory for total metals analysis following ISM01.2 [15, pp. 44-46; 34, p. 20; 35, p. 1; 40, p. 1; 79, pp. 1-2; 84, pp. 1-2; 89, pp. 1-2]. As part of this HRS documentation reco rd and the evaluation of b ackground concentrations, the following hazardous substances in background samples ar e presented: one VOC (PCE), two PCB aroclors (Aroclor-1254 and Aroclor-1260), and three tota l metals (arsenic, chromium, and lead).

Table 29 - Hazardous Substances Asso ciated with Background Samples

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-01 Soil 16 Nov. 2010 PCE 4.9 U μg/Kg 4.9 μg/Kg 15, p. 44; 34, p. 20; 35, Table 1 (p. 1 of 3); 112, p. 3 (Table 1), Attachment A (p. 2)

SS-01 Soil 16 Nov. 2010 Aroclor-1254 42 U μg/Kg 42 μg/Kg 15, p. 44; 34, p. 20; 35, Table 2 ( p. 1 of 3); 53, Attachment B (p. 1)

SS-01 Soil 16 Nov. 2010 Aroclor-1260 42 U μg/Kg 42 μg/Kg 15, p. 44; 34, p. 20; 35, Table 2 ( p. 1 of 3); 53, Attachment B (p. 1)

SS-02 Soil 16 Nov. 2010 Arsenic 4.4 mg/Kg 1.1 mg/Kg 15, pp. 44-45; 34, p. 20; 40, Table 1 (p. 1 of 3); 58, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 2)

SS-02 Soil 16 Nov. 2010 Chromium 1 23.1 (17.9 J) mg/Kg 1.1 mg/Kg 15, pp. 44-45; 34, p. 20; 40, Table 1 (p. 1 of 3); 58, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 2)

SS-02 Soil 16 Nov. 2010 Lead 1 5.1 (5.1 JEB) mg/Kg 1.1 mg/Kg 15, pp. 44-45; 34, p. 20; 40, Table 1 (p. 1 of 3); 58, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 2)

SB-01 Soil 16 Nov. 2010 PCE 3.6 U μg/Kg 3.6 μg/Kg 15, p. 44; 34, p. 20; 35, Table 1 (p. 1 of 3); 112, p. 4 (Table 1), Attachment A (p. 18)

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Source No. 5

SB-01 Soil 16 Nov. 2010 Aroclor-1254 36 U μg/Kg 36 μg/Kg 15, p. 45; 34, p. 20; 35, Table 2 (p. 2 of 3); 53, Attachment B (p. 7)

SB-01 Soil 16 Nov. 2010 Aroclor-1260 36 U μg/Kg 36 μg/Kg 15, p. 45; 34, p. 20; 35, Table 2 (p. 2 of 3); 53, Attachment B (p. 7)

SB-02 Soil 16 Nov. 2010 Chromium 1 35.9 (27.8 J) mg/Kg 1.4 mg/Kg 15, pp. 45-46; 34, p. 20; 40, Table 1 (p. 2 of 3); 58, pp. 8 (Table 2), 10 (Table 3), Attachment B (p. 4)

SB-02 Soil 16 Nov. 2010 Lead 1 5.2
(5.2 JEB) mg/Kg 1.4 mg/Kg 15, pp. 45-46; 34, p. 20; 40, Table 1 (p. 2 of 3); 58, pp. 8 (Table 2), 10 (Table 3), Attachment B (p. 4)

PCE = Tetrachloroethene.

Nov. = November. CRQL = Contract Required Quantitation Limit. μg/Kg = Micrograms per kilogram. mg/Kg = Milligrams per kilogram. U = The compound or element was analyzed for, but not detected. The associated numerical value is the sample-adjusted CRQL [103, p. B-47].J = The associated numerical value is an estimated quantity [40, Table 1 (pp. 1-2 of 3); 103, p. B47]. EB = The compound was also detected in an associated equipment rinsate blank [40, Table 1 (pp. 1­ 2 of 3)]. ( ) = For hazardous substance concentrations, denotes concentration of the compound or element prior to adjustment.

1 Chromium and lead results were qualified as estimated following data review. Chromium had a low bias (serial dilution results exceeded percent difference criteria) and was adjusted by multiplying by the adjustment factor of 1.29 [40, p. 5; 58, pp. 2, 3 (Exhibit 3), 10 (Table 3)]. Lead had a high bias [equipment (rinsate) blank contamination] and was not numerically ad justed [40, p. 4; 58, pp. 2, 3 (Exhibit 3), 10 (Table 3)].

- Source Samples:

On 9, 11, 17, 18, and 30 November 2010, as part of the EPA Site Assessment Site Inspection, soil/source sampling activities of the Former Operations Area were conducted [14, pp. 46-48; 15, pp. 18-19; 16, pp. 21­ 22, 28-33, 38-39; 17, p. 6; 34, pp. 12-13, 16, 25-28, 31]. The surface and subsurface soil/source samples were

collected in accordance with the EPA -approved Site-Specific QAPP, dated 26 October 2010 [6]. As part of the Former Operations Area characterization, 13 surface soil/source samples (SS-09, SS-13, SS-17, SS-20 through SS-27, SS-41, and field duplicate SS-44) and four subsurface soil/source samples (SB-09, SB-17, SB22, and SB-27) were collected from various places th roughout Source No. 5 (see Figure 3a) [14, pp. 46-48; 15, pp. 18-19; 16, pp. 21-22, 28-33, 38-39; 17, p. 6; 34, pp. 12-13, 16, 25-28, 31]. Surface soil/source sample SS-09 was described as dark brown-to-rusty brown, silty fine sand, debris (metal, wire, and foam), trace medium-to-coarse sand, trace fine gravel, trace organics [75, p. 8]. Surface soil/source sample SS-13 was described as dark brown-to-black, silty sand, some debr is (wire, tile, metal nodules, metal parts, rubber, and wood), trace clay, and trace organics [75, p. 12]. Surface soil/source sample SS-17 was described as medium brown, fine-to-coarse sand, some silt, some debris (melted metal, wire, foam, and rubber), little fine-tomedium gravel, trace clay [75, p. 16]. Surface soil/source sample SS-20 and field duplicate SS-44 were

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MEN000103584 September 2011Source Characterization

Source No. 5

described as dark brown, fine sandy silt, some medi um-to-coarse sand, some debris (foam, wire coating, rubber, and metal fragments), trace organics, trace fine-to medium gravel, and trace clay [75, p. 19]. Surface soil/source sample SS-21 was described as dark brown, silty sand, major debris (wire, rubber, metal slag, plastic, paper), trace fine-to-medium gravel, and trace organics [75, p. 20]. Surface soil/source sample SS-22 was described as dark brown, silty sand, some debris (metal and rubber), trace fine-to-medium gravel, trace clay, and trace organics [75, p. 21]. Surface soil/source sample SS-23 was described as medium-to-dark brown, silty sand, major debris (metal, rubber, fo am, plastic, comb, and paper), trace fine gravel, trace organics, and containing a burned odor [75, p. 22]. Surface soil/source sample SS-24 was described as medium-to-cinnamon brown, fine sand, some silt, little medium-to-coarse sand, trace fine-to-medium gravel, and trace clay [75, p. 23]. Surface soil/source sample SS-25 was described as dark brown, silty sand, some debris (wire, rubber, and metal), trace fine gravel, trace clay, and trace organics [75, p. 24]. Surface soil/source sample SS-26 was described as medium-to-dark br own, silty and, some debris (plastic, metal, rubber), little gravel, little clay, trace organics [75, p. 25]. Surface soil/source sample SS-27 was described as dark brown, silty sand, some debris (metal, plastic, rubber), trace fine gravel, trace clay, and trace organics [75, p. 26]. Surface soil/source sample SS-41 was described as medium-to-light brown, silty fine sand, trace clay, trace organics [75, p. 40]. Subsurface soil/source sample SB-09 was described as dark brown, sand and silt, major debris (metal, rubber, plastic, and wire), trace organics, and trace clay [76, p. 3]. Subsurface soil/source sample SB-17 was described as medium-to-light brown, sand, some silt, little fine-to-medium gravel, trace clay [76, p. 10]. Subsurface soil/source samp le SB-22 was described as saturated, medium gray, fine-to-medium sand, little coarse sand, some silt, trace clay [76, p. 12]. Subsurface soil/source sample SB-27 was described as wet, medium gray, fine-to-coarse sand, little silt, trace clay [76, p. 13].

Source samples (SS-09, SS-13, SS-17, SS-20 through SS-27, SS-41, SS-44, SB-09, SB-17, SB-22, and SB27) were submitted to CLP Laboratories for VOC, PCB, a nd total metals analysis [14, pp. 46-48; 15, pp. 18­ 19; 16, pp. 21-22, 28-33, 38-39; 17, p. 6; 34, pp. 12-13, 16, 25-28, 31, 52-58, 60-62, 64-65; 36, p. 1; 37, p. 1; 38, p. 1; 39, p. 1; 41, p.1; 42, p. 1; 43, p. 1; 44, p. 1; 80, pp. 1-4; 81, pp. 1, 3; 82, pp. 1-2; 83, p. 1; 85, pp. 1; 86, p. 1; 87, p. 1; 88, p. 1; 90, p. 1; 91, p. 1; 92, p. 1; 93, p. 1]. The analytical data were validated according to EPA New England Regional Functional Guidelines Ti er II requirements (for VOCs, PCBs, and total metals analyses) [36, p. 1; 37, p. 1; 38, p. 1; 39, p. 1; 41, p.1; 42, p. 1; 43, p. 1; 44, p. 1]. For the purposes of Source No. 5 evaluation and the HRS documentation record, analytical results of 17 surface and subsurface soil/source samples (SS-09, SS-13, SS-17, SS-20 through SS- 27, SS-41, SS-44, SB-09, SB-17, SB-22, and SB-27) confirm the presence of the following hazardous substances: one VOC (PCE), two PCB aroclors (Aroclor-1254 and Aroclor-1260) and three tota l metals (arsenic, chromium, and lead).

PCE was detected in surface source samples SS-20, SS-22, SS-23, SS-25, SS-27, and SS-44, and subsurface source samples SB-22 and SB-27 at a maximum concentr ation of 10,000 μg/Kg in SS-27 [14, pp. 47-48; 15, pp. 18-19; 16, pp. 28-31; 34, pp. 13, 16, 26-27; 36, Table 1 (pp. 1-3 of 3); 39, Table 1 (pp. 1-2 of 3)]. Among the selected source samples: Aroclor-1254 was detected in 13 source samples, at a maximum concentration of 2,100 μg/Kg in SS-44, located adjacent to Debris Pile D; Aroclor-1260 was detected in 13 source samples, at a maximum concentration of 2,600 μg/Kg in SS-13, located along the eastern pr operty boundary, adjacent to the railroad tracks; arsenic was detected in one sour ce sample, at a concentration of 28.9 mg/Kg in SS-13; chromium was detected in six source samples, at a ma ximum concentration of 1,190 mg/Kg in SB-09, located in a depression/gulley along the eastern property boundary; and lead was detected in 14 source samples, at a maximum concentration of 9,140 mg/Kg in SS-21, located adjacent to Debris Pile D (see Figure 3a) [15, pp. 18-19; 16, pp. 29, 39; 17, p. 6; 34, pp. 16, 27-28, 31; 37, Table 2 (p. 1 of 3); 39, Table 2 (p. 2 of 2); 41, Table 1 (p. 1 of 3); 42, Table 1 (p. 1 of 3); 55, pp. 7 (Table 2) , 10 (Table 3); 57, pp. 7 (Table 2), 8 (Table 3); 59, pp. 7 (Table 2), 10 (Table 3); 60, pp. 7 (Table 2), 11 (Table 3)].

Leeds Metal 84 HRS Documentation Record

MEN000103584 September 2011Source Characterization

Source No. 5

Table 30 - Hazardous Substances Associated with Source No. 5

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-09 Soil/

Source 18 Nov. 2010

Aroclor-1254 1,000 μg/Kg 220 μg/Kg 16, p. 38; 34, p. 28; 38, Table 2 (p. 1 of 2); 56, pp. 6 (Table 2), 8 (Table 3), Attachment B (p. 1­ 2)

Aroclor-1260 1 2,500 (2,500 J) μg/Kg 220 μg/Kg 16, p. 38; 34, p. 28; 38, Table 2 (p. 1 of 2); 56, pp. 6 (Table 2), 8 (Table 3), Attachment B (p. 1­ 2)

Chromium 361 mg/Kg 264 mg/Kg 16, p. 38; 34, p. 28; 43, Table 1 (p. 1 of 2); 61, pp. 6 (Table 2), 8 (Table 3), Attachment B (p. 2)

Lead 2 1,750 (2,520 J) mg/Kg 264 mg/Kg 16, p. 38; 34, p. 28; 43, Table 1 (p. 1 of 2); 61, pp. 6 (Table 2), 8 (Table 3), Attachment B (p. 2)

SS-13 Soil/

Source 30 Nov. 2010

Aroclor-1254 1,100 μg/Kg 400 μg/Kg 17, p. 6; 34, p. 31; 37, Table 2 (p. 1 of 3); 55, pp. 7 (Table 2), 10 (Table 3), Attachment B (pp. 17-18)

Aroclor-1260 2,600 μg/Kg 400 μg/Kg 17, p. 6; 34, p. 31; 37, Table 2 (p. 1 of 3); 55, pp. 7 (Table 2), 10 (Table 3), Attachment B (pp. 17-18)

Arsenic 2 28.9 (50.2 J) mg/Kg 1.2 mg/Kg 17, p. 6; 34, p. 31; 42, Table 1 (p. 1 of 3); 60, pp. 7 (Table 2), 11 (Table 3), Attachment B (p. 5)

Leeds Metal 85 HRS Documentation Record

MEN000103584 September 2011Source Characterization

Source No. 5

Table 30 - Hazardous Substances Associated with Source No. 5

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-13

Cont. Soil/

Source 30 Nov. 2010

Chromium 338 mg/Kg 23.7 mg/Kg 17, p. 6; 34, p. 31; 42, Table 1 (p. 1 of 3); 60, pp. 7 (Table 2), 11 (Table 3), Attachment B (p. 5)

Lead 5,190 mg/Kg 23.7 mg/Kg 17, p. 6; 34, p. 31; 42, Table 1 (p. 1 of 3); 60, pp. 7 (Table 2), 11 (Table 3), Attachment B (p. 5)

SS-17 Soil/

Source 18 Nov. 2010

Aroclor-1254 180 μg/Kg 35 μg/Kg 16, pp. 31-32; 34, p. 27; 36, Table 2 (p.1 of 3); 54, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 2)

Aroclor-1260 470 μg/Kg 35 μg/Kg 16, pp. 31-32; 34, p. 27; 36, Table 2 (p.1 of 3); 54, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 2)

Chromium 587 mg/Kg 441 mg/Kg 16, pp. 31-32; 34, p. 27; 41, Table 1 (p. 1 of 3); 59, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 2)

Lead 2,480 mg/Kg 441 mg/Kg 16, pp. 31-32; 34, p. 27; 41, Table 1 (p. 1 of 3); 59, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 2)

Leeds Metal 86 HRS Documentation Record

MEN000103584 September 2011Source Characterization

Source No. 5

Table 30 - Hazardous Substances Associated with Source No. 5

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-20 Soil/

Source 11 Nov. 2010

PCE 490 μg/Kg 270 μg/Kg 15, pp. 18-19; 34, p. 16; 39, Table 1 (p. 1 of 3); 112, p. 3 (Table 1), Attachment A (p. 3)

Aroclor-1254 1,800 μg/Kg 370 μg/Kg 15, pp. 18-19; 34, p. 16; 39, Table 2 (p. 1 of 2); 57, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 1-2)

Aroclor-1260 690 μg/Kg 370 μg/Kg 15, pp. 18-19; 34, p. 16; 39, Table 2 (p. 1 of 2); 57, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 1-2)

Lead 2 116 (167 JEB) mg/Kg 1.1 mg/Kg 15, pp. 18-19; 34, p. 16; 44, Table 1 (p. 1 of 2); 62, pp. 6 (Table 2), 8 (Table 3), Attachment B (p. 1)

SS-21 Soil/

Source 18 Nov. 2010

Aroclor-1254 810 μg/Kg 200 μg/Kg 16, p. 29; 34, p. 27; 36, Table 2 (p. 1 of 3); 54, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 4)

Aroclor-1260 2,500 μg/Kg 200 μg/Kg 16, p. 29; 34, p. 27; 36, Table 2 (p. 1 of 3); 54, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 4)

Chromium 606 mg/Kg 590 mg/Kg 16, p. 29; 34, p. 27; 41, Table 1 (p. 1 of 3); 59, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 4)

Lead 2 9,140 (9,140 J) mg/Kg 590 mg/Kg 16, p. 29; 34, p. 27; 41, Table 1 (p. 1 of 3); 59, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 4)

Leeds Metal 87 HRS Documentation Record

MEN000103584 September 2011Source Characterization

Source No. 5

Table 30 - Hazardous Substances Associated with Source No. 5

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-22 Soil/

Source 18 Nov. 2010

PCE 3,800 μg/Kg 210 μg/Kg 16, pp. 29-30; 34, p. 27; 36, Table 1 (p. 1 of 3); 112, p. 3 (Table 1), Attachment A (p. 5)

Aroclor-1254 750 μg/Kg 74 μg/Kg 16, pp. 29-30; 34, p. 27; 36, Table 2 (p. 1 of 3); 54, pp. 7 (Table 2), 10 (Table 3), Attachment B (pp. 11-12)

Lead 198 mg/Kg 1.2 mg/Kg 16, pp. 29-30; 34, p. 27; 41, Table 1 (p. 1 of 3); 59, pp. 7 (Table 2), 11 (Table 3), Attachment B (p. 5)

SS-23 Soil/

Source 18 Nov. 2010

PCE 1,300 μg/Kg 380 μg/Kg 16, p. 28; 34, p. 26; 36, Table 1 (p. 1 of 3); 112, p. 3 (Table 1), Attachment A (p. 8)

Aroclor-1254 960 μg/Kg 120 μg/Kg 16, p. 28; 34, p. 26; 36, Table 2 (p. 1 of 3); 54, pp. 7 (Table 2), 10 (Table 3), Attachment B (pp. 13-14)

Lead 3,000 mg/Kg 472 mg/Kg 16, p. 28; 34, p. 26; 41, Table 1 (p. 1 of 3); 59, pp. 7 (Table 2), 11 (Table 3), Attachment B (p. 6)

Leeds Metal 88 HRS Documentation Record

MEN000103584 September 2011Source Characterization

Source No. 5

Table 30 - Hazardous Substances Associated with Source No. 5

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-24 Soil/

Source 18 Nov. 2011

Aroclor-1254 38 μg/Kg 35 μg/Kg 16, pp. 28-29; 34, p. 26; 36, Table 2 (p. 1 of 3); 54, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 15)

Aroclor-1260 94 μg/Kg 35 μg/Kg 16, pp. 28-29; 34, p. 26; 36, Table 2 (p. 1 of 3); 54, pp. 7 (Table 2), 10 (Table 3), Attachment B (p. 15)

Lead 36.4 mg/Kg 1.1 mg/Kg 16, pp. 28-29; 34, p. 26; 41, Table 1 (p. 1 of 3); 59, pp. 7 (Table 2), 11 (Table 3), Attachment B (p. 7)

SS-25 Soil/

Source 9 Nov. 2010

PCE 1,900 μg/Kg 240 μg/Kg 14, pp. 47-48; 34, p. 13; 39, Table 1 (p. 1 of 3); 112, p. 3 (Table 1), Attachment A (p. 10)

Aroclor-1254 850 μg/Kg 190 μg/Kg 14, pp. 47-48; 34, p. 13; 39, Table 2 (p. 1 of 2); 57, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 3-4)

Aroclor-1260 1,400 μg/Kg 190 μg/Kg 14, pp. 47-48; 34, p. 13; 39, Table 2 (p. 1 of 2); 57, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 3-4)

Lead 2 645 (929 JEB) mg/Kg 1.1 mg/Kg 14, pp. 47-48; 34, p. 13; 44, Table 1 (p. 1 of 2); 62, pp. 6 (Table 2), 8 (Table 3), Attachment B (p. 2)

Leeds Metal 89 HRS Documentation Record

MEN000103584 September 2011Source Characterization

Source No. 5

Table 30 - Hazardous Substances Associated with Source No. 5

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-26 Soil/

Source 9 Nov. 2010

Aroclor-1254 1,200 μg/Kg 190 μg/Kg 14, p. 46; 34, p. 12; 39, Table 2 (p. 1 of 2); 57, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 5-6)

Aroclor-1260 2,400 μg/Kg 190 μg/Kg 14, p. 46; 34, p. 12; 39, Table 2 (p. 1 of 2); 57, pp. 6 (Table 2), 8 (Table 3), Attachment B (pp. 5-6)

Chromium 2 77.5 (100 J) mg/Kg 1.2 mg/Kg 14, p. 46; 34, p. 12; 44, Table 1 (p. 1 of 2); 62, pp. 6 (Table 2), 8 (Table 3), Attachment B (p. 3)

Lead 2 2,701 (3,890 JEB) mg/Kg 232 mg/Kg 14, p. 46; 34, p. 12; 44, Table 1 (p. 1 of 2); 62, pp. 6 (Table 2), 8 (Table 3), Attachment B (p. 3)

SS-27 Soil/

Source 18 Nov. 2010

PCE 10,000 μg/Kg 210 μg/Kg 16, p. 29; 34, p. 26; 36, Table 1 (p. 2 of 3); 112, p. 3 (Table 1), Attachment A (p. 12)

Aroclor-1254 1 49 (490 J) μg/Kg 37 μg/Kg 16, p. 29; 34, p. 26; 36, Table 2 (p. 2 of 3); 54, pp. 8 (Table 2), 10 (Table 3), Attachment B (pp. 16-17)

Aroclor-1260 1,200 μg/Kg 150 μg/Kg 16, p. 29; 34, p. 26; 36, Table 2 (p. 2 of 3); 54, pp. 8 (Table 2), 10 (Table 3), Attachment B (pp. 16-17)

Lead 1,710 mg/Kg 459 mg/Kg 16, p. 29; 34, p. 26; 41, Table 1 (p. 2 of 3); 59, pp. 8 (Table 2), 11 (Table 3), Attachment B (p. 8)

Leeds Metal 90 HRS Documentation Record

MEN000103584 September 2011Source Characterization

Source No. 5

Table 30 - Hazardous Substances Associated with Source No. 5

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SS-41 Soil/

Source 17 Nov. 2011

Aroclor-1260 44 μg/Kg 42 μg/Kg 16, pp. 21-22; 34, p. 25; 36, Table 2 (p. 2 of 3); 54, pp. 8 (Table 2), 11 (Table 3), Attachment B (p. 18)

Lead 36.0 mg/Kg 1.3 mg/Kg 16, pp. 21-22; 34, p. 25; 41, Table 1 (p. 2 of 3); 59, pp. 8 (Table 2), 12 (Table 3), Attachment B (p. 9)

SS-44 Soil/

Source 11 Nov. 2010

PCE 350 μg/Kg 230 μg/Kg 15, pp. 18-19; 34, p. 16; 39, Table 1 (p. 2 of 3); 112, p. 3 (Table 1), Attachment A (p. 16)

Aroclor-1254 2,100 μg/Kg 190 μg/Kg 15, pp. 18-19; 34, p. 16; 39, Table 2 (p. 2 of 2); 57, pp. 7 (Table 2), 8 (Table 3), Attachment B (pp. 15-16)

Aroclor-1260 590 μg/Kg 38 μg/Kg 15, pp. 18-19; 34, p. 16; 39, Table 2 (p. 2 of 2); 57, pp. 7 (Table 2), 8 (Table 3), Attachment B (pp. 15-16)

Lead 2 599 (863 JEB) mg/Kg 1.1 mg/Kg 15, pp. 18-19; 34, p. 16; 44, Table 1 (p. 2 of 2); 62, pp. 7 (Table 2), 9 (Table 3), Attachment B (p. 8)

Leeds Metal 91 HRS Documentation Record

MEN000103584 September 2011Source Characterization

Source No. 5

Table 30 - Hazardous Substances Associated with Source No. 5

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SB-09 Soil/

Source 18 Nov. 2010

Aroclor-1254 1,700 μg/Kg 160 μg/Kg 16, p. 39; 34, p. 28; 38, Table 2 (p. 2 of 2); 56, pp. 7 (Table 2), 8 (Table 3), Attachment B (pp. 11-12)

Aroclor-1260 1,700
(1,700 J) μg/Kg 160 μg/Kg 16, p. 39; 34, p. 28; 38, Table 2 (p. 2 of 2); 56, pp. 7 (Table 2), 8 (Table 3), Attachment B (pp. 11-12)

Chromium 1,190 mg/Kg 251 mg/Kg 16, p. 39; 34, p. 28; 43, Table 1 (p. 2 of 2); 61, pp. 7 (Table 2), 9 (Table 3), Attachment B (p. 8)

Lead 2 2,833 (4,080 J) mg/Kg 251 mg/Kg 16, p. 39; 34, p. 28; 43, Table 1 (p. 2 of 2); 61, pp. 7 (Table 2), 9 (Table 3), Attachment B (p. 8)

SB-17 Soil/

Source 18 Nov. 2010

Aroclor-1260 45 μg/Kg 34 μg/Kg 16, pp. 32-33; 34, p. 27; 36, Table 2 (p. 2 of 3); 54, pp. 8 (Table 2), 11 (Table 3), Attachment B (p. 19)

SB-22 Soil/

Source 18 Nov. 2010

PCE 32 μg/Kg 5.3 μg/Kg 16, pp. 30-31; 34, p. 27; 36, Table 1 (p. 2 of 3); 112, p. 4 (Table 1), Attachment A (p. 20)

Leeds Metal 92 HRS Documentation Record

MEN000103584 September 2011Source Characterization

Source No. 5

Table 30 - Hazardous Substances Associated with Source No. 5

Sample

ID Sample Type Date Hazardous
Substance Hazardous
Substance

Concentration SampleAdjusted

CRQL Reference

SB-27 Soil/

Source 18 Nov. 2010

PCE 410 μg/Kg 180 μg/Kg 16, p. 30; 34, p. 27; 36, Table 1 (p. 3 of 3); 112, p. 4 (Table 1), Attachment A (p. 22)

Nov. = November. CRQL = Contract Required Quantitation Limit.

PCE = Tetrachloroethene. μg/Kg = Micrograms per kilogram. mg/Kg = Milligrams per kilogram. J = The associated numerical value is an estimated quantity [41, Table 1 (p. 1 of 3); 42, Table 1 (p. 1 of 3); 43, Table 1 (pp. 1-2 of 2); 44, Table 1 (pp. 1-2 of 2); 103, p. B-47]. EB = The compound was detected in an associated equipment rinsate blank [44, Table 1 (pp. 1-2 of 2)]. ( ) = For hazardous substance concentrations, denot es concentration of the compound or element prior to adjustment. Based on the EPA Fact Sheet, Using Qualified Data to Document an Observed
Release and Observed Contamination , for HRS purposes it is not required to adjusted qualified source data. Although the fact sheet was not inte nded for application to source data, it has been applied as a conservative measure in this situ ation to demonstrate the relative increase in contamination in the source samples over background levels [113].

1 Aroclor-1254 and Aroclor-1260 results were qualified as estimated following data review. Aroclor-1254 had an unknown bias (surrogate rec overies did not meet criteria) in surface soil/source sample SS-27, and wasadjusted by dividing by the adjustment factor of 10 [36, p. 7; 54, pp. 2, 3 (Exhibit 3), 10 (Table 3)]. Aroclor1260 had low bias (compound did not meet percent difference criteria in the instrument continuing calibration) in surface soil/source sample SS-09, and was not numerically adjusted [38, p. 4; 56, pp. 6 (Table 2), 8 (Table 3)].

2 Arsenic, chromium, and lead results were qualified as estimated following data review. Arsenic had a high bias (matrix spike analytes did not meet percent recovery criteria) in surface soil/source sample SS-13, and was adjusted by dividing by the adjustment factor of 1.74 [42, p. 5; 60, pp. 2, 3 (Exhibit 3), 11 (Table 3)]. Chromium had a high bias (matrix spike analytes did not meet percent recovery criteria) in surface soil/source sample SS-26, and was adjusted by dividing by the adjustment factor of 1.29 [44, p. 5; 62, pp. 6 (Table 2), 8 (Table 3)]. Lead had a high bias [equipment (rinsat e) blank contamination] in surface soil/source samples SS20, SS-25, SS-26, and SS-44, and was adjusted by dividing by the adjustment factor of 1.44 [44, p. 3; 62, pp. 2, 3 (Exhibit 3), 8-9 (Table 3)]. Lead had a low bias (interference check standard did not meet criteria) in surface soil/source sample SS-21, and was not numerically adju sted [41, p. 7; 59, pp. 7 (Table 2), 10 (Table 3)]. Lead had a high bias (serial dilution results exceeded percent difference criteria) in surface and subsurface soil/source samples SS-09 and SB-09, and was adjusted by dividing by the adjustment factor of

1.44 [43, p. 5; 61, pp. 2, 3 (Exhibit 3), 8-10 (Table 3)].

List of Hazardous Substances Associated with Source

Based on samples collected as part of the EPA Site Assessment Site Inspection, Source No. 5 has been documented to contain PCE [14, pp. 47-48; 15, pp. 18-19; 16, pp. 28-31; 34, pp. 13, 16, 26-27, 31; 36, Table

Leeds Metal 93 HRS Documentation Record

MEN000103584 September 2011Source Characterization

Source No. 5

1 (pp. 1-3 of 3); 39, Table 1 (pp. 1-2 of 3)]. In addition, Source No. 5 has been documented to contain two PCB Aroclors (Aroclor-1254 and Aroclor-1260) and three to tal metals (arsenic, chromium, and lead) [14, p. 46; 15, pp. 18-19; 16, pp. 21-22, 28-33, 38-39; 17, p. 6; 34, pp. 12, 16, 25-28, 31; 36, Table 2 (pp.1-2 of 3); 37, Table 2 (p. 1 of 3); 38, Table 2 (p. 1 of 2); 39, Table 1 (p. 2 of 2), Table 2 (p. 1 of 2); 41, Table 1 (pp. 1-2 of 3); 42, Table 1 (p. 1 of 3); 43, Table 1 (pp. 1-2 of 2); 44, Table 1 (p. 1 of 2); 54, pp. 7-8 (Table 2), 10-11 (Table 3); 55, pp. 7 (Table 2), 10 (Table 3); 56, pp. 6 (T able 2), 8 (Table 3); 57, pp. 6 (Table 2), 8 (Table 3); 59, pp. 7-8 (Table 2), 10-12 (Table 3); 60, pp. 7 (Table 2), 11 (Table 3); 61, pp. 6-7 (Table 2), 8-10 (Table 3); 62, pp. 6 (Table 2), 8 (Table 3)]. Therefore th e substances PCE, Aroclor-1254, Aroclor-1260, arsenic, chromium, and lead are considered to be associated with the Former Operations Area source [1, p. 51588, Section 2.2.2]. These hazardous substances are consistent among the on-site sources (see Source Characterization for Sources 1 through 4). Based on anal ysis of aerial photographs, and GPS data collected by START as part of the EPA Site Assessment Site In spection, the Former Oper ations Area encompasses an area of approximately 190,558 ft 2 (see Figure 2) [133, p. 1].

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

On-site observations indicate that no portion of Source No . 5 has a maintained engineered cover or complete runoff control management systems [17, p. 11]. No report of a natural or man-made liner was documented during source sampling activities [17, p. 11]. Therefore, Source No. 5 does not have full containment, and the source yields a containment value of 10 [1, p. 51596 (Table 3-2)].

Table 31 - Hazardous Substances Available to Pathways

Containment Description Containment Factor References

Gas release to air : NS

Particulate release to air : NS

Release to ground water : Based on the lack of a liner, a maintained engineered cover, and any complete run-on control and runoff management systems, a Containment Factor Value of 10 has been assigned for release to ground water for Source

No. 5. 10 1, p. 51596, Table 3-2; 17, p. 11

Release via overland migration and/or flood : NS

NS = Not Scored.

Leeds Metal 94 HRS Documentation Record

MEN000103584 September 2011Source Characterization

Source No. 5

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1 Hazardous Waste Quantity

The Hazardous Waste Quantity for Source No. 5 w as assigned based on the Area Factor Value of a “contaminated soil” source type [1, p. 51591 (Table 2- 5, Section 2.4.2.1.3)]. The Hazardous Constituent Quantity, Hazardous Wastestream Quantity, and Volume F actor Values were not evaluated for Source No. 5 because insufficient information was available [1, p. 51591 (T able 2-5, Sections 2.4.2.1.1 and 2.4.2.1.2)].

2.4.2.1.1 Hazardous Constituent Quantity

Description

There is insufficient information to evaluate Source No. 5 for Hazardous Constituent Quantity.

Table 32 – Hazardous Constituent Quantity

Hazardous Substance Constituen t Quantity (pounds) References

NS (insufficient information)

Sum (pounds):

Hazardous Constituent Quantity Assigned Value: NS

2.4.2.1.2 Hazardous Wastestream Quantity

Description

There is insufficient information to evaluate Source No. 5 for Hazardous Wastestream Quantity.

Table 33 – Hazardous Wastestream Quantity

Hazardous Wastestream Wastestrea m Quantity (pounds) References

NS (insufficient information)

Sum (pounds):

Sum of Wastestream Quantity/5,000 (1, p. 51591, Table 2-5):

Hazardous Wastestream Quantity Assigned Value : NS

2.4.2.1.3 Volume

Description

There is insufficient information to evaluate Source No. 5 for Volume.

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Source No. 5

Table 34 – Volume

Source Type Description (# drums or dimensions) Units (yd 3 ) References

NS (insufficient information)

Sum (yd 3 ):

Equation for Assigning Value (1, p. 51591, Table 2-5):

Volume Assigned Value: NS

2.4.2.1.4 Area

Description

GPS data collected at the Leeds Metal property were utilized to determine the area which Source No. 5 encompasses (see Figure 2) [133, p. 1]. According to the GPS data collected, Source No. 5 encompasses an area of approximately 190,558 ft 2 (4.37 acres) [133, p. 1]. Based on observations of the extent of operations on the Leeds Metal property, this source could be documented as encompassing a larger area with further sampling (see Figure 2) [14, pp. 8-11; 17, pp. 10-11; 19, p. 1, Figure 2; 21, p. 3].

Table 35 – Area

Source Type Units (ft 2 ) References

Contaminated Soil 190,558 Figure 2; 133, p. 1

The area of a “contaminated soil” source, in ft 2 , is divided by 34,000 to assign a Hazardous Waste Quantity to the source [1, p. 51591, Table 2-5]. Sum (ft 2 ): 190,558

Equation for Assigning Value (1, p. 51591, Table 2-5): 190,558 ft 2 ÷ 34,000 = 5.6

Area Assigned Value: 5.6

2.4.2.1.5 Source Hazardous Waste Quantity Value

The Hazardous Waste Quantity Value for Source No. 5 wa s assigned based on the Area Factor Value (5.6) [1,

p. 51591, Table 2-5]. The Hazardous Constituent Quantity, Hazardous Wastestream Quantity, and Volume

Factor Values were not evaluated for Source No. 5 b ecause insufficient information was available [1, p. 51591, Sections 2.4.2.1.1, 2.4.2.1.2, 2.4.2.1.3].

Highest HWQ value assigned from Ref. 1, Table 2-5: 5.6

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SUMMARY OF SOURCE DESCRIPTIONS

Table 36 – Summary of Source Descriptions

Source

No. Source HWQ

Value Source

Hazardous
Constituent

Quantity Complete? (Y/N) Containment Factor Value by Pathway

Ground

Water (GW) (Ref. 1, Table 3-2) Surface Water (SW)* Air

Overland/

flood (Ref. 1, Table 4-2) GW to

SW (Ref. 1, Table 3-2) Gas (Ref. 1, Table 6-3) Particulate (Ref. 1, Table 6-9)

1 2,565.2 N 10 NS NS NS NS

2 8,226.4 N 10 NS NS NS NS

3 690.8 N 10 NS NS NS NS

4 4,512.0 N 10 NS NS NS NS

5 5.6 N 10 NS NS NS NS

HWQ = Hazardous Waste Quantity.

NS = Not Scored.

No. = Number.

Total Source Hazardous Waste Quantity Value: 16,000.0 Other possible sources not scored:

As part of the reconnaissance of the Leeds Metal property, conducted as part of the EPA Site Assessment SI, multiple rusted 55-gallon drums located along the sout hern property boundary were observed and designated as the Abandoned Drum Area [14, pp. 11-12]. Analytical results of five surface and subsurface soil/source samples (SS-37, SS-38, SS-39, SB-37, SB-38) collected from the Abandoned Drum Source Area, as part of the EPA Site Assessment SI, indicated a source containing the following two VOCs, two PCBs, and 13 total metals at concentrations above background: acetone , 2-butanone, Aroclor-1254, Aroclor-1260, aluminum, barium, cadmium, calcium, chromium, copper, iron, lead, magnesium, manganese, mercury, nickel, and zinc [11, pp. 38, 71-72, 88, Attachment A [Table 1 (p. 6 of 7) , Table 2 (p. 6 of 7), Table 3 (p. 6 of 7)], Attachment C [Table 1 (p. 4 of 4), Table 2 (p. 4 of 4), Table 3 (p . 4 of 4)]; 16, pp. 14-16; 17, p. 12; 34, pp. 23-24; 35, Table 1 (pp. 2-3 of 3), Table 2 (pp. 2-3 of 3); 40, Table 1 (pp. 2-3 of 3)]. This source does not affect the Total Source Hazardous Waste Quantity Value and was therefore not scored.

On 2 March 2000, as part of the investigation of past industrial practices at the Leeds Metal property, ME DEP personnel interviewed the former assistant fire ch ief of the Town of Leeds, ME, who stated that transformers and batteries were drained from cars adjacen t to the entrance trailer, between the trailer and railroad trestle [26]. On 16 March 2010, as part of the EPA Site Assessment SI Leeds Metal property reconnaissance, the Battery Drop Area was observed on th e northern portion of the property, adjacent to the parking area [14, p. 15]. Analytical results of seven surface soil samples coll ected from the Battery Drop Area as part of the EPA Removal Program Preliminary Assessment/Site Investigation indicated a source containing the following three metals above screening de tection limits: antimony, arsenic, and lead [11, p. 4 (Figure 2); 32, pp. 27-28, 40-41 (Figure 4a and Figure 4b) , 57-60, 126]. This source does not affect the Total Source Hazardous Waste Quantity Value and was therefore not scored.

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During the 16 March 2010 EPA Site Assessment SI Leed s Metal property reconnaissance, the Container Disposal Area was observed, located along the western property boundary, adjacent to the two lagoons [14, pp. 12-13]. The Container Disposal Area contained numerous metal containers (with labels depicting contents of motor oil, brake fluid, antifreeze, etc. ) and bottles [14, pp. 12-13]. Analytical results of four surface soil/source samples (SS-03, SS-04, SS-05, and SS-43) collected from the Container Disposal Area, as part of the EPA Site Assessment SI, indicated a source containing the following VOC and six total metals at concentrations above background: methyl acetate, bari um, cadmium, copper, lead, potassium, and zinc [11, pp. 26-27, 39, 42, 73, Attachment A [Table 1 (p. 1, 6 of 7) , Table 2 (p. 1, 6 of 7), Table 3 (p. 1, 7 of 7)]; 16, pp. 2-4; 34, p. 21; 35, Table 1 (pp. 1-2 of 3), Table 2 ( pp. 1-2 of 3); 40, Table 1 (pp. 1-2 of 2)]. This source

does not affect the Total Source Hazardous Waste Quantity Value and was therefore not scored.

On 17 June 2004, Roux Associates, Inc. (Roux Associat es), on behalf of Guilford Rail System, completed a Targeted Environmental Investigation of the northwest portion of the Leeds Metal property [21, pp. 1-4]. The purpose of the investigation was to determine if hazardous substances were present on the northwestern portion of the property due to filling activities allegedl y conducted by an adjacent business, Rinker Industries (located at 173 State Route 106 in Leeds, ME) [21, pp. 1-2, Figure 2]. During the 16 March 2010 EPA Site Assessment SI Leeds Metal property reconnaissance, numer ous pieces of concrete pi pe and other concrete debris were observed on the northwestern portion of the property [14, p. 15]. This Concrete Disposal Area extended along the northwestern property boundary, and extended approximately 100 to 125 feet onto the Leeds Metal property [14, p. 15]. Surface soil samples co llected from the Concrete Disposal Area as part of the Roux Associates Targeted Environmental Investigation indicated a source containing DRO and the following ten SVOCs and seven RCRA 8 metals at c oncentrations above laboratory detection limits: benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranth ene, benzo(g,h,i)perylene, benzo(k)fluoranthene, chrysene, fluoranthene, indeno(1,2,3-cd)pyrene, phenanthrene, pyrene, arsenic, barium, cadmium, chromium, lead, selenium, and silver [21, pp. 10-14, Table 1, Appendix H]. This source does not affect the Total Source Hazardous Waste Quantity Value and was therefore not scored.

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3.0 GROUND WATER MIGRATION PATHWAY

3.0.1 GENERAL CONSIDERATIONS

Ground Water Migration Pathway Description

Regional Geology/Aquifer Description:

The Leeds Metal property is located within an area generally underlain by the meta-sedimentary bedrock geologic Sangerville Formation, which is Silurian in age and is highlighted by thick-bedded, weakly calcareous, poorly-graded greywacke, sands tone, and siltstone [Figure 1; 7; 8; 63, pp. 1-2; 63a; 64, pp. 1-4; 65, p. 3; 66; 66a; 67, p. 10 (Map 16)]. The Sangerville Formation is further divided into subdivisions, of which the Patch Mountain Member is one [63, pp. 1-2; 63a; 64, p. 2; 66; 66a]. The Leeds Metal property lies within an area underlain by the early Silurian Patch Mountain Member of the Sangerville Formation [7; 63, pp. 1-2; 63a; 64, p. 2; 66; 66a]. The Patch Mount ain Member is characterized by ‘thin well-bedded alternations of light-to-medium greenish-gray calc-sili cate granofels, quartzo-feldspathic biotite granofels, and fine-grained impure granobl astic marble’ [64, p. 2].

The regional surficial geology around the Leeds Metal property is highlighted by Pleistocene glaciomarine deposits [7; 8; 67, pp. 11-12; 68; 68a ; 69; 69a; 70; 70a]. Surficial deposits beneath the Leeds Metal property are classified as Island Pond Marine Delta, which were formed under glacial-marine deltaic conditions and are composed of sorted and stratified sand and gravel [ 69; 69a; 70; 70a]. Depositional characteristics of the

Island Pond Marine Delta materials indi cate that the deposit was graded to th e surface of a late-glacial sea and contains flat top, forset, and topset beds [69; 69a; 70; 70a]. The area of the Island Pond Marine Delta is classified as a significant sand and gravel aquifer with surficial deposits considered to contain moderate-togood potential ground water yield of up to 50 gallons per minute [69; 69a; 70; 70a; 71; 71a].

Surficial deposits south and southeast of the Leeds Meta l property are classified as Marine Nearshore deposits and Presumpscot Formation [7; 69; 69a; 70; 70a]. Marine Nearshore deposits are characterized as containing sand, gravel, and silt deposited by wa ve and current action in shoreline and shallow nearshore environments [69; 69a; 70; 70a]. The Presumpscot Formation is characterized as containing materials such as silt, clay, and sand deposited on the late-glacial to early pos tglacial sea floor [69; 69a; 70; 70a].

Thickness of the overburden material northwest of the Leeds Metal property, along Plains Road, is approximately 97 feet; and the thickness of the overburden material to the south and southwest of the property is 148 to 188 feet [72; 72a; 73, pp.1-2].

Site Geology/Aquifer Description:

Limited information is available regarding the Leeds Metal property geology from the four investigations completed on behalf of the propert y owner between 1999 and 2004 as will be described below. The property is approximately 36 acres, and the majority of the prope rty was used during the past operations at the property [19, p. 1; 24, p. 1]. Subsurface investigations and ground water monitoring well installation on the Leeds Metal property have been conducted to a maximum depth of 47 feet bgs within the overburden aquifer [25, p. 3].

The ground water flow direction in the shallow overburde n, deep overburden, and bedrock aquifers is not fully characterized. As discussed below, the ground water in the “shallow overburden” was originally interpreted to flow in a southerly di rection and later in a north to northwest direction (as indicated by wells with a maximum depth of 22 ft bgs) by the property owner’s consultants [24, p. 3; 25, p. 5]. Interpretation of

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the shallow overburden data, by ME DEP personnel, concluded that the gr ound water flow direction was in a more westward direction than noted in the property ow ner’s report [9; 141, p. 2, Figure 3]. In addition, as noted by the ME DEP, the investigation reports prepared on behalf of the property owner do not discuss the ground water flow direction in the “deeper overburden” (maximum depth of 47 feet bgs) [141, p. 2]. ME DEP further noted that, based on the property owner’ s data, the monitoring well couplets on the property exhibit a downward vertical gradient [141, p. 2]. In addition, Roux, working on behalf of the property owner, noted that a ground water recharge condition exists on property based on the comparison of ground water elevations in the shallow and deep overburden monitori ng wells [21, p. 16]. Furthermore, no monitoring well data exists to indicate flow direction at depths greater than 47 ft bgs [141, p. 2]. According to ME DEP and the ME Geological Survey, the overburden material in the area is estimated to exceed 100 ft in thickness, based on boring logs from a private well in the immediate vicinity of the property boundary [72; 72a; 73, pp. 1-2]. Moreover, as discussed below, the slope of the bedrock surface will influence contaminant flow direction due to tendency of the observed release cont aminants to sink through the ground water column and travel downward along impermeable surfaces due to their densities being greater than that of water. MEDEP notes that deeper ground water flow will likely follow th e regional surface water drainage pattern towards the Dead River, located to the southwest of the site [163, pp. 4-5; 164; 165, p.3].

On 16 and 17 September 1998, ERM, on behalf of Maine Central Railr oad, installed 11 temporary ground water monitoring wells at various locations throughout th e Leeds Metal property [24, pp. 1-2, 7, 11]. The intent of the temporary ground water monitoring well poi nts was to provide a preliminary evaluation of onsite ground water quality [24, p. 2]. ERM advanced the temporary monitoring wells to a maximum total depth of 28 feet bgs and gauged the de pth to water within each well point [ 24, p. 2]. Depth to water ranged from 5.5 to 22 feet bgs [24, p. 3]. ERM determined that in general, ground water elevations were highest in the north and northeast areas of the site [24, p. 3]. ER M further stated that ground water flow directions are generally from north to south across the site [24, pp. 3, 12].

On 1 through 3 November 1999, ERM, on behalf of Ma ine Central Railroad, in stalled nine overburden ground water monitoring wells at soil boring locations on the Leeds Metal property [25, pp. 2-3, 12]. Four sets of monitoring well clusters were installed whose design involved installing one shallow water table well and one deep overburden well [25, pp. 3, 13]. In add ition, ERM installed one shallow water table well on the central portion of the site to provide data for ground water flow determination [25, pp. 3, 13]. Shallow water table wells were installed to a maximum depth of 22 feet bgs [25, p. 3]. Deep over burden wells were installed to a maximum depth of 47 feet bgs [25, p. 3]. Sp lit spoon soil samples were collected at approximate fivefoot intervals in each boring of the deep overburden we lls [25, pp. 3, 5]. An ERM geologist characterized each soil sample [25, p. 3]. The soil at the site consists primarily of brown-to-gray, medium-to-fine sand with some medium-to-coarse gravel [25, p. 5, Appendix A]. Bedrock was not encountered at any of the four deep overburden wells [25, p. 5]. ER M conducted ground water gauging at the monitoring well locations [25, p. 5]. Ground water elevation ranged from 90.00 feet to 92.44 feet as measured with respect to an arbitrary survey datum [25, p. 5]. In general, ERM found th at ground water elevations for shallow overburden wells are highest in the south and southeast areas of the site [25, p. 5]. ERM stated that ground water flow directions are generally from southeast to the northw est [25, p. 5]. In response comments to the ERM Investigation Report, ME DEP personne l, utilizing the ERM data, noted that ground water flow appears to be directed west, towards lot 43 and 44 [9; 141, p. 2, Figure 3]. ME DEP also pointed out that the ERM report did not discuss the ground water flow in the deeper overburden or the vertical gradient measured between the shallow and the deep wells [141, p. 2]. ME DEP noted that all of the wells have downward vertical gradients [141, p. 2]. In addition, ME DEP noted that the flow direction in the deeper aquifer appears to be much different from the shallow ground water flow direction [ 141, p. 2]. The water levels measured in ground water monitoring wells ERM-3D and ERM-4D have the same el evation of 90.00 (90.01 is within the accuracy of the measurement) [141, p. 2]. ME DEP suggested that the flow in the deep overburden has a more westerly component than the shallow ground water flow direction [141, p. 2]. ME DEP declared that looking at the

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hydrogeology setting, the stratigraphy will influence gr ound water flow and contaminant distribution [141, p. 3]. ME DEP stated that it was not clear if the stratigraphy will dominate both ground water flow and contaminant distribution, but it is likely to play a majo r role in one or both [141, p. 3]. ME DEP concluded that further off-site investigation and site characterization was needed [141, p. 3].

On 27 through 29 November 2000, ERM and their subcont ractor, Pine & Swallow, on behalf of Maine Central Railroad, conducted a shallow ground water investiga tion at the site to evaluate the extent of VOCs in ground water [28, pp. 1-3]. One temporary monitori ng well (SB-1) and 11 semi-permanent wells (SB-2 through SB-12) were installed on the Leeds Metal propert y [28, p. 2, 10]. Wells were installed based on previous detections of PCE in monito ring wells installed on the site [28, p. 2]. The total depths of the wells ranged from 8 to 24 feet bgs [28, p. 3]. Ground water sa mples were collected from each of the newly installed wells [28, p. 3]. In addition, ground water samples we re collected from existing monitoring wells ERM-2S, ERM-3S/D, and ERM-4S/D [28, pp. 1-3].

In June 2004, on behalf of Guilford Rail, Roux comple ted a Targeted Environmental Investigation for a portion of the Guilford Rail property [21, p. 1]. Roux noted that the Guilford Rail property is approximately 39 acres and is listed on the ME DEP List of Sites Reported to the Uncontrolled Sites Program as the Leeds Metal site [12; 21, p. 1]. The Targeted Environmen tal Investigation focused on an approximately one-acre area located along the north-western property boundary of the Leeds Metal property, defined as the portion of land located between the filled area and the tree line [ 21, p. 1, Figure 2]. On 10 May 2004 Roux advanced three soil borings, RX-1S through RX-3S, along the toe of the concrete waste fill that had been deposited on the property by Rinker Industries and/ or previous owners/operators of the property located at 173 State Route 106 [21, p. 7, Figure 2]. Ground water was encountered at less than one to approximately four feet below grade [21, p. 7]. Soil samples were continuously collected for visual characterization [21, p. 7]. Roux Soil Boring and Monitoring Well Construction Logs indicate that soils characterized for borings RX-1S through RX-3S primarily consisted of brown-to-gray, fine-to-co arse sand with some fine gravel [21, Appendix G].

On 11 May 2004, ground water elevation data for the accessible existing wells (shallow and deep well pairs ERM-1 through ERM-4, and ERM-5) located on the L eeds Metal Area and the newly installed ground water monitoring wells RX-1S through RX-3S located on the S ite was completed [21, p. 16]. The Leeds Metal Area was defined by Roux as the area of historical autom obile storage and metal recycling operations [21, p. 3]. Based on the gauging data combined with the surv ey results produced by Guilford Rail, it was concluded that the direction of ground water flow beneath the site in the shallow overburden aquifer is in a north to northwesterly direction [21, p. 16]. Roux also noted that a comparison of ground water elevations in the shallow and deep overburden monitoring wells located in the Leeds Metal Area indicates that ground water recharge conditions (i.e., downward vertical flow) exist in this portion of the Guilford Rail property [21, p. 16].

Leeds Aquifer:

Surficial deposits beneath the Leeds Metal property ar e classified as Island Pond Marine Delta, which were formed under glacial-marine deltaic conditions and are com posed of sorted and stratified sand and gravel [69; 69a; 70; 70a]. On-site investigations conducted to date indicate the subs urface geology consists of fine-tocoarse sand, with some fine-to-coarse gravel and inconsis tent inclusions of silt and clay on the property [21, Appendix G; 25, pp. 3, 14-26; 32, Narrative Chronology (pp. 4-6), Table 1]. Overburden material thickness in the area around the Leeds Metal property is approxi mately 97 feet northwest, along Plains Road, and

between 148 and 188 feet to the south and southwest of the property [72; 72a; 73, pp. 1-2]. The hydraulic conductivity of fine-to-coarse sand deposits such as this is approximately 10 -4 centimeters per second (cm/s) [1, p. 51601 (Table 3-6)].

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The Leeds Metal property is underlain by meta-sedimen tary bedrock of the Sange rville Formation, Patch Mountain Member [7; 8; 63, pp. 1-2; 63a; 64, pp. 1-4; 65, p. 3, 66; 66a; 67, p. 10]. The Patch Mountain Member is characterized by ‘thin well-bedded alterna tions of light to medium greenish-gray calc-silicate granofels, quartzo-feldspathic biotite granofels, and fine -grained impure granoblastic marble’ [64, p. 2]. In places, the Patch Mountain Member is composed of massi ve marble only [64, p. 2]. Bedding is frequently accentuated on weathered surfaces by the differential solution of marble beds [64, p. 2]. Evidence of faulting in the area is almost entirely lacking and the metamorphi c rocks, as a rule, are poorly jointed [64, p. 9]. The hydraulic conductivity of low to moderate permeable fracture metamorphic bedrock such as this is from approximately 10 -4 to 10 -6 cm/s [1, p. 51601 (Table 3-6)].

Depth to bedrock northwest of the Leeds Metal propert y, along Plains Road, is 97 feet bgs (Well location DW-02), while the depth to bedrock immediately sout h of the Leeds Metal property on the adjacent property (Town of Leeds, ME Tax Assessors Office Map No. 4, Lot No. 39) is 148 feet bgs (Well location DW-09) [72; 72a; 73, pp.1-2; 144 p. 1].

Based on GPS data collected by START in November and December 2010, local residential well information regarding the depth to bedrock, and overburden thickness in the area of the Leeds Metal property, the bedrock surface elevation (topography) in the vicinity of the Leeds Metal property, generally slopes from north to south along ME Route 106 [144, p. 1, ]. The bedrock surface topography slopes from 267.4 ft above mean sea level (amsl) northwest of the site along Plains Ro ad (Background drinking water well location DW-02, 0.51 miles northwest of Debris Pile D), to 180.9 ft amsl adjacent the southwestern corner of the site along ME Route 106 (Sample DW-09 location, 0.1 miles southwest of Debris Pile D), to 160.9 ft amsl south of the southwestern corner of the site along ME Route 106 (Sample DW-23 location, 0.3 miles southwest of Debris Pile D) [144].

According to ME DEP, the hydrogeologic environment is very complex and the limited sampling completed to date had been inadequate to unde rstand the temporal and spatial comple xities and variations [142, p. 1; 165, p. 3]. There is insufficient data to determine th e location, size or relative strength of the source areas or

vertical and horizontal distribution of VOCs in the subs urface [142, p. 1]. However, no physical barriers to ground water flow, such as mountains or large rivers, have been identified within a 4-mile radius of the Leeds Metal property (See Figure 6) [7; 8; 150; 151; 152]. Subsurface investigations to date have not identified any continuous aquitards in the vicinity of the Leeds Me tal property [21; 24; 25; 28]. Furthermore, as noted above, the fine-to-coarse sand overburden deposits and moderately permeable fracture metamorphic bedrock do not demonstrate any significantly lower hydraulic c onductivity layers that separate aquifers throughout a 2-mile radius of the site sources [1, Table 3-6]. Ther efore the hydrogeology beneath the site is characterized by a single aquifer consisting of the on-site shallow a nd deep glacial overburden aquifer and the hydraulically connected underlying meta-sedimentary be drock aquifer. The aquifer interconnection is also demonstrated by a downward migration of hazardous substances (PCE) fro m the Leeds Metal sources into the on-site shallow and deep overburden aquifers, and then to the bedrock a quifer, which supplies nearby residential wells within 1 mile of the site sources (See Observed Release Data Tables – Tables 41 and 45). Therefore, an aquifer

interconnection occurs within 2 miles of the sources at the site and the combined aquifer constitutes the aquifer being evaluated that is used for scoring the s ite [1, p. 51595 (Section 3.0.1.2.1)]. For the purposes of this evaluation, since the Shallow Overburden, Deep Glacial and underlying Meta-sedimentary Bedrock Aquifers are interconnected the combined aquifer (Leeds Aquifer) constitutes the aquifer being evaluated.

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Table 37 - Summary of Aquifers Being Evaluated

Aquifer

No. Aquifer Name Is Aquifer

Interconnected

with Upper Aquifer within 2 miles? (Y/N/NA) Is Aquifer

Continuous within 4-mile TDL? (Y/N) Is Aquifer Karst? (Y/N)

1 Leeds Aquifer N/A Y N

NA

TDL = Not Applicable. = Target Distance Limit. Y

N =

= Yes.

No.

3.1 LIKELIHOOD OF RELEASE

3.1.1 OBSERVED RELEASE

Chemical Analysis – Ground Water

Aquifer Being Evaluated: Leeds Aquifer

As described above the hydrogeology beneath the site is characterized by the on-site shallow and deep glacial overburden aquifer which is hydraulically connected to the underlying meta-sedimentary bedrock aquifer and the aquifer interconnection is demonstrated by a downwar d migration of hazardous substances. Therefore, an aquifer interconnection occurs within 2 miles of the s ources at the site, and the combined aquifer constitutes the aquifer being evaluated that is used for scoring th e site [1, p. 51595 (Section 3.0.1.2.1)]. For the purpose of this evaluation, since the Shallow Overburden, Deep Glacial, and underlying Meta-sedimentary Bedrock Aquifers are interconnected the combined aquifer (Leeds Aquifer) constitutes the aquifer being evaluated.

Background Concentrations (Ove rburden Monitoring Wells):

On 10, 11, and 16 November 2010, as part of the EPA Site Assessment Site Inspection, 12 ground watersamples (GW-01 through GW-12), including one field duplicate, were collected from eleven permanent onsite monitoring wells installed throughout the Leeds Metal property (see Figure 4) [11, pp. 123, Attachment D; 15, pp. 8-11, 20-24, 40-41, 43-44, 46; 34, pp. 14- 17, 19-20; 77, pp. 1-13]. The 12 ground water samples were collected in accordance with the EPA-approved Site-Specific QAPP, dated 26 October 2010, using lowflow sampling techniques [6, pp. 79-80; 15, pp. 8-11, 20-24, 40-41, 43-44, 46; 34, pp. 14-17, 19-20; 77, pp. 1­ 13]. The ground water samples were collected from ni ne overburden ground water monitoring wells (ERM1S, ERM-1D, ERM-2S, ERM-2D, ERM-3S, ERM-3D, ER M-4S, ERM-4D, and ERM-5] installed by ERM on 1 through 3 November 1999, and from two overburden ground water m onitoring wells (RX-2S and RX3S) installed by Roux Associates on 10 May 2004 [11, pp. 116, 122, 124-127; 15, pp. 8-11, 20-24, 40-41, 43­ 44, 46; 21, p. 7, Figure 2, Appendix G; 25, pp. 3, 12, 14-26; 34, pp. 14-17, 19-23; 77, pp. 1-13]. The 12 ground water samples were collected from the wells as follows: GW-01 from well ERM-5; GW-02 from well ERM-2S; GW-03 from well ERM-2D; GW-04 from well ERM-1S, GW-05 from well ERM-1D; GW-06 from well ERM-4S; GW-07 and field duplicate GW-10 fro m well ERM-4D; GW-08 from well ERM-3S; GW-09 from well ERM-4D; GW-11 from well RX-3S; and GW- 12 from well RX-2S (see Figure 4) [11, pp. 124-127; 15, pp. 8-11, 20-24, 40-41, 43-44, 46; 34, pp. 14-17, 19-23; 77, pp. 1-13]. One ground water sample, GW-12, was collected to determine background concentrations fo r comparison [11, pp.123; 15, pp. 43, 46; 34, p. 20; 77, p. 13].

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The ground water samples were submitted to CLP Laboratories for VOC analyses following SOM01.2 [11, pp. 123; 15, pp. 8-11, 20-24, 40-41, 43-44, 46; 34, pp. 14- 17, 19-23, 69-72 (Table 1); 46, p. 1; 47, p. 1; 95; 96]. The analytical data were validated according to EPA New England Regional Functional Guidelines Tier II requirements (for VOC analysis) [46, p. 1; 47, p. 1]. Sample, GW-12, was used to establish background chemical composition/conditions of the matrix materi als within the local vicinity and to establish a concentration value that demonstrates that a signifi cant concentration of a hazardous substance is present above background concentrations. For the purposes of this HRS documentation record and as part of the Ground Water Sample section, one hazardous substance, PC E, is used to document a release to the on-site overburden ground water aquifer; however, background concentrations for both PCE and TCE are presented.

Table 38 - Background Ground Wat er Sample Location Description

Sample

ID Screened Interval (feet amsl) Date Sampled Backgrounds

GW-12 318.4 to 308.4 16 Nov. 2010 15, pp. 43, 46; 21, p. 7, Table 3, Appendix G; 34, p. 20; 153, pp. 1-2; 155, p. 1

amsl = above mean sea level. Nov. = November.

Background ground water sample GW-12 was collected from ground water overburden monitoring well RX2S, which is located on the northwestern portion of the Leeds Metal property, adjacent to the northern property boundary (see Figure 4) [15, pp. 43, 46; 21, p. 7, Figure 2, ; 34, p. 20; 77, p. 13]. The background sample, GW-12, was collected from within the same aquifer, similar geologic zone (overburden vs. bedrock), and during the same time period as the other on-site ground water samples collected for this evaluation [11, pp.123-127; 15, pp. 8-11, 20-24, 40-41, 43-44, 46; 21, Table 3; 34, pp. 14-17, 19-23; 63, pp. 1-2; 63a; 68; 68a]. On 16 November 2010, the total depth of ground water monitoring well RX-2S was 14.7 feet as measured from the top of the poly vinyl chloride (PVC) casing, and the low-flow bladder pump used to purge and collect the sample from the well was placed at 12 f eet below the top of the PVC casing [15, pp. 43, 46; 34, p. 20; 77, p. 13]. The sample was collected, utilizing low-flow sampling procedures, after a total of 16.3 liters of ground water were purged from monitoring well RX-2S and water quality parameters stabilized [15, pp. 43, 46; 34, pp. 19-20; 77, p. 13].

Laboratory analytical results of the VOC fraction fo r background ground water sample GW-12 indicated that a positive spectral match for PCE and TCE were not detected, therefore the concentrations were reported to the sample-adjusted CRQL and qualified as non-detect (0.5 U μg/L) [46, Table 1 (p. 3 of 3); 103, Exhibit C (pp. 1-6); Exhibit D Trace VOA (pp. 31-32); 104, pp. 1-10]. Background concentrations for PCE and TCE are set to equal the sample-adjusted CRQL if the h azardous substances were not detected in the background samples [1, p. 51589 (Table 2-3)]. Therefore, for the purposes of this HRS documentation record, PCE and TCE in ground water samples at concentrations greater than or equal to 0.5 μg/L can be used to document an observed release to the aquifer [1, pp. 51588 (Section 2.2.3), 51589 (Table 2-3)].

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Table 39 - Hazardous Substances Associated with Background Ground Water Samples

Sample

ID Hazardous
Substance Concentration (μg/L) SampleAdjusted

CRQL (μg/L) References

GW-12 PCE 0.5 U 0.5 15, pp. 43, 46; 34, p. 20; 46, Table 1 (p. 3 of 3); 153 (pp. 1-2)

GW-12 TCE 0.5 U 0.5 15, pp. 43, 46; 34, p. 20; 46, Table 1 (p. 3 of 3); 153 (pp. 1-2)

PCE = Tetrachloroethene. TCE = Trichloroethene. μg/L = Micrograms per liter. CRQL = Contract Required Quantitation Limit. U = The compound or element was analyzed for, but not detected. The associated numerical value is the sample-adjusted CRQL [103, p. B-47].

Contaminated Samples (Overburden Monitoring Wells):

On 10, 11, and 16 November 2010, as part of the EPA Site Assessment Site Inspection, 12 ground water samples (GW-01 through GW-12), including one field duplicate, were collected from 11 permanent on-site monitoring wells installed throughout the Leeds Metal pr operty (see Figure 4) [11, pp. 123; 15, pp. 8-11, 20­ 24, 40-41, 43-44, 46; 34, pp. 40, 69-72 (Table 1); 77, pp. 1-13]. The 12 ground water samples were collected in accordance with the EPA-approved Site-Specific QA PP, dated 26 October 2010, using low-flow sampling techniques [6, pp. 79-80; 11, pp. 110-165, Attachment D; 15, pp. 8-26, 39-46; 34, pp. 14-17, 19-23, 69-72 (Table 1); 77, pp. 1-13]. The ground water samples were collected from nine overburden ground water monitoring wells (ERM-1S, ERM-1D, ERM-2S, ERM-2D, ERM-3S, ERM-3D, ERM-4S, ERM-4D, and ERM-5] installed by ERM on 1 through 3 Nove mber 1999, and from two overburden ground water monitoring wells (RX-2S and RX-3S) installed by Roux Associates on 10 May 2004 [11, pp. 116, 122, 124­ 127, Attachment D; 15, pp. 8-26, 39-46; 21, p. 7, Figur e 2, Appendix G; 25, p. 3, 12, 14-26; 34, pp. 14-17, 19-23; 77, pp. 1-13]. The 12 ground water samples were collected from the wells as follows: GW-01 from well ERM-5; GW-02 from well ERM-2S; GW-03 fro m well ERM-2D; GW-04 from well ERM-1S, GW-05 from well ERM-1D; GW-06 from well ERM-4S; GW-07 and field duplicate GW-10 from well ERM-4D; GW-08 from well ERM-3S; GW-09 from well ERM-4D; GW-11 from well RX-3S; and GW-12 from well RX-2S (see Figure 4) [11, pp. 124-127, Attachment D; 15, pp. 8-26, 39-46; 34, pp. 14-17, 19-23, 69-72 (Table 1); 77, pp. 1-13]. Ground water sample GW-12 was collected to determine background concentrations for comparison, while ground water samples GW-01 through GW-11 were collected to determine if a release

of hazardous substances to the overbur den aquifer had occurred [11, pp. 123; 15, pp. 8-26, 39-46; 34, pp. 14­ 17, 19-23, 69-72 (Table 1); 77, pp. 1-13]. ]. As noted above, the background sample was collected from within the same aquifer, similar geologic zone (ove rburden vs. bedrock), and during the same time period as the other on-site ground water samples collected for this evaluation.

The ground water samples were submitted to CLP Laboratories for VOC analyses following SOM01.2 [11, pp. 123, Attachment D; 15, pp. 8-11, 20-24, 40-41, 43-44, 46; 34, pp. 40, 69-72; 46, p. 1; 47, p. 1; 95; 96]. The analytical data were validated according to EPA New England Regional Functional Guidelines Tier II requirements (for VOC analysis) [46, p. 1; 47, p. 1] . For the purposes of this HRS documentation record, PCE analytical results from four ground water samples (GW-02, GW-06, GW-07, and GW-11) are used to

document an observed release to the overburden ground water aquifer.

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Table 40 – Ground Water Sample Location Description

Sample

ID Screened

Interval (feet amsl) Date Sampled References

GW-02 319.1 to 309.1 10 Nov. 2010 15, p. 11; 25, pp. 12, 19; 34, pp. 15, 41, 69; 155 p. 1

GW-06 312.5 to 302.5 10 Nov. 2010 15, pp. 9-10; 25, pp. 12, 23; 34, pp. 14, 41, 70; 155 p. 1

GW-07 297.5 to 292.5 11 Nov. 2010 15, pp. 21-22; 25, pp. 12, 24-25; 34, pp. 17,41,71; 155 p. 1

GW-11 315.6 to 305.6 16 Nov. 2010 15, pp. 41, 44; 21, p. 7, Figure 3, Table 3, Appendix G; 34, pp. 20, 41, 72; 155 p. 1

amsl = above mean sea level. Nov. = November.

Ground water sample GW-02 was collected from ground water monitoring well ERM-2S, located on the southern portion of the Leeds Metal property, directly s outh of Debris Pile B (see Figures 2 and 4) [15, p. 11; 25, p. 3, 12, 19; 34, pp. 15, 41, 69 (Table 1); 77, p. 3]. The total depth of ground water monitoring well ERM-2S was 20.8 feet as measured from the top of the casing, and the low-flow bladder pump used to purge and collect the sample from the well was placed at 19.3 feet below the top of the casing [15, p. 11; 34, pp. 15, 69 (Table 1); 77, p. 3]. The sample was collected, utilizing low-flow sampling procedures, after a total of

11.0 liters of water were purged from ground water monitoring well ERM- 2S and water quality parameters stabilized [15, p. 11; 34, pp. 15, 69 (Table 1); 77, p. 3].

Ground water sample GW-06 was collected from ground water monitoring well ERM-4S, located on the southern-central portion of the Leeds Metal property, nor thwest of Debris Pile D (see Figures 2 and 4) [15, pp. 9-10; 25, pp. 12, 23; 34, pp. 14, 70 (Table 1); 77, p. 7]. The total depth of ground water monitoring well ERM-4S was 16.95 feet as measured from the top of the cas ing, and the low-flow bladder pump used to purge and collect the sample from the well was placed at 13.9 feet below the top of the casing [15, pp. 9-10; 34, pp. 14, 70 (Table 1); 77, p. 7]. The sample was collected, utilizing low-flow sampling procedures, after a total of

10.0 liters of water were purged from ground water monitoring well ERM- 4S and water quality parameters stabilized [15, pp. 9-10; 34, pp. 14, 70 (Table 1); 77, p. 7].

Ground water sample GW-07 was collected from ground water monitoring well ERM-4D, located on the southern-central portion of the Leeds Metal property, nor thwest of Debris Pile D (see Figures 2 and 4) [15, pp. 21-22; 25, pp. 12, 24-25; 34, pp. 17, 41, 71 (Table 1); 77, p. 8]. The total depth of ground water monitoring well ERM-4D was 26.3 feet as measured from the top of the casing, and the low-flow bladder pump used to purge and collect the sample from the we ll was placed at 24.5 feet below the top of the casing [15, pp. 21-22; 34, pp. 17, 71 (Table 1); 77, p. 8]. The sample was collected, utilizing low-flow sampling protocols, after a total of 30.0 liters of water we re purged from ground water monitoring well ERM-4D and water quality parameters stabilized [15, pp. 21- 22; 34, pp. 17, 71 (Table 1); 77, p. 8].

Ground water sample GW-11 was collected from ground water monitoring well RX-3S, located on the northern-central portion of the Leeds Metal property, adjacent to the northern property boundary (see Figures 2 and 4) [15, pp. 41, 44; 21, p. 7, Figure 3, Table 3, Appendix G; 34, pp. 20, 41, 72 (Table 1); 77, p. 12]. The total depth of ground water monitoring well RX-3S was 14.7 feet as measured from the top of the casing, and the low-flow bladder pump used to purge and collect the sample from the well was placed at 12 feet below the

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top of the casing [15, pp. 41, 44; 34, pp. 20, 72 (Table 1); 77, p. 12]. The sample was collected, utilizing lowflow sampling protocols, after a total of 9.1 liters of water were purged from ground water monitoring well RX-3S and water quality parameters stabilized [15, pp. 41, 44; 34, pp. 20, 72 (Table 1); 77, p. 12].

Of the four ground water samples presented, PCE was detected at a maximum concentration of 19 μg/L in ground water sample GW-06 [15, pp. 9-10; 34, p. 14; 46, Tabl e 1 (p. 2 of 3); 47, Table 1 (pp. 1-2 of 3)]. PCE was detected in each of the four ground water samples as c oncentrations greater than or equal to the relevant background sample concentrations (GW-12, concentrati on 0.5 U μg/L) [11, pp. 110-165, Attachment D; 15, pp. 9-11, 21-22, 41, 43-44, 46; 34, pp. 14-15, 17, 20; 46, Ta ble 1 (pp. 2of 3); 47, Table 1 (pp. 1-2 of 3)].

Table 41 - Hazardous Substances Associated with Ground Water Samples

Sample

ID Hazardous
Substance Concentration (μg/L) SampleAdjusted

CRQL (μg/L) References

GW-02 PCE 1.2 0.5 15, p. 11; 34, p. 15; 47, Table 1 (p. 1 of 3); 153, pp. 3-4

GW-06 PCE 19 0.5 15, pp. 9-10; 34, p. 14; 47, Table 1 (p. 2 of 3); 153, pp. 5-6

GW-07 PCE 5.7 0.5 15, pp. 21-22; 34, p. 17; 47, Table 1 (p. 2 of 3); 153, pp. 7-8

GW-11 PCE 0.59 0.5 15, pp. 41, 44; 34, p. 20; 46, Table 1 (p. 2 of 3); 153, pp. 9-10

PCE = Tetrachloroethene. CRQL = Contract Required Quantitation Limit. μg/L = Micrograms per liter.

Note: TCE was detected in two ground water samples (GW-06 and GW-07) at c oncentrations above CLP laboratory reporting limits but below the sample-adjuste d CRQL, and was therefore not evaluated for scoring in this HRS documentation record [47, Table 1 (p. 2 of 3); 103, Exhibit C (pp. 1-6), Exhibit D Trace VOA (pp. 31-32); 104, pp. 1-10]. TCE is a common breakdown product of PCE [49, pp. 189-190; 50, pp. 197, 202­ 203; 51, Section 1 (pp. 8-12), Table 1.1, Figure 1.4, Sec tion 2 (pp. 1-16), Figure 2.2, Figure 2.3, Figure 2.4]. TCE is a colorless liquid used mainly as a solvent to remove grease from metal parts [147, pp. 1-2]. TCE is not thought to occur naturally in the environment [147, pp. 1-2].

Chemical Analysis – Drinking Water Samples

- Background Concentrations:

On 8 through 11, 16, and 17 November 2010, as part of the Leeds Metal EPA Site Assessment Site Inspection, 31 drinking water samples, including two field duplicates (DW-01 through DW-06, DW-08 through DW-16, DW-18 through DW-31, DW-33, and DW -34) were collected from 29 drinking water supply wells located northwest, west, southwest, south, south east, and east of the Leeds Metal property (see Figure 5) [11, pp. 133-149; 14, pp. 23-28, 31-39, 44-45; 15, pp. 4- 7, 12, 15-17, 19-20; 16, pp. 4-5, 7-10, 14-19, 22-23, 25-26; 34, pp. 8-16, 22-25, 41, 42-45, 73-87 (Table 1) ; 78, pp. 1-29]. The drinking water samples were collected in accordance with the EPA-approved Site-S pecific QAPP, dated 26 October 2010 [6, pp. 79-80; 14, pp. 23-28, 31-39, 44-45; 15, pp. 4-7, 12, 15-17, 19-20; 16, pp. 4-5, 7-10, 14-19, 22-23, 25-26; 34, pp. 7-17, 19-26, 73-87 (Table 1); 78, pp. 1-29]. Drinking wate r samples DW-01, DW-02, and DW-03 were collected

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from overburden and bedrock drinking water supply wells located northwest of the Leeds Metal property to establish background concentrations for comparison (see Fi gure 5) [11, pp. 133-135; 14, p. 26; 16, pp. 7-9; 34, pp. 8, 22, 73-74 (Table 1)]. The background sampl es were collected from within the same aquifer, at similar well screen elevations, similar geologic formati on (overburden or bedrock), and during the same time period as the other drinking water samples collected for this evaluation [14, pp. 23-28, 31-39, 44-45; 15, pp. 4-7, 12, 15-17, 19-20; 16, pp. 4-5, 7-10, 14-19, 22-23, 25-26; 34, pp. 8-16, 22-25, 41, 42-45, 73-87 (Table 1); 154, p. 1]

The drinking water samples were submitted to CLP Laboratories for VOC analysis according to SOM01.2 (trace level for VOC compounds) [14, pp. 23-28, 31-39, 44- 45; 15, pp. 4-7, 12, 15-17, 19-20; 16, pp. 4-5, 7­ 10, 14-19, 22-23, 25-26; 34, pp. 8-16, 22- 25, 41, 42-45, 73-87 (Table 1); 45, p. 1; 46, p. 1; 47, p. 1; 94; 95, 96;. The analytical data were validated according to EPA New England Regional Functional Guidelines Tier II requirements for VOC analysis [45, p. 1; 46, p. 1; 47, p. 1]. For the purposes of this HRS documentation record and as part of the Ground water Sample section, two hazardous substances, PCE and TCE, are used to document a release to the Leeds Aquifer. The thr ee background samples were used to establish background chemical composition/conditions of the matrix materi als within the local vicinity, and to establish a concentration value that demonstrates that a signifi cant concentration of a hazardous substance is present above naturally occurring concentrations [6, p. 79; 14, p. 26; 16, pp. 7-9; 34, pp. 8, 22, 73-74 (Table 1)].

Table 42 - Background Drinking Wa ter Sample Location Description

Sample ID Well Depth (feet amsl) Date Sampled References

DW-01 271.1 8 Nov. 2010 9; 11, pp. 133-134; 14, p. 26; 34, pp. 8, 73 (Table 1); 78, p. 1; 105, pp. 1-2, Figure 1; 106, pp. 1-2; 107, pp. 1-2; 108; 154 p. 1

DW-02 164.4 16 Nov. 2010 9; 11, pp. 133, 135; 16, pp. 7-8; 34, pp. 22, 73 (Table 1); 73, p. 1, Figure; 78, p. 2; 105, pp. 1­ 2, Figure 1; 109, pp. 1-2; 110, pp. 1-2; 154 p. 1

DW-03 297.7 16 Nov. 2010 9; 11, pp. 133, 135; 16, pp. 8-9; 34, pp. 22, 74 (Table 1); 78, p. 3; 105, pp. 1-2, Figure 1; 111, pp. 1-2; 112; 154 p. 1

amsl = above mean sea level. Nov. = November.

Drinking water sample DW-01 was collected from a residen tial property is located in Leeds, ME, depicted on the Town of Leeds, ME Tax Assessor’s Map No. 4, Lo t No. 55, located 0.511 miles northwest of the Leeds Metal property, Debris Pile D, Source No. 4 (see Figure 5) [9; 11, pp. 133-134; 14, p. 26; 34, pp. 8, 73 (Table 1); 78, p. 1; 105, pp. 1-2, Figure 1; 106, pp. 1-2; 107, pp. 1-2; 108]. The residence is supplied drinking water from an on-site, 87-foot deep drilled overburden private supply well [ 

### 14, p. 26 ; 34, pp. 8, 73 (Table 1); 78, p.1; 105, pp. 1-2, Figure 1; 106, pp. 1-2; 107, pp. 1-2; 108]. START personnel collected the sample from an inline spigot utilizing a spigot adaptor, after system purging was completed and water quality parameters stabilized [14, p. 26; 34, pp. 8, 73 (Table 1); 78, p. 1]. The sample was collected after water flowed through a holding tank and prior to any filtration system [14, p. 26; 34, pp. 8, 73 (Table 1); 78, p. 1].

Drinking water sample DW-02 was collected from a reside ntial property is located in Leeds, ME, and is depicted on the Town of Leeds, ME Tax Assessor’s Ma p No. 4 as Lot No. 54, located 0.514 miles northwest of the Leeds Metal property, Debris Pile D, Source No. 4 (see Figure 5) [9; 11, pp. 133, 135; 16, pp. 7-8; 34, pp. 22, 73 (Table 1); 73, p. 1, Figure; 78, p. 2; 105, pp. 1-2, Figure 1; 109, pp. 1-2; 110, pp. 1-2]. The

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residence is supplied drinking water from an on-site 200-foot deep drilled bedrock private supply well [16, pp. 7-8; 34, pp. 22, 73 (Table 1); 73, p. 1, Figure; 78, p. 2; 105, pp. 1-2, Figure 1; 109, pp. 1-2; 110, pp. 1-2]. Drilling records for this well, compiled by the state of Maine, indicate an overburden thickness depth of 97 feet bgs [73, p. 1, Figure; 109, pp. 1-2; 110, pp. 1-2]. START personnel collected the sample from the kitchen sink spigot after system purging was completed and water quality parameters stabilized [16, pp. 7-8; 34, pp. 22, 73 (Table 1); 78, p. 2]. The sample was collected after water flowed through an approximately 20­ gallon holding tank and the home’s piping system [16, pp. 7-8; 34, pp. 22, 73 (Table 1); 78, p. 2]. No filtration systems exist within the house [16, pp. 7-8; 34, pp. 22, 73 (Table 1); 78, p. 2].

Drinking water sample DW-03 was collected from a reside ntial property located in Leeds, ME, depicted on the Town of Leeds, ME Tax Assessor’s Map No. 4, Lot No. 48), located 0.478 miles north of the Leeds Metal property, Debris Pile D, Source No. 4 [9; 11, pp. 133, 135; 16, pp. 8-9; 34, pp. 22, 74 (Table 1); 78, p. 3; 105, pp. 1-2, Figure 1; 111, pp. 1-2]. The residence is supplied drinking water from an on-site, 55-foot deep, drilled gravel-pack overburden private supply well [16, pp. 8-9; 34, pp. 22, 74 (Table 1); 78, p. 3; 111, pp. 1­ 2]. START personnel collected the sample from an outside spigot after system purging was completed and water quality parameters stabilized [16, pp. 8-9; 34, pp. 22, 74 (Table 1); 78, p. 3]. The sample was collected after water flowed through an approximately 30-gallon holding tank and the home’s piping system [16, pp. 8­ 9; 34, pp. 22, 74 (Table 1); 78, p. 3]. According to the homeowner, the filtration system in the household had been bypassed due to cost issues [16, pp. 8-9; 34, pp. 22, 74 (Table 1); 78, p. 3].

Laboratory analytical results of the VOC fraction for background drinking water samples DW-01, DW-02, and DW-03 indicated that a positive spectral match for PCE and TCE was not detected, therefore the concentrations of PCE and TCE were reported to the sample-adjusted CRQL and qua lified as non-detect (0.5 U μg/L) [45, Table 1 (p. 1 of 3); 46, Table 1 (p. 1 of 3); 74, pp. 1-2; 103, Exhibit C (pp. 1-6), Exhibit D Trace VOA (pp. 31-32); 104, pp. 1-10]. Background concentra tions for PCE and TCE are equal to the sampleadjusted CRQL, if the hazardous substances were not detected in the background samples [1, p. 51589 (Table 2-3)]. For the purposes of this HRS documentation record, PCE and TCE in drinking water samples at concentrations greater than or equal to 0.5 μg/L can be used to document an observed release to the aquifer [1, pp. (Section 2.3), 51589 (Table 2-3)]. For the purpo ses of this HRS documentation record, the values for drinking water sample DW-02 are presented as backgr ound concentrations because they represent the well conditions most similar to the release samples (i.e. well depth, bedrock well, etc.).

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Table 43 - Hazardous Substances Associated with Background Drinking Water Samples

Sample ID Hazardous
Substance Concentration (μg/L) SampleAdjusted

CRQL (μg/L) References

DW-02 PCE 0.5 U 0.5 16, pp. 7-8; 34, pp. 22; 46, p.7, Table 1 (p. 1 of 3); 74, pp. 1-2; 153 (pp. 13-14)

DW-02 TCE 0.5 U 0.5 16, pp. 7-8; 34, pp. 22; 46, p. 7, Table

1 (p. 1 of 3); 74, pp. 1-2; 153 (pp. 13-14)

PCE = Tetrachloroethene. TCE = Trichloroethene. μg/L = Micrograms per Liter. CRQL = Contract Required Quantitation Limit. U = The compound or element was analyzed for, but not detected. The associated numerical value is the sample-adjusted CRQL [103, p. B-47].

Contaminated Samples:

On 8 through 11, 16, and 17 November 2010, as part of the Leeds Metal EPA Site Assessment Site Inspection, 31 drinking water samples, including two field duplicates (DW-01 through DW-06, DW-08 through DW-16, DW-18 through DW-31, DW-33, and DW -34) were collected from 29 drinking water supply wells located northwest, west, southwest, south, south east, and east of the Leeds Metal property (see Figure 5) [9; 10; 11, pp. 133-150 ; 14, pp. 23-28, 31-39, 44-45; 15, pp. 4-7, 12, 15-17, 19-20; 16, pp. 4-5, 7-10, 14-19, 22-23, 25-26; 34, pp. 8-16, 22-25, 41, 42-45, 73-87 (Table 1); 78, pp. 1-29; 105, pp. 1-2, Figure 1]. The drinking water samples were collected in accordance with the EPA-approved Site-Specific QAPP, dated 26 October 2010 [6, pp. 79-80; 14, pp. 23-28, 31-39, 44-45; 15, pp. 4-7, 12, 15-17, 19-20; 16, pp. 4-5, 7-10, 14­ 19, 22-23, 25-26; 34, pp. 8-16, 22-25, 41, 42-45, 73-87 (Table 1); 78, pp. 1-29]. Drinking water samples DW-01, DW-02, and DW-03 were collected to estab lish background concentrations for comparison [9; 11, pp. 133-135; 14, p. 26; 16, pp. 7-9; 34, pp. 8, 22, 73- 74 (Table 1)]. As noted above, the background samples were collected from within the same aquifer, at similar well screen elevations, from similar geologic formations, and during the same time period as the other drinking water samples collected for this evaluation.

Drinking water samples DW-04 through DW-06, DW-08 through DW-16, DW-18 through DW-31, DW-33, and DW-34 were collected from supply wells located west, southwest, south, southeast, and east of the Leeds Metal property to determine if a release of hazardous substances to the overburde n and bedrock aquifer had occurred (see Figure 5) [9; 10; 14, pp. 23-25, 27-28, 31-39, 44-45; 15, pp. 4-7, 12, 15-17, 19-20; 16, pp. 4-5, 9-10, 14-19, 22-23, 25-26; 34, pp. 8-16, 22-25, 41, 42-45, 73-87 (Table 1); 78, pp. 1-29; 105, pp. 1-2, Figure 1].

The drinking water samples were s ubmitted to CLP Laboratories for VOC analyses [14, pp. 23-28, 31-39, 44­ 45; 15, pp. 4-7, 12, 15-17, 19-20; 16, pp. 4-5, 7-10, 14-19, 22-23, 25-26; 34, pp. 8-16, 22-25, 41, 42-45, 73­ 87 (Table 1); 45, p. 1; 46, p. 1; 47, p. 1; 94; 95, 96; . The analytical data were validated according to EPA New England Regional Functional Guidelines Tier II requirements for VOC analysis [45, p. 1; 46, p. 1; 47, p. 1]. For the purposes of this HRS documentation record, PCE and TCE analytical results from seven drinking water samples (DW-12, DW-13, DW-16, DW-18, DW-23, DW-24, and DW-25), collected from residential properties supplied by bedrock drinking water supply wells, are used to document an observed release to the Leeds Aquifer.

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Table 44 - Drinking Water Sample Location Description

Sample ID Well Depth (feet amsl) Date References

DW-12 188.4 17 Nov. 2010 10; 16, pp. 22-23; 34, pp. 25, 78 (Table 1); 78, p. 11; 105, pp. 1-2, Figure 1; 115, pp. 1-2; 116, pp. 1-2, Attachment; 117; 154 p. 1

DW-13 142.3 8 Nov. 2010 10; 14, pp. 23-25; 34, pp. 8, 78 (Table 1); 78, p. 12; 105, pp. 1-2, Figure 1; 118, pp. 1-2; 119; 154 p. 1

DW-16 144.5 8 Nov. 2010 10; 14, pp. 37-38; 34, pp. 11, 80 (Table 1); 78, p. 15; 105, pp. 1-2, Figure 1; 120, pp. 1-2; 121, pp. 1-2; 154 p. 1

DW-18 114.5 10 Nov. 2010 10; 15, pp. 16-17; 34, pp. 15, 80 (Table 1); 73, p. 1, Figure; 78, p. 16; 105, pp. 1-2, Figure 1; 123, pp. 1-2; 124, pp. 1-4; 154 p. 1

DW-23 -149.9 16 Nov. 2010 10; 16, pp. 9-10; 34, pp. 22-23, 83 (Table 1); 73, p. 1, Figure; 78, p. 21; 105, pp. 1-2, Figure 1; 125, pp. 1-2; 126, pp. 1-4; 127; 154 p. 1

DW-24 approx. -39.1

to -64.1 9 Nov. 2010 10; 14, pp. 44-45; 34, pp. 12, 83 (Table 1); 73, p. 1, Figure; 78, p. 22; 105, pp. 1-2, Figure 1; 128, pp. 1-2; 129; 154 p. 1

DW-25 -41.5 8 Nov. 2010 10; 14, pp. 35-36; 34, pp. 10, 84 (Table 1); 78, p. 23; 105, pp. 1-2, Figure 1; 130, pp. 1-2; 131; 132; 154 p.

1

amsl = above mean sea level. Nov. = November. approx. = Approximately.

Drinking water sample DW-12 was collected from a reside ntial property is located in Leeds, ME, and is depicted on the Town of Leeds, ME Tax Assessor’s Ma p No. 1, Lot No. 67-1), located 0.149 miles southwest of the Leeds Metal property, Debris Pile D, Source No. 4 (see Figure 5) [10; 16, pp. 22-23; 34, pp. 25, 78 (Table 1); 78, p. 11; 105, pp. 1-2, Figure 1; 115, pp. 1-2; 116, pp. 1-2, Attachment; 117]. The residence is supplied drinking water from an on-site 160-foot deep drilled bedrock private suppl y well [16, pp. 22-23; 34, pp. 25, 78 (Table 1); 116, pp. 1-2, Attachment; 117]. START personnel collected the sample from a basement spigot after system purging was completed and water qua lity parameters stabilized [16, pp. 22-23; 34, pp. 25, 78 (Table 1); 78, p. 11]. The sample was collected after water flowed through an approximately 20-gallon holding tank [16, pp. 22-23; 34, pp. 25, 78 (Table 1); 78, p. 11]. The homeowner reported that the residence had a filter system; however, the system was not used [16, pp. 22-23; 34, pp. 25, 78 (Table 1); 78, p. 11].

Drinking water sample DW-13 was collected from a reside ntial property is located in Leeds, ME, and is depicted on the Town of Leeds, ME Tax Assessor’s Ma p No. 1, Lot No. 67-A), located 0.199 miles southwest of the Leeds Metal property, Debris Pile D, Source No. 4 [10; 14, pp. 23-25; 34, pp. 8, 78 (Table 1); 78, p. 12; 105, pp. 1, Figure 1; 118, pp. 1-2; 119]. The resi dence is supplied drinking water from an on-site, approximately 187-foot deep drilled bedr ock private supply well [14, pp. 23-25; 34, pp. 8, 78 (Table 1); 78, p. 12; 118, pp. 1-2; 119]. START personnel collected the sample from the kitchen sink faucet after system purging was completed and water quality parameters stabilized [14, pp. 23-25; 34, pp. 8, 78 (Table 1); 78, p. 12]. The sample was collected after water flowed through an approximately 30-gallon holding tank and the home’s piping system [14, pp. 23-25; 34, pp. 8, 78 (Table 1); 78, p. 12]. A sediment filtration system was

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noted by START; however, according to the homeowner, the filtration system was previously bypassed and was no longer in service [14, pp. 23-25; 34, pp. 8, 78 (Table 1); 78, p. 12].

Drinking water sample DW-16 was collected from a reside ntial property is located in Leeds, ME, and is depicted on the Town of Leeds, ME Tax Assessor’s Ma p No. 1, Lot No. 58-7), located 0.166 miles southwest of the Leeds Metal property, Debris Pile D, Source No. 4 (see Figure 5) [10; 14, pp. 37-38; 34, pp. 11, 80 (Table 1); 78, p. 15; 105, pp. 1, Figure 1; 120, pp. 1-2; 121, pp. 1-2; 122]. The residence is supplied drinking water from an on-site 198-foot deep drilled bedrock priv ate supply well [14, pp. 37-38; 34, pp. 11, 80 (Table 1); 78, p. 15; 120, pp. 1-2; 121, pp. 1-2; 122]. START personnel collected the sample from an inside basement spigot after system purging was completed a nd water quality parameters stabilized [14, pp. 37-38; 34, pp. 11, 80 (Table 1); 78, p. 15]. The sample was collected after water flowed through a holding tank [14, pp. 37-38; 34, pp. 11, 80 (Table 1); 78, p. 15]. No filtr ation or water softener system were observed in the house [14, pp. 37-38; 34, pp. 11, 80 (Table 1); 78, p. 15].

Drinking water sample DW-18 was collected from a reside ntial property is located in Leeds, ME, and is depicted on the Town of Leeds, ME Tax Assessor’s Ma p No. 1, Lot No. 58-5), located 0.232 miles southwest of the Leeds Metal property, Debris Pile D, Source No. 4 (see Figure 5) [10; 15, pp. 16-17; 34, pp. 15, 80 (Table 1); 73, p. 1, Figure; 78, p. 16; 105, pp. 1, Figure 1; 123, pp. 1-2; 124, pp. 1-4]. The residence is supplied drinking water from an on-site 220-foot deep drilled bedrock private suppl y well [15, pp. 16-17; 34, pp. 15, 80 (Table 1); 73, p. 1, Figure; 124, pp. 1-4]. START personnel collected the sample from the kitchen sink faucet after system purging was completed and wate r quality parameters stabilized [15, pp. 16-17; 34, pp. 15, 80 (Table 1); 78, p. 16]. The sample was collected after water flowed through an approximately 20-gallon holding tank and the home’s piping system, prior to any f iltration system [15, pp. 16-17; 34, pp. 15, 80 (Table 1); 78, p. 16].

Drinking water sample DW-23 was collected from a reside ntial property is located in Leeds, ME, and is depicted on the Town of Leeds, ME Tax Assessor’s Ma p No. 1, Lot No. 63), located 0.317 miles southwest of the Leeds Metal property, Debris Pile D, Source No. 4 (see Figure 5) [10; 16, pp. 9-10; 34, pp. 22-23, 83 (Table 1); 78, p. 21; 105, pp. 1, Figure 1; 125, pp. 1-2; 126, pp. 1-4; 127]. The residence is supplied drinking water from an on-site, 497-foot deep, drilled bedrock private supply well [16, pp. 9-10; 34, pp. 22-23, 83 (Table 1); 73, p. 1, Figure; 126, pp. 1-4;127; 157]. START personnel collected the sample from an inside (utility room) spigot after system purging was complete d and water quality parameters stabilized [16, pp. 9­ 10; 34, pp. 22-23, 83 (Table 1); 78, p. 21]. The sample was collected prior to an approximately 30-gallon holding tank and two sediment filters [16, pp. 9-10; 34, pp. 22-23, 83 (Table 1); 78, p. 21].

Drinking water sample DW-24 was collected from a reside ntial property is located in Leeds, ME, and is depicted on the Town of Leeds, ME Tax Assessor’s Ma p No. 1, Lot No. 63-2), located 0.336 miles southwest of the Leeds Metal property, Debris Pile D, Source No. 4 (see Figure 5) [10; 14, pp. 44-45; 34, pp. 12, 83 (Table 1); 105, pp. 1, Figure 1; 129]. The residence is supplied drinking water from an on-site, approximately 375- to 400-foot deep, drilled bedrock private supply well [14, pp. 44-45; 34, pp. 12, 83 (Table 1); 73, p. 1, Figure; 129; 157]. START personnel collected the sample from an outdoor spigot after system purging was completed and water quality parameters stabilized [14, pp. 44-45; 34, pp. 12, 83 (Table 1); 78, p. 22]. The sample was collected after water flowed through a 40-gallon holding tank and the home’s piping system [14, pp. 44-45; 34, pp. 12, 83 (Table 1); 78, p. 22]. Acco rding to the homeowner, the house has a water softener system; however, the system was bypassed for sample collection purposes [14, pp. 44-45; 34, pp. 12, 83 (Table 1); 78, p. 22].

Drinking water sample DW-25 was collected from a reside ntial property is located in Leeds, ME, and is depicted on the Town of Leeds, ME Tax Assessor’s Ma p No. 1, Lot No. 63-1), located 0.353 miles southwest of the Leeds Metal property, Debris Pile D, Source No. 4 see Figure 5) [10; 14, pp. 35-36; 34, pp. 10, 84

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(Table 1); 78, p. 23; 105, pp. 1-2, Figure 1; 130, pp. 1-2; 131; 132]. The residence is supplied drinking water from an on-site 355-foot deep drilled bedrock private supply well [14, pp. 35-36; 34, pp. 10, 84 (Table 1); 131; 132]. START personnel collected the sample from a basement spigot after system purging was completed and water quality parameters stabilized [14, pp. 35-36; 34, pp. 10, 84 (Table 1); 78, p. 23]. The sample was collected after water flowed through an approximately 25-gallon holding tank [14, pp. 35-36; 34, pp. 10, 84 (Table 1); 78, p. 23]. The sample was collected prior to a filter system [14, pp. 35-36; 34, pp. 10, 84 (Table 1); 78, p. 23]. According to the homeowner , the drilled well was recently installed due to problems with water yield from the former dug drinking water supply well [131].

Of the seven drinking water samples presented, PCE was de tected at a maximum concentration of 3.9 μg/L in drinking water sample DW-12 [16, pp.22-23; 34, pp. 25; 46, Table 1 (p. 1 of 3); 74, pp. 1-2]. PCE was detected in five of the selected drinking water samples (DW-12, DW-13, DW-18, DW-23, and DW-24) at concentrations greater than or equal to the bac kground sample concentration (DW-02, concentration 0.5 U μg/L) [14, pp. 23-25, 44-45; 15, pp. 16-17; 16, pp. 7-10, 22-23; 34, pp. 8, 12, 15, 22-23, 25; 45, Table 1 (pp. 1-2 of 3); 46, Table 1 (pp. 1-2 of 3); 47, Table 1 (p. 1 of 3); 74, pp. 1-2].

Of the seven drinking water samples presented, TCE was de tected at a maximum concentration of 18 μg/L in drinking water sample DW-12 [16, pp. 22-23; 34, pp.25; 46, Table 1 (p. 1 of 3); 74, pp. 1-2]. TCE was detected in each of the seven drinking water samples as c oncentrations greater than or equal to the relevant background sample concentrations (DW-02, TCE concentr ation of 0.5 U μg/L) [14, pp. 23-25, 35-38, 44-45; 15, pp. 16-17; 16, pp. 7-10, 22-23; 34, pp. 8, 10-12, 15, 22- 23, 25; 45, Table 1 (pp. 1-2 of 3); 46, Table 1 (pp. 1-2 of 3); 47, Table 1 (p. 1 of 3); 74, pp. 1-2].

Table 45 - Hazardous Substances Associat ed with Drinking Water Samples

Sample

ID Hazardous
Substance Concentration (μg/L) SampleAdjusted

CRQL (μg/L) References

DW-12

PCE 3.9 0.5 16, pp. 22-23; 34, p. 25; 46, Table 1 (p. 1 of 3) ); 74, pp. 1-2; 153, pp. 17-18

TCE 18 0.5 16, pp. 22-23; 34, p. 25; 46, Table 1 (p. 1 of 3) ); 74, pp. 1-2; 153, pp. 17-18

DW-13

PCE 0.91 0.5 14, pp. 23-25; 34, p. 8; 45, Table 1 (p. 1 of 3); 153, pp. 19-20

TCE 0.96 0.5 14, pp. 23-25; 34, p. 8; 45, Table 1 (p. 1 of 3); 153, pp. 19-20

DW-16

TCE 0.63 0.5 14, pp. 37-38; 34, p. 11; 45, Table 1 (p. 2 of 3); 153, pp. 21-22

DW-18

PCE 1.1 0.5 15, pp. 16-17; 34, p. 15; 47, Table 1 (p. 1 of 3); 153, pp. 23-24

TCE 0.52 0.5 15, pp. 16-17; 34, p. 15; 47, Table 1 (p. 1 of 3); 153, pp. 23-24

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Table 45 - Hazardous Substances Associated with Drinking Water Samples (Concluded)

Sample

ID Hazardous
Substance Concentration (μg/L) SampleAdjusted

CRQL (μg/L) References

DW-23

PCE 0.61 0.5 16, pp. 9-10; 34, pp. 22-23; 46, Table 1 (p. 2 of 3); 153, pp. 25-26

TCE 0.91 0.5 16, pp. 9-10; 34, pp. 22-23; 46, Table 1 (p. 2 of 3); 153, pp. 25-26

DW-24

PCE 0.77 0.5 14, pp. 44-45; 34, p. 12; 45, Table 1 (p. 2 of 3); 153, pp. 27-28

TCE 1.5 0.5 14, pp. 44-45; 34, p. 12; 45, Table 1 (p. 2 of 3); 153, pp. 27-28

DW-25

TCE 0.65 0.5 14, pp. 35-36; 34, p. 10; 45, Table 1 (p. 2 of 3); 153, pp. 29-32

PCE = Tetrachloroethene. TCE = Trichloroethene. μg/L = Micrograms per liter. CRQL = Contract Required Quantitation Limit.

Note: TCE was also detected in three additional drinking water well samples (DW-09, DW-15, and DW-34) at concentrations above CLP laboratory reporting lim its, but below the sample-adjusted CRQL, and these samples were therefore not evaluated for scoring in this HRS documentation record [45, Table 1 (p. 1 of 3); 46, Table 1 (p. 2 of 3); 103, Exhibit C (pp. 1-6), Exhibit D Trace VOA (pp. 31-32); 104, pp. 1-10]. TCE is a common breakdown product of PCE [49, pp. 189-190; 50, pp. 197, 202-203; 51, Section 1 (pp. 8-12), Table 1.1, Figure 1.4, Section 2 (pp. 1-16), Figure 2.2, Figure 2.3, Figure 2.4].

Attribution:

Attribution of PCE and TCE are established based on the following: documentation of the historical operations conducted on site, which included parts cleaning for resale; the common practice of using solvents containing PCE and TCE to remove grease from metal parts; the documentation, via chemical analyses, of PCE in on-site source samples; the documented chemical breakdown process of PCE to TCE; the documentation, via chemical analyses, of PCE in on- site “shallow” and “deep” overburden monitoring wells; and the documentation, via chemical analyses, of PCE and TCE in off-site drinking water samples. In addition, other possible sources of PCE and TCE to gr ound water were investigated through review of file information and observations made during field activities. These are explained in further detail at the end of

this section.

As outlined below, historical records document that from approximately 1969 to 1984, scrap metal recovery processes were conducted on the Leeds Metal property. A ccording to a former Town of Leeds official, cars were transported to the property for “shredding”; however , lead batteries and other auto parts were salvaged and cleaned for resale [26]. Automotive part cleaners, rust removers (penetrating oils), and lubricants commonly contain large amounts of PCE [156]. Many common aerosol and liquid automotive part cleaners contain high percentages of PCE; these include brake cleaners (greater than 90% PCE), carburetor cleaners

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(15-20% PCE), non-flammable Penetrating Oils (60- 65% PCE), automotive wire drying products (45-55% PCE), and multipurpose lubricants (65-80% PCE) [156]. A former town official also stated that materials such as “gasoline, diesel, transformer oil, brake fluid, oils, battery acid, and antifreeze” were dumped on the ground and that approximately 100 “barrels” were stag ed along the southern property boundary [26]. This same official noted that the Leeds and Monmouth Fire Departments responded to fires at the property, and that gasoline tanks would ignite and cause oil-saturated soil to burn [26].

According to information compiled by the State of Maine, from approximately 1969 to 1984, scrap metal recovery processes were conducted on the property by various entities [18, pp. 1-2; 19, p. 1, Figure 2]. Prior to 1969, the Leeds Metal property, then known as Libby’s Pit, was mined for sand and gravel [18, p. 1]. According to records summarized by a lawyer re presenting Maine Central Railroad, National Metal Converters, Inc. leased the Leeds Metal property in 1969, to conduct a metal shredding operation at the site [136, pp. 1-2; 137, pp. 1-7]. In addition, in a 1968 in ternal letter between railroad employees, Saco Steel Co. (believed by the lawyer representing the railroad to be the predecessor of National Metal Converters, Inc.) proposed the use of a machine known as a ‘fragmentizer’ to demolish junked cars [136, pp. 1-2]. The material would then be separated into ferrous and non-ferrous material, a nd the non-ferrous material would be

discarded as waste suitable to be used as fill material [136, pp. 1-2; 137, pp. 1-7]. A newspaper article published in April 1970 stated that operations at the L eeds Metal property had recently been initiated [136, p. 4]. In February 1976, National Metal Converters, In c. sought and obtained consent from the railroad to transfer their 10-year lease at the Leeds Metal property to Michael Schiavone & Sons, Inc. [136, p. 2, 4].

Available records indicate that Michael Schiavone & Sons, Inc. operated an automobile shredding plant on the property until 1978 [18, p. 2]. From 1978 to 1980, Lucas Salvage Company operated a scrap metal recovery facility as a tenant of Michael Schiavone & Sons , Inc. [18, p. 2]. In 1980, Leeds Metal acquired the assets of Michael Schiavone & Sons, Inc., and operated a scrap metal recovery operation on the property until 1982 [18, p. 2]. Available file information indicates that the last operations on the Leeds Metal property were conducted by a private individual, who operated a scrap metal recovery facility on the site for a portion of 1984 [18, p. 2]. According to the Town of Leeds Ta x Assessor’s records, the 36-acre property is currently owned by Maine Central Railroad Gu ilford Transportation Industries, In c., which was rebranded under the name of Pan AM Railways in March 2006 [9; 12, p. 1; 13; 18, pp. 1-3; 52].

On 2 March 2000, as part of the investigation of past industrial practices at the Leeds Metal property, ME DEP personnel interviewed the former Assistant Fire Ch ief of the Town of Leeds, ME [26]. The former Assistant Fire Chief stated that cars were transported to the property via truck for ‘shredding’ [26]. He also stated that within an on-site cement building, lead batte ries and other auto parts were cleaned for resale [26].

The former Assistant Fire Chief added that metal from the shredded cars was salvaged (sent off site via railroad), while upholstery was piled in former gravel excavation pits [26]. He also stated that such materials as ‘gasoline, diesel, transformer oil, brake fluid, oils , battery acid, and antifreeze’ were dumped on the ground and that approximately 100 ‘barrels’ were staged al ong the southern property boundary [26]. The former

Assistant Fire Chief recalled that the Leeds and M onmouth Fire Departments responded to fires at the property, and that gasoline tanks would ign ite and cause oil-saturated soil to burn [26].

On 2 June 1983, ME DEP personnel r esponded to a complaint of a leaking transformer at the Leeds Metal property (Spill No. P-10-83) [22, pp. 1-3]. ME DEP personnel performed an on-site reconnaissance, noting the presence of five transformers and 27 drums, some of which were leaking [22, p. 3].

Several investigations of the surface and subsurface so ils in various areas on the Leeds Metal property have been conducted [11, p. 13; 21, pp. 1, 7-8; 25, pp. 3-5; 32, pp. 16, 40-41 of 480]. On 15 through 18 June 2009, as part of the EPA Removal Program Preliminary Assessm ent/Site Investigation, STA RT collected a total of 196 surface and subsurface soil samples from locations th roughout the Leeds Metal property [32, pp. 24-26, 39, 44-49]. Of the 196 surface and subsurface soil sam ples collected, 177 samples were screened on site for

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VOCs, and 152 samples were screened on site for metals [32, pp. 77, 50-55, 118-136]. In addition, for confirmatory results, 24 of the soil samples were s ubmitted to the EPA OEME laboratory for VOAs in soil (high level method) analysis, and 20 of the soil sam ples were submitted to the EPA OEME laboratory for metals in soil (medium level) analysis by ICP [32, pp. 27-28, 40-41, 57-60, 233-284, 333-378, 411-453]. VOC screening results indicated the presence of PCE in 30 surface and subsurface soil samples at a maximum concentration of 4,140 μg/Kg [32, pp. 27, 40, 50-52, 118-136]. Laboratory confirmation analysis indicated the presence of 14 VOCs and 17 total metals above laboratory reporting limits, including PCE, arsenic, cadmium, chromium, and lead [32, p. 27-28, 40-41, 57-60, 233-284, 333-378, 411-453].

On- and off-site surface and subsurface soil samples were also collected between 9 and 30 November 2010, as part of the EPA Site Assessment Site Inspection [11, p. 13; 14, pp. 21-48; 15, pp. 2-26, 29-48; 16, pp. 2-40, 46-48; 17, pp. 2-6; 34]. A total of 47 surface soil/source samples, and 29 subsurface soil/source samples were collected to identify source areas on the property, and determine potential impacts [6; 11, pp. 25-41, 79-90; 14, pp. 21-48; 15, pp. 2-26, 29-48; 16, pp. 2-40, 46-48; 17, pp. 2-6; 34]. Analytical results of one surface soil/source sample (SS-07) collected from Debris Pile A indicated a source containing two VOCs, three PCBs, and 13 total metals at concentr ations above background [11, pp. 42-43, Attachment A [Table 1 (p. 1 of 7), Table 2 (p. 1 of 7), Table 3 (p. 1 of 7)]; 17, pp. 3-4; 34, p. 30, Table 1; 37, Table 2 (p. 1 of 3); 42, Table 1 (p. of 3)]. Analytical results of seven surface and subsurface soil/source samples (SS-34, SS-35, SS-36, SB34, SB-35, SB-36, and SB-43) collected from Debris Pile B indicated a source containing 15 VOCs, four PCBs, and 20 total metals at con centrations above background, includi ng TCE at a concentration of 52 J μg/Kg [11, pp. 67-70, 101-107, Attachment A [Table 1 (p. 5 of 7), Table 2 (p. 5 of 7), Table 3 (pp. 5-6 of 7)], Attachment C [Table 1 (pp. 3-4 of 4), Table 2 (pp. 3-4 of 4), Table 3 (pp. 3-4 of 5)]; 16, pp. 33-35; 34, pp. 27­ 28; 38, Table 2 (pp. 1-2 of 2); 43, Table 1 (pp. 1-2 of 2)]. Analytical results of four surface and subsurface soil/source samples (SS-32, SS-33, SB-32, and SB-33) collected from Debris Pile C indicated a source containing four VOCs, two PCBs, and five total metals at concentrations above background [11, pp. 66, 100­ 101, Attachment A [Table 1 (p. 5 of 7), Table 2 (p. 5 of 7), Table 3 (p. 5 of 7)], Attachment C [Table 1 (p. 3 of 4), Table 2 (p. 3 of 4), Table 3 (p. 3 of 5)]; 15, p. 48; 16, p. 2; 34, p. 21; 35, Table 2 (pp. 1-2 of 3); 40, Table 1 (p. 1-3 of 3)]. Analytical results of eight surface and subsurface soil/source samples (SS-28, SS-29, SS-30, SS-31, SB-28, SB-29, SB-30, SB-31) collected from Debris Pile D indicated a source containing nine VOCs, four PCBs, and 16 total metals at concentr ations above background, including PCE at a maximum concentration of 3,900 μg/Kg [11, pp. 61-66, 95-99, Attachment A [Table 1 (pp. 4-5 of 7), Table 2 (pp. 4-5 of 7), Table 3 (pp. 4-5 of 7)], Attachment C [Table 1 (pp. 2-3 of 4), Table 2 (pp. 2-3 of 4), Table 3 (p. 3 of 5)]; 14, pp. 46-48; 15, pp. 2-3; 34, pp. 12-13; 39, Table 1 (pp. 1-2 of 3), Table 2 (pp. 1-2 of 2); 44, Table 1 (pp. 1­ 2 of 2)]. Analytical results of surface and subsurface soil/source samples (SS-09, SS-13, SS-17, SS-20 through SS-27, SS-44, SB-09, SB-17, SB-22, SB-27 and SB-44) collected from the Former Operations Area indicated a source containing 10 VOCs, four PCBs, and 23 total metals at concen trations above background, including PCE at a maximum concentration of 10,000 μg /Kg [11, pp. 44, 47, 51, 53-61, 73-74, 91-92, 95, Attachment A [Table 1 (pp. 2-4, 7 of 7), Table 2 (pp. 2-4, 7 of 7), Table 3 (pp. 2-4, 7 of 7)], Attachment C [Table 1 (pp. 1-2 of 4), Table 2 (pp. 1-2 of 4), Table 3 (pp. 1-2 of 5)]; 15, pp. 18-19; 16, pp. 28-31, 38-39; 17,

p. 6; 34, pp. 13, 16, 26-28, 31].

TCE and PCE are among the most common chlorinated solvents released to the environment [49, p. 179; 51,

p. 1-7].

TCE is a colorless, highly volatile liquid that is miscible with water and a number of organic solvents [50, pp. 1, 184; 147, pp. 1-2]. TCE is mainly used as a solven t to remove grease from metal parts, but is also an ingredient in adhesives, paint removers, typewriter corr ection fluids, and spot remove rs [50, p. 1; 147, pp. 1­ 2; 149, p. 8]. TCE does not occur naturally in the environment [50, p. 191; 147, pp. 1-2]. However, it has been found in underground water sources and many surface waters as a result of the manufacture, use, and disposal of the chemical [50, pp. 197-200; 147, pp. 1-2]. TCE has a molecular weight of 131.4 grams per

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mole (g/mol) and a density of 1.465 grams per milliliter (g/mL) [50, p. 184; 51 pp. 2-24 (Table 2.5), 6-17 (Table 6.4)149, p. 9]. TCE dissolves a little in water, but can remain in ground water for a long time [147, pp. 1-2].

PCE is a colorless, highly volatile liquid with a limited te ndency to mix with or dissolve in water [146, pp. 1­ 2; 148, pp. 1-3]. PCE is a manufactured chemical that is widely used for metal degreasing and for dry cleaning of fabrics [49, pp. 1, 181]. PCE is also a common compound found in part cleaners, rust removers (penetrating oils), and lubricants. Some common automo tive aerosol and liquid part cleaners, rust removers and lubricants contain high percentages of PCE; th ese include brake cleaners (greater than 90% PCE), carburetor cleaners (15-20% PCE), non-flammable Penetr ating Oils (60-65% PCE); automotive wire drying products (45-55% PCE), and multipurpose lubricant (65-80% PCE) [156]. PCE has a high vapor pressure allowing it to easily evaporate into the air [148, pp. 1-3]. PCE has a molecular weight of 165.83 g/mol and a density of 1.6227 g/mL [49, p. 171; 51 pp. 2-24 (Table 2.5), 6-17 (Table 6.4)]. As a result of its low solubility and high density, liquid PCE tends to “si nk” through water and can exist in the ground water environment as a separate dense non-aqueous phase liquid (DNAPL) that will collect or pool at or along low points in water containing vessels or conveyances [ 145, Appendix B (pp. B-1 – B-8); 148, p. 1].

Given the high vapor pressure of PCE, much of it that enters into the environment evaporates into the air [148, pp. 1-3]. In the air, PCE is broken down by sunli ght or brought back to the soil and water by rain [148, pp. 1-3]. Small amounts of PCE (roughly 0.012 % by volume) can dissolve in ground water or surface water [148, pp. 1-3]. This PCE will move as a dissolved phase along with the water [148, pp. 1-3]. Releases of larger amounts of PCE can exist as a separate DNAPL [148, pp. 1-3].

Under reducing conditions in soil a nd/or ground water, naturally occurring microorganisms can break PCE down (through a process known as anaerobic reductive dechlorination) [51, Section 1.4.4 (pp. 1-10 - 1-11, Figure 1.4); 148, pp. 1-3]. Under oxygenated conditi ons in soil and/or ground water, PCE tends to be environmentally persistent [148, pp. 1-3]. TCE is a common degradation product of PCE through biotic anaerobic reductive dechlorination [51, Section 1.4.4 ( pp. 1-10 - 1-11, Figure 1.4)]. Degradation of TCE continues and breaks down TCE to the dichloroethene (DCE) isomers ( cis -DCE or trans -DCE) [51, Section

1.4.4 (pp. 1-10 - 1-11, Figure 1.4)]. Both TCE and PCE can exist as DNAPLs [149, p. 8].

ME DEP staff notes that anaerobic, reduced ground water in Maine bedrock is common, especially under this hydrogeologic setting where deeper ground water is not in contact with the atmosphere [165, p. 2]. The presence of dissolved arsenic, iron, and sulfates in ma ny of the water supply wells drilled into bedrock suggests that the ground water in the bedrock is reduced and anaerobic [165, p. 2]. PCE degradation is a relatively slow and complex process even under reducing conditions [165, p. 2]. This allows the compound to travel greater distances before attenuation can re duce it below levels capable of producing daughter compounds that exceed safe levels for human consumption [165, p. 2].

DNAPLs are denser than water and are relatively immi scible in water, allowing them to remain in a nonaqueous phase [145, Appendix B (pp. B-1 – B-8)]. DNA PLs are difficult to detect in the environment and

can act as a source for dissolved contamination in ground water over time [148, pp. 1-3]. While these are defining features of DNAPLs, there are a number of other physical and chemical properties that influence actual migration in the subsurface and their physical/g eochemical behavior [145, Appendix B (pp. B-1 – B8)]. Their behavior is determined by comple x interactions between the DNAPL chemicals and the hydrogeological formations through which the DNAPLs move [145, Appendix B (pp. B-1 – B-8)]. DNAPL chemicals are subject to several processes, including downward migration by gravity; absorption and adsorption on soil; volatilization into soil gas; dissolution and dispersion in ground water; preferential solution of components; phase separation or the form ation of emulsions; and transformation into other chemicals by microbiological and/or chemical pro cesses (when chemicals are in solution or air) [145,

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Appendix B (pp. B-1 – B-8)]. Given relatively equal viscosities, the greater the specific gravity, the greater the tendency of the substance to migrate under the infl uence of gravity through the subsurface [145, Appendix B (pp. B-1 – B-8)].

Provided there is sufficient mass to drive the m ovement, the DNAPL will continue to move downward through preferential pathways (i.e., coarser grained materials that provide less capillary resistance) until it meets a zone of low permeability, where it will tend to pool or, if the zone has a dip, will move across the surface to lower areas [145, Appendix B (pp. B-1 – B-8) ]. DNAPLs will tend to move vertically downward and collect in low spots or along impermeable barriers [148, pp. 1-3].

In September 1998, ERM, on behalf of Maine Cent ral Railroad, installed 11 temporary ground water monitoring wells at various locations throughout the Leeds Metal property [24, pp. 1-2, 7, 11]. The temporary ground water monitoring wells were installed to a maximum depth of 28 feet bgs [24, p. 2]. The ground water elevation survey performed on the installe d wells indicated that the depth to ground water on the property ranged from between 5.5 and 22.0 feet bgs, and that ground water flow beneath the property was generally from north to south [24, pp. 3, 12]. In addition, on 16 and 17 September 1998, 11 ground water samples were collected from the temporary ground water monitoring wells [24, pp. 2-3]. The ground water samples were collected in laboratory prepared containe rs and shipped to Alpha Analytical Laboratories for VOC analysis [24, p. 3]. Analytical results of the ground water samples indicated the presence of one VOC (PCE) above MDLs, at concentrations of 0.27 mg/L in sample MW-8 and 0.13 mg/L in sample MW-9 [24, pp. 4, 11, 15-48]. These two temporary monitoring wells were located along the southeastern property boundary [24, p. 12].

In November 1999, ERM, on behalf of Maine Centra l Railroad, installed ni ne overburden ground water monitoring wells on the Leeds Metal property [25, pp. 2-3, 12]. Eight of the ground water monitoring wells were installed as shallow and deep couplets on the southe rn portion of the Leeds Metal property [25, pp. 2-3, 12]. One shallow ground water monitoring well (ERM-5) was installed on the central portion of the Leeds Metal property [25, pp. 2-3, 12]. The shallow ground water monitoring wells were installed to a maximum depth of 22 feet bgs in order to intersect the ground wate r table [25, pp. 2-3, 12, 14-26]. The deep overburden ground water monitoring wells were installed to a maximum depth of 47 feet bgs [25, pp. 2-3, 12, 14-26]. On 18 November 1999, ERM conducted a ground water elevation survey of the newly installed wells, and noted that ground water flow in the shallow overburden was predominately from the southeast to the northwest [25, pp. 3, 5, 13]. On 18 and 19 November 1999, ERM collected 10 ground water samples, including one field duplicate, from the nine wells installed on the prope rty [25, pp. 3-4, 12, 27-28, 43]. The ground water samples were collected using low-flow techniques and submitted to Alpha Analytical Laboratories for VOC analysis by Method 8260 [25, pp. 3-4, 12, 43]. Analytical results of the ground water samples indicated the presence of the two VOCs, 1,1,1-trichloroethane and PCE, above laboratory RLs, at concentrations of 2.6 μg/L and 140 μg/L, respectively [25, pp. 6, 11-12, 44-76].

Based on the ERM data from previous investigati ons, ME DEP personnel noted that ground water flow appears to be directed west, towards lot 43 and 44 [9; 141, p. 2, Figure 3]. ME DEP also pointed out that the ERM November 1999 report did not discuss the ground water flow in the deeper overburden or the vertical gradient measured between the shallow and the deep wells [141, p. 2]. ME DEP noted that all of the wells have a downward vertical gradients [141, p. 2]. In a ddition, ME DEP noted that the flow direction in the deeper aquifer appears to be much different from th e shallow ground water flow direction [141, p. 2]. The water levels measured in ground water monitoring wells ERM-3D and ERM-4D have the same elevation of

90.00 (90.01 is within the accuracy of the measurement) [ 141, p. 2]. ME DEP suggested that the flow in the deep overburden has a more westerly component than the shallow ground water flow direction [141, p. 2]. ME DEP concluded that looking at the hydrogeology setting, the stratigraphy will influence ground water flow and contaminant distribution [141, p. 3]. ME DEP stated that it was not clear if the stratigraphy will

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dominate both ground water flow and contaminant distribution, but it is likely to play a major role in one or both [141, p. 3].

Due to on-site ground water sampling results from the pr evious investigations, which indicated the presence of chlorinated solvents in ground water on the Leeds Metal property, ME DEP initiated an inventory of downgradient local drinking water supply wells in anticipation of collecting drinking water samples [135]. Between February 2000 and December 2005, ME DEP personnel collected drinking water samples from residential drinking water supply wells located south a nd southwest of the Leeds Metal property [135]. The drinking water samples were submitted to the State of Maine Health and Environmental Testing Laboratory for VOC analysis [135]. Analytical results of the ME DEP drinking water samples collected during this time period indicated the presence of several VOCs above MDLs, including cis-1,2- DCE, PCE, and TCE [135].

In November 2000, on behalf of Maine Central Railroa d, ERM oversaw a shallow ground water investigation [28, pp. 1-4, 16-25]. As part of the investigation, 12 temporary monitoring well points were installed from 8 to 24 feet bgs, at locations near existing on-site permanent and temporary ground water monitoring wells where PCE had previously been detected in ground wate r samples [28, pp. 1-4, 10, 16-25]. As part of the ERM investigation, 13 ground water samples were coll ected from the 12 newly installed temporary ground water monitoring wells, and five samples were collect ed from previously installed ground water monitoring wells [28, p. 19]. All 18 ground water samples collect ed were submitted to Pine & Swallow personnel for field analysis of target compounds (1,1-DCE, cis-1,2-DCE, trans-DCE, PCE, TCE, and vinyl chloride) using a gas chromatograph [28, pp. 3-4, 19-20]. Field screening analytical results of the samples collected from the newly installed temporary ground water monitoring wells indicated the presence of PCE in samples collected from four of the wells, at a maximum concentration of 4. 3 μg/L [28, pp. 4-6, 10-11, 30]. In addition, field screening results indicated the presence of PCE in three of the ground water samples collected from the previously installed monitoring wells, at a maximum c oncentration of 46 μg/L [28, p. 4-6, 1030]. ME DEP submitted the five ground water samples collected from the previously installed ground water monitoring wells to the Maine Health and Environmental Testing Laboratory for VOC analysis by Method 8260 [28, pp. 4, 31-47]. Laboratory analytical results of the five ground water samples indicated the presence of PCE and 1,1,1-trichloroethane at maximum concentrations of 120 μg/L and 2.8 μg/L, respectively [28, pp. 4-6, 12-13, 31-47]. In June 2009, as part of an EPA Removal Program Preliminary Assessment/Site Investigation, ME DEP personnel collected 10 ground water samples, including one field duplicate, from the nine on-site ground water monitoring wells installed by ERM in Novemb er 1999 [31, pp. 1-15]. The ground water samples were relinquished to START personnel and submitted to th e EPA OEME Laboratory for VOAs in water, total recoverable metals in water by ICP, total mercury in wa ter, and total cyanide in water analyses [31, p. 4; 32, pp. 28, 155-157]. Analytical results of the ground water samples collected by ME DEP indicated the presence of one VOC (PCE), at a maximum concentration of 15 μg/L in samples ERM-4S and field duplicate ERM-6S [32, pp. 61, 158-200].

On 17 and 18 June 2009, as part of the EPA Removal Program Preliminary Assessment/Site Investigation, eight temporary well points were installed at locations throughout the Leeds Metal property [32, pp. 26, 39]. Six of the temporary well points (WP-01 through WP-06) were installed in areas west and north of Debris Pile D, while two temporary well points (WP-07 and WP -08) were installed along the southeastern property boundary [32, pp. 26, 39]. A total of 19 ground water sam ples were collected, using a peristaltic pump, from various depth intervals within the temporary mon itoring well points, and submitted to the EPA Mobile Laboratory for VOC field screening [32, pp.26-28, 39, 56, 118-136]. In addition, two ground water samples were collected, using a peristaltic pump, from two gr ound water monitoring wells previously installed on the property (ERM-4S and ERM-4D), and submitted to the EP A Mobile Laboratory for VOC field screening [32, pp. 26-27, 39, 56, 118-136]. Analytical results of the ground water samples indicated the presence of PCE in all of the samples, at a maximum concentration of 86 μg/L, and the presence of 1,1,1-trichloroethane in one

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sample at a concentration of 1.0 μg/L [32, pp. 26-28, 39, 56, 118-136].

On 10, 11, and 16 November 2010, as part of the EPA Site Assessment Site Inspection, 12 ground water samples (GW-01 through GW-12), including one field duplicate, were collected from 11 permanent on-site monitoring wells installed throughout the Leeds Metal pr operty (see Figure 4) [11, pp. 123-128; 15, pp. 8-26, 39-46; 34, pp. 14-17, 19-23; 77, pp. 1-13]. The ground water samples were collected from nine overburden ground water monitoring wells installed by ERM on 1 through 3 November 1999, and from two overburden ground water monitoring wells installed by Roux Asso ciates on 10 May 2004 [11, pp. 123-128; 15, pp. 8-26, 39-46; 21, p. 7, Figure 2, Appendix G; 25, p. 3, 12, 14-26; 34, pp. 14-17, 19-23; 77, pp. 1-13]. Ground water sample GW-12 was collected to determine background concentrations for comparison, while ground water samples GW-01 through GW-11 were collected to dete rmine if a release of hazardous substances to the overburden aquifer had occurred [11, pp. 123-128; 15, pp. 8-26, 39-46; 34, pp. 14-17, 19-23, 69-72 (Table 1); 77, pp. 1-13].

The ground water samples were submitted to CLP Laboratories for VOC analyses [11, pp. 123-128, Attachment D; 15, pp. 8-26, 39-46; 34, pp. 14-17, 19-23, 69- 72 (Table 1); 46, p. 1; 47, p. 1; 94; 95; 96]. For the purposes of this HRS documentation record, PCE an alytical results from four ground water samples (GW02, GW-06, GW-07, and GW-11) are used to docum ent an observed release to the overburden ground water aquifer. Background sample GW-12 was utilized to es tablish background chemical composition/conditions of the matrix materials within the local vicinity, a nd to establish a local conditions and determine if

contamination is attributable to sources and demons trates that a significant concentration of a hazardous substance is present above backgr ound concentrations. Analytical results of the ground water samples indicated the presence of PCE in all of the samples, at a maximum concentration of 19 μg/L in ground water sample GW-06 [15, pp. 9-10; 34, p. 14; 47, Table 1 (p. 2 of 3)]. PCE was detected in each of the four selected ground water samples at concentrations greater th an or equal to the relevant background sample concentrations (GW-12, PCE concentration 0.5 U μg/L) [11, pp. 123-133, Attachment D; 15, pp. 9-11, 21-22, 41, 43-44, 46; 34, pp. 14-15, 17, 20; 46, Table 1 (p. 2 of 3) ; 47, Table 1 (pp. 1-2 of 3)]. In addition, TCE was detected in two ground water samples (GW-06 and GW-07) at concentrations above CLP laboratory reporting limits, but below the sample-adjusted CRQL, and were therefore not evaluated for scoring in this HRS documentation record [47, Table 1 (p. 2 of 3); 103, Exhibit C (pp. 1-6), Exhibit D Trace VOA (pp. 31-32); 104, pp. 1-10]. TCE is a common breakdown product of PCE [49, pp. 189-190; 50, pp. 197, 202-203; 51, Section 1 (pp. 8-12), Table 1.1, Figure 1.4, Section 2 (pp. 1-16), Figure 2.2]

On 8 through 11, 16, and 17 November 2010, as part of the Leeds Metal EPA Site Assessment Site Inspection, 31 drinking water samples, including two field duplicates (DW-01 through DW-06, DW-08 through DW-16, DW-18 through DW-31, DW-33, and DW -34) were collected from 29 drinking water supply wells located northwest, west, southwest, south, south east, and east of the Leeds Metal property (see Figure 5) [9; 10; 11, pp. 133-149; 14, pp. 21-48; 15, pp. 2-26, 39-48; 16, pp. 2-26; 34, pp. 7-17, 19-26, 73-87 (Table 1); 78, pp. 1-29; 105, pp. 1-2, Figure 1]. The drinking wa ter samples were collected in accordance with the EPAapproved Site-Specific QAPP, dated 26 October 2010 [6, pp. 79-80; 14, pp. 21-48; 15, pp. 2-26, 39-48; 16, pp. 2-26; 34, pp. 7-17, 19-26, 73-87 (Table 1); 78, pp. 1-29]. Drinking water samples DW-01, DW-02, and

DW-03 were collected from overburden and bedrock s upply wells located northwest of the Leeds Metal property to establish background concentrations for comp arison [11, pp. 133-135; 14, p. 26; 16, pp. 7-9; 34,pp. 8, 22, 73-74 (Table 1)]. Drinking water samples DW-04 through DW-06, DW-08 through DW-16, DW18 through DW-31, DW-33, and DW-34 were collected from supply wells located west, southwest, south, southeast, and east of the Leeds Metal property to de termine if a release of hazardous substances to the overburden and bedrock aquifer had occurred [9; 10; 11, pp. 133-149; 14, pp. 21-48; 15, pp. 2-26, 39-48; 16, pp. 2-26; 34, pp. 7-17, 19-26, 73-87 (Table 1); 78, pp. 1-29; 105, pp. 1-2, Figure 1].

The drinking water samples were submitted to CLP Labor atories for VOC analyses [14, pp. 21-48; 15, pp. 2­

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26, 39-48; 16, pp. 2-26; 34, pp. 7-17, 19-26, 73-87 (Table 1); 45, p. 1; 46, p. 1; 47, p. 1; 94; 95, 96]. For the purposes of this HRS documentation record, PCE and TCE results from seven drinking water samples (DW12, DW-13, DW-16, DW-18, DW-23, DW-24, and DW- 25), collected from residences with bedrock drinking water supply wells, are used to document an observed release to the aquifer. Of the seven drinking water samples presented, PCE was detected at a maximum concen tration of 3.9 μg/L in drinking water sample DW12 (see Table 45 of this HRS documentation record) [16, pp. 22-23; 34, pp. 25; 46, Table 1 (p. 1 of 3); 74, pp. 1-2]. PCE was detected in five (DW-12, DW-13, DW-18, DW-23, and DW-24) of the seven selected drinking water samples at concentrations greater than or equal to the background sample concentration (DW02, PCE concentration of 0.5 U μg/L) [14, pp. 23-25, 44- 45; 15, pp. 16-17; 16, pp. 7-10, 22-23; 34, pp. 8, 12, 15, 22-23, 25; 45, Table 1 (pp. 1-2 of 3); 46, Table 1 (pp. 1-2 of 3); 47, Table 1 (p. 1 of 3); 74, pp.1-2]. Of the seven drinking water samples presented, TCE was det ected at a maximum concentration of 18 μg/L in drinking water sample DW-12 [16, pp. 22-23; 34, p. 25; 46, Table 1 (p. 1 of 3); 74, pp. 1-2]. TCE was detected in each of the seven selected ground water samples, at concentrations greater than or equal to the relevant background sample concentration (DW-02, TCE concentration of 0.5 U μg/L) [14, pp. 23-25, 32-33, 35-38, 44-45; 15, pp. 16-17; 16, pp. 7-10, 22-23; 34, pp. 8, 10-12, 15, 22-23, 25; 45, Table 1 (pp. 1-2 of 3); 46, Table 1 (pp. 1-2 of 3); 47, Table 1 (p. 1 of 3); 74, pp. 1-2].

A review of available information was conducted to identify other potential sources of PCE and TCE contamination in the area of the Leeds Metal property. As part of the review effort, a search of the Hazardous & Oil Spill System for Maine was conducted. This datab ase allows spills to be searched and identified by the following attributes: spill number, reported date range, location, tank type, and/or keywords. This service allows users to retrieve a report once the data re lative to it have been approved by MEDEP for public viewing. As part of the potential source search, the database was queried for the following spill criteria: Reported Date Range equal to 1 January 1961 (the earliest possible search date within the system) to 30 November 2010 (the last day of sampling conducted as part of the EPA SI); Municipality equal to Town of “Leeds”; and Keywords equal to “Hazardous” [161, pp. 1-5]. The database search identified 64 spill records based on these criteria [161, pp. 1-5]. The majority (52 records) were listed as “hazardous material incidents”, while 12 were listed as “non-oil, non-hazardous incidents” [161, pp. 1-5]. A review of the online

documentation of the 52 hazardous material incident spills identified one spill in which PCE or TCE was identified: Spill Number A-708-1998 [161, pp. 1-7]. The Spill Report for Spill Number A-708-1998 summarized that “a leaking gasket on a drum caused a mi nor perchloroethylene spill inside a truck. It was picked up using sorbents” [161, p. 7]. The documentati on further noted that 0.10 gallons of PCE were spilled and recovered at the Safety-Kleen facility located along Route 202, Leeds, Maine, at the corner of Goldrup Road (see Figure 1) [161, p. 7]. The Safety-Kleen fac ility is located approximately 1.1 miles southwest of the Leeds Metal site [7]. The other hazardous material incide nt spills identified by the database query either were

not located with 4 radial miles of the Leeds Metal site , or were not identified as spills containing PCE or TCE contamination [158; 161, pp. 1-5].

As part of the review effort, Weston START personne l also queried the Maine Hazardous & Oil Spill System database by the following spill criteria: Reported Date Range equal to 1 January 1961 to 30 November 2010; Municipality equal to Town of “Monmouth”; and Ke ywords equal to “Hazardous” [161, pp. 8-10]. The

database search identified 27 records based on these criteri a [161, pp. 8-10]. Only four of the spills were listed as “hazardous material incidents”, while the majority of the spills (23 records) were listed as “non-oil, non-hazardous incidents” [161, pp. 8-10]. A review of the online documentation of the four hazardous material incident spills identified no hazardous materi al incidents involving PCE or TCE [161, pp. 8-10].

In addition, a former Concrete Manufacturing Fac ility was observed during field activities along Route 106, which was comprised of a large warehouse and garage buildings [14, pp. 12-13; 158]. Database reviews did not identify any PCE and/or TCE releases at the former Concrete Manufacturing Facility [158; 159; 160; 161].

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In the effort to identify other potential sources of PCE and TCE contamination, reviews of the EPA RCRA

and CERCLIS databases were conducted. These databa se reviews identified three RCRA and one CERCLIS (Leeds Metal) sites in Leeds, Maine, and zero RCRA or CERCLIS sites in Monmouth, Maine [159; 160]. One of the three RCRA sites identified in Leeds, Maine was identified as containing known PCE and TCE contamination: the Safety-Kleen Systems Inc. (Safety-Kleen) facility (EPA Facility ID Number MED980667810), located on a 5.8-acre lot identified on th e Town of Leeds Tax Assessors Map No. 1 as Lot 47-1, along Route 202 [corner of Goldrup Road (also known as Sumner Road)] [10; 159; 162; 175, p. 9]. The other RCRA sites identified were two gravel pits located to the north of the Leeds Metal property, which were not identified as containing PCE or TCE contamination [159].

Safety-Kleen operated a facility in Leeds, Maine beginning on 15 October 1982 [175, p.1]. From October 1982 until operations ceased in June 2008, Safety-Kleen ope rated the Leeds facility for the distribution and recycling of cleaning and degreasing solvents and pain t-related wastes, most of which are identified as hazardous wastes under Chapter 850 of the ME DEP Rules [175, p. 3; 174, p 1-1]. Safety-Kleen distributed unused or recycled solvents to approximately 2, 000 businesses in Maine for use, then collected and transported the resulting waste to its facility in Leeds for storage, prior to shipment to the appropriate recycling centers (located throughout the United States) for treatment and recovery [175, pp. 3, 9-10]. The Leeds Safety-Kleen facility consisted of five distin ct activity and storage areas: the Warehouse Area, the Return and Fill Area, the Tank Storage Area, the Flammable Storage Shelter, and the Containerized Transfer Waste Storage Area [175, pp. 4, 9-10]. The Warehou se Area (Area A) contained offices, storage areas for new products, and storage areas for solid dry-cleaning wastes, and could store a maximum volume of 1,584 gallons of waste [175, pp. 4, 10]. The Return and F ill Area (Area B) building permitted the transfer of waste part washers or mineral spirits ( i.e. petroleum naphtha) from containers to metal dumpsters, and pumped the material via piping to the Tank Storage Area (Area C) [175, pp. 4, 9-11]. The Tank Storage Area (Area C), comprised two above-ground 12,000-gallon capacity tanks (which included a stainless steel containment liner): one for waste mineral spirits, and the other for r ecycled mineral spirits that had been reclaimed at one of Safety-Kleen’s recycling facilities and returned to the Leeds facility [175, pp. 4, 9-11]. The Flammable Storage Shelter (Area D) was a storage area (with a secondary containment system) for various waste paint materials, spent immersion cleaners, chlorinated solvents, additional dry-cl eaning waste, universal wastes, and sediment or sludge for the waste mineral spirit dumpste rs [175, pp. 4, 9-10, 12-13]. The Containerized Transfer Waste Storage Area (Area E) building was used for waste streams not generated or recycled by Safety-Kleen in their solvent recycling system, including wastes designated as hazardous and typically assigned “D” waste codes due to toxicity characteristics [175, pp. 4, 12].

On 31 July 1986, Safety-Kleen submitted an applica tion to MEDEP for a hazardous waste storage facility permit for the Safety-Kleen Leeds Service Center [167, p.1]. Because of the facility’s proximity to private drinking water wells, Safety-Kleen was required to perform a hydrogeologic assessment at the facility to refute the rebuttable presumption contained in MEDEP re gulations that the facility will pose a serious threat to public health and the environment [167, p.1].

Wang Engineering, Inc. (WEI) and Groundwater Tec hnology, Inc. conducted hydrogeologic assessments and an Aquifer Investigation of the facility on behalf of Safety-Kleen [166, p 1; 167, p 1; 169, p. 1]. WEI completed a Comprehensive Hydrogeologic Study in April 1989 [197; 169, p 1; 175, p. 30]. Groundwater Technology, Inc. completed an Aquifer Investigation for Safety-Kleen in March 1990 [169, coverpage; 175,

p. 30]. The Aquifer Investigation included the insta llation of six additional ground water monitoring wells, including five off-site wells and one on-s ite well [169, p. 5; 175, p. 30].

The WEI and Groundwater Technology, Inc. investigati ons determined that approximately 75-80 ft of overburden material overlies bedrock at the facility [167, p.16; 169, p. 25]. The overburden material consists

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primarily of fluvial and lacustrine sand and silt depos its overlying marine silt and clay of the Presumpscot Formation and a lower sand and gravel stratum, unde rlain by metamorphosed bedrock [167, pp.14-16; 169, p.25]. Groundwater Technology, Inc. demonstrated th at the facility does not overlie the mapped sand and gravel aquifer [169, p. 9].

A perched ground water surface, located at an approximate depth of 6 feet, was identified in the sand lens beneath the facility [169, p. 25]. The perched ground water surface is a result of inhibited vertical ground water flow through the marine silt and clay [169, p. 25]. Based on topography, and on ground water elevation observations in monitoring wells between 1987 and 1989, the on-site shallow ground water radiates from the facility and the predominant flow direction is to the south [169, p. 25]. Generally, the regional topographic slope to the south causes the shallow ground water to fl ow southerly from the facility [169, pp. 25-26]. The shallow ground water flow is occasionally interrupt ed by surfical depressions, which are ground water discharge zones during wet seasons [169, p. 26]. Ther efore, some of the shallow ground water flow is discharged to the surface relatively close to the facility , and does not continue to the south [169, p. 26].

Additional variations in shallow flow direction are a pparent to the northwest, west and east [169, p. 26].

These variations are the result of the seasonal influen ces on recharge and the physical characteristics of the site [169, p. 26].

The hydrogeological data revealed there is a vertical downward gradient between the upper aquifer and the lower aquifer [167, p. 16]. However, the estimated flow velocity through the marine clay aquitard ranges from

0.001 to 1.0 feet per year [167, p. 16]. Deeper ground water flow direction beneath the marine deposits is expected to be to the southeast to wards the Dead River, ge nerally following the regional topographic slope of the watershed [169, p. 26]. The attitude of the bedrock surface is also expected to influence the direction of the deep ground water flow [169, pp. 26-27].

Both PCE and TCE were detected at the Safety-Kleen facility in on-site soils [162 pp. 2-3; 168, pp 8-9; 169,

p. 4; 167, pp.11-12, Appendix C-2]. Since 1987, VOCs, in cluding PCE, have been detected in several on-site wells [169, pp. 17-20; 167, pp 12-14, Appendix D; 170 Fi gure 2, Table 2 (pp.1-96); 171, Table 2 (pp.1-12); 173, Table 4 (pp. 1-27)]. Trace levels of VOCs were detected in limited on-site upper aquifer monitoring wells [167, pp.16-17, Appendix D]. WEI noted that PC E was detected in 1987 at a concentration of 0.030 ppm in on-site monitoring well MW-4U and TCE was det ected in 1989 at a concentration of 0.003 ppm in onsite monitoring well MW-8L [167, pp. 16-17 , Exhibit 10, Appendix C-2].

As part of the hydrogeologic investigations, eight dom estic drinking water supply wells within 0.25 miles of the facility were sampled and analyzed in May 1989 by representatives of ME DEP and Safety-Kleen [162 p. 2; 169, p 3, Figure 3]. Two of the wells sampled were bedrock wells, and four of the wells sampled were located in surfical deposits [169, p 3]. Information on the other two wells was not available [169, p 3]. The eight domestic drinking water supply wells that were sam pled are located to the east, north, and west of the facility [169, p 3, Figure 3]. The samples were analyzed for VOCs by Maine Public Health Laboratories, and the analytical results indicated that no VOCs were detect ed above the sample detection limits [162 p. 2; 169, p 3].

From early 1990, until December 2010, regular ground wate r sampling has occurred at and around the SafetyKleen facility [170, Table 2 (pp. 15-16); 171, Table 2 (p. 7); 173, Table 4 (pp. 1-27)]. In December 2006, Barton & Loguidice (B&L), on behalf of Safety-Kleen, advanced four borings at locations hydraulically downgradient (southeast) of the Leeds Safety-Kleen facility, across Route 202 [172, p.1]. Eight ground water samples, as well as one blind duplicate sample, were co llected from four wells and analyzed for VOCs by EPA Method 8260 [172, pp. 2, 4]. Sample results indicated the presence of PCE in ground water samples from SB-25 [172, p. 4]. PCE was detected in ground water sample from SB-25 (screened depth of 15-18 ft), at a concentration of 0.003 ppm [172, p. 4, Attachment A (Figure 1), Attachment A (Table 1)]. Review of the

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available ground water monitoring data indicates that PCE was detected sporadically in both on- and off-site wells associated with the facility, at a maximum concentration of 0.056 mg/L in ground water monitoring well MW-9D (on 8/10/2004) located southeast of the facility [169, p. 18 (Table II); 170 Figure 2, Table 2 (pp.1­ 96); 171, Table 2 (pp.1-12); 173, Table 4 (pp. 1-27)]. In addition, TCE was detected sporadically in both onand off-site wells, at a maximum concentration of 0.009 mg/L in ground water monitoring well MW-10M (on 8/23/2005 and 4/23/2008) located southwest of the facility [169, p. 18 (Table II); 170, Figure 1, Table 1; 171,Table 2; 173, Table 4]. Based on the above information, a release of PCE has been documented at the SafetyKleen facility; however, the recent hydrogeologic investiga tions have shown that the resulting impacts are to ground water to the south-southeast of the facility, and do not extend in the direction of the PCE- and TCEcontaminated drinking water wells along Route 106 investigated as part of the Leeds Metal SI.

During field activities conducted in 2010 in the area of the Leeds Metal site, small-scale automobile and small engine repair operations were observed at several of the residential properties near the Leeds Metal property [158]. These operations included, but were not limited to, the following: small engine repairs conducted at the residence depicted on the Town of Leeds, ME Ta x Assessor’s Office Map No. 4 as Lot No. 48 (location of drinking water sample DW-03); automobile repairs conduc ted at residences depicted on the Town of Leeds, ME Tax Assessor’s Office Map No. 1 as Lot No. 66 (location of drinking water sample DW-14 and field duplicate DW-33), Lot No. 59-2 (location of drinking water sample DW-29), and Lot No. 59 (location of DW-30); and automobile repairs conducted at the r esidence depicted on the Town of Leeds, ME Tax Assessor’s Office Map No. 4 as Lot No. 49 [9; 10; 158]. Based on these observations, automobile parts cleaners potentially containing PCE or TCE may be u sed during operations on these residential properties, resulting in a potential point source for a release of these contaminants to the environment [156; 158]. However, due to the limited scale of the operations conduc ted on the residential properties, compared to the relatively significantly larger scale of the former r ecycling operation at the Leeds Metal property, it is presumably unlikely that these potential residential point sources could contribute a significant volume of PCE and/or TCE to the environment [158]. In addition, as noted above, PCE has been documented within the source areas on the Leeds Metal site and within on-site ground water wells; therefore, at least partial attribution has been demonstrated (see Source Section and Table 41 of this HRS Documentation Record).

Hazardous Substances Released

Tetrachloroethene/Tetrachloroethy lene/Perchloroethylene (PCE) Trichloroethene/Trichloroethylene (TCE)

Ground Water Observed Release Factor Value: 550

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3.2 WASTE CHARACTERISTICS

3.2.1 TOXICITY/MOBILITY

The Toxicity Factor Value and the Mobility Fact or Value are assigned to the hazardous substances
associated with the sources and rel eases at the site, and are based on the values presented in the Superfund Chemical Data Matrix (SCDM) [2, pp. BI-1, 3, 8; 176, pp. A-1-2; 177 pp. BI-10-11, A-295-296, 335-336; 178; 179].

Hazardous
Substance Source No. (and/or
Observed Release) Toxicity

Factor

Value Mobility

Factor
Value* Does Hazardous
Substance Meet
Observed Release by Chemical Analysis? (Y/N) Toxicity/ Mobility (Ref. 1, Table 3-9) References

PCE 4,5 100 1 Y 100 177 pp. BI-11

, A335, A-336; 178;
179

TCE Degradation
Product of
PCE 1,000 1 Y 1,000 176 pp. A-1, A-2; 177 pp. BI-11; 178; 179

Aroclor1254 1, 2, 3, 4, 5 10,000 0.0001 N 1 177 pp. BI-10

, A295, A-296; 178;
179

Aroclor1260 1, 2, 3, 4, 5 10,000 0.0001 N 1 177 pp. BI-10

, A295, A-296; 178;
179

Arsenic 1, 4 10,000 0.01 N 100 2 p

. BI-1

Chromium 1, 2, 4, 5 10,000 0.01 N 100 2 p

. BI-3

Lead 1, 2, 3, 4, 5 10,000 0.01 N 100 2 p

. BI-8
*Per the HRS, any hazardous substance that meet s the criteria for an observed release by chemical analysis to one or more aquifers underlying the s ources at the site, regardless of the aquifer being evaluated, assign a mobility factor va lue of 1 (Ref. 1, Section 3.2.1.2).

The observed release substance, TCE, is assigned a Toxi city Factor Value of 1,000 and a Mobility Factor Value of 1.0 [1, p. 51601 (Sections 3.2.1.1 and 3.2.1.2) ; 176, pp. A-1-2; 177 pp. BI-11; 178; 179 ]. From HRS Table 3-9, a Toxicity Factor Value of 1,000 an d Mobility Factor Value of 1.0 for TCE are assigned a Toxicity/Mobility Factor Value of 1,000 [1, 51602 (Table 3-9)].

Toxicity/Mobility Factor Value (Ref. 1, Table 3-9): 1,000

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3.2.2 HAZARDOUS WASTE QUANTITY

Source No. Source Type Source Hazardous Waste Quantity

1 Pile 2,565.2

2 Pile 8,226.4

3 Pile 690.8

4 Pile 4,512.0

5 Contaminated Soil 5.6

Sum of Values: 16,000.0

Based on HRS Section 2.4.2.2, if the Hazardous Cons tituent Quantity is not adequately determined for one or more sources, and if any target for the groun d water pathway is subject to Level I or Level II concentrations, a factor value is assigned from Table 2-6 or a value of 100, whichever is greater, as the Hazardous Waste Quantity Factor Value for that pathway [1, pp. 51591 (Table 2-6), 51592 (Section 2.4.2.2)].

Hazardous Waste Quantity Factor Value (Ref. 1, Table 2-6): 10,000

3.2.3 WASTE CHARACTERISTICS FACTOR CATEGORY VALUE

The Toxicity Factor Value (1,000) and the Mobility Factor Value (1.0) for TCE are multiplied in order to determine the Toxicity/Mobility Factor Value (1 ,000) [1, pp. 51590 (Section 2.4.2), 51602 (Section 3.2.1.3, Table 3-9)]. The Toxicity/Mobility Factor Value for the aquifer (1,000) is multiplied by the Hazardous Waste Quantity Factor Value for the aquifer (10,000) in order to determine the Waste Characteristics Product, subject to a maximum value of 1 × 10 8 [1, pp. 51592 (Section 2.4.3.1), 51602 (Section 3.2.3)]. 1,000 × 10,000 = 1 × 10 7

.

Toxicity/Mobility Factor Value: 1,000 Hazardous Waste Quantity Factor Value: 10,000

Toxicity/Mobility Factor Value (1,000) × Hazardous Waste Quantity Factor Value (10,000): 1 × 10 7

From HRS Table 2-7, the Waste Characteristics Product (1 × 10 7 ) is assigned a Waste Characteristics Factor Category Value of 56 [1, pp. 51592 (Section 2.4.3.1), 51602 (Section 3.2.3)].

Waste Characteristics Factor Category Value (Ref. 1, Table 2-7): 56

3.3 TARGETS

Of the seven drinking water samples presented, PCE was detected at a maximum concentration of 3.9 μg/L in drinking water sample DW-12 [16, pp. 22-23; 34, pp. 25; 46, Table 1 (p. 1 of 3); 74, pp. 1-2]. PCE was detected in five (DW-12, DW-13, DW-18, DW-23, and DW-24) of the seven selected drinking water samples at concentrations greater than or e qual to the background sample concentration (DW-02, PCE concentration of 0.5 U μg/L) [14, pp. 23-25, 44- 45; 15, pp. 16-17; 16, pp. 7-10, 22-23; 34, pp. 8, 12, 15, 22-23, 25; 45, Table 1 (pp. 1-2 of 3); 46, Table 1 ( pp. 1-2 of 3); 47, Table 1 (p. 1 of 3); 74, pp. 1-2].

Of the seven drinking water samples presented, TC E was detected at a maximum concentration of 18

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μg/L in drinking water sample DW-12 [16, pp. 22-23; 34, pp. 25; 46, Table 1 (p. 1 of 3); 74, pp. 1-2]. TCE was detected in each of the seven selected ground water samples, at concentrations greater than or equal to the relevant background sample concentrati on (DW-02, TCE concentration of 0.5 U μg/L) [14, pp. 23-25, 35-38, 44-45; 15, pp. 16-17; 16, pp. 7-10, 22-23; 34, pp. 8, 10-12, 15, 22-23, 25; 45, Table 1 (pp. 1-2 of 3); 46, Table 1 (pp. 1-2 of 3); 47, Table 1 (p. 1 of 3); 74, pp. 1-2].

Level I Concentrations

Of the seven drinking water samples presented, TCE w as detected at a concentration above the healthbased benchmarks for hazardous substances in dri nking water (screening concentration for cancer corresponding to that concentration that corresponds to the 10 -6 individual cancer risk for oral exposures) in two drinking water samples (DW-12 and DW-24) [1, pp. 51593 (Section 2.5.1 and Section 2.5.2), 51603 (Table 3-10); 14, pp. 44-45; 16, pp. 22-23; 34, pp. 12, 25; 45, Table 1 (pp. 2 of 3); 46, Table 1 (pp. 1 of 3); 74, pp. 1-2; 176, pp. A-1-2; 177 pp. BII-23; 178; 179].

Sample

ID Hazardous
Substance Hazardous
Substance
Concentration (μg/L) Benchmark
Concentration (μg/L) Benchmark References for

Benchmark

DW-12 TCE 18 1.0 Cancer Risk 176, pp. A-1-2; 177 pp. BII-23. A-1, A-2; 178; 179

DW-24 TCE 1.5 1.0 Cancer Risk 176, pp. A-1-2; 177 pp. BII-23; 178; 179

TCE = Trichloroethene. μg/L = Micrograms per Liter.

Level II Concentrations

Of the seven drinking water samples presented, TCE w as detected at a concentration greater than or equal to the relevant background sample concentration but below the health-based benchmarks for hazardous substances in drinking water (screening concentration for cancer corresponding to that concentration that corresponds to the 10 -6 individual cancer risk for oral exposures) in five drinking water samples (DW-13, DW-16, DW-18, DW-23, and DW-25) [1, pp. 51593 (Section 2.5.1 and Section 2.5.2), 51603 (Table 3- 10); 14, pp. 23-25, 35-38, 44-45; 15, pp. 16-17; 16, pp . 9-10, 22-23; 34, pp. 8, 10-12, 15, 22-23, 25; 45, Table 1 (pp. 1-2 of 3); 46, Table 1 (pp. 1-2 of 3); 47 , Table 1 (p. 1 of 3); 74, pp. 1-2; 176, pp. A-1-2; 177 pp. BII-23; 178; 179].

Sample

ID Hazardous
Substance Hazardous
Substance
Concentration (μg/L) Benchmark
Concentration (μg/L) Benchmark References for

Benchmark

DW-13 TCE 0.96 1.0 Cancer Risk 176, pp. A-1-2; 177 pp. BII-23; 178; 179

DW-16 TCE 0.63 1.0 Cancer Risk 176, pp. A-1-2; 177 pp. BII-23; 178; 179

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DW-18 TCE 0.52 1.0 Cancer Risk 176, pp. A-1-2; 177 pp. BII-23; 178; 179

DW-23 TCE 0.91 1.0 Cancer Risk 176, pp. A-1-2; 177 pp. BII-23; 178; 179

DW-25 TCE 0.65 1.0 Cancer Risk 176, pp. A-1-2; 177 pp. BII-23; 178; 179

TCE = Trichloroethene. μg/L = Micrograms per Liter.

3.3.1 NEAREST WELL

Based on TCE analytical results of drinking water samples, a release to the supply aquifer has been documented, and Level I concentra tions confirmed [1, pp. 51593 (Secti on 2.5.1 and Section 2.5.2), 51603 (Table 3-10); 14, pp. 44-45; 16, pp. 22-23; 34, pp. 12, 25; 45, Table 1 (pp. 2 of 3); 46, Table 1 (pp. 1 of 3); 74, pp. 1-2; 176, pp. A-1-2; 177 pp. BII-23; 178; 179]. As a drinking water supply well is subject to Level I concentrations, a Nearest Well Factor Value of 50 is assigned [1 , pp. 51602-51603 (Section 3.3.1)]. The closest drinking water supply well contai ning Level I concentrations of the target compounds is located 0.149 miles southwest of Source No. 4 [105, pp. 1-2, Figure 1].

Well ID: DW-12 Level of Contamination (I, II, or potential): I If potential contamination, distance from source in miles:

Nearest Well Factor Value (Ref. 1, Table 3-11): 50
3.3.2 POPULATION

3.3.2.1 Level of Contamination

3.3.2.2 Level I Concentrations

Level I Population Targets

Based on TCE analytical results of drinking water sa mples, a release to two drinking water supply wells has been documented, and Level I concentrations confirmed [1, pp. 51593 (Section 2.5.1 and Section 2.5.2), 51603 (Table 3-10); 14, pp. 44-45; 16, pp. 22-23; 34, pp.12, 25; 45, Table 1 (pp. 2 of 3); 46, Table 1 (pp. 1 of 3); 74, pp. 1-2; 176, pp. A-1-2; 177 pp. BII-23; 178; 179]. Information provided by the residents served by the drinking water supply wells indicate that a total of five Level I Actual Contamination Targets have been documented [1, pp. 51593 (Section 2.5.1 and Section 2.5.2), 51603 (Table 3-10); 14, pp. 44-45; 16, pp. 22-23; 34, pp.12, 25; 45, Table 1 (pp. 2 of 3); 46, Table 1 (pp. 1 of 3); 74, pp. 1-2; ; 117; 129; 176, pp. A-1-2; 177 pp. BII-23; 178; 179].

Level I Well Aquifer No. Population References

DW-12 1 3 117; 16, p. 22

DW-24 1 2 129; 14, p. 44

Sum of Population Served by Level I Wells: 5

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Sum of Population Served by Level I Wells x 10: 50

Level I Concentrations Factor Value: 50 [1, p. 51603, Section 3.3.2.2]

3.3.2.3 Level II Concentrations

Level II Population Targets

Based on TCE analytical results of drinking water samples, a release to five drinking water supply wells has been documented, and Level II concentrations confirmed [1, pp. 51593 (Section 2.5.1 and Section 2.5.2), 51603 (Table 3-10); 14, pp. 23-25, 35-38, 15, pp. 16-17; 16, pp. 9-10; 34, pp. 8, 10-11, 15, 22-23; 45, Table 1 (pp. 1-2 of 3); 46, Table 1 (pp. 1-2 of 3); 47, Table 1 (p. 1 of 3); 74, pp. 1-2; 176, pp. A-1-2; 177 pp. BII-23; 178; 179 ]. Informa tion provided by the residents served by the drinking water supply
wells indicate that a total of 12 Level II Actual Contamination Targets have been documented [1, pp. 51593 (Section 2.5.1 and Section 2.5.2), 51603 (Table 3-10); 14, pp. 23-25, 35-38; 15, pp. 16-17; 16, pp. 9-10; 34, pp. 8, 10-11, 15, 22-23; 45, Table 1 (pp. 1-2 of 3); 46, Table 1 (pp. 1-2 of 3); 47, Table 1 (p. 1 of 3); 74, pp. 1-2;; 114; 119; 121, p. 2; 122; 124, p. 4; 127; 131; 176, pp. A-1-2; 177 pp. BII-23; 178; 179].

Level II Well Aquifer No. Population References

DW-13 1 2 119; 14, p. 23

DW-16 1 2 121, p. 2; 122; 14, p. 37

DW-18 1 2 124, p. 4; 15, pp. 16-17

DW-23 1 3 127; 16, p. 9

DW-25 1 3 131; 14, pp. 35-36

Sum of Population Served by Level II Wells: 12

Level II Concentrations Factor Value: 12 [1, p. 51603, Section 3.3.2.3]

3.3.2.4 Potential Contamination

Potential Population Targets

Potential Population Targets were evaluated as part of this HRS Documentation Record to determine the number of people served by drinking water from points of withdrawal subject to potential contamination. This calculation does not include those people alrea dy counted under Level I and Level II concentration
factors.

As noted previously in Section 3.0.1 of this HRS Documentation Record, there are no physical barriers to ground water flow, such as mountains or large rivers, wh ich have been identified within a 4-mile radius of the Leeds Metal property; subsurface investigations to date have not identifie d any continuous aquitards in the vicinity of the Leeds Metal property; and the fine-to-coarse sand overburden deposits and moderately permeable fracture metamorphic bedr ock do not demonstrate any significantly lower hydraulic conductivity layers that separate aquifers th roughout a 2-mile radius of the site sources, thus characterizing hydrogeology beneath the site as by a single aquifer consisting of the on-site shallow and deep glacial overburden aquifer and the hydraulical ly connected underlying meta-sedimentary bedrock

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aquifer. Therefore, an aquifer interconnection occurs within 2 miles of the sources at the site and the combined aquifer constitutes the aquifer being evaluate d that is used for scoring the site [1, p. 51595 (Section 3.0.1.2.1)]. For the purposes of this eval uation, the entire population served by drinking water from points of withdrawal within 4-radial miles of the site are eligible for evaluation as potential population targets [1, p. 51595, Section 3.0.1.1].

The calculation of Potential Population Targets was evaluated as part of this HRS Documentation Record utilizing two separate techniques. Method 1 utilized the 1990 and 2000 census data to estimate the populations relying upon both priv ate and public ground water supplies presented in the SI report (Reference 11) [11, pp. 1 12-115; 180]. To estim ate the population served by private ground water supplies, a comparison was made between the 1990 a nd 2000 census data to determine the change (net increase) in population between the two census periods. This calculated proportional change in population was then applied to a subset of the 1990 census da ta (population relying on private drinking water supply wells) to estimate the number of persons relying u pon private water supplies in 2000 [11, pp. 112-115; 180]. Method 2 utilized the most recent census data (2010), which became available after completion of the SI report (Reference 11), and discussions with local personnel knowledgeable of the public and private ground water resource within 4-radial mil es of the site. These discussions with local personnel were used to validate the drinking water suppl y of the entire population presented in the 2010 census within 4-radial miles of the site [11, pp. 112-115; 180]. Potential Population Targets calculation determined through the two methods (Method 1 and Method 2) confirms that there are no significant impact to the Distance-Weighted Population Value and, therefore, no significant impact to the Potential
Contamination Factor Value or the overall site sco re. This HRS Documentation Record report s the method resulting in the minimal Potential Population Targets for determining the Potential Contamination Factor Value. Furthermore, the listing decision rema ins the same using the Method 1 data utilized at proposal or using the newer 2010 census data, reflecti ng current site conditions; conversely the new data confirms the listing decision [11, pp. 112-115; 180]

Method 1 utilized the 1990 and 2000 census data to cal culate a percent change in the total population
within 4-radial miles of the Leeds Metal Site. This calculated proportional change was then applied to the population by radius for the private wells subset of the 1990 census data within each distance ring. The resulting population utilizing private drinking water s upply wells within each radial ring, represented the same proportional increase as the total population from 1990 to 2000 [11, pp. 112-11 5; 180]. In addition, the population served by drinking water from public water supply wells within a 4-mile radius of the Leeds Metal property was determined through informa tion in the ME Drinking Water Program database and summarized in the Leeds Metal SI [11, pp. 112-115; 180].

Method 2 utilized the most recent census data (2010), which became available after completion of the SI report (Reference 11), and discussions with local pe rsonnel knowledgeable of the public and private ground water resource within 4-radial miles of the site. The discussions with local personnel were used to validate the drinking water supply of the entire popu lation presented in the 2010 census within 4-radial miles of the site [11, pp. 112-115; 180]. The 2010 census data (supplied by EPA) was utilized to determine the total population within each distance ring. Discussions with official s, for the towns located within 4-radial miles of the site, were conducted to establish the sources utilized for drinking water supplies located within each of the towns. Public water supply information from the Maine Drinking Water Program database was utilized to determine the supply type, location, and population served by each public supply source located within 4-radial miles of the site. Further discussion with Maine Drinking Water Program, Town, and public water supply system representatives confirmed the data presented in public water supply system database, al ong with activity status, source, location of the withdrawal point, population served, and distribution area (as needed) within each distance ring within a 4-mile radius of the Leeds Metal property. This information was used to estimate the populations currently relying upon private and public ground water supplies within each distance ring within a 4-mile

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radius of the Leeds Metal site [180].

The following table presents the comparison of the Potential Population Targets within a 4-mile radius of the Leeds Metal property utilizing the two methods and the resulting Distance-Weighted Population
Value for each method.

Distance Category Method 1
Potential Population

[11, 180] Method 1 Distance-Weighted Population Value (Ref. 1, Table 3-12) Method 2
Potential Population [180] Method 2 DistanceWeighted Population

Value (Ref. 1, Table 3-12)

0 to 1/4 mile 21* 17 53* 53

>1/4 to 1/2 mile 169* 102 137* 102

>1/2 to 1 mile 184 52 300 52

>1 to 2 miles 574 94 856 94

>2 to 3 miles 2,921** 212 1,340 212

>3 to 4 miles 1,832 131 2,343 131

Total 5,701 608 5,046 644

* A total of nine Level I and/or Le vel II Population Targets have been accounted for within 1⁄4 mile of the Leeds Metal site, and eight Level I and/or Level II Population Targets have been accounted for greater
then 1⁄4 mile to 1⁄2 mile of the site [ 1, pp. 51593 (Section 2.5.1 and Section 2.5.2), 51603 (Table 3-10); 11, pp. 112-115; 14, pp. 23-25, 35-38, 44-45; 15, pp. 16-17; 16, pp. 9-10, 22-23; 34, pp. 8, 10-12, 15, 22-23, 25; 45, Table 1 (pp. 1-2 of 3); 46, Table 1 (pp. 1-2 of 3); 47, Table 1 (p. 1 of 3); 74, pp. 1-2].; 97, p. 12; 117; 119; 121, p. 2; 124, p. 4; 127; 129; 131; 180].

** Note that an error has occurred in the 2011 SI p opulation value calculation due to triple counting of one publi c ground water supply (Monmouth Water Asso ciation) system’s population (the actual value for this ring is 1,835 people). However due to the ra nge in the HRS Population Served By Wells Within Distance Categories, no change occurs in the Distan ce-Weighted Population Valu e [11, pp. 112-115; 180]

This HRS Documentation Record reports the met hod resulting in the minimal Potential Population Targets for determining the Potential Contamination Factor Value [1, Table 3-12; 11, pp. 112-115; 180 ]. The listing decision will remain the same using the Me thod 1 data utilized at proposal or using the newer 2010 census data, reflecting current s ite conditions; conversely the new da ta confirms the listing decision.

Distance Category Population References Distance-Weighted Population Value (Ref. 1, Table 3-12)

0 to 1/4 mile 21* 11, pp. 112-115; 180 17

>1/4 to 1/2 mile 169* 11, pp. 112-115; 180 102

>1/2 to 1 mile 184 11, pp. 112-115; 180 52

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Distance Category Population References Distance-Weighted Population Value (Ref. 1, Table 3-12)

>1 to 2 miles 574 11, pp. 112-115; 180 94

>2 to 3 miles 2,921 ** 11, pp. 112-115; 180 212

>3 to 4 miles 1,832 11, pp. 112-115; 180 131

* A total of nine Level I and/or Le vel II Population Targets have been accounted for within 1⁄4 mile of the Leeds Metal site, and eight Level I and/or Level II Population Targets have been accounted for greater
then 1⁄4 mile to 1⁄2 mile of the site [ 1, pp. 51593 (Section 2.5.1 and Section 2.5.2), 51603 (Table 3-10); 11, pp. 112-115; 14, pp. 23-25, 35-38, 44-45; 15, pp. 16-17; 16, pp. 9-10, 22-23; 34, pp. 8, 10-12, 15, 22-23, 25; 45, Table 1 (pp. 1-2 of 3); 46, Table 1 (pp. 1-2 of 3); 47, Table 1 (p. 1 of 3); 74, pp. 1-2].; 97, p. 12; 117; 119; 121, p. 2; 124, p. 4; 127; 129; 131; 180].

** Note that an error has occurred in the 2011 SI p opulation value calculation due to triple counting of one publi c ground water supply (Monmouth Water Asso ciation) system’s population (the actual value for this ring is 1,835 people), however due to the ra nge in the HRS Population Served By Wells Within Distance Categories, no change occurs in the Distance-Weighted Population Value. [ 11, pp. 112-115; 180 ]

Calculations:

Sum of Distance-Weighted Population Values: 608 Sum of Distance-Weighted Population Values/10: 60.8

Potential Contamination Factor Value: 60.8 (1, p. 51603-51604, Section 3.3.2.4)

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3.3.3 RESOURCES

No Resources were evaluated as part of this HRS Documentation Record.

Well ID Aquifer No. Resource Use References

Resources Factor Value: Not Scored

3.3.4 WELLHEAD PROTECTION AREA

No Wellhead Protection Areas were evaluated as part of this HRS Documentation Record.

Area Use References Value

Wellhead Protection Area Factor Value: Not Scored

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