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 migration 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 Leeds 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 surface 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 2011
Leeds Metal 1 HRS Documentation Record

MEN000103584 Revised July 9, 2012

HRS DOCUMENTATION RECORD

Name of Site: Leeds Metal Date Prepared: September 2011

 Date Revised: July 9, 2012

EPA Region: Region I

Street Address of Site*: Off of Blue Rock Road

City, County, State, Zip Code: Leeds, Androscoggin 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 located. 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 National Priorities List (NPL) listing. EPA lists national priorities among the 

known “releases or threatened releases” of hazardous substances; thus, the focus is on the release, not precisely 

delineated boundaries. A site is defined as where a hazardous substance has been “deposited, stored, placed, 

or 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 

Environmental 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 latitude and longitude measurement point. 
S S2 

1.	 Ground Water Migration Pathway Score (Sgw) 

2. Surface Water Overland/Flood Migration Component 

64.512 4161.798 

(from Table 4-1, line 30) 

3.	 Soil Exposure Pathway Score (Ss) 

NS --

(from Table 5-1, line 22) 

4. Air Migration Pathway Score (Sa) 

(from Table 6-1, line 12) 

2 5. Total of Sgw

2

 + Ssw2 + Ss

2

 + Sa 

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, 2012
 

 

 

 

 

 

 

 

 

 

 

 

HRS 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 (Sgw), 

(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 2011 
ACRONYM/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 2011 
ACRONYM/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 

Yd3 Cubic Yards 

Leeds Metal 5 HRS Documentation Record 

MEN000103584 September 2011 
 

 

 

 

I

0 0.5 1

Miles 

0 0.5 1

Kilometers 

Leeds Metal property 

Nearest Residence 

Nearest Private Drinking 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 Area 

Lagoons 

Property Boundary 

Debris Pile B 

Debris Pile D 

Debris Pile C 

Debris Pile A 

Battery Drop Area 

ME Route 106 

Blue Rock Road 

Pond 

Nearest Residence and 

Private Drinking Water Supply Well 

Concrete Disposal Area 

Access Road 

Concrete Pad/Building 

ERM-5S 

Railroad Tracks 

ERM-2S/2D 

ERM-1S/1D 

ERM-3S/3D 

ERM-4S/4D 

Extent of Operations 

RX-2S 

RX-3S 

On-site Wetland 

Former Operations Area (Leeds Metal Site Location) 

Leeds Metal 7 

MEN000103584 
SS-01/SB-01 SS-02/SB-02 

(Collected Northwest, see Figure 3b) 

SS-06 

SS-41 

SS-08/SB-08 

SS-09/SB-09 

"/

"/

"/

"/

"/"/

"/

"/

"/

"/

"/

"/

SS-10/SB-10 

SS-52 

SS-15/SB-15SS-53 

SS-42/SB-42 SS-16 

"/

SS-35/SB-35 SS-07 

SS-11/SB-11 

SS-12/SB-12 

Concrete Pad 

SS-13/SB-13 

SS-14/SB-14 A "/

"/

"/

"/

SS-34/SB-34 

SS-50 

SS-17/SB-17 

SS-32/SB-32 "/ B "/ "/

"/

C SS-18/SB-18 

SS-33/SB-33 "/

"/

"/

SS-40/SB-40 

"/"/ "/"/"/ "/"/"/"/ "/ 

SS-19 "/ D 

"/

"/

"/

"/

"/"/"/

SS-37/SB-37 SS-03 

SS-05/SS-43 SS-39 

SS-04 

"/ SS-27/SB-27/ SS-36/SB-36 SB-44 S B-43 SS-23 SS-22/ SS-25 SS-38/SB-38 SB-22 

SS-24 

SS-26 

"/ "/ SS-21 "/ "/ "/ "/"/ "/ "/ SS-20/

SS-44 

"/ D SS-31/SB-31 "/

SS-28/SB-28 "/

SS-30/SB-30 

SS-29/SB-29 

Leeds Metal MEN000103584 

8 
"/

SS-01/SB-01 SS-02/SB-02 

A 

Leeds Metal 

9

MEN000103584 
!>

!>

!> !>

!>

!>

!>

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) 

Leeds Metal 

10 MEN000103584 
hg

hg

hg

hg

hg

hg

hg

hg

hg

hg

hg

hg

hg

hg

hghg

hghg hg

hg

hg hg

hg

hg

hg

hg

hg

hg

hg

DW-01 DW-03

DW-02 

DW-05 

DW-06 

DW-09 

DW-10 

DW-18 

DW-12 

DW-13 

DW-14/DW-33 

DW-23 

DW-24 

DW-25 

DW-31 

DW-30 DW-29

DW-15/DW-34 

DW-16 

DW-11 

DW-19 

DW-27 

DW-26 

DW-28 

DW-20 

DW-22 

DW-21 

DW-08

DW-04 

Leeds Metal 

11 

MEN000103584 
 

I

0 0.5 1 2 3

Miles 0 0.5 1 2 3 4 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 2011 
 

 

 

REFERENCES 

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 Quality 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, 2012
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

REFERENCES 

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 Technical 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 Technical 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 Technical 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 Technical 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 Activities 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 & Martin, Inc. 1999. Letter to Ms. Lynne Cayting, 

Maine Department of Environmental Protection, Re: Leeds Metal Scrapyard, Bancroft & 

Martin, Inc.’s Supplemental Response to Request 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: Results of Monitoring Well Installation & 

Groundwater Sampling, Leeds Metal Site – Leeds, Maine. 20 January. 92 pages. 

Leeds Metal 14 HRS Documentation Record 

MEN000103584 September 2011 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

REFERENCES 

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 Substance Site. 28 September. 10 pages. 

[28] Drobinski, J. Environmental Resources Management. 2001. Letter Report to Ms. Cynthia 

Scarano, Maine Central Railroad, Re: November 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 Metal, 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 Technical Assessment and Response Team III (START). 

2010. Removal Program Preliminary Assessment/Site 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 Protection. 2009. Leeds Metal Residential Drinking 

Water Well SAP. June. 9 pages. 

[34] Weston Solutions, Inc., Superfund Technical 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 2011 
 

 

 

 

 

 

 

 

 

 

 

 

 

REFERENCES 

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 Services, Public Health Service, Agency for Toxic 

Substances and Disease Registry. 1997. Toxicological Profile for Tetrachloroethylene. 

September. 318 pages. 

[50] U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic 

Substances and Disease Registry. 1997. Toxicological Profile for Trichloroethylene. 

September. 335 pages. 

Leeds Metal 16 HRS Documentation Record 

MEN000103584 September 2011 
 

 

 

 

 

 

 

 

 

 

 

 

 

REFERENCES 

Ref. 

No. Description of the Reference 

[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/Home/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. 

[62] 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 MA3SW8. TDD No. 10-03-0002. 15 March. 110 pages. 

Leeds Metal 17 HRS Documentation Record 

MEN000103584 September 2011 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

REFERENCES 

Ref. 

No. Description of the Reference 

[63] Anderson, W.A. (Maine Geologic Survey, Department of Conservation, State Geologist). 

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[97] Reference Reserved. 

[98] Reference Reserved. 

[99] Reference Reserved. 

[100] Reference Reserved. 

[101] Reference Reserved. 

[102] Reference Reserved. 

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[113] U.S. Environmental Protection Agency. 1996. Using Qualified Data to Document an 

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[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 

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[117] Hornok, G. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III 

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Tax Assessor’s Map No. 1, Lot No. 67-1. 23 February. 1 page. 

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

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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. Environmental 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 Response 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. Environmental 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. Environmental 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 Response 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 Response 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 Response 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. 

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[135] Howatt, K. (Maine Department of Environmental Protection). 2011. Email correspondence 

with Gerald Hornok, Re: Leeds. 20 June. 1 page. 

[136] Hamilton, P.A. (Eaton, Peabody, Bradford & Veague, P.A., Attorneys at Law). 2000. Letter 

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Protection, Re: Leeds Metal/Maine Central 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 Specialist, Maine Department of Environmental 

Protection, Re: Maine Central Railroad/Leeds. 18 May. 7 pages. 

[138] Maine Department of Environmental Protection, 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 January 20, 2000 report on the Results of 

Monitoring Well Installation and Groundwater Sampling, 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, Maine. 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. Environmental 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. September. Excerpt. 165 pages. 

[146] U.S. Department of Health and Human Services, Agency for Toxic Substances and Disease 

Registry. 1997. Tetrachloroethylene, CAS # 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. 4 April. 4 pages. 

[149] Environment Agency. 2003. An illustrated handbook of DNAPL transport and fate in the 

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

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[151] U.S. Geological Survey (USGS). 1979. Lake Auburn East, Maine (7.5-minute series 

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[152] U.S. Geological Survey (USGS). 1967. Turner Center, Maine (7.5-minute series topographic 

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 TCE. 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 

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[161] Maine Department of Environmental Protection, Bureau of Remediation & Waste 

Management. 2011. Hazardous & Oil Spill System, Re: Leeds, ME and Monmouth, ME. 

Available at http://www.maine.gov/dep/rwm/hoss/. 10 pages. 

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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 Update, Leeds Metals, Leeds. 7 April. 5 

pages. 

[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, Comprehensive Hydrogeological Study at SafetyKleen Corp Service Center, Leeds, Maine. 4 April. 230 pages. 

[168] Groundwater Technology, Inc. 1989. Soil Investigation, Safety-Kleen Facility, Leeds, 

Maine. October. 90 pages. 

[169] Groundwater Technology, Inc. 1990. Aquifer Investigation, Safety-Kleen Facility, Leeds, 

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[170] Barton & Loguidice, P.C. 1999. Quarterly Groundwater Sampling Results, Safety-Kleen 

Leeds, Maine Service Center, Hazardous Facility License No. 0-28-95-A-N, Leeds, Maine. 

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[171] Barton & Loguidice, P.C. 2000. Quarterly Groundwater Sampling Results, Safety-Kleen 

Leeds, Maine Service Center, Hazardous Facility License No. 0-28-95-A-N, Leeds, Maine. 

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[172] Messmer, M., Barton & Loguidice. 2007. Letter RE: Safety-Kleen, Leeds, Maine Service 

Center Off-Site Groundwater Sampling Letter Stamped Transmittal. 2 March. 63 pages. 

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Leeds, Maine. February. 247 pages. 

[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. 31 March. 2 pages. 

[177] U.S. Environmental Protection Agency (EPA). 2012. Superfund Chemical Data Matrix 

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[178] U.S. Environmental Protection Agency (EPA). 2012 Methodology for Determining 

Chemical and Physical Properties Factor Values and Screening Concentration Benchmarks 

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March. 40 pages. 

[179] U.S. Environmental Protection Agency (EPA). 2012. SUBSET of SCDM Volatile Substances 

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31 March. 8 pages. 

[180] Hornok, G. and Kelly, J. Weston Solutions, Inc. 2012. Project Note, Re: Summary of 

methods used to calculate Potential Groundwater Population within 4 Radial Miles of Leeds 

Metal. 27 June. 40 pages. 

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SITE SUMMARY – Leeds Metal 

The Leeds Metal property is located along Blue Rock Road in Leeds, Androscoggin 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]. 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]. In addition, available file information indicates that cast concrete 

manufacturing and disposal took place on the northwestern 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 [four pile sources (Debris Piles A through D) and one 

contaminated soil source (Former Operations Area)], which were documented and sampled as part of the 2010 

EPA Site Inspection (SI), and are located on the central-southeastern portion of the property (see Figure 2) 

[see Source Characterization sections of this HRS Documentation Record]. These on-site sources have been 

documented to contain one volatile organic compound (VOC) [tetrachloroethene (PCE)], two polychlorinated 

biphenyls (PCBs) (Aroclor-1254 and Aroclor-1260), and three total metals (arsenic, chromium, and lead) [see 

Source Characterization sections of this HRS Documentation 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 section of this HRS Documentation Record]. In 

addition, a release of PCE, and its breakdown product trichloroethene (TCE), to downgradient residential 

drinking water supply wells was documented in seven drinking water wells affecting 17 residents [see Ground 

Water Migration Pathway section of this 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 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, 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 Leeds Metal property had recently been initiated [136, p. 

4]. In February 1976, National Metal Converters, Inc. 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 Environmental 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 2011 
 

 

two 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 PCB 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 Spill 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 report of abandoned drums at the Leeds Metal property 

(Spill No. A/158/87) [23, pp. 1-2]. The ME DEP investigator, 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 completed [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 for 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 determine if a release of hazardous substances to soils had 

occurred [19, p. 2, Figures 2 and 3]. The 15 soil samples were collected from the following locations on the 

property: near the suspected loading dock and incinerator; near a foundation of a building located adjacent to 

the railroad tracks on the southeastern portion of the property; 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 property, as well as on conditions during the October 1997 

sampling event [19, p. 2]. The soil samples were submitted 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, Appendix A (pp. 8-21)]. Each of the RCRA 8 metals, including arsenic, 

cadmium, chromium, and lead was detected above laboratory 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 monitoring wells at various locations throughout the Leeds 

Metal property [24, pp. 1-2, 7, 11]. Temporary ground water monitoring wells were installed, based on 

consultation with ME DEP, to evaluate ground water flow direction beneath the property as well as ground 

water quality in relation to documented soil contamination [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 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, after stagnant water was purged [24, pp. 2-3, 13-14]. The 

ground water samples were collected in laboratory-prepared 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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ground 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 southeastern 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 concentrations above MDLs [24, pp. 4, 11, 16-48]. 

On 1 through 3 November 1999, on behalf of Maine Central Railroad, ERM 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 from 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 property [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 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 and 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-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 chief 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 southern property boundary [26]. The former assistant fire 

chief recalled 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]. 

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On 28 September 2000, ME DEP designated the Leeds Metal property as an Uncontrolled Hazardous 

Substance Site based on previous investigations and known operational history [27, pp. 1-10]. 

From 27 through 29 November 2000, on behalf of Maine Central Railroad, ERM oversaw a shallow ground 

water investigation at the Leeds Metal property, which 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 previously been detected in ground water samples [28, pp. 

1-4, 10, 16-25]. As part of the ERM investigation, 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 & Swallow 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 installed 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 collected 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 collected from the following locations [sediment (SS-#) 

and surface water (SW-#) sample locations in parentheses]: the lagoon/trench areas located on the western 

portion of the property (SS-1 and SW-1); the wetland area 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 Method 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, chromium, 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 total metals (barium, cadmium, chromium, lead, and 

mercury) above the reporting detection limit [28, pp. 5, 10, 15, 48-60]. 

On 10 November 2003, on behalf of Maine Central Railroad, 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 encountered within the test pit was documented by ERM 

personnel [29, pp. 4-5, Appendix B]. Soil samples were collected from the excavator 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 from each of the test pits and screened in the field for PCBs and total 

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metals, 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 metals 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, and 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 personnel 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]. Screening results of soil samples indicated the presence of total 

VOCs at a concentration of 54.1 parts per million (ppm) and 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 limits, 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, metal, 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 analyses 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 laboratory 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, occasional 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 VOCs 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, including 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, Appendix D (pp. 155-159)]. Laboratory analytical results 

indicated the presence of 11 VOCs, three SVOCs, two PCBs, and six total metals above laboratory reporting 

detection limits, including Aroclor-1260, arsenic, cadmium, 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 and total PCBs at concentrations greater than 25 ppm 

[29, pp. 39-60, 70, 74]. In addition, metals screening 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. 

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67-68, 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 located along the southeastern property boundary, and is 

equivalent to the area referred to as the Former Operations 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 indicated 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 lead [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 (yd3

), 55,600 yd3, 10,400 yd3, and 55,500 yd3, 

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 yd3

, 20,566 yd3, 1,727 yd3, and 11,280 yd3, for Debris Piles A, B, C, and D, respectively [29, Appendix 

A]. 

On 17 June 2004, Roux Associates, Inc. (Roux Associates), 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 allegedly 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 property 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 water 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 range 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 composite soil samples (CS-1, CS-2, and CS-3) from 

locations adjacent to the three newly installed monitoring 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 

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following analyses: VOCs by EPA Method 8260B, SVOCs by EPA Method 8270B, PCBs by EPA Method 

8082B, RCRA metals by EPA Methods 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 listed 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 requested 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, including one field duplicate, from the nine ground water 

monitoring wells installed on the Leeds Metal property by ERM in November 1999 [31, pp. 1-15]. The 

ground water samples were relinquished to Weston Solutions, 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 Chelmsford, Massachusetts (MA) for VOC, RCRA metals, 

and cyanide analyses [31, p. 2; 32, p. 24]. 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]. 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 surface 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, for confirmatory results, 24 of the soil samples were 

submitted to the EPA OEME laboratory for VOCs in soil (high level method) analysis, and 20 of the soil 

samples were submitted to the EPA OEME laboratory for 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 laboratory 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 samples were collected, using a peristaltic pump, from 

various depth intervals within the temporary monitoring 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 ground water monitoring wells previously installed on the 

property (ERM-4S and ERM-4D), and submitted to the EPA 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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sample 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 personnel 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 analyses [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 (COC) 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 well 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 portion 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 northwestern 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 properties 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 and 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 containing the following two VOCs, three PCBs, and 13 total 

metals at concentrations above background: 2-butanone [also known as methyl 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 

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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, SB-34, SB-35, 

SB-36, and SB-43) collected from Debris Pile B during 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, chloroform, 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, vanadium, 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)], 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 during the EPA Site Assessment 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), 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. 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 during the EPA Site Assessment Site Inspection indicated 

a source containing the following nine VOCs, four PCBs, and 16 total metals at concentrations above 

background: 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 the 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 collected 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, arsenic, and lead [Figure 2; 11, p. 4 (Figure 2); 32, 

pp. 27-28, 40-41, 55, 122]. 

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 during the EPA 

Site Assessment Site Inspection indicated a source containing the following 10 VOCs, four PCBs, and 23 

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

Leeds Metal 34 HRS Documentation Record 

MEN000103584 September 2011 
 

 

 

 

methyl acetate, methyl tert-butyl ether (MTBE), styrene, PCE, m,p-xylene, 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 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 concentrations above laboratory detection 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, and 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. 

Leeds Metal 35 HRS Documentation Record 

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Source 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 Assessor’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 of) 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 cleaned for resale [26]. The former assistant fire chief 

noted that metal from the shredded cars was salvaged (sent 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 acid, 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 Departments 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 both 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, working on behalf of the property owner, 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 extensive 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 metal 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 concentrations exceeding state standards [29, pp. 12-15, 65, 70­

71; 138, Appendix 1]. ERM estimated the approximate volume of Debris Pile A to be 16,700 yd3

 [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 yd3

 [29, Appendix A (pp. 1-2, 6-7)]. 

Leeds Metal 36 HRS Documentation Record 

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Source 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 with 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 (SB-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 source 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 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 three total metals (arsenic, chromium, and lead). 

Table 1 - Hazardous Substances Associated 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 Chromium1 

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 Lead1 

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 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 Chromium1 

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 Lead1 

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 adjusted [40, p. 4; 58, pp. 2, 3 (Exhibit 3), 10 (Table 

3)]. 

- Source Samples: 

On 30 November 2010, as part of the EPA Site Assessment Site Inspection, soil/source 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 2011 
 

 

 

 

 

Source 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 debris (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 brown, fine sandy silt, major debris (wire, slag, 

plastic, metal), little medium-to-coarse sand, little fine-to-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-medium gravel, trace debris (plastic), and trace organics 

[76, p. 4]. Subsurface soil/source sample SB-12 was described as dark brown, sandy silt, some debris (rubber, 

metal, metal slag, glass), trace fine gravel, and trace clay [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, chromium, and lead) as presented in the following table. 

Among the 12 selected soil/source samples, Aroclor-1254 was detected at a maximum concentration of 

11,000 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 concentration of 819 mg/Kg 

in surface soil/source sample SS-50, located on the southeastern 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)]. 

Leeds Metal 39 HRS Documentation Record 

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Source 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) 

Leeds Metal 40 HRS Documentation Record 

MEN000103584 September 2011 
 

 

 

 

 

 

Source 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 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-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-12601 

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) 

Lead2 

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) 

Leeds Metal 42 HRS Documentation Record 

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Source 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-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) 

Lead2 

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) 

Leeds Metal 43 HRS Documentation Record 

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Source 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 

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) 

Arsenic3 

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) 

Leeds Metal 44 HRS Documentation Record 

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Source Characterization 

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 quantity [42, Table 1 (p. 2 of 3); 43, Table 1 (pp. 1­

2 of 2); 103, p. B-47]. 

( ) = For hazardous substance concentrations, denotes 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 intended 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

 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 exceeded 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]. 

Leeds Metal 45 HRS Documentation Record 

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Source Characterization 

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, Table 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 (Table 2); 10-13 (Table 3); 61, pp. 6-7 (Table 2), 8 (Table 

3), 10 (Table 3)]. Therefore, the substances Aroclor-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 yd3 [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. 

Leeds Metal 46 HRS Documentation Record 

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Source Characterization 

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 assigned 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 for 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 Constituent 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 Wastestream 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 source characterization fully encompasses and is larger than 

Leeds Metal 47 HRS Documentation Record 

MEN000103584 September 2011 
 

 

 

Source Characterization 

Source No. 1 

the source extent presented in the ERM Debris Pile Evaluation [Figure 2; 29, 70-71, Appendix A (pp. 1-2)]. 

There, for the purposes of this HRS documentation record, 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 yd3 [29, Appendix A (pp. 1-2)]. 

Table 6 – Volume 

Source 

Type 

Description 

(# drums or dimensions) 

Units 

(yd3

) References 

Pile Debris Pile 6,413 

29, 70, Appendix A (pp. 

1-2) 

The volume of a “pile” source, in yd3

, is divided by 2.5 to assign a Hazardous Waste Quantity to the source 

[1, p. 51591, Table 2-5]. 

Sum (yd3

): 6,413 

Equation for Assigning Value (1, p. 51591, Table 2-5): 6,413 yd3

 ÷ 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 (ft2

) References 

NS 

The area of a “pile” source, in ft2

, 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 information 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 

Leeds Metal 48 HRS Documentation Record 

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Source Characterization 

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 Assessor’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 cleaned for resale [26]. The former assistant fire chief 

noted that metal from the shredded cars was salvaged (sent 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 acid, 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 Departments 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 both 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, plastic, and metal debris [14, p. 6]. 

In November 2003, ERM personnel, working on behalf of the property owner, 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 extensive 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 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, indicated the presence of four PCBs (Aroclor-1016/Aroclor1242, Aroclor-1248, Aroclor-1254, and Aroclor-1260) and nine total metals (antimony, arsenic, cadmium, 

cobalt, copper, iron, lead, manganese, and nickel) at concentrations exceeding state standards [29, pp. 16-35, 

65-66, 70, 72; 138, Appendix 1]. ERM estimated the approximate volume of Debris Pile B to be 55,600 yd3 

[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 Characterization 

Source No. 2 

Appendix A (p. 3)]. Following the Maine Central Railroad survey of Debris Pile B, the volume estimate of 

Debris Pile B was adjusted by ERM to 20,566 yd3

 [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 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 (SB-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. 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 background concentrations, the following 

hazardous substances in background samples are presented: two PCB aroclors (Aroclor-1254 and Aroclor1260), and two total metals (chromium and lead). 

Table 8 - Hazardous Substances Associated 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 Chromium1 

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 Lead1 

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) 

Leeds Metal 50 HRS Documentation Record 

MEN000103584 September 2011 
 

 

 

 

Source Characterization 

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 Chromium1 

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 Lead1 

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 adjusted [40, p. 4; 58, pp. 2, 3 (Exhibit 3), 10 (Table 

3)]. 

- Source Samples: 

On 18 November 2010, as part of the EPA Site Assessment Site Inspection, soil/source 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 Characterization 

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 (rubber, fabric/cloth), little fine-to-coarse sand, little clay, 

trace gravel, trace organics, and containing a “petroleum” odor [75, p. 34]. Surface soil/source sample SS-36 

was described as dark brown, silt, little debris (woven fabric, 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]. Subsurface soil/source sample SB-36 and field duplicate SB-43 

were described as dark brown-to-black, silt, some debris (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 (Aroclor-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, located 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, Table 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 Characterization 

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-12602 

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) 

Lead1 

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-12602 

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) 

Lead1 

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 Characterization 

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-12602 

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) 

Lead2 

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-12602 

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) 

Lead1 

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 Characterization 

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-12542 

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-12602 

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) 

Lead1 

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-12602 

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) 

Lead1 

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 Characterization 

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-12602 

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) 

Lead1 

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, denotes 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 intended 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 results were qualified as estimated following data review. Lead had a high bias (serial dilution results 

exceeded percent difference criteria) and 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 Characterization 

Source No. 2 

Note: Trichloroethene was detected in one subsurface 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 consistent 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) was determined to be approximately 20,566 yd3 [29, Appendix A (p. 

3)]. As part of the EPA Site Assessment Site Inspection, 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 Characterization 

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 assigned 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 for 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 Constituent 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 Wastestream 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 Characterization 

Source No. 2 

2.4.2.1.3 Volume 

Description 

For the purposes of this HRS documentation record, the 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 yd3 [29, Appendix A (p. 3)]. 

Table 13 – Volume 

Source 

Type 

Description 

(# drums or dimensions) 

Units 

(yd3

) References 

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

The volume of a “pile” source, in yd3

, is divided by 2.5 to assign a Hazardous Waste Quantity to the source 

[1, p. 51591, Table 2-5]. 

Sum (yd3

): 20,566 

Equation for Assigning Value (1, p. 51591, Table 2-5): 20,566 yd3

 ÷ 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 (ft2

) References 

NS 

The area of a “pile” source, in ft2

, 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 Characterization 

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 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: 8,226.4 

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Source Characterization 

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 Assessor’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 cleaned for resale [26]. The former assistant fire chief 

noted that metal from the shredded cars was salvaged (sent 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 acid, 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 Departments 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 both on the ground surface and in piles, including Source 

No. 3 (Debris Pile C) (see Figure 2) [14, pp. 2-15]. Debris 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 material which comprises Debris Pile C was observed to be 

consistent with that of several other debris piles on the property, and included rubber, plastic, and metal debris 

[14, p. 6]. 

In November 2003, ERM personnel, working on behalf of the property owner, 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 extensive 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 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, and plastic” [29, pp. 9-10]. Screening and laboratory analyses of test pit samples 

collected from Debris Pile C, on behalf of the property owner, indicated the presence of two PCBs (Aroclor1254 and Aroclor-1260) and seven metals (arsenic, cadmium, 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 yd3

 [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 yd3

 [29, Appendix A (p. 4)]. 

Leeds Metal 61 HRS Documentation Record 

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Source Characterization 

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 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 (SB-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 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 materials [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 Associated 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) 

Leeds Metal 62 HRS Documentation Record 

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Source Characterization 

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 Lead1 

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 (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 Assessment Site Inspection, soil/source sampling activities of 

Debris Pile C were conducted [15, p. 48; 16, p. 2; 34, p. 21]. 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 C characterization, two surface soil/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, plastic, 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 debris (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 clay [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 analysis 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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Source Characterization 

Source No. 3 

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/Kg 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-12602 

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) 

Lead1 

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) 

Lead1 

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 Characterization 

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, denotes 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 intended 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 correlation 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 Characterization 

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)]. Therefore 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 yd3 [29, Appendix A (p. 4)]. As part of the EPA Site Assessment Site 

Inspection, four surface and subsurface soil/source samples were 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 Characterization 

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 assigned 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 for 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 Constituent 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 Wastestream 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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MEN000103584 September 2011 
 

 

Source Characterization 

Source No. 3 

2.4.2.1.3 Volume 

Description 

For the purposes of this HRS documentation record, the 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 yd3 [29, Appendix A (p. 4)]. 

Table 20 – Volume 

Source 

Type 

Description 

(# drums or dimensions) 

Units 

(yd3

) References 

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

The volume of a “pile” source, in yd3

, is divided by 2.5 to assign a Hazardous Waste Quantity to the source 

[1, p. 51591, Table 2-5]. 

Sum (yd3

): 1,727 

Equation for Assigning Value (1, p. 51591, Table 2-5): 1,727 yd3

 ÷ 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 (ft2

) References 

NS 

The area of a “pile” source, in ft2

, 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 Constituent Quantity and Hazardous Wastestream Quantity 

Factor Values were not evaluated for Source No. 3 because 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 

Leeds Metal 68 HRS Documentation Record 

MEN000103584 September 2011 
 

Source Characterization 

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 Assessor’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 Debris 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 cleaned for resale [26]. The former assistant fire chief 

noted that metal from the shredded cars was salvaged (sent 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 acid, 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 Departments 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 both 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, working on behalf of the property owner, 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 extensive 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 (Aroclor-1254 and Aroclor-1260) and six metals (arsenic, 

cadmium, cobalt, copper, lead, and nickel) at concentrations exceeding state standards [29, pp. 39-60, 67-68, 

70, 74; 138, Appendix 1]. ERM estimated the approximate volume of Debris Pile D to be 55,500 yd3

 [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 Characterization 

Source No. 4 

Appendix A (p. 5)]. Following the Maine Central Railroad survey of Debris Pile D, the volume estimate of 

Debris Pile D was adjusted by ERM to 11,280 yd3

 [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 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 (SB-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 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 materials [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 aroclors (Aroclor-1254 and Aroclor-1260), and three total 

metals (arsenic, chromium, and lead). 

Table 22 - Hazardous Substances Associated 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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Source Characterization 

Source No. 4 

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 Chromium1 

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 Lead1 

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 Chromium1 

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 Lead1 

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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Source Characterization 

Source No. 4 

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 adjusted [40, p. 4; 58, pp. 2, 3 (Exhibit 3), 10 (Table 

3)]. 

- Source Samples: 

On 9 November 2010, as part of the EPA Site Assessment 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 described 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 coating, 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, and wire coating), and trace clay [75, p. 29]. Surface 

soil/source samples SS-31 was described as dark-brown, silty-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 saturated medium-to-rusty brown, 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 sample 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 Aroclors (Aroclor-1254 and Aroclor-1260) and three total 

metals (arsenic, chromium, and lead). 

PCE was detected in surface and subsurface soil/source 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 concentration 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 detected 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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Source Characterization 

Source No. 4 

(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) 

Arsenic1 

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) 

Chromium1 

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) 

Lead1 

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 Characterization 

Source No. 4 

Arsenic1 

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) 

Chromium1 

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) 

Lead1 

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) 

Arsenic1 

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) 

Chromium1 

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) 

Lead1 

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 Characterization 

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) 

Arsenic1 

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) 

Chromium1 

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) 

Lead1 

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) 

Chromium1 

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) 

Lead1 

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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Source Characterization 

Source No. 4 

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) 

Chromium1 

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) 

Lead1 

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) 

Arsenic1 

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) 

Chromium1 

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) 

Lead2 

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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Source Characterization 

Source No. 4 

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 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) 

Arsenic1 

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) 

Chromium1 

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) 

Lead1 

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, denotes 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 intended 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 dividing by the adjustment factor of 1.29 [44, p. 5; 62, 

p. 2, 3 (Exhibit 3), 8-11 (Table 3)]. Lead had a high 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)]. 

Leeds Metal 77 HRS Documentation Record 

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Source Characterization 

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, chromium, 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 Debris Pile D (Source No. 4) was determined to be 

approximately 11,280 yd3 [29, Appendix A]. As part of the EPA Site Assessment Site Inspection, eight 

surface and subsurface soil/source samples were collected from 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. 

Leeds Metal 78 HRS Documentation Record 

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Source Characterization 

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 assigned 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 for 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 Constituent 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 Wastestream 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, the 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 

Leeds Metal 79 HRS Documentation Record 

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Source Characterization 

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 yd3 [29, Appendix A (p. 5)]. 

Table 27 – Volume 

Source 

Type 

Description 

(# drums or dimensions) 

Units 

(yd3

) References 

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

The volume of a “pile” source, in yd3

, is divided by 2.5 to assign a Hazardous Waste Quantity to the source 

[1, p. 51591, Table 2-5]. 

Sum (yd3

): 11,280 

Equation for Assigning Value (1, p. 51591, Table 2-5): 11,280 yd3

 ÷ 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 (ft2

) References 

NS 

The area of a “pile” source, in ft2

, 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 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: 4,512.0 

Leeds Metal 80 HRS Documentation Record 

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Source Characterization 

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 Area, 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 cleaned for resale [26]. The former assistant fire chief 

noted that metal from the shredded cars was salvaged (sent 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 acid, 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 Departments 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 both on the ground surface and in piles, including Source 

No. 5 (Former Operations Area) [14, pp. 2-15]. The western extent of operations on the property is generally 

defined as the tree-line that runs north-south on the property, while the eastern extent of operations is the 

railroad bed [14, pp. 8-11; 17, pp. 10-11; 19, p. 1, Figure 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 automobile 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 ft2 

[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 contaminated 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 activities were conducted [15, pp. 44-46; 34, p. 20]. 

Leeds Metal 81 HRS Documentation Record 

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Source Characterization 

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 (SB-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 source 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 record and the evaluation of background concentrations, the 

following hazardous substances in background samples are presented: one VOC (PCE), two PCB aroclors 

(Aroclor-1254 and Aroclor-1260), and three total metals (arsenic, chromium, and lead). 

Table 29 - Hazardous Substances Associated 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 Chromium1 

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 Lead1 

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 Characterization 

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 Chromium1 

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 Lead1 

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 adjusted [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 throughout 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 debris (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 

Leeds Metal 83 HRS Documentation Record 

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Source Characterization 

Source No. 5 

described as dark brown, fine sandy silt, some medium-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, foam, 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 brown, 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 sample 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, and 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 Tier 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 total 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 concentration 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 property boundary, adjacent to 

the railroad tracks; arsenic was detected in one source sample, at a concentration of 28.9 mg/Kg in SS-13; 

chromium was detected in six source samples, at a maximum 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)]. 

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Source 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-12601 

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) 

Lead2 

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) 

Arsenic2 

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) 

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Source 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) 

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Source 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) 

Lead2 

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) 

Lead2 

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) 

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Source 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) 

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Source 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) 

Lead2 

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) 

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Source 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) 

Chromium2 

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) 

Lead2 

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-12541 

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) 

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Source 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) 

Lead2 

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) 

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Source 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) 

Lead2 

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) 

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Source 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, denotes 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 intended 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

 Aroclor-1254 and Aroclor-1260 results were qualified as estimated following data review. Aroclor-1254 

had an unknown bias (surrogate recoveries did not meet criteria) in surface soil/source sample SS-27, and was 

adjusted 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 (rinsate) 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 adjusted [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 

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Source 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 total 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 (Table 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 the 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 analysis of aerial photographs, and GPS data collected 

by START as part of the EPA Site Assessment Site Inspection, the Former Operations Area encompasses an 

area of approximately 190,558 ft2

 (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. 

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Source 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 was 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 Factor Values were not evaluated for Source No. 5 

because insufficient information was available [1, p. 51591 (Table 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 Constituent 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 Wastestream 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 Characterization 

Source No. 5 

Table 34 – Volume 

Source Type 

Description 

(# drums or dimensions) 

Units 

(yd3

) References 

NS (insufficient information) 

Sum (yd3

): 

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 ft2

 (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 (ft2

) References 

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

The area of a “contaminated soil” source, in ft2

, is divided by 34,000 to assign a Hazardous Waste Quantity to 

the source [1, p. 51591, Table 2-5]. 

Sum (ft2

): 190,558 

Equation for Assigning Value (1, p. 51591, Table 2-5): 190,558 ft2

 ÷ 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 was 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 because 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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Source Characterization 

Summary of Source Descriptions/Other Possible Sources 

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 southern 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 chief of the Town of Leeds, ME, who stated that 

transformers and batteries were drained from cars adjacent 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 the northern portion of the property, adjacent to the 

parking area [14, p. 15]. Analytical results of seven surface soil samples collected 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, 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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Source Characterization 

Summary of Source Descriptions/Other Possible Sources 

During the 16 March 2010 EPA Site Assessment SI Leeds 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, barium, 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 Associates), 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 allegedly 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, numerous pieces of concrete pipe 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 collected 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 concentrations above laboratory detection 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]. This source does not affect the Total Source 

Hazardous Waste Quantity Value and was therefore not scored. 

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Ground Water Migration Pathway 

Leeds Aquifer 

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, sandstone, 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 Mountain Member is characterized by ‘thin well-bedded 

alternations of light-to-medium greenish-gray calc-silicate granofels, quartzo-feldspathic biotite granofels, 

and fine-grained impure granoblastic 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 indicate that the deposit was graded to the 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 Metal 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 wave 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 postglacial 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 property owner between 1999 and 2004 as will be described below. The property 

is approximately 36 acres, and the majority of the property 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 overburden, 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 direction 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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Ground Water Migration Pathway 

Leeds Aquifer 

the shallow overburden data, by ME DEP personnel, concluded that the ground water flow direction was in a 

more westward direction than noted in the property owner’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 monitoring 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 contaminants 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 the 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 Railroad, installed 11 temporary ground 

water monitoring wells at various locations throughout the Leeds Metal property [24, pp. 1-2, 7, 11]. The 

intent of the temporary ground water monitoring well points 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 depth 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]. ERM 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 Maine Central Railroad, installed 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 addition, 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 overburden wells were installed 

to a maximum depth of 47 feet bgs [25, p. 3]. Split spoon soil samples were collected at approximate fivefoot intervals in each boring of the deep overburden wells [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]. ERM 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 that 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 northwest [25, p. 5]. In response comments to the ERM 

Investigation Report, ME DEP personnel, 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 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 declared that looking at the 

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Ground Water Migration Pathway 

Leeds Aquifer 

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 dominate both ground water flow and 

contaminant distribution, but it is likely to play a major 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 subcontractor, Pine & Swallow, on behalf of Maine 

Central Railroad, conducted a shallow ground water investigation at the site to evaluate the extent of VOCs in 

ground water [28, pp. 1-3]. One temporary monitoring well (SB-1) and 11 semi-permanent wells (SB-2 

through SB-12) were installed on the Leeds Metal property [28, p. 2, 10]. Wells were installed based on 

previous detections of PCE in monitoring 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 samples were collected from each of the newly installed 

wells [28, p. 3]. In addition, ground water samples were 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 completed 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 Environmental 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-coarse 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 Leeds Metal Area and the newly installed ground water 

monitoring wells RX-1S through RX-3S located on the Site was completed [21, p. 16]. The Leeds Metal 

Area was defined by Roux as the area of historical automobile storage and metal recycling operations [21, p. 

3]. Based on the gauging data combined with the survey 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 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]. On-site investigations conducted to date indicate the subsurface geology consists of fine-tocoarse sand, with some fine-to-coarse gravel and inconsistent 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 approximately 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-sedimentary bedrock of the Sangerville 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 alternations 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 massive 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 metamorphic 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 property, along Plains Road, is 97 feet bgs (Well location 

DW-02), while the depth to bedrock immediately south 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 Road (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 understand the temporal and spatial complexities and variations [142, p. 1; 

165, p. 3]. There is insufficient data to determine the location, size or relative strength of the source areas or 

vertical and horizontal distribution of VOCs in the subsurface [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 Metal 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 conductivity layers that separate aquifers throughout a 

2-mile radius of the site sources [1, Table 3-6]. Therefore the hydrogeology beneath the site is characterized 

by a single aquifer consisting of the on-site shallow and deep glacial overburden aquifer and the hydraulically 

connected underlying meta-sedimentary bedrock aquifer. The aquifer interconnection is also demonstrated by 

a downward migration of hazardous substances (PCE) from the Leeds Metal sources into the on-site shallow 

and deep overburden aquifers, and then to the bedrock aquifer, 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 site [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 downward migration of hazardous substances. 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 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 (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 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 nine overburden ground water monitoring wells (ERM1S, ERM-1D, ERM-2S, ERM-2D, ERM-3S, ERM-3D, ERM-4S, ERM-4D, and ERM-5] installed by ERM 

on 1 through 3 November 1999, and from two overburden ground water monitoring 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 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; 

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 for 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 materials within the local vicinity and to establish a 

concentration value that demonstrates that a significant 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, PCE, 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 Water 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 feet 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 for 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 hazardous 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 property (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 QAPP, 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 November 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, Figure 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 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 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 overburden 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 (overburden 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 south 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, northwest 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 casing, 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, northwest 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 well 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 were 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, Table 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 concentrations greater than or equal to the relevant 

background sample concentrations (GW-12, concentration 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, Table 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 concentrations above CLP 

laboratory reporting limits but below the sample-adjusted 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, Section 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, southeast, 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-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. 7-17, 

19-26, 73-87 (Table 1); 78, pp. 1-29]. Drinking water 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 Figure 5) [11, pp. 133-135; 14, p. 26; 16, pp. 7-9; 

34, pp. 8, 22, 73-74 (Table 1)]. The background samples were collected from within the same aquifer, at 

similar well screen elevations, similar geologic formation (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 three background samples were used to establish background 

chemical composition/conditions of the matrix materials within the local vicinity, and to establish a 

concentration value that demonstrates that a significant 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 Water 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 residential property is located in Leeds, ME, depicted on 

the Town of Leeds, ME Tax Assessor’s Map No. 4, Lot 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 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. 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 residential 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 qualified 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 concentrations 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 purposes of this HRS documentation record, the values for 

drinking water sample DW-02 are presented as background 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, southeast, 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 establish 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 overburden 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 submitted 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 residential property is located in Leeds, ME, and is 

depicted on the Town of Leeds, ME Tax Assessor’s Map 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 supply 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 quality 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 residential property is located in Leeds, ME, and is 

depicted on the Town of Leeds, ME Tax Assessor’s Map 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 residence is supplied drinking water from an on-site, 

approximately 187-foot deep drilled bedrock 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 residential property is located in Leeds, ME, and is 

depicted on the Town of Leeds, ME Tax Assessor’s Map 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 private 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 and 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 filtration 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 residential property is located in Leeds, ME, and is 

depicted on the Town of Leeds, ME Tax Assessor’s Map 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 supply 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 water 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 filtration system [15, pp. 16-17; 34, pp. 15, 80 (Table 

1); 78, p. 16]. 

Drinking water sample DW-23 was collected from a residential property is located in Leeds, ME, and is 

depicted on the Town of Leeds, ME Tax Assessor’s Map 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 completed 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 residential property is located in Leeds, ME, and is 

depicted on the Town of Leeds, ME Tax Assessor’s Map 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]. According 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 residential property is located in Leeds, ME, and is 

depicted on the Town of Leeds, ME Tax Assessor’s Map 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 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 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 background 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 detected 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 concentrations greater than or equal to the relevant 

background sample concentrations (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]. 

Table 45 - Hazardous Substances Associated 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 limits, 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 ground 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. According 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 staged 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 representing 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 internal 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, and 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 Leeds Metal property had recently been initiated [136, p. 

4]. In February 1976, National Metal Converters, Inc. 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 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]. 

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 Chief 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 batteries 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 along the southern property boundary [26]. The former 

Assistant Fire Chief recalled 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]. 

On 2 June 1983, 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 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 soils 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 Assessment/Site Investigation, START collected a total of 

196 surface 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 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 submitted to the EPA OEME laboratory for VOAs in soil 

(high level method) analysis, and 20 of the soil samples 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 concentrations 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 concentrations above background, including 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 concentrations 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 concentrations 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 solvent to remove grease from metal parts, but is also an 

ingredient in adhesives, paint removers, typewriter correction fluids, and spot removers [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 tendency 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 automotive aerosol and liquid part cleaners, rust removers 

and lubricants contain high percentages of PCE; these include brake cleaners (greater than 90% PCE), 

carburetor cleaners (15-20% PCE), non-flammable Penetrating 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 “sink” 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 sunlight 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 and/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 conditions 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 many 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 reduce 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 immiscible in water, allowing them to remain in a nonaqueous phase [145, Appendix B (pp. B-1 – B-8)]. DNAPLs 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/geochemical behavior [145, Appendix B (pp. B-1 – B8)]. Their behavior is determined by complex 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 formation of emulsions; and transformation into other 

chemicals by microbiological and/or chemical processes (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 influence of gravity through the subsurface [145, Appendix 

B (pp. B-1 – B-8)]. 

Provided there is sufficient mass to drive the movement, 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 Central 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 installed 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 containers 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 Central Railroad, installed nine 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 southern 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 water 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 property [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 investigations, 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 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 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 previous 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 and 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 Railroad, 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 water samples [28, pp. 1-4, 10, 16-25]. As part of the 

ERM investigation, 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 collected 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 concentration 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 November 1999 [31, pp. 1-15]. The ground water samples were 

relinquished to START personnel and submitted to the EPA OEME Laboratory for VOAs in water, total 

recoverable metals in water by ICP, total mercury in water, 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 samples were collected, using a peristaltic pump, from 

various depth intervals within the temporary monitoring 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 ground water monitoring wells previously installed on the 

property (ERM-4S and ERM-4D), and submitted to the EPA 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 property (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 Associates 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 determine 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 analytical results from four ground water samples (GW02, GW-06, GW-07, and GW-11) are used to document an observed release to the overburden ground water 

aquifer. Background sample GW-12 was utilized to establish background chemical composition/conditions of 

the matrix materials within the local vicinity, and to establish a local conditions and determine if 

contamination is attributable to sources and demonstrates that a significant concentration of a hazardous 

substance is present above background 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 than 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, southeast, 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 water 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 supply wells located northwest of the Leeds Metal 

property to establish background concentrations for comparison [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 determine 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 Laboratories 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 concentration 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 detected 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 database 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 relative 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 minor perchloroethylene spill inside a truck. It was 

picked up using sorbents” [161, p. 7]. The documentation 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 facility is located approximately 1.1 miles southwest of the 

Leeds Metal site [7]. The other hazardous material incident 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 personnel 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 Keywords equal to “Hazardous” [161, pp. 8-10]. The 

database search identified 27 records based on these criteria [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 material incidents involving PCE or TCE [161, pp. 8-10]. 

In addition, a former Concrete Manufacturing Facility 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 database 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 the 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 operated the Leeds facility for the distribution and 

recycling of cleaning and degreasing solvents and paint-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 distinct 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 Warehouse 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 Fill 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 recycled 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-cleaning waste, universal wastes, and 

sediment or sludge for the waste mineral spirit dumpsters [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 application 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 regulations that the facility will pose a serious threat 

to public health and the environment [167, p.1]. 

Wang Engineering, Inc. (WEI) and Groundwater Technology, 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 installation of six additional ground water monitoring wells, 

including five off-site wells and one on-site well [169, p. 5; 175, p. 30]. 

The WEI and Groundwater Technology, Inc. investigations 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 deposits overlying marine silt and clay of the Presumpscot 

Formation and a lower sand and gravel stratum, underlain by metamorphosed bedrock [167, pp.14-16; 169, 

p.25]. Groundwater Technology, Inc. demonstrated that 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 flow southerly from the facility [169, pp. 25-26]. The 

shallow ground water flow is occasionally interrupted by surfical depressions, which are ground water 

discharge zones during wet seasons [169, p. 26]. Therefore, 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 apparent to the northwest, west and east [169, p. 26]. 

These variations are the result of the seasonal influences 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 towards the Dead River, generally 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, including PCE, have been detected in several on-site 

wells [169, pp. 17-20; 167, pp 12-14, Appendix D; 170 Figure 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 PCE was detected in 1987 at a concentration of 0.030 

ppm in on-site monitoring well MW-4U and TCE was detected 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 domestic 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 sampled 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 detected above the sample detection limits [162 p. 2; 169, p 

3]. 

From early 1990, until December 2010, regular ground water 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 collected 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 investigations 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 Tax Assessor’s Office Map No. 4 as Lot No. 48 (location of 

drinking water sample DW-03); automobile repairs conducted 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 residence 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 used 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 conducted on the residential properties, compared to the 

relatively significantly larger scale of the former recycling 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/Tetrachloroethylene/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 Factor Value are assigned to the hazardous substances 

associated with the sources and releases 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 meets the criteria for an observed release by chemical 

analysis to one or more aquifers underlying the sources at the site, regardless of the aquifer being 

evaluated, assign a mobility factor value of 1 (Ref. 1, Section 3.2.1.2). 

The observed release substance, TCE, is assigned a Toxicity 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 and 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 Constituent Quantity is not adequately determined for 

one or more sources, and if any target for the ground 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 × 108

 [1, pp. 51592 (Section 2.4.3.1), 51602 

(Section 3.2.3)]. 1,000 × 10,000 = 1 × 107

. 

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 × 107 

From HRS Table 2-7, the Waste Characteristics Product (1 × 107

) 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 equal 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, TCE 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 concentration (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 was detected at a concentration above the healthbased 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 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 was 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 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]. 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 containing 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 samples, 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 ]. Information 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 already 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, which have been identified within a 4-mile radius of 

the Leeds Metal property; subsurface investigations to date have not identified any continuous aquitards 

in the vicinity of the Leeds Metal property; and the fine-to-coarse sand overburden deposits and 

moderately permeable fracture metamorphic bedrock do not demonstrate any significantly lower 

hydraulic conductivity layers that separate aquifers throughout 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 hydraulically 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 evaluated that is used for scoring the site [1, p. 51595 

(Section 3.0.1.2.1)]. For the purposes of this evaluation, 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 private and public ground water supplies presented in the SI report 

(Reference 11) [11, pp. 112-115; 180]. To estimate the population served by private ground water 

supplies, a comparison was made between the 1990 and 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 data (population relying on private drinking water supply 

wells) to estimate the number of persons relying upon 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 miles of the site. These discussions with local personnel 

were used to validate the drinking water supply 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 score. This HRS Documentation Record reports the 

method resulting in the minimal Potential Population Targets for determining the Potential Contamination 

Factor Value. Furthermore, the listing decision remains the same using the Method 1 data utilized at 

proposal or using the newer 2010 census data, reflecting 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 calculate 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 supply wells within each radial ring, represented the 

same proportional increase as the total population from 1990 to 2000 [11, pp. 112-115; 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 information 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 personnel 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 population 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 officials, 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, along 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 Level 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 population value calculation due to triple counting of 

one public ground water supply (Monmouth Water Association) system’s population (the actual value 

for this ring is 1,835 people). However due to the range in the HRS Population Served By Wells Within 

Distance Categories, no change occurs in the Distance-Weighted Population Value [11, pp. 112-115; 180] 

This HRS Documentation Record reports the method 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 Method 1 data utilized at proposal or using the newer 

2010 census data, reflecting current site conditions; conversely the new data 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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Ground Water Migration Pathway 

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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 Level 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 population value calculation due to triple counting of 

one public ground water supply (Monmouth Water Association) system’s population (the actual value 

for this ring is 1,835 people), however due to the range 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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