Central Maine Power (207) 626-9620

Engineering Department, N.A.O.A. FAX (207) 626-9633

Edison Drive, Augusta. Maine 04336

August 4, 1995

VIA EXPRESS MAIL

 SDMS Docl° 282535

Supcrfund Records Center

SITt: Q

Mr. Ross L. Gilleland, RPM

 B h L A K:

U.S. Environmental Protection Agency O IIiLK :

Maine and Vermont Superfund Section

90 Canal Street

J.F.K. Federal Building (HPS-CAN1)

Boston, Massachusetts 02114

RE: O'CONNOR COMPANY SUPERFUND SITE

AUGUSTA, MAINE

SUPPORT FOR SELECTION OF THE CONTINGENCY CLEANUP PLAN

SUPPLEMENTAL INFORMATION

Dear Mr. Gilleland:

Central Maine Power Company (CMP) is providing, herein, additional information to

support changing the Source Control portion of the Remedial Action for the O'Connor

Company Superfund Site (Site) from solvent extraction to the Contingency Cleanup Plan.

This submittal is in direct response to the U.S. Environmental Protection Agency's (EPA)

June 16, 1995 letter to CMP which requested specific information regarding CMP's

intentions to evaluate other treatment technologies and the Contingency Cleanup Plan

established in the 1994 Explanation of Significant Differences (ESD).

The ESD signed on July 11,1994 "allows for off-site disposal in accordance with federal and

state laws should EPA, after consultation with the DEP, determine that full-scale

implementation of solvent extraction is not feasible at this site." The ESD further states that

"soils will not have to be treated prior to off-site disposal should the EPA make the

determination that treatment is not feasible."

CMP believes that sufficient data, analyses, and Site-specific design and experience now exist

to support a determination that solvent extraction is not feasible at the Site. CMP further

holds that the Contingency Cleanup Plan described in the ESD satisfies the criteria

established under Comprehensive Environmental Response Compensation and Liability Act

(CERCLA) for selection of remedy. Specifically, CMP believes that the Contingency

Cleanup Plan satisfies CERCLA's requirement that EPA select a Remedial Action "that

utilizes permanent solutions and alternative treatment technologies or resource recovery

technologies to the maximum extent practicable." (CERCLA §121 (b)(l), (emphasis added).
R. L. Gilleland, RPM

Page 2

August 4, 1995

Information is presented in the attached report to assist EPA in evaluating the infeasibility

of implementing the solvent extraction remedy at the Site; in addition, CMP wishes to

demonstrate how the Contingency Cleanup Plan meets the requirements of CERCLA and

the National Contingency Plan (NCP). Finally, information is presented which indicates that

alternative treatment technologies to solvent extraction will Likely not offer a substantially

better opportunity for a treatment-based Source Control remedy.

CMP proposes submittal of a revised Remedial Design Work Plan within 60 days of your

written acceptance of the Contingency Cleanup Plan. The Remedial Design Work Plan

would specify the general scope of effort, deliverables, and schedule associated with

implementing the Contingency Cleanup Plan.

CMP appreciates your consideration of this submittal. Please call if you have any questions.

Sincerely,

CENTRAL MAINE POWER COMPANY

Terence R. Peacock, P.E.

Project Coordinator

TRPrlhr

Attachment

cc: L. M. Brausch, Westinghouse

L. W. Brown, DEP

J. A. Klaiber, GEI

W. H. Laubenstein, IH, Esquire

M. Pothier, CDM Federal Programs