## U.S. ENVIRONMENTAL PROTECTION AGENCY EPA NEW ENGLAND

RECORD OF DECISION AMENDEMNT EASTLAND WOOLEN MILL OPERABLE UNIT I

SEPTEMBER 2006

## Record of Decision Amendment Table of Contents

PART 1: THE DECLARATION
A. SITE NAME AND LOCATION
B. STATEMENT OF BASIS AND PURPOSE
C. ASSESSMENT OF SITE
D. DESCRIPTION OF SELECTED REMEDY
E. STATUTORY DETERMINATIONS
F. SPECIAL FINDINGS
G. ROD DATA CERTIFICATION CHECKLIST
H. AUTHORIZING SIGNATURES PART 2: THE DECISION SUMMARY
A. SITE NAME, LOCATION AND BRIEF DESCRIPTION
B. SITE HISTORY AND EN FORCEMENT ACTIVITIES
1. History of Site Activities
2. History of Federal and St ate Investigations and Rem oval and Remedial Actions
3. History of CERCLA Enforcement Activities
C. COMMUNITY PARTICIPATION
D. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
E. SITE CHARACTERISTICS
F. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES
G. SUMMARY OF SITE RISKS
1. Human Health Risk Assessment
2. Ecological Risk Assessment
3. Basis for Response Action

Record of Decision Amendment - Operable Unit I 

## 2 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Table of Contents

H. REMEDIATION OBJECTIVES
I. DEVELOPMENT AND SCREENING OF ALTERNATIVES
J. DESCRIPTION OF ALTERNATIVES
K. SUMMARY OF THE COMPARATIV E ANALYSIS OF ALTERNATIVES
L. THE SELECTED REMEDY
M. STATUTORY DETERMINATIONS
N. DOCUMENTATION OF NO SIGNIFICANT CHANGES
O. STATE ROLE

APPENDICES Appendix A: Tables and Figures not included in the text of the ROD Appendix B: State of Maine DEP Letter of Concurrence Appendix C: Responsiveness Summary Appendix D: Administrative Record Index

Record of Decision Amendment - Operable Unit I Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 1 – The Declaration DECLARATION FOR THE RECORD OF DECISION AMENDMENT A. SITE NAME AND LOCATION Eastland Woolen Mill Superfund Site Corinna, Penobscot County, Maine MED980915474 Site ID No: 0101043 EPA Lead Operable Unit I
B. STATEMENT OF BASIS AND PURPOSE This decision document presents an am endment to the September 19, 2002 Record of Decision (ROD) that identified the selected reme dial action for Operable Unit I (OU I) at the Eastland Woolen Mill Superfund Site in Corinna , Maine (the Site), which was chosen in accordance with the Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended (CERCL A), 42 USC § 9601 et seq ., and, to the exte nt practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300, as amended. The Director of the Office of Site Re mediation and Restorati on (OSRR) of the United States Environmental Protection Agency (EPA), Region 1 has been delegated the authority to approve this Record of Deci sion Amendment (ROD Amendment). This decision is based on the Administra tive Record, which has been developed in accordance with Section 113(k) of CERCLA, and wh ich is available for review at the Stewart Public Library, Corinna, Maine and at the EPA Region 1, OSRR Records Center at One Congress Street, Boston, Massachusetts during normal busines s hours. The Administrative Record Index (Appendix D to the ROD) iden tifies each of the items comprising the Administrative Record upon which the selection of the remedial ac tion is based. In accordance with 40 C.F.R. §300.825(a)(2), this ROD Amendmen t will become part of the Administrative Record file. The State of Maine concurs with the selected remedy. C. ASSESSMENT OF THE SITE The response action selected in this ROD Amendment is nece ssary to protect the public health or welfare or the environment from actual or threatened releases of hazardous substances into the environment.
D. DESCRIPTION OF THE SELECTED REMEDY This ROD Amendment changes the original remedy set forth in the ROD for OU I (2002 OU I ROD) for the Site. Both the origin al 2002 remedy and amended remedy target the restoration of contaminated groundwater through treatment usi ng the application of in-situ reagents. The amended remedy, however, elimin ates the long-term groundwater extraction and Record of Decision Amendment - Operable Unit I 

## 1 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 1 - The Declaration treatment system and the enhanced flushing with surfactants or solven ts components of the original remedy. Specifically, the OU I amended remedial action w ill include the following major components:

• In-situ chemical oxidation of the source materi al in the deep overburden soil and the shallow and deep bedrock;

• Application of biostimulan ts after the in-situ ch emical oxidation program ;

• Connection of residences to the public water supply;

• Implementation of instituti onal controls to restrict future groundwater use;

• Long-term monitoring of site groundwater; and

• Five-Year Reviews to ensure that the remedy remains protective of human health and the environment. The selected remedy addresses principal and low-level threat wastes at the Site by reducing the mass of contamination, including Dense Non-Aqueous Phase Liquid (DNAPL), in the soil and bedrock fractures to achieve groundwater restoration.
E. STATUTORY DETERMINATIONS The selected remedy is protective of human health and the environment, complies with federal and state requirements that are applicable or relevant a nd appropriate to the remedial action (unless justified by a waiver), is cost -effective, and utilizes permanent solutions and alternative treatment (or resource recovery) t echnologies to the maximum extent practicable. The remedy also satisfies the statutory prefer ence for treatment as a principal element of the remedy by reducing the toxicity, mobility, and volume of source materials comprising principal threats through in-sit u chemical oxidation treatment. Because this remedy will result in hazardous substances remaining on-site above levels that allow for unlimited use and unrestricted ex posure (and groundwater use restrictions are necessary), a review will be conducted within fi ve years after initiation of remedial action to ensure that the remedy continues to provide adequate protection of human health and the environment.
F. SPECIAL FINDINGS
None.

Record of Decision Amendment - Operable Unit I 

## 2 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Recor d o f Decisio n Amendmen t 

## Par t 1 - Th e Declaratio n G

. RO D DAT A CERTIFICATIO N CHECKLIS T Th e followin g informatio n i s include d i n th e Decisio n Summar y sectio n o f thi s RO D Amendmen t

o r i s reference d t o th e 200 2 O U I RO D whe n th e languag e fro m th e origina l 200 2 O U I RO D di d no t

requir e revision

. Additiona l informatio n ca n b e foun d i n th e Administrativ e Recor d fil e fo r

thi s Site

. 1

. Chemical s o f

concer n (COCs ) an d thei r

respectiv e concentrations

. 2

. Baselin e ris k

represente d b y th e COCs

. 3

. Cleanu p level s establishe d fo r COC s an d th e basi s fo r

th e levels

. 4

. Ho w sourc e material s constitutin g principa l threat s ar e addressed

. 5

. Curren t

an d reasonabl y anticipate d futur e lan d assumption s an d curren t an d potentia l futur e beneficia l use s o f groundwate r

use d i n th e baselin e ris k assessmen t

an d RO D Amendment

. 6

. Potentia l lan d an d groundwate r us e tha t wil l b e availabl e a t

th e Sit e a s a resul t

o f th e selecte d remedy

. 7

. Estimate d capital , operatio n an d maintenanc e (O&M) , an d tota l presen t wort h costs ; discoun t

rate ; an d th e numbe r

o f year s ove r

whic h th e remed y cos t estimate s ar e projected

. 8. Key factor(s ) tha t

led to selectin g the remedy , includin g a descriptio n of how the selecte d remed y provide s th e bes t balanc e o f

tradeoff s wit h respec t

t o th e balancin g an d modifyin g criteri a an d highlightin g criteri a ke y t o th e decision

. H

. AUTHORIZIN G SIGNATURE S Thi s RO D Amendmen t

document s th e selecte d remed y fo r O U I a t th e Eastlan d Woole n Mil l Superfun d Site

. Th e Stat e o f Main e Departmen t

o f Environmenta l Protectio n (M E DEP ) concur s wit h th e selecte d remedy. Concu r an d recommen d fo r

immediat e implementation : U.S

. Environmenta l Protectio n Agenc y 

# By : &LQCU I 5\vd\\0 \ Date : Susa n Studlien , Directo r Offic e o f Sit e Remediatio n an d Restoratio n EP A Ne w Englan d

Recor d o f Decisio n Amendmen t - Operabl e Uni t I 3 Version : Fina l Eastlan d Woole n Mil l Superfun d Sit e Date : Septembe r 28 , 200 6 Corinna , Main e

## Record of Decision Part 2 – The Decision Summary RECORD OF DECISION AMENDMENT SUMMARY A. SITE NAME, LOCATION AND BRIEF DESCRIPTION Eastland Woolen Mill Superfund Site Corinna, Penobscot County, Maine MED980915474 Site ID No: 0101043 EPA Lead Operable Unit I The Eastland Woolen Mill Superfund Site is located in the Town of Corinna, Penobscot County, Maine, approximately 6 miles north of Newport and 25 miles northwest of Bangor, Maine (Figure 1). Approximately 800 people live within one mile of the Site and 2,500 live within four miles. The Town of Corinna is located within th e East Branch of the Sebasticook River (EBSR) watershed, which drains to Sebast icook Lake approximately three miles south of the Town. Topography within the watershed is typi fied by gently rolling hills to steeply sloping ridges, varying from narrow valleys to fairly e xpansive low-lying floodplains. Elevations within the immediate vicinity of Corinna range from 200 to 320 feet above mean sea level (msl). The former Eastland Woolen Mill straddled the EBSR and the southern portion of the former Mill Pond. The future land use assumptions for the 25 acre Site and surroundi ng areas are based on the Reuse Plan that was developed by the Town of Corinna. The large la nd area in the center of town, currently occupied by the Site, has been ta rgeted for a mix of commercial, residential and mixed-use development. An expansion of the water supply has been implemented by the local water district to support future gr owth. The majority of the Site is available for re-use since the current cleanup program only occupi es about three of the 25 acr es covered by the Site. The available 22 acres are currently be ing marketed by the Town of Corinna. The back portion of the Site has already been brought into productive re -use. A 20 unit senior housing facility, Corundel Commons, opened on this portion of th e Site in February 2006. A more complete description of the Site can be found in Section 1 of the Focused Feasibility Study (FFS) Re port released in May 2006.
B. RATIONALE FOR ROD AMENDMENT On September 19, 2002 EPA, with the concurre nce of the ME DEP, in accordance with the Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended (CERCLA), 42 USC § 9601 et seq ., issued the ROD for OU I at the Eastland Woolen Mill Site. The 2002 OU I ROD included in-situ chemical oxidation (ISCO) and groundwater extraction and treatment as the appr oach to achieve restor ation of the contaminated aquifer. The 2002 OU I ROD also included the potential for the us e of enhanced flushing solvents/surfactants) in addition to the ISCO program. A long-term groundwater extraction and treatment system was included in the 2002 OU I ROD to limit migratio n of the contaminated groundwater, prevent contaminated groundwater from having an adve rse impact on the benthic community in the EBSR, and facilitate the restorat ion of the aquifer after the co mpletion of the ISCO program. Record of Decision Amendment - Operable Unit I 

## 1 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary The 2002 OU I ROD was written prio r to the completion of the non- time-critical removal action (NTCRA) that commenced in 1999. Therefore, the impact of the NTCRA-related excavation and treatment of the contaminated overburden source areas was uncertain at the time of the ROD. Subsequent to the signing of the 2002 OU I ROD and the completion of the NTCRA excavation and treatment program, EPA performe d assessment monitoring of the groundwater. EPA also developed an improved conceptual site model through a dditional hydro-geologic investigations and groundwater modeling. The primary results of th e investigations and monitoring from 2002 – 2005 are presented below:

• The groundwater plume was found to be receding as a result of the NTCRA cleanup activities and the connec tion of certain water supply wells to the Corinna Water District water line. This eliminated the major pumping stresses that were influencing the expansion of the groundwater contamination. Sin ce the groundwater was no longer expanding, containment of the groundwater to prevent expansion was no longer necessary. The institutional controls that ar e being developed as part of the OU I Remedial Action will prevent the re-use of the water supply wells that could cause th e area of groundwater contamination to expand.

• Monitoring of the groundwater and surface wate r indicates that the EBSR is not being impacted by the groundwater contamination; ther efore the benthic commun ity in the EBSR is no longer threatened by the Si te contamination. An assumption of the 2002 OU I ROD was that the EBSR may be impacted by the discharg e of contaminated overb urden groundwater. Prior to the NTCRA, contaminat ed groundwater contributed to severe ecological impacts in the EBSR. The EBSR was relocated as part of the NTCRA and the combined benefit of the relocation of the EBSR and elimination of the majority of the source contamination was not known at the time of the 2002 OU I ROD. To as sess the potential for impacts to the EBSR after completion of the soil excavation and ex-situ treatment phase of the NTCRA, groundwater samples were collected from a series of piezometers instal led within the EBSR channel. One sample collected from a piezo meter located adjacent to Area 1 contained chlorinated benzene compounds at concentratio ns less than the fede ral and state drinking water standards. In addition, samples collected from piezometers installe d within the base of the river did not contain dete ctable concentrations of chlorinated benzene compounds.

• Groundwater modeling based on the most updated Site information revealed that the time frame to achieve aquifer rest oration without a groundwater ex traction and treatment system was only slightly longer than the time frame with the groundwater ex traction and treatment system. The time frame to achieve aquifer restoration has two components. The first component is the removal of the principal threat source material through the ISCO and biological enhancements. This first component is identical in both the original 2002 OU I ROD remedy, identified as GW-4 in the FFS, and the amended OU I remedy, identified as GW-4a in the FFS. The second component of th e restoration is the a quifer recovery through long-term natural attenuation processes, ei ther facilitated by gr oundwater extraction, as included in Alternative GW-4, or through non-activ e processes, as included in Alternative GW-4a. The time frame for the source remova l under both Alternative GW-4 and GW-4a is estimated at 15 years. Subsequent to the 15 year period required for source removal, an
Record of Decision Amendment - Operable Unit I 

## 2 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Part 2 – The Decision Summary additional 15 to 60 years is estimated to be n ecessary to achieve full aquifer restoration for Alternative GW-4 with the us e of long-term groundwater extr action and treatment. This results in an estimated range for the cleanup of 30 to 75 years, with 60 years being selected in the FFS as a reasonable estimate for the basis of alternative comparison and cost evaluation. For Alternative GW-4a, without the use of long-term groundwa ter extraction and treatment, the estimated time period to achieve aquifer re storation is 30 to 74 years, resulting in a cleanup range of 45 to 89 years and with 80 year s being selected as a reasonable estimate for the basis of alternative comparison and cost evaluation.

• The 20 year time difference between GW-4 and GW-4a is not considered significant for the following reasons:

o The groundwater plume that will remain after the NTCRA and ISCO programs is located under roadways and greenspace w ithin an area where groundwater use is prohibited and a water line is available. There is therefore minimal potential for human consumption of the groundwater during the additional 20 years. o The time frame estimates were developed using the information available and are considered reasonable for al ternative comparison; however, there is substantial uncertainty associated with these estimate s. The actual difference in time frame for aquifer restoration could therefore be much smaller than estimated.

• The pilot testing and initial a pplications of the oxi dizing reagent, persulfate, supports the conclusion that this technology would be appropriate for use in the deep bedrock. Therefore, EPA does not expect to use the enhanced flus hing with surfactants or co-solvents as a cleanup technology for OU I. Based on the above information, EPA decide d to amend the 2002 OU I ROD to eliminate the groundwater extraction and treatment system as well as the enhanced flushing component with surfactants or co-solvent s in order to achieve the reme dial action objectives and cleanup goals in a more cost effective manner. An upda ted cost estimate for original OU I remedy, GW4, and a cost estimate for the amended remedy, GW-4a, was developed as part of the FFS. Alternative GW-4 has an estimated present worth of $10.5 million as compared with the estimated present worth of GW-4a of $4.5 million. Fu rther, the projected total cost (not adjusted for present value) for GW-4 is $20.8 million as compared with $6.5 million for GW-4a. Therefore, GW-4a with a $6 million lower presen t value and $14.3 million lower total cost is the most cost effective alternative, given that GW-4 a provides a similar level of protection of human health and the environmental and compliance with ARARs. The amended OU I Remedial Action will achie ve the original OU I remedial action objectives and cleanup goals and will be e qually protective of human health and the environment. In addition, the elimination of the long-term groundwater extraction and treatment system substantially reduces the financial burden to the State of Maine and provides additional area for re-use at the Site.

Record of Decision Amendment - Operable Unit I 

## 3 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary Table 1 listed a comparison of the or iginal 2002 OU IROD components and the ROD amendment. Table 1 2002 OU I ROD ROD Amendment Extraction and treatment of th e contaminated overburden Long-term extraction and treatment is not included in the and bedrock groundwater. The extraction system will be amended Remedial Action. designed to prevent off-site migration of contaminated groundwater and restore the aquifer to federal and state MCLs, federal non-zero MCLGs and more stringent state MEGs. In-situ treatment of the c ontaminated overburden and In-situ treatment of the c ontaminated overburden and bedrock groundwater and remaining areas of bedrock groundwater and remaining areas of contaminated soil/DNAPL. A chemical reagent (e.g., contaminated soil/DNAPL. A chemical reagent (e.g., Fenton = s Reagent or another oxidizing agent) will be Fenton = s Reagent or another oxidizing agent) will be added to the overburden and bedrock aquifer to reduce added to the overburden and bedrock aquifer to reduce the mass of contaminants in the system. If the mass the mass of contaminants in the system. If the mass reduction is not sufficient to achieve cleanup levels, then reduction is not sufficient to achieve cleanup levels, then enhanced flushing (using surfactants/solvents) and biological degradation (using bio-stimulants) will be biological degradation (using bio-stimulants) will be attempted to further reduce the mass of contamination. attempted to further reduce the mass of contamination. Enhanced flushing with surfactants/solvents is not included in the amended Remedial Action. Connection of certain residences to the water supply Connection of certain residences to the water supply lines to prevent their wells from becoming contaminated lines to prevent their wells from becoming contaminated and to prevent expansion of the contamination in the and to prevent expansion of the contamination in the groundwater. groundwater. Implementation, monitoring and maintenance of Implementation, monitoring and maintenance of institutional controls (i.e., deed restrictions) in the form institutional controls (i.e., deed restrictions) in the form of groundwater use restric tions (e.g., easements or of groundwater use restric tions (e.g., easements or restrictive covenants) to prevent ingestion of restrictive covenants) to prevent ingestion of groundwater and disturbance of the groundwater groundwater and disturbance of the remedy. extraction and treatment system. Long-term monitoring of gr oundwater, surface water and Long-term monitoring of gr oundwater, surface water and sediments to evaluate the success of the remedial action. sediments to evaluate the success of the remedial action. Implementation of five-year reviews to assess the Implementation of five-year reviews to assess the protectiveness of the remedy until cleanup goals have protectiveness of the remedy until cleanup goals have been met. been met. 

## This ROD Amendment and the documents that form the basis for the Amendment are available at the following information repositories:
EPA Records Center One Congress Street, Suite 1100 Boston, MA 02114-2023 (617) 918-1459 Hours: 10 a.m. to noon and 2 p.m. to 5 p.m. Stewart Public Library 8 Levi Stewart Drive Corinna, ME 04928

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## 4 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## OU I Record of Decision Amendment Part 2: The Decision Summary
C. SITE HISTO RY AND ENFORCEMENT ACTIVITIES 1. History of Site Activities The Eastland Woolen Mill operated a textile mill in Corinna, Maine from about 1909 to 1996. Liquid wastes were discharged directly into the EBSR until 1972, when the liquid wastes were sent to the local sewage treatment plant. In 1983, local water supplies were found to be contaminated with chlorinated benzene compounds released by the Eastland Woolen Mill. As a result of this contamination, five locations were fitted with carbon filters in 1983. This number increased to ten locations by 1988. In 1995, a water li ne was installed to serve the properties with contaminated water supplies. From 1984 to 1995, th e Eastland Woolen Mill performed a series of environmental assessments. The Eastland Woolen Mill ceased to operate in 1996. All of the equipment and land were either sold at a creditor auction or taken by th e Town of Corinna to address tax liability. Please refer to the 2002 OU I ROD and the associated OU I remedial investigation and feasibility study (R I/FS) for a more detailed history of Site activitie s prior to the 2002 OU I ROD. A detailed description of the Site operating history can al so be found in Section 1 of the OU I RI Report and S ection 1.3 of the FFS Report. 2. History of Federal and State Invest igations and Removal and Remedial Actions After the closure of the Eastland Woolen Mi ll, the State of Maine performed a response action in 1997 to remove hazardous materials from the former mill buildings. The State of Maine also provided technical and financial support to ma intain the Corinna Water District after closure of the mill. In 1998, EPA began investigation activ ities at the Eastland W oolen Mill. In July 1999, EPA placed the Eastland Woolen Mill site on the National Priorities List and signed an Action Memorandum to begin a Non-Time-Critical Removal Action (NTCRA) to address the primary source of the contamination in groundwater, surface water, and sediment. From 1999 to 2002, EPA performed the RI/FS for the Eastland Woolen Mill. In September 2002, EPA signed a ROD for OU I of the Eastland Woolen Mill Su perfund Site to address contaminant source material remaining after the NTCRA, as well as the associated groundwat er contamination. The OU I RI/FS also identified and designated sedime nt and associated floodplain areas of the EBSR as well as the old dump as a second operable uni t (OU II) for the Site. Please refer to the 2002 OU I ROD and the associated OU I RI/FS for more detail regarding the history of federal and state Investigations and Removal and Remedial Actions prior to the 2002 OU I ROD. Subsequent investigations and response actions are described in Section 1 of the FFS. A brief summary of the federal and state response actions since the OU I ROD was issued is presented below. During the period from September 2002 through September 2006 there were three major categories of activity at the Site. These are:

• Completion of the Operable Unit II ( OU II) RI/FS and the associated ROD;
• Completion of the NTCRA; and

Record of Decision Amendment - Operable Unit I 

## 5 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary

• Completion of the pre-design and design activities for the OU I Remedial Action, initiation of the Remedial Action, and c onstruction completion of the Remedial Action. Each of these activities will be summarized be low. See Figure 2 for the general location of the NTCRA, OU I, and OU II areas of the Site. (a) Operable Unit II Remedial Investigation/Feasibility Study and Operable Unit II Record of Decision In September 2002, EPA created OU II to addres s the sediment and associated floodplain areas of the EBSR downstream of NTCRA excava tion, as well as an area of solid and liquid waste disposal known as the old dump. The OU I RI included the entire Site (both the OU I and OU II area) in the Human Health Risk Assessment. The Human Health Risk Assessment for OU I/OU II did not identify any unacceptabl e threats to human health from current or future use of the OU II areas. The current and future use assumpti ons in the Human Health Risk Assessment were based on non-residential recreati onal activities (swimming, hunti ng, fishing). The OU I RI did identify the potential for impacts to ecologi cal receptors in the OU II area. During 2002 and 2003, EPA performed a series of stud ies to better define the potenti al for ecological impacts in the OU II area. Surface water, sediment, floodplain soil, and crayfish tissue samples were collected, and biological assessments of the benthic macro-invertebrate community were performed. The information from these studies was presented in a Supplemental RI Report. The information was also combined with the initial RI data to prep are a revised Baseline Ecological Risk Assessment Report that found there was no unacceptable risk to ecological receptors in the OU II area. Both reports were released in 2004 as part of the Admi nistrative Record and were available for review during the public comment period for the OU II Proposed Plan. On September 30, 2004, EPA signed a ROD selecting No Furt her Action for OU II of the Site. EPA activities in the OU II Study Area are complete, and no furt her activities ar e anticipated. (b) Non-Time Critical Remedial Action In July 1999, EPA signed an Action Memorandu m to initiate the NTCRA at the Site. Beginning in 1999, EPA retained the United Stat es Army Corps of Engineers (USACE) to implement the NTCRA. The USACE retained We ston Solutions, Inc. (Weston) as the prime contractor to perform the NTCR A cleanup activities. The NTCRA has included the removal of the mill buildings (performed during the winter of 1999-2000) and contaminated soils from four areas (performed from 2000-2001). NTCRA work areas are descri bed below and shown in Figure 2:

• Area 1: Region underlying former Eastland Wool en Mill Buildings 1, 1A, and 3 extending across the former location of Main Street (Rout e 7), and including the segment of the EBSR beneath the former Eastland Woolen Mill and ex tending across the former Main Street. The contaminated soil in this area was removed in 2001.

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## OU I Record of Decision Amendment Part 2: The Decision Summary

• Area 2: Segment of ESBR down river from the former Eastland Woolen Mill to the abandoned railroad trestle. The contaminated soil and sediment in this area was removed in 2000.
• Area 2a: Segment of EBSR under the abandoned ra ilroad trestle between Area 2 and Area 3. The contaminated soil and sediment in this area was removed in 2000.
• Area 3: Segment of EBSR for a distance of seve ral hundred feet beyond the railroad trestle. The contaminated soil and sediment in this area was removed in 2000.
• Area 4: Lot 88, Building 9, UST Area, Building 14 Area, and other miscellaneous areas. The initial contaminated soil removal for these areas occurred in 2000 and 2001. Additional contaminated soil removal for the Building 14 Area was performed in 2005. During 2000 and 2001 approximately 75,000 yd 3 

## of chlorinated-benzene contaminated soils were excavated and stockpiled at the Site in lined containment structures. In 2001, pilot testing of an on- site thermal soil treatment system was performed. The results of this pilot test indicated that the treatment system could meet the treatment goals established for the NTCRA. Full-scale treatment of contaminated soil using an on-site ex-situ low temperature thermal system began in Oc tober 2002 and was completed in October 2003. Quality control testing of the soil after treatment documented that all of the soil that was used for on-site backfill contained residua l levels of contamination below residential cleanup standards and met the NTCRA groundwater leaching criteria that were developed during the NTCRA. Table 2 contains a summary of the data collec ted as part of the ex-situ treatment program. Table 2 NTCRA Soil Cleanup Summary Summary Statistics for Soil Excavated and Subject to Treatment Contaminant 95% Upper Confidence Level Concentration of soil prior to treatment (ug/kg) – based on 100 soil samples 95% Upper Confidence Level Concentration of soil used as backfill after treatment (ug/kg) based on 4,200 soil samples Soil concentration that allows for residential use - direct contact with of soil (ug/kg) Soil concentration that was determined to be protective of groundwater (ug/kg) (dependent upon soil organic carbon content) 1,2,4 Trichlorobenzene 

## 92,070 4,451 540,000 3,900 – 8,000 1,2,3 Trichlorobenzene 

## 25,955 1,408 1,2 Dichlorobenzene 

## 17,091 610 370,000 4,700 – 4,900 1,3 Dichlorobenzene 

## 1,427 285 16,000 4,300 – 4,800 1,4 Dichlorobenzene 

## 12,279 563 3,400 3,400 – 3,800 Chlorobenzene 

## 3,938 169 150,000 3,300 – 3,600 To support the NTCRA excavation and ther mal treatment activities, a temporary groundwater extraction and treatmen t system was constructed to ai d in control of groundwater infiltration during excavation activities. One bedrock well and four overburden wells were connected to the temporary groundw ater extraction and treatment sy stem. The system remained

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## 7 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary operational until November 2004 to provide hydraul ic control over the groundwater plume during the initial phase of the NTCRA . Since 2004, the temporary groundw ater extraction and treatment system has been operated as necessary to support the NTCRA in-situ oxidation program. Details concerning the NTCRA excavation and thermal treatment program are presented in the Final Completion Report, Areas 2, 3, 4-Lot 88, and 4-Building 4 Soil Remediation NTCRA , Eastland Woolen Mill Superfund Site, Corinna, Maine, Weston Solutions, Final Completion Report Areas 2,3,4-Lot 88 and 4-Building 4 Soil Re mediation Non-time Critical Removal Action , Eastland Woolen Mill Superfund Site, Corinna , Maine, June 2001; Weston Solutions, Final Completion Report Areas 1 and 4 Soil Remediation Non-time Critical Removal Action , Eastland Woolen Mill Superfund Site, Corinna, Maine, June 2001. NTCRA In-Situ Treatment Program Three areas of contaminated soil were not accessible to the NTCRA excavations. One area was located within Area 1 and the other tw o were within the Area 4 UST Area and Building 14 Area. These areas are shown in Figure 3. Thes e remaining soils are located in the saturated zone between depths of 6 to 40 ft below ground surface (bgs). The final phase of the NTCRA targeted the reduction of contamination in thes e source areas using in-s itu chemical oxidation (ISCO). EPA also retained the USACE to impl ement this component of the NTCRA. USACE retained Nobis Engineering, Inc. as the lead co ntractor for the remaining NTCRA activities. An ISCO Pilot Study was performed to identif y the optimal oxidant technology for use in the NTCRA ISCO program. In the Spring and Summe r of 2004, Nobis installed 23 ISCO injector wells in Area 1 to depths ranging from 35 to 40 ftbgs. Following injector installations, a fieldscale pilot study was performed by a subcontract or to Nobis, Xpert Design and Diagnostics (XDD), and Nobis in November 2004. The pilot st udy was designed to evaluate effectiveness of two potential oxidant technologies, Fenton’s reagent and iron-catalyzed sodium persulfate (ICP). The Fenton’s Study Area consisted of injecting 10,000 gallons of sulfuric acid and 11,534 gallons of hydrogen peroxide into two injection wells. Th e Persulfate Study Area consisted of injecting 5,580 gallons of persulfate and chelated Fe+2 catalyst into two injection wells. The results of this pilot study indicated that ICP achieved supe rior subsurface distribution relative to Fenton’s reagent due to its longer reaction half-life. Based on post-pilot study soil sampling, a 48% total mass reduction was estimated over the pilot study area. Based on these results, ICP was selected as the oxidant for fu ll-scale treatment applicat ion for the NTCRA ISCO program. The NTCRA ISCO Pilot Study was also incorporated in the Remedial Design for the OU I ISCO program that was occurring simultaneous ly with the final phase of the NTCRA, and resulted in the selection of ICP as the oxida nt technology for the OU I Remedial Action ISCO programs. The NTCRA ISCO Program consisted of two work areas: Phase I, which included the contaminated soil associated with the former UST Area and Building 14 Area; and Phase II, which included the contaminated soil associated with Area 1. These work areas are shown in Figure 3. Record of Decision Amendment - Operable Unit I 

## 8 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## OU I Record of Decision Amendment Part 2: The Decision Summary
Phase I Activities Following demolition of Building 14 by the Town of Corinna in 2004, a limited excavation was undertaken by Weston adjacent to the former loading dock to remove a small quantity of contaminated soil that was present in the vadose zone adjacent to the loading dock. The excavation did not extend below the water tabl e. Analytical results for confirmation soil samples collected from base of the excavation indi cated contaminated soil remained in-place at depths below the water tabl e (approximately 6 ft bgs). In Spring 2005, Nobis installed 20 injector we lls in the UST Area and the former Building 14 Area to depths ranging from 15 to 30 ft bgs. ISCO treatment consis ted of two full-scale injections of ICP, followed by confirmatory soil borings and groundwater sampling. These injections were performed in July and October/November 20 05. A total of 13,319 gallons of persulfate solution (22,120 lbs of oxidant) and 13,514 gallons of chelat ed iron solution were delivered to the UST Area and Building 14 Area. Confirmatory soil borings and groundwater sampling indicated an approximate 90% reducti on of dissolved phase contamination and an approximate 71% reduction in sorbed phase so il contamination following the Phase I ICP applications. The Phase I Task Plan and the Chemical Oxidation Phase I ISCO Work Plan describe in detail the activities that were pe rformed to complete the NTCRA source reduction in this area. The 2005 Phase I and Phase II ISCO Remedial Performance Assessment documents that the ISCO has been successful in reducing th e mass of contamination in the Phase 1 Area. The NTCRA for the Phase 1 Area is complete. The OU I Remedial Action will include long-term monitoring of the Phase I Ar ea to confirm whether groundwater restoration is achieved. Phase II Activities In August 2005, Nobis and XDD performed one fu ll-scale round of Phase II ISCO treatment for Area 1. ICP was delivered to the subsurface via 11 ISCO injector wells. Approximately 19,256 gallons of persulfate (31,947 lbs of oxidant) and 19,423 gallons of chelated iron solution (2,429 lbs) were delivered to the Phase II treat ment area. Confirmatory groundwater sampling performed following full-scale ISCO applica tion indicated a reduction of dissolved phase contamination by approximately 63%. Soil samp ling performed following the ISCO Pilot study indicated a 38% reduction in residual DNAPL contam ination. The Phase II Task Plan and Phase II Full Scale ISCO Injection Plan - Application #1 describe the activities that were performed to further the completion of NTCRA source reduction in this area. The “2005 Phase I and Phase II ISCO Remedial Performance Assessment Ea stland Woolen Mill Superfund Site, Non-Time Critical Removal Acion, Corinna, Maine, May 2006” documents that the ISCO has been successful in reducing the mass of contamination in the Phase II Area. The Phase II program will continue as part of the OU I Remedial Action. (c) OU I Remedial Desi gn, and Remedial Action The 2002 OU I ROD was issued to address overburden and bedrock groundwater and remaining areas of contaminated soil/DNAPL and restore the aquifer to federal and state MCLs,

Record of Decision Amendment - Operable Unit I 

## 9 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary federal non-zero MCLs and more stringent st ate MEGs. The OU I remedy targeted the restoration of contaminated groundwater thr ough treatment using both extraction and ex-situ treatment and the application of in-situ reagents. Treatment of the groundwater will be accomplished in two ways: (1) groundwater will be extracted from the ground and treated to reduce the concentration of contaminants to leve ls that are protective of human health and the environment and achieve the applicable criteria for discharge into eith er the EBSR or the groundwater; and (2) in-situ reagents will be used to facilitate th e removal of contamination (via in-situ oxidation and in-situ surfactant additi on, in combination with the addition of biostimulants as a polishing step). Institutional cont rols will restrict the futu re use of the Site to prevent ingestion of groundwat er and disruption of the groundw ater extraction and treatment system. This cleanup approach is expected to control the off-s ite migration of contaminated groundwater and restore the aquifer to drinking water standards. OU I also targets the soil contamination re maining after the NTCRA ex-situ and in-situ soil treatment programs. The soil excavation and ex-situ soil treatment program conducted under the NTCRA removed all soil contamination above the water table and most soil contamination, including the DNAPL below the water table, exce pt in a few areas under the former Eastland Woolen Mill complex, the UST Area and Buildi ng 14 Area that were not accessible during the NTCRA. The in-situ ISCO program performed as part of the NTCRA completed the source reduction in the UST Area and Building 14 Area and re duced the source material in Area 1 of the Site. The OU I ISCO program will target the remaining contaminated soils and DNAPL located in Area 1 of the Site that acts as a conti nuing source of groundwater contamination. The OU I program will also include long-term assessment of the Building 14 Area and UST Area to confirm that the NTCRA source reduction was successful. Fi gure 4 shows the area that will be the focus of OU I Remedial Action. Specifically, the 2002 OU I ROD include s the following major components:

$ Extraction and treatment of the contaminated overburden and bedrock groundwater. The extraction system will be designed to prev ent off-site migration of contaminated groundwater, prevent contaminated groundwater from having an adverse impact on the benthic community in the EBSR, and restor e the aquifer to federal and state MCLs, federal non-zero MCLGs and more stringent state MEGs.

$ In-situ treatment of the contaminated over burden and bedrock groundw ater and remaining areas of contaminated soil and DNAPL. A chemical reagent ( e.g. , Fenton = s Reagent or another oxidizing agent) will be added to the overburden and bedrock aquifer to reduce the mass of contaminants in the system. If the mass reduction is not sufficient to achieve cleanup levels, then enhanced flushing (u sing surfactants/solve nts) and biological degradation (using bio-stimulants) will be attempted to further reduce the mass of contamination.

$ Connection of certain residences to the wate r supply lines to prevent their wells from becoming contaminated, and to prevent e xpansion of the cont amination in the groundwater. Record of Decision Amendment - Operable Unit I 

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## OU I Record of Decision Amendment Part 2: The Decision Summary

$ Implementation, monitoring and maintena nce of institutional controls ( i.e. , deed restrictions) in the form of groundwater use restrictions ( e.g. , easements or restrictive covenants) to prevent ingestion of groundw ater and disturbance of the groundwater extraction and treatment system.

$ Long-term monitoring of groundwater, surface water and sediments to evaluate the success of the remedial action.

$ Implementation of five-year reviews to assess the protectiveness of the remedy until cleanup goals have been met. The selected remedy addresses principal and lo w-level threat wastes at the Site by both reducing the mass of contamination, including D NAPL, in the soil and bedrock fractures and containing and treating the contaminated ground water to achieve groundwater restoration. The Remedial Design for the OU I Remedial Action was initiated in 2003 and completed in August 2005. Two components of the OU I Remedial Action were not included in the design: design of a long-term groundwater extraction and treatment system and the enhanced flushing (using surfactants or solvents) of the deep bedroc k aquifer. Remedial Design was implemented in close coordination with the final phase of the NTCRA ISCO program since both programs relied on ISCO to reduce the mass of c ontamination in the overburden so il and bedrock. As such, the NTCRA design support activities an d the Remedial Design support ac tivities are complementary. As referred to in the previous NTCRA desc ription, a series of additional studies and investigations were performed between 2003 and 2005 to develop the design for the NTCRA ISCO program and the in-situ treatment portion of the OU I Remedial Action. The results and conclusions of these investigations are summarized in the FFS and are reported in greater detail in the Conservative Interwell Tracer Test (CITT) Design, Conceptual Model Update Report, and the OU I Remedial Design Report. Th e studies and investigations performed to support the design activities included:

• ISCO Pilot Study: The ISCO Pilot Study performed for the NTCRA ISCO program was incorporated in the Remedial Design for the OU I ISCO program and resulted in the selection of ICP as the oxidant technology for the OU I Remedial Action ISCO programs.

• Bedrock Well Installations : Fifteen bedrock boreholes we re drilled in Area 1. Bedrock fractures were characterized by borehole geophy sics, and water samples were collected by packer methods. Shallow fracture DNAPL dist ribution and rock matrix properties were assessed by methanol extracted rock sample s (MERC). These well locations provide characterization data for the Area 1 bedrock groundwater and contri bute to the overall understanding of the bedrock fracture system and its behavior under pumping conditions.

• Hydraulic Control Pump Test : In September 2004, a multi-we ll pump test was initiated utilizing six pumping wells (EW-2, EW-3, EW-4 , EW-5, EW-6, and EW-7). During the test,

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## Record of Decision Amendment Part 2- The Decision Summary individual well flow rates were gradually increased or decreas ed depending on individual well responses. The pumping test was completed by October 2004, when the CITT/Electrical Resistivity Tomography (ERT ) baseline was initiated.

• Conservative Interwe ll Tracer Test (CITT) : A CITT was designed and performed during October 2004 under forced gradie nt conditions to demonstrate that measurable flow paths exist within the aquifer. Data was used to eval uate dilution factors to ve rify the scale at which adequate minimum oxidant and surfactant conc entrations could be maintained and to demonstrate sufficient aquifer connection at a scale suitable for treatment.

• Partitioning Tracer Test (PITT) : An initial PITT was designed and performed in conjunction with the CITT. This pilot-scale PITT was pe rformed within the DNAPL source zone to assess the volume of DNAPL contacted with in the swept aquifer volume.

• Electrical Resistivity Tomography (ERT)/Induced Polarization (IP) : ERT was completed prior to and in conjunction with the CI TT to identify preferential pathways of saline solutions in the fracture system between individual boreholes. Selected IP profile panels were also completed. The selected IP profiles were co mpleted to provide potential evidence for the presence or absence of DNAPL in weathered bedrock and potenti ally contaminated fractures.

• Assessment Monitoring : Area-wide groundwater and dr inking water sampling was implemented to evaluate and quantify the natu re and extent of the overburden and bedrock contaminant plumes that remained after NTCRA activities. The results from the 2004 areawide sampling event are presented in the 2005 Area-Wide Groundwater Sampling Technical Memorandum . The results from the 2005 area-wide sampling results are presented in the spring 2006 Area-Wide Groundwater Sampling Technical Memorandum

.

• Bedrock wells to assess aquifer characteristics: Off-site bedrock bore hole installations and groundwater pumping tests prov ided refined estimates of aquifer transmissivity and anisotropy at locations east of the EBSR. Results are presented in the Conceptual Model Update Technical Memorandum.

• Groundwater Modeling : Groundwater flow and contamin ant transport numerical model simulations assessed the long-term impacts of the bedrock contaminant plume under various potential future site conditions based on vary ing degrees of contaminant mass reduction. The modeling is described in the Institutional Control Zones Groundwater Modeling Report.

• Long-Term Monitoring: A Long-Term Monitoring Plan (LTMP) was developed for future area-wide sampling to be perfor med for the evaluation of plume migration and impacts.

• Institutional Controls an d Water Line Connections : The results of the area-wide sampling and groundwater modeling were used to identify the properties that should be connected to the public water supply. The results were also used to finalize the extent of the institutional control zones (ICZ).
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## OU I Record of Decision Amendment Part 2: The Decision Summary
The information from the studies described above was used to develop the Remedial Design that was approved in August 2005 and to develop the implementation work plans for the OU I Remedial Action. The OU I Remedial Action was initiated in September 2005 with th e installation of the first of the three water line connections. All of the water line connections have now been completed. The construction phase of the OU I Remedial Action also included the installation of the injection system for the OU I ISCO program as well as the long-term monitoring wells. Restrictive environmental covenants for the use of groundwater at the Site are being developed. All construction ac tivities for the OU I Remedial Action were completed in September 2006 as documented in the Preliminar y Close Out Report for the Eastland Woolen Mill Site. 3. History of CERCLA Enforcement Activities Enforcement activities have been limited by the lack of viable potentially responsible parties (PRPs) at the Site. Ea stland Woolen Mill ceased to oper ate in 1996. The family-owned company is now defunct (it ceased operations shortly after proposing a reorganization plan pursuant to Chapter 7 of the Bankruptcy Code), and most of its offi cers are deceased. The Site is currently owned by numerous enti ties, including the Town of Corinna and the State of Maine. The State acquired its title through eminent domain and abandonment, and the Town of Corinna acquired its ti tle through tax foreclosure and an eminent domain taking. There is currently one private owner of a portion of th e mill complex who acquired title at a creditor’s auction. EPA is continuing to investigate its enfor cement options at the Eastland Woolen Site.
D. COMMUNITY PARTICIPATION This ROD Amendment meets the criteria for community involvement specified in CERCLA Section 117 and in S ections 300.435(c)(2)(ii)(A) th rough (H) of the NCP. Throughout the EPA cleanup of the Site, commun ity concern and involvement have been high. The local Selectboard ac tively sought EPA’s involvement at the Site to address the contamination left behind by the closure of th e mill in 1996. EPA has kept the community and other interested parties informed of Site activit ies through informational meetings, fact sheets, press releases and public meetings. Information about the Site is posted on EPA’s website at http://www.epa.gov/ne/superfund/index2.htm. EPA has met regularly with the community and Selectboard to keep them inform ed and to seek their input re garding Site activities. The community has also benefited from a website (www.cattailpress.com), which was developed and is maintained by a local resident. The website contained daily photograp hs of Site activities during the NTCRA demolition and excavation activ ities and has provided a forum for community

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## Record of Decision Amendment Part 2- The Decision Summary dialogue regarding the Site. EP A’s public notices and fact sheets have been posted on this website as well. Below is a brief chronology of public outre ach efforts subsequent to the 2002 OU I ROD:

• In April 2003, March 2004, and February 2006, EP A released public information updates to keep the public informed of Site activities.
• On April 30, 2003, EPA met with the community to provide an update of the NTCRA, OU I, and OU II activities.
• In support of the cleanup decision for the OU II ROD, EPA implemented the following public involvement activities. Updates regarding the NTCRA and OU I cleanup were provided as part of these efforts: o On June 7, 2004, EPA met with the local organization, Sebasticook Committee for a Clean Environment (SCCE) to present the findings of the Ecological Risk Assessment and Supplemental RI for OU II. The SCCE is a recipient of a Technical Assistance Grant from EPA. EPA presen ted a description of the Suppl emental RI and the results of the revised Baseline Ecological Risk Assessment to the SSCE, its Technical Advisors, and members of the public and news media at the meeting. o On June 30, 2004 EPA held an informational meeting to discuss the results of the RI Report, particularly the Supplemental RI and revised Baseline Ecological Risk Assessment, and to present the Agency = s Proposed Plan to a broader community audience than those that had already been involved at the Site. At this meeting, representatives from EPA answ ered questions from the public. o From July 13, 2004 to August 12, 2004, EPA held a 30 day comment period for the no further action proposal. o On August 10, 2004, EPA held a public hearing to receive oral comments regarding the no further action proposal. o In September 2004, EPA signed the ROD for OU II documenting that no further action was necessary in the OU II area.

• On February 28, 2006, EPA participated in an open house for the Corundel Commons housing development where EPA provided an update of Site activities as part of the poster presentation at the open house.

• In May 2006, EPA published a Proposed Plan to amend the 2002 OU I ROD. The Proposed Plan for the ROD Amendment asked for pub lic comment on the proposal to eliminate groundwater extraction and treatm ent of deep bedrock groundwate r and to eliminate enhanced flushing with surfactants or solvents of the aquifer.

• On May 25, 2006, EPA held a public informati on meeting which was followed by a public hearing to accept comment on the Proposed Plan to amend the 2002 OU I ROD.

• From May 25 to June 25, 2006 EPA held a thir ty day public comment period for the proposal to amend the 2002 OU I ROD.
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## 14 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## OU I Record of Decision Amendment Part 2: The Decision Summary All formal comments are summarized and re sponded to in the Responsiveness Summary, which is included as Appendix C to this ROD Amendment. Pursuant to Section 300.825(c) of the NCP, EPA updated the Administrative Record in May 2006 to add the documents which EPA relied on to form the basis for the decision to amend the response action for 2002 OU I at the East land Woolen site. See Appendix D for the Administrative Record Index.
E. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION There are three cleanup actions at the Eastland Woolen Mill Site. The first cleanup action is the NTCRA that was authorized by an Ac tion Memorandum signed in July 1999. The second is the remedy described in the 2002 OU I ROD and is the subject for this ROD Amendment. The third is the RI/FS and associated No Furthe r Action decision for the OU II Study Area. The location of the areas affected by these actions is shown on Figures 1 and 2. The NTCRA is complete and the OU II ROD terminated EPA in volvement in the OU II Study Area. The OU I ROD targets the groundwater contaminati on and the associated DNAPL and source contamination remaining after the NTCRA in the downtown area of Corinna. The OU I ROD includes treatment of the principl e threat wastes and restoratio n of the overburden and bedrock aquifers. The ROD Amendment only adjusts the 2002 OU I Remedial Action to eliminate a component of the remedy that was determined not to be necessary and does not change the overall scope, role, or expected outcome in that restoration of groundwater will occur within a similar timeframe as the original ROD remedy without the need for long-term extr action and treatment of groundwater. Please refer to the 2002 OU I ROD for more details regarding the scope and role of the OU I Remedial Action.
F. SITE CHARACTERISTICS Chapter 1 of the FS Report contains an overview of the RI Report and the general characteristics of the Site. The significan t findings of the pre-design, design, and NTCRA activities performed after the 2002 OU I ROD are summarized below and are further presented in the FFS. Refer to the 2002 OU I ROD for a summary of the RI/FS for OU I.
1. Soil and Bedrock Source Contamination Overburden materials in Area 1 consist of an thropogenic fill materials (treated and reworked site soil) overlying gl acial till up to 26 feet thick. Underlying the glacial till is weathered bedrock (Waterville formation) which slopes generally to the east, towards the EBSR, and ranges in thickness from less than one foot to approximately ten fe et. Underlying highly weathered bedrock is moderately competent to competent fractured bedrock. In the overburden system, a pocket of residual DNAPL resides in an area just outside the deepest portion of the NTCRA soil excavation (down to and including some of the weathered bedrock surface) adjacent to the relocated Main Street. Significant lateral and vertical variability exists in soil contaminant concentrations due to heterogeneity in the overburden. Within the bedrock system, residual DNAPL resides in weathered bedrock and compet ent rock (upper 100 feet) immediately below

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## 15 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary the DNAPL entry area and the bottom of the NTCRA excavation. Under st atic (non-pumping) groundwater conditions, overburden groundwater flow is to the s outheast where the groundwater discharges to the EBSR. Bedrock groundwater flow is upward to overburden and to the drainage divide created by the EBSR. There are two source areas that are the fo cus of the OU I Remedial Action. Area 1 Deep Overburden Soil The release of chlorinated benzenes at the Eastland Woolen Mill resulted in extensive contamination of saturated overburden soils and bedrock underlying DNAPL source areas. Two zones of DNAPL entry are presumed to exist in Area 1, based on the di stribution of residual DNAPL saturations above bedrock and bedrock sa mple data collected during investigations performed in 2004. The more significant of the tw o areas is present with in deep overburden till located along the southeastern edge of the former NTCRA Area 1 Excavation, and it is presumed to contain both residual and sorbed-contaminati on (contamination either adsorbed or absorbed onto soil particles). The residual- and sorbed-soil contamination in Area 1 soil exists at depths of approximately 31 to 41 feet bgs along the sout heastern portion of the former Area 1 NTCRA excavation. Figure 4 shows the areas of remainin g contamination in this area after the NTCRA excavation and ex-situ treatment program and Figure 5 shows a cross-section of the soil contamination remaining after the NTCRA. Bedrock DNAPL and Resi dual Contamination Chlorinated benzene compounds in pure form are DNAPLs and have the potential to migrate vertically downward thr ough the water table regardless of the direction of groundwater flow. To account for the deep penetration of cont amination in bedrock directly under the mill, the contamination had to migrate counter to the overa ll direction of bedrock gr oundwater flow. It is believed that deep penetration of DNAPL along fr acture planes in bedrock underlying the Site accounts for the observed distribution of contamination. The results of MERC sampling indicate that diffusion of contaminant mass into the weathered bedrock matrix and oxidized bedrock adj acent to fractures is an important feature of the mass distribution within the bedrock system . The presence of high concentrations of chlorinated benzene compounds in the MERC data support the conclusion that DNAPL migration did occur down deep along specific bedding planes and vertical fractures, opposite of the upward flow direction of discharging bedrock groundw ater. The MERC data also indicates that contaminant mass has diffused up to several feet fr om contaminated fractures into the fresh rock matrix. Compared to the mass in the oxidized rock matrix, this fresh matrix contaminant mass is a small component of residual mass. Diffusion coefficients of chlorinated benzene compounds are similar but vary an order of magnitude in solubility from 1,2,4-trichlorobe nzene to monochlorobenzene. Extremely high groundwater concentrations for 1,2,4-trichloroben zene approaching 30 to 50 percent of compound solubility were measured in a number of bedroc k boreholes. This data, in addition to the MERC Record of Decision Amendment - Operable Unit I 

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## OU I Record of Decision Amendment Part 2: The Decision Summary data, suggests that limited amounts of DNAPL may still be present in specific fractures in the two regions of the fractured bedrock aquifer. In general, many of the high contaminant co ncentrations observed in groundwater and MERC data within the competent fractured bedr ock may result from the backward diffusion of contamination from weathered rock matrix n ear fractures. Although rock porosity was not measured during this investigation, the weathe red porosity adjacent to fractures has been measured at similar sites and may range from 1 to 5 percent. The total porosity in the rock matrix is assumed to be a combination of the weathere d porosity along fractures , primary rock porosity (generally less than one-half to one per cent) and open micro-fracture networks. Bedrock contaminant mass estimates were re vised in 2005 as part of the Conceptual Model Update Report. The total estimated mass for the shallow bedrock (0-10 feet in depth) includes 5.4 kg of DNAPL and 120 kg of mass diffuse d in oxidized rock matrix adjacent to fractures. The total estimated mass for the deep fractured bedr ock includes 14.5 kg of DNAPL, 182 kg of mass diffused in oxidized rock matrix adjacent to fractures, and 16 kg of mass diffused into fresh rock matrix. Figure 6 shows the approx imate extent of the bedrock contamination that will be targeted by the OU I cleanup.
2. Groundwater Contamination Two regions of overburden groundwater c ontaining Site-related dissolved-phase contamination at concentrations above federal and state drinking water criteria are present at the groundwater source area. One region is associated with shallow soil at the UST/Building 14 area (NTCRA Area 4), and the other with deep overburden soil at the former location of Buildings 1, 1A, and 3 (NTCRA Area 1). Additionally, bedr ock groundwater located directly under the former mill location is contaminated at con centrations in excess of MCLs/MEGs. These groundwater systems are described separately while recognizing that they are related because of interactions between bedrock, overburden and surface water systems. Figure 7 depicts the boundaries of the bedrock and overburden contam inant plumes in 2002 and 2006, as well as the regions of groundwater that cont ain site related contaminants in excess of federal and state drinking water criteria. Overburden Groundwater Plumes Area 1 Overburden Based upon data collected between 2004 and 2005, it appears that th e groundwater flow direction (potentiometric surface) in Area 1 is heavily influenced by the operation of the temporary groundwater extraction and treatment system installed duri ng the NTCRA. Under pumping conditions, the overburden groundwater in this area flow s generally toward the NTCRA excavation and the temporary extraction wells . Under non-pumping/static conditions, the overburden groundwater flow in th is area is toward the south/s outheast and discharges to the EBSR approximately 135 feet from the easte rn edge of soil excavation to bedrock.

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### -- -- -- -- --

-- -- 

## Record of Decision Amendment Part 2- The Decision Summary Both a pilot-study and a full-sc ale application of ICP were completed in Area 1 between 2004 and 2005. Samples of groundwater were collected prior to the full-scale application in order to evaluate the potential for contaminant “re bound” resulting from th e mass reduction during the pilot test, as well as after the fu ll-scale application in order to evaluate reme dial success. Table 3 provides a summary of the analy tical results from the most r ecent Area 1 overburden groundwater sampling round that was conducted in November 2005 af ter the first full-scale ICP application. A select number of wells along with the major cont aminants of concern area shown in Table 3 below. Table 3 Area 1 Overburden Groundwater Contamination OU I Compound Cleanup Levels IM-04-01 IM-04-09 P2-04-07 P2-04-09 P2-04-12R P2-04-27

ug/L μg/L μg/L μg/L μg/L μg/L μg/L Benzene 

## 5 6.6J CB 

## 47 4,100 13,000 640 84 16J 2,300 1,2-DCB 

## 85 3,900 8,500 350 110 25 1,900 1,3-DCB 

## 85 150 260 12J 110 1,4-DCB 

## 27 2,600 7,000 270 100 21 2,000 1,2,4-TCB 

## 70 7,400 10,000 160 54 83 3,200 

## An assumption of the 2002 OU I ROD was that the EBSR may be impacted by the discharge of contaminated overburden groundwat er. Prior to the NTCRA, contaminated groundwater contributed to severe ecological impacts in the EBSR . The EBSR was relocated as part of the NTCRA, and the combined benefit of the relocation of the EBSR and elimination of the majority of the source contamination was not known at the time of the 2002 OU I ROD. To assess the potential for impacts to the EBSR af ter completion of the NTCRA soil excavation and ex-situ treatment program, groundwater samples we re collected from a series of piezometers installed within the EBSR channel. One sample collected from a piezometer located adjacent to Area 1 contained chlorinated benzene compounds at concentrations less than their respective MCLs. In addition, samples collected from piezomete rs installed within the base of the river did not contain detectable concentratio ns of chlorinated benzene compounds . As a result of this data, EPA has concluded that the groundwa ter is not a threat to the EBSR. See Fi gure 7 for the extent of Area 1 groundwater contamination. UST Area and Building 14 Area Based upon data collected during 2004 a nd 2005, overburden groundwater within the Building 14 Area and UST Area is inferred to migr ate toward and ultimately discharge to the EBSR, located approximately 270 to 340 feet to th e west/southwest of the UST Area dissolved plume.

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## 18 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## OU I Record of Decision Amendment Part 2: The Decision Summary The OU I RI identified an area approximatel y 200 long and 50 feet wide of overburden groundwater containing contaminants above MCLs and MEGs. This dissolved contaminant plume is interpreted to be continuous between Building 14 Area and the UST Area based upon the direction of overburden groundwater fl ow. Groundwater sampling conducted in 2005 following two full-scale ISCO applications to so il indicated that the gr oundwater contamination plume in the Building 14 Area and UST Area ha d retracted from the southwest towards the northeast to an area approxima tely 100 feet long and 40 f eet wide. The groundwater contamination is primarily observed in shallo w overburden groundwater and will be included in the long-term monitoring program . See Figure 7 for the location of the Building 14 Area and UST Area groundwater contamination. Bedrock Groundwater Plume An assumption of the 2002 OU I ROD was that containment was necessary for the bedrock groundwater contamination. Contamination has spread from the former Eastland Woolen Mill to water supply wells serving the Sunshine Village housing project. The 2002 OU I ROD included a groundwater extracti on and treatment system to cont ain the bedrock plume. The bedrock groundwater system at the Site respond s in a strongly anisotropic (non uniform) manner to groundwater pumping stresses because of the do minance of the bedding plane fracture network on groundwater movement. This high degree of anisotropy has allowed distant pumping stresses to pull deep and shallow bedr ock groundwater outward from the source area if the pumping sources are aligned parallel to the source area al ong the direction of bedding plane fractures. A groundwater plume with high concentrations of chlorinated benzene compounds exists in bedrock groundwater to dept hs in excess of 300 feet bgs. In 2000, the bedrock plume was estimated to extend approximately 1,200 feet la terally along a southwest-northeast axis, and approximately 400 feet downgradient from the s ource area as described in the OU I FS. Based on area-wide sampling performed in 2004 and 2005, the bedrock plume is believed to have receded and is now estimated to extend 240 feet latera lly (reduced from 1,200 feet in 2000) along a southwest-northeast axis and a pproximately 230 feet downgradient (reduced from 400 feet in 2000) from the source area. Figure 7 depicts the former and current extents of the bedrock plume contamination and residual DNAPL. Based on th e data collected since the 2002 OU I ROD, the bedrock plume discharges to overburden and surf ace waters and rapidly diminishes downgradient. The plume appears to be in a stable configuratio n with respect to downgradient migration and has receded when compared with results prior to 200 4. The stability and reduction of the plume is enhanced by the removal of downgradient pumping stresses, such as the Sunshine Village well, and the removal of over 90% of the contaminant source material as part of the NTCRA. The groundwater monitoring data documents that the gr oundwater plume is contracting as a result of the combined impacts of the NTCRA and Remedial Action activities.

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## 19 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary
Maximum concentration of VOCs detected in bedrock groundwater above MCLs and MEGs are summarized in Table 4 below. Table 4 Maximum Bedrock Groundwater COC Concentrations in Area 1
Compound Benzene CB 1,2-DCB 1,3-DCB 1,4-DCB 1,2,4-TCB OU I Cleanup Levels (ug/L) 5 47 85 85 27 70 BM-99-04F (ug/L)

11 13,000 6,000

380 6,100 3,700 BM-04-37 (ug/L)

12 18,000 7,400

240 6,100 3,500 R-2 (ug/L)

1.7 1,200

770 81 890 880



## 3. Conceptual Site Model Refer to the 2002 OU I ROD for the full descript ion of the Conceptual Site Model (CSM). The Amended ROD retains the focus on treating th e principle threat wastes in the soil and bedrock, including DNAPLs. The pre-design, desi gn, and preliminary implementation phases of OU I along with the activities performed to comple te the NTCRA have further validated that the CSM for the Site presented in the 2002 OU I ROD was accurate. The only changes in the CSM since 2002 are:

• The groundwater plume is not expanding, it is contracting. This is due to the source removal activities to date and the removal of the major pumping stresses in the area.

• The contamination is no longer impacting the surface water of the East Branch of the Sebasticook River. The removal of the c ontaminated material and the hydrological changes resulting from relocating the river ha ve eliminated the ecological impacts from contaminated overburden groundwater.
F. CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES Refer to the 2002 OU I ROD for the summary of current and potential future land uses. Since the 2002 OU I ROD was issued, Site soils ha ve been excavated, treated to residential use levels and backfilled. The Reuse Plan for Corinna has been implemented, three residences have been connected to the public water line, and institutional controls prohibiting the use of groundwater have been developed but not yet im plemented. One area of the Site has been redeveloped into a senior housing project, and a historic structur e that was relocated has been renovated into a General Store and restaurant. The Town of Corinna is currently marketing several lots within the Site for re use. Currently, 22 acres of the 25 acre Site that have been part of
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## 20 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## OU I Record of Decision Amendment Part 2: The Decision Summary the cleanup action are available for reuse. Figure 8 shows the areas th at are currently available for re-use. G. SUMMARY OF SITE RISKS The 2002 OU I ROD included an assessment of the potential threats to human health in the OU I study area. Based on the Human Health Ri sk Assessment prepared as part of the RI and the 2002 OU I ROD, the only pathways that exceed EPA’s acceptable cancer risk range and/or a hazard quotient of concern are ingestion of groundw ater in the overburden and bedrock plumes by a future resident. The lifetime cancer risk estima te for a combined child and adult exposure to the bedrock plume groundw ater is 6 x 10 -3 

## . Seventy-five percent of this risk is due to arsenic, with twenty-five percent attributab le to the 1,4-DCB. EPA’s hazard index of concern for noncarcinogenic risk is exceeded for children and adults for several target organs. The major contributors to these exceedances are chlor obenzene, 1,2-DCB, 1,3-D CB, 1,4-DCB, 1,2,4-TCB and arsenic. These COCs also were detected at concentrations above federal and state maximum contaminant levels (MCLs) and more stringe nt state maximum expos ure guidelines (MEGs). The lifetime cancer risk estimates for th e overburden plume groundwater is 2 x 10 -3



## . Sixty-seven percent of this risk is attributable to 1,4-DCB, with arsenic cont ributing to the remainder of the cancer risk. EPA’s hazard index of concern for non-carcinogenic risk is exceeded for children and adults for several target organs. The major contributors to these exceedances are chlorobenzene, 1,2-DCB, 1,3-DCB, 1,4-DCB, 1,2,4-TCB and arsenic. These COCs also were detected at concentrations abov e federal and state MCLs and more stringent state MEGs. The Baseline Human Health Risk Assessment concluded that the estimated risk for the soils, surface water, or sediments within the OU I area do not represent an unacceptable threat to human health. Only groundwater represents a threat to human health. Soil contamination that is causing groundwater contamination is al so relevant to the cleanup action. The groundwater beneath and surrounding the Site still remains a drinking water aquifer. Although data gathered since the 2002 OU I ROD wa s issued demonstrates that the groundwater plume has receded and contaminant mass is reduced, contaminant levels still exceed drinking water standards and ingestion of groundwater continues to pose a risk to human health consistent with the risks summarized above. The OU I ROD concluded that contaminant le vels in surface waters, surface soils and sediments within the OU I area of the EBSR are not sufficiently elevated to pose a substantial risk to invertebrates, fish and wildlife through direct contact and dietary exposur e to the Site-related COCs. Exposure to the contaminated water at the groundwater/surface wa ter interface, however, was identified as an unacceptable risk to those or ganisms dwelling in this zone. Data gathered since the 2002 OU I ROD, however, demonstrate that the concentration of contaminants in the groundwater do not exceed the levels that have the potential for an unaccepta ble risk to organisms dwelling in the groundwater/surface water interface. Therefore, the successful implementation of the NTCRA and OU I remedy has eliminated this risk.

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## 21 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary Refer to the 2002 OU I ROD for the complete presentation of the human health and ecological risks. Actual or threatened releases of hazardous substances from th is Site, if not addressed by implementing the response action se lected in this ROD, may presen t an imminent and substantial endangerment to public health, we lfare, or the environment.
H. REMEDIATION OBJECTIVES Based on preliminary information relating to the types of contaminants, environmental media of concern and potential exposure pa thways, response action objectives (RAOs) were developed to aid in the development and screeni ng of alternatives. These RAOs were developed to mitigate, restore and/or prevent existing and fu ture potential threats to human health and the environment. The RAOs for the selected OU I Remedial Action remain the same and are repeated below:

- Prevent the ingestion of gr oundwater containing contaminan ts that exceed federal or state MCLs, federal non-zero MCL Goals (MCLGs ) and more stringent state MEGs, or in their absence, an excess cancer risk of 1 x 10 -6 

## or a hazard quotient of 1;

- Prevent, to the extent practicable, the off-site migration of groundwater containing contaminants at a concentration above Site cleanup levels;

- Prevent, to the extent practicable, the di scharge of groundwater c ontaining contaminants at a concentration above levels that could im pact ecological receptors to the East Branch of the Sebasticook River;

- Restore groundwater to meet federal or state MCLs, federal non-zero MCLGs or state MEGs (whichever is most stringent), or in their absence, an excess cancer risk of 1 x 10 -6 

## or a hazard quotient of 1; and

- Perform long-term monitoring of surface water, sediments and groundwater to verify that the cleanup actions at the Site are protective of human health and the environment.
I. DEVELOPMENT AND SCREENING OF ALTERNATIVES 1. Statutory Requirements/Response Objectives Under its legal authorities, EPA’s primary responsibility at Superfund sites is to undertake remedial actions that are protective of human h ealth and the environment. In addition, Section 121 of CERCLA establishes seve ral other statutory requirement s and preferences, including a requirement that EPA’s remedial action, when comp lete, must comply with all federal and more stringent state environmental and facility siting standards, requir ements, criteria or limitations, unless a waiver is invoked; a requi rement that EPA select a remedi al action that is cost-effective and that utilizes permanent solutions and alternat ive treatment technologies or resource recovery Record of Decision Amendment - Operable Unit I 

## 22 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## OU I Record of Decision Amendment Part 2: The Decision Summary technologies to the maximum extent practicable; and a preference fo r remedies in which treatment that permanently and significan tly reduces the volume, toxicity or mobility of the hazardous substances is a principal element over remedi es not involving such treatment. Response alternatives were develope d to be consistent with these Congressional mandates. 2. Technology and Alternative Development and Screening CERCLA and the National Contingency Pl an (NCP) set forth the process by which remedial actions are evaluated and selected. In accordance with these requirements, a range of alternatives were deve loped for the Site. With respect to the groundwater respons e action, the OU I RI/FS developed a limited number of remedial alternatives that attain Site cleanup levels w ithin different time frames using different technologies, as well as a no-action alternative. The FFS incorporated the alternative development and screening step completed as part of the OU I RI/FS by reference.
J. DESCRIPTION OF ALTERNATIVES This Section provides a narrative summary of the alternatives considered as part of the ROD Amendment Focused Feasibility Study (FFS). The FFS was prepared to evaluate the original OU I Remedial Action against the revised OU I Remedial Action. Alternative GW-1: No Further Action Alternative GW-1, the No Further Action alternativ e, was retained as a baseline with which to compare the other alternatives, as required by the NCP. This alternative would not include remedial action components beyond those already performed in the NTCRA to contain or reduce contaminant concentrations in groundwater. Nor would GW-1 control potential risks from exposure to contaminated groundwater by implem enting institutional controls, extending the public water supply, or environmental monitoring. S ite reviews would not be performed as part of this alternative. The NTCRA groundwater ma nagement system would be turned off and decommissioned upon completion of the NTCRA in 2006, and no further groundwater cleanup activities would occur at the Site. Capital Costs: none Present Worth of Long Term Monitoring: None Alternative GW-4: Hydraulic Containment plus Mass Reduction (2002 OU I ROD Remedial Action) Alternative GW-4 includes actions to hydraulically contain groundwat er in the source area of the mill footprint, reduce contaminant mass contribu ting to the contamination of groundwater through chemical oxidation, extend the public water supply system to prevent ingestion of contaminated groundwater and plume expansion and migration, implement institu tional controls to prevent exposure to contaminated groundwater, and pe rform environmental monitoring to assess

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## 23 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary migration of contamination and potential human health risks from exposure to contaminated groundwater. Hydraulic containment of the Ar ea 1 bedrock and overbur den groundwater plumes would occur by extraction and treatment of bedr ock and overburden grou ndwater from beneath the Site. These actions would accelerate clean up of groundwater to some degree, control plume migration and prevent discharge of contamin ated groundwater to th e EBSR in excess of concentrations that would pos e potential ecological risk. Capital Costs: $6.9 million Total Present Value of Alternative GW-4: $10.5 million Estimated time to achieve gro undwater restoration: 60 years. Alternative GW-4a: Mass Reduction without Active Hydraulic Containment Alternative GW-4a include s actions to reduce contaminant mass contributing to the contamination of groundwater through chemical oxi dation and extends the public wa ter supply system to prevent ingestion of contaminated groundwater and to pr event plume migration and/or address potential threats to human health. It also relies upon instit utional controls and environmental monitoring to control potential human health ri sks from exposure to contaminat ed groundwater. These actions would accelerate clean up of groundwater, further control plume migration, and prevent discharge to the EBSR of groundwater with contaminan t concentrations that would pose potential ecological risk. Capital costs: $3.54 million Present Value of Alternative GW-4a: $4.5 million Estimated time to achieve a quifer restoration: 80 years.
K. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES Section l2l(b)(1) of CERCLA presents seve ral factors that, at a minimum, EPA is required to consider in its assessment of alte rnatives. Building upon these specific statutory mandates, the NCP articulates nine evaluation crit eria to be used in assessing the individual remedial alternatives. These criteria are summarized as follows: Threshold Criteria The two threshold crite ria described below must be met in order for the alternatives to be eligible for selection in accordance with the NCP:
1. Overall protection of human health and the environment addresses whether or not a remedy provides adequate protection and describes how risks posed through each pathway are eliminated, reduced or cont rolled through treatment, engineering controls, or institutional controls.
2. Compliance with applicable or relevant and appropriate requirements (ARARs) addresses whether or not a remedy will meet all federal environmental and more stringent state environmental and facility siting standards, requirements, criteria or limitations, unless a waiver is invoked. Record of Decision Amendment - Operable Unit I 

## 24 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## OU I Record of Decision Amendment Part 2: The Decision Summary Primary Balancing Criteria The following five criteria are utilized to compare and evaluate the elements of one alternative to another that meet the threshold criteria:
3. Long-term effectiveness and permanence addr esses the criteria th at are utilized to assess alternatives for the long-term effectiveness a nd permanence they afford, along with the degree of certainty that they will prove successful.
4. Reduction of toxicity, mobility, or volu me through treatment addresses the degree to which alternatives employ recycling or treatment that reduces toxicity, mobility, or volume, including how treatment is used to address the principal threats posed by the Site. 5. Short-term effectiveness addresses the pe riod of time needed to achieve protection and any adverse impacts on human health and the environment that may be posed during the construction and implemen tation period, until cleanup goals are achieved.
6. Implementability addresses the techni cal and administrative feasibility of a remedy, including the availability of materi als and services need ed to implement a particular option.
7. Cost includes estimated capital and Operation and Maintenance (O&M) costs, as well as present-worth costs. Modifying Criteria The modifying criteria are used as the final evaluation of remedial alternatives, generally after EPA has received public comment on the RI/FS and Proposed Plan:
8. State acceptance addresses the State’s pos ition and key concerns related to the preferred alternative and other alternatives, and th e State’s comments on ARARs or the proposed use of waivers.
9. Community acceptance addresses the public’s general response to the alternatives described in the Propos ed Plan and RI/FS. The following is a comparison of the 2002 OU I ROD remedy and the alternatives evaluated for this ROD Amendment, contrasting each remedy’s components with respect to the nine evaluation criteria. Only thos e alternatives that sa tisfied the first two threshold criteria were balanced and modified using the remaining seven criteria.

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## 25 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary Summary for the Comparative Analysis of Alternatives Overall Protection of Human Health and the Environment Overall protection of human health and the environment addresses whether each alternative provides adequate pr otection of human health and th e environment and describes how risks posed through each exposure pathway are eliminated, reduced, or controlled, through treatment, engineering controls , and/or institu tional controls. Results of Baseline Human-health Risk Assessment for overburden and bedrock groundwater indicate that cancer risks due to chlorinated benzene compounds exceed the EPA target cancer risk range of 1x10 -4 

## to 1x10 -6 

## and a non-cancer risk target of an HI=1, (for inorganic and chlorinated benzene compounds). As identified in the OU I FS and 2002 OU I ROD, Alternative GW-1 would not take any actions to prevent poten tial human receptor exposure to contaminated groundwater. The No Further Acti on alternative would not reduce these risks and would not be protective of huma n health or the environment. Alternatives GW-4 and GW-4a are considered protective of potential risks to human health and the environment. Th ey utilize active remedial actions that either destroy or remove COCs from the aquifer in combin ation with using a public water s upply and institutional controls that prohibit groundwater use, which are to be implemented until such time that MCLs/MEGs are achieved or it can be shown that risk levels posed by the COCs in groundwater are within target risk ranges. Alternative GW-4, the origin al 2002 OU I ROD remedy, included a groundwater extraction and treatment component to aid in achieving aquifer rest oration. The reduction of the contaminant mass through NTRCA activities and th e elimination of local pumping stresses that could cause the expansion of th e groundwater plume have eliminated the primary need for the long-term groundwater extraction and treatment sy stem, which was to prevent plume migration and protect the EBSR from contaminated water discharge until cleanup levels are met. As a result, the only remaining reason for long-term groundwater extraction and treatment would be to facilitate aquifer restoration. Ho wever, given that the groundwater contamination is limited to an un-developable area consisting of either road way or designated greenspace, the anticipated placement of institutional controls to prevent future groundwater use, the availability of a water line, and the fact that the groundwater contamin ation is receding rather than expanding, EPA considers the less aggressive approach defined in Alternative GW-4a to provide an equivalent level of protection of human health and the environment to that of Alternative GW-4. Alternatives GW-4 and GW-4a both include gro undwater monitoring as a component to provide information on the ability of the alternative to destroy/remove contaminants within the aquifer and to confirm that COCs are eventually reduced to concentrations that protect against potential risks to human health an d the environment. Compliance with Applicable or Relevant and Appropriate Requirements Section 121(d) of CERCLA requires that remedi al actions at CERCLA sites attain legally applicable or relevant and appr opriate federal and state requirem ents, standards, criteria, and Record of Decision Amendment - Operable Unit I 

## 26 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## OU I Record of Decision Amendment Part 2: The Decision Summary limitations which are collectively referred to as “ARARs,” unless such ARARs are waived pursuant to CERCLA section 121(d)( 4). This criterion must be met for a remedial alternative to be chosen as a final site remedy in accordance with CERCLA. Chemical-specific ARARs. Chemical-specific ARARs fo r groundwater (MCLs, non-zero MCLGs, and MEGs) would not be met by Altern ative GW-1 for an estimated 600 years. Alternatives GW-4 and GW-4a ar e expected to attain chemical -specific ARARs within 60 and 80 years, respectively. Location-specific ARARs. Alternatives GW-4 and GW-4a can be designed and implemented to comply with location-specific ARARs, with Alte rnative GW-4a having slightly fewer impacts to wetlands and floodplains since construction or expa nsion of the groundwater treatment system is eliminated. There are no location- specific ARARs for Alternative GW-1. Action-specific ARARs. Alternative GW-1 entails no action and therefore triggers no actionspecific ARARs. Alternatives GW-4 and GW-4a produce investigation-derived waste from groundwater sampling that would be required to be managed in accordance with EPA OSWER Publication 9345.3-03FS, which is a “to be consider ed” (TBC) guidance. Alternatives GW-4 and GW-4a will also meet applicable groundwater injection program standards during subsurface application of remedial solutio ns. Alternative GW-4’s long- term groundwater extraction and treatment system produces waste streams from wa ter treatment that requ ires potential handling, storage, transportation, and dis posal/treatment of hazardous waste. For Alternative GW-4, groundwater discharged to the EBSR would need to be treated to prev ent exceedance of AWQC in the river at low-flow and to protect surface water quality. Long-Term Effectiveness and Permanence Long-term effectiveness and permanence refers to expected residual risk and the ability of a remedy to maintain reliable protection of hu man health and the environment over time, once cleanup levels have been met. Alternative GW-4 uses chemical oxidation, possibly surfactant or cosolvent flushing, and bioremediation to remove or destroy contaminants within the aquifer. Hydraulic capture and treatment performed during these processes will result in contaminants being isolated ex-situ for further treatment a nd disposal off-site. Alternative GW-4a uses chemical oxidation and bioremediation to remove or destroy contaminants within the aquifer. There is no long-term hydraulic capture and treatm ent performed as part of GW-4a because the plume is no longer expanding and the EBSR is not threatened by the remaining groundwater contamination. Alternatives GW-4 and GW-4a both rely on an aggressive treatment approach. Although GW-4a is presumed to require a longer pe riod of time for aquife r restoration (80 years as opposed to 60 years), they offer essentia lly equivalent long-term effectiveness. For long-term protectiveness, Alternatives (GW-4 and GW-4a) both rely on restrictive environmental covenants to prevent the use of groundwater until cleanup goals are met. Because waste remains in place, EPA will review the reme dy every five years to ensure the effectiveness and protectiveness of this control and to implem ent further controls if necessary. Long-term monitoring will continue unde r both alternatives.

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## 27 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary Reduction of Toxicity, Mobility, or Volume Through Treatment Reduction of toxicity, mobility, or volume through treatment refers to the anticipated performance of the treatment technologies that may be included as part of a remedy. Alternatives GW-4 and GW-4a use aggressive treatment appro aches to destroy contaminants in-situ. The hydraulic containment portion of Alternative GW-4 would actively control contaminant mobility in the subsurface during in-situ treatment impl ementation. The ex-situ treatment portion would reduce contaminant mobility in extracted groundwat er. Alternative GW-4a does not include longterm active hydraulic containment. The RAO for groundwater restoration can be met without long-term hydraulic containment based upon the result of the groundwater modeling performed for the OU I design. A decrease has been observed in the volume of the groundwater contamination plume and the COC concentrations w ith the absence of hydrau lic control. It is anticipated that a continued decrease in plum e volume and COC concentrations will occur with continued ISCO applications. Alternatives GW-4 and GW-4a provide the same reduction in toxicity, mobility, and volume of contaminants through treatment, although GW-4a is presumed to require a longer peri od of time for aquifer restoration (80 years as opposed to 60 years). Short-Term Effectiveness Short-term effectiveness addresses the period of time needed to implement the remedy and any adverse impacts that may be posed to wo rkers and the community during construction and operation of the remedy until cleanup goals are achi eved. Because there is no current exposure to groundwater, there will be no short-term adverse effects to the community from exposure to groundwater during implementation of any of th e groundwater remedies. Site workers will experience the same short-term impacts duri ng ICP ISCO in-situ remediation with both alternatives. Alternatives GW4 and GW-4a both include connection to a public water line to offer immediate protection to nearby residences and businesses from ingestion of contaminated drinking water. Alternative GW4a has a slight advantage over altern ative GW-4 in that elimination of the long-term groundwater extrac tion and treatment systems and surfactant/cosolvent flushing results in less onsite constr uction, less truck traffic, and fewer impacts on wetlands and floodplains. Implementability Implementability addresses the technical and administrative feasibility of a remedy from design through construction and operation. Factors such as availability of services and materials, administrative feasibility, and coordination with ot her governmental entities are also considered. Although both alternatives rely on innovative technologies, ICP IS CO has been successfully implemented at the Site during 2004 and 2005 NTCRA activities. Surfactant/cosolvent flushing in Alternative GW-4 has yet to be successfu lly implemented in a fr actured bedrock setting comparable in scale to the Site and must be considered unproven. Based on this general comparison, the alternative GW-4a is cons idered more implementable than GW-4.

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## 28 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## OU I Record of Decision Amendment Part 2: The Decision Summary Cost The estimated present worth costs for the a lternatives, not including Alternative GW-1, range from $4.5 million for Alternative GW-4a to $10.5 million for Alternative GW-4. When evaluating the alternatives based upon an annual outlay as opposed to present value, the cost benefit of Alternative GW-4a is more apparent. The cumulative e xpenditures to achieve aquifer restoration using Alternative GW-4a will be approximately $6.5 million by the end of 80 years whereas the cumulative expenditure for Alternativ e GW-4 is estimated at $20.8 million at the end of 60 years. Although the revised OU I remedi al action, GW-4a, would require 20 additional years to achieve the restoration of the aquifer, the cost to achieve restoration is significantly lower than GW-4, which relies on a long-term groundwater extraction and treatment system to facilitate the groundwater restoration in a shorter period. However, given the reduced size of the groundwater plume and the implementation of ins titutional controls, there is no consequence to public health as a result of the additional 20 years to achieve rest oration. Capital, present worth, and total long-term costs for each alternativ e are shown in the following Table 5 below. Table 5 Comparison of Costs Cost Category Alternative GW-1 Alternative GW-4 Alternative GW-4a Capital Costs $0 $6,891,283 $3,541,980 Present Worth of Annual and Periodic Costs $0 $3,614,296 $926,674 Present Worth $0 $10,505,579 $4,468,653 Total (Long-term) Costs – non-discounted $0 $20,777,431 $6,508,976 costs (60 years) (80 years) Capital costs are greater for GW-4 due to the installation of the groundwater extraction and treatment system and injection system fo r enhanced flushing. Long-term operation and maintenance costs are also greater for GW-4 due to the cost associated with the operation and maintenance of the treatment system. State/Support Agency Acceptance This criterion addresses whether, based on its re view of the data derived from the Site and the Proposed Plan, the State concurs with, oppos es, or has no comment on the Amendment that EPA has selected for the Site. ME DEP has reviewed the May 2006 Proposed Plan to amend the 2002 OU I ROD and a draft of this ROD Amendment. The State of Maine supports th e proposed changes to the OU I remedy as described in Alternative GW-4a. Community Acceptance: This criterion addresses whet her the public concurs with EPA’s proposed Amendment. Compliance with this criterion is based on the comments received at the public meeting and public hearing.

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## 29 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary The community is supportive of the proposed changes to the OU I remedy as described in Alternative GW-4a.
L. THE SELECTED REMEDY 1. Summary of the Rationale for the Selected Remedy The selected remedy is the proposed preferre d alternative, Alternative GW-4a, that was identified in the Proposed Plan and presented in more detail in the FFS. The amended OU I remedy remains a comprehensive remedy for the OU I portion of the Site that utilizes the application of in-situ reagents , incorporates groundwater us e restrictions and long-term monitoring and will require fi ve-year reviews as long as waste remains in place. For the amended remedy for OU1, EPA has selected a remedy which ensures protectiveness of human health and the environment, attain s all federal and state regulations, provides long-term and short-term effectiveness, is implementable, and reduces toxicity, volume, and mobility through treatment. 2. Description of Remedial Components The major components of the remedy are: Alternative GW-4a includes actions to 1) re duce the contaminant ma ss contributing to the contamination of groundwater th rough chemical oxidation; 2) extend the public water supply system to prevent ingestion of contaminated groundwater; and 3) preven t plume migration to address potential threats to human health and the environment. It also relies upon institutional controls and environmental monitoring to control potential human health risks from exposure to contaminated groundwater. Alternative GW-4a is presented in Figure 9 and consists of the following key components:

• Groundwater source mass reduction o ISCO treatment of Area 1 deep saturate d soil and shallow weathered bedrock o ISCO treatment of Area 1 deep fractur ed bedrock including installation of additional bedrock injection wells o Bio-stimulation of Area 1 deep fractured bedrock
• Environmental monitoring o Groundwater monitoring to assess reme dy effectiveness and progress toward attaining cleanup goals
• Institutional Controls to prevent future us e of the contaminated groundwater and prevent disturbance of the remedy
• Connecting currently occupied pr operties within the institut ional controls zone to the existing public water supply system
• Five-year reviews to ensure that the remedy remains protective of human health and the environment. Record of Decision Amendment - Operable Unit I 

## 30 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## OU I Record of Decision Amendment Part 2: The Decision Summary Groundwater Source Mass Reduction This alternative focuses mass reduction technologie s on three specific areas of contamination that represent residual sources below the wa ter table. These areas include:

• Area 1 deep saturated soil
• Area 1 shallow weathered bedrock surface
• Area 1 deep fractured bedrock Area 1 Deep Saturated Soil ISCO An estimated 1,289 kg of contaminant mass exists as residual DNAPL within approximately 809 yd 3 

## of dense glacial till approximately two to four feet thick immediately above the bedrock surface in Area 1. An additiona l contaminant mass of approximately five kg of contaminants is estimated to be present as sorbed contamination in approximately 543 yd 3 

## of soil, forming a wedge shape overlying and adj acent to the DNAPL saturated soils. The ISCO application will be performed in the Area 1 overburden during 2006 to reduce soil concentration to allow gr oundwater to achieve MCLs/MEGS. Post-injection soil and groundwater sampling will be performed to evaluate the success of these future treatments. Additional ISCO applications will occur as necessary to achieve a level of source reduction that will support the restorat ion of the aquifer. Area 1 Shallow Weathered Bedrock Surface ISCO This area is estimated to contain appr oximately 5.4 kg of DNAPL mass and 120 kg of mass diffused in oxidized rock matrix adjacent to fractures. To treat residual DNAPL dispersed along the top of weathered bedrock, an ISCO pr ogram will be performed. During the ISCO injections, groundwater will be extracted from th e fractured bedrock underlying Area 1 from the existing extraction well (former Lot 120 Recovery Well 2 (R2), re-conver ted as EW-1). The extracted groundwater will be tr eated onsite by carbon absorbtion a nd discharged to the EBSR. Best management practices will be used during extraction, treatment and di scharge activities. Area 1 Deep Fractured Bedrock ISCO and Bio-stimulation The total estimated contaminant mass for this area includes 14.5 kg of DNAPL, 182 kg of mass diffused in oxidized rock matrix adjacent to fractures, and 16 kg of mass diffused into fresh rock matrix. An ISCO program would be performed to target the deep bedrock contamination and to stimulate biological degr adation processes that would pr ovide the long-term reduction in contaminant levels necessary to achieve cleanup levels. An option included in the 2002 OU I ROD was po ssibility of using bio-stimulants as a polishing step to remove any contamination that remained after the IS CO. This ROD Amendment incorporates the use of bio-stimulants into th e remedy. The bio-stimulant composition will likely be designed or formulated from commercially available products such as HRCTM, specialized

Record of Decision Amendment - Operable Unit I 

## 31 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary sugars and nutrients, or injection of air with gaseous phase nutrients (nitrogen and phosphorous) with methane as a carbon source. The full- scale application of bio-stimulant would be accomplished through approximately eight vertical bedrock wells. The bio-stimulant injection would be repeated on an as-needed frequency to maintain productiv e levels of biol ogical activity. The level of biological activity w ould be assessed using phospho-lipid fatty acid analysis or other specialized analytical procedures, in addition to monitoring methane, chloride and nutrient levels within the aquifer treatment zone. As with the shallow bedrock, hydraulic cont rol would be establis hed and maintained during active treatment of the bedrock groundwater system by operation of the temporary groundwater extraction and trea tment system installed duri ng the NTCRA. Once the active treatment phase is completed and treatment fluids have been recovered from the subsurface, the temporary groundwater extraction and treatment system will be removed. Environmental Monitoring The monitoring program will be initiated after completion of the mass reduction phase. Environmental monitoring will consist of collection and analysis of groundwater samples for VOCs, inorganics, and field parameters from approximately 24 overburden and 16 bedrock monitoring wells. This includes four new overburden and six new bedrock groundwater monitoring wells. The monitoring locations include wells within and outside the limits of the bedrock and overburden groundwater plumes. The monitoring will occur annually for five years and then may be reduced to s upport each five year review. Details of the monitoring program, including quality assurance/quality control (QA/QC) protocols and institutional control compliance, will be specified in a long-term monitoring plan to be submitted to ME DEP for review and concurrence prior to implementation. Institutional Control Components Based on the groundwater modeling that was performed as part of the OU I Remedial Design, the Institutional Control Zo ne (ICZ) was modified to reflect additions or changes to the ICZ components. The final proposed ICZ is shown in Figure 10. The ICZ contains three propert y categories, IC Zone A (ICZ- A), IC Zone B (ICZ-B), and IC Zone C (ICZ-C). These properties that are classified as ICZ would have environmental covenants that either prohibit (ICZ-A and ICZ-B) or restrict (ICZ-C) groundwater use. ICZ-A identified those properties that w ill be subject to environmental covenants prohibiting use of groundwater over the entire property. All of th e ICZ-A properties are currently served by the water line. With in the ICZ-A boundary, all existi ng bedrock and overburden water supply wells will be formally decommissioned, unle ss the wells are converted to monitoring wells for use in the long-term remedial action. IC Z-A properties are depi cted on Figure 10. ICZ-B identified those properties where conne ction to the water line and implementation of an environmental covenant prohibiting use of groundwater over the en tire property was Record of Decision Amendment - Operable Unit I 

## 32 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## OU I Record of Decision Amendment Part 2: The Decision Summary determined to be necessary. All of the proper ties have now been connected to the water line, moving these properties to ICZ-A; there is therefore no longer a functional application for ICZ-B. ICZ-C identified those properties where the cu rrent well is not contaminated and does not appear to be impacting the groundwater cont amination, however, the groundwater modeling suggested that a modification to th e existing well to increase yield or the installation of a new well at locations on the property closer to the Site could have an ad verse impact on the groundwater contamination by inducing migratio n of the groundwater contaminati on. The restrictions on these properties will prohibit installation of future groundwater wells in locations or at depths that differ from existing water supply wells located on these properties. ICZ-C prope rties may continue to use their private water wells within this zone for domestic or other uses. There are two properties included in ICZ-C. The ICZ-C properties are shown on Figure 10. In addition to ICZ-A, ICZ-B, and ICZ-C, the Town Cemetery will also be included in the institutional controls pertaining to property where treated soil wa s placed. The Town of Corinna, EPA, and ME DEP agreed that any backfilled, treat ed soil that was subject to EPA’s removal or remedial activities that is excavated during fu ture Town redevelopment may be moved to and backfilled at the Village Cemetery located on Stet son Road. The Town of Corinna has agreed to implement this environment restriction. Once the institutional controls have been im plemented, compliance with the restrictions will be monitored and enforced to ensure that the institutional controls are effective. Over time, EPA will also evaluate whether the land use rest rictions can be removed or modified because acceptable levels have been met at the Site. Five-Year Reviews. As long as contamination that prevents unr estricted use of the S ite remains, EPA will review the Site at least once ever y five years after the initiation of remedial action to ensure that the remedial action continues to protect human health and the environment.

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## 33 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary
3. Summary of the Estimated Remedy Costs The estimated capital cost for the remedial action is $3.54 million. The capital costs are detailed in Table 6 below. Table 6 CAPITAL COST SUMMARY FO R ALTERNATIVE GW-4a: 

## Description Cost Site Management, Equipment, and Facilities (2006-2008) 

## $512,151 Connection of residences to public water supplies 

## $54,761 Long-term monitoring well installation 

## $239,273 Institutional Control Support 

## $33,607 ISCO – Area 1 Shallow Bedrock 

## $796,648 ISCO – Area 1 Deep Bedrock 

## $741,118 ISCO – Area 1 Polishing Injections 

## $374,571 Biological Enhancement Treatment – Area 1 

## $309,345 Performance Monitoring (2006/2007) 

## $160,000 Site restoration (removal of temporary treatment plant and well decommissioning) 

## $120,016 Direct Cost Subtotal 

## $3,341,490 Indirect Capital Costs Construction Management 

## $100,245 Project Management 

## $100,245 Indirect Cost Subtotal 

## $200,489 TOTAL CAPITAL COSTS 

## $3,541.980 The estimated monitoring and periodic injectio n costs are summarized in Table 7 below.
Table 7 COST SUMMARY FOR ALTERNATIVE GW-4a: Annual Operation and Maintenance Costs 

## Description Quantity Unit Unit Cost Cost Annual Costs Annual Groundwater monitoring (years 1-5) – including 10% contingency, 5 percent project management, and 10% technical support 45 wells annual LS 

## $75,000

Periodic Costs Periodic monitoring to support 5 year reviews (every fourth year, for years 5-80) – including 10% contingency, 5 percent project management, and 10% technical support 45 wells Event LS 

## $75,000
Five-Year Reviews (every 5 years beginning in 2011) – including 10% contingency, 5 percent project management, and 10% technical support Event LS 

## $31,250
Bio-stimulant Injections (years, 2,4,6, and 8) – including 10% contingency, 5 percent project management, and 10% technical support LS 

## $120,454

Record of Decision Amendment - Operable Unit I 

## 34 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## OU I Record of Decision Amendment Part 2: The Decision Summary The present value of the long-term costs for Alternative GW-4a is $926,674. The total cost, including capital and present value of long-term costs, for Alternative GW-4a is $4,468,653. The detailed breakout of long-term costs and the present value is presented in Table 8, which is attached to this ROD Amendment. The information in this cost estimate su mmary table is based on the best available information regarding the anticipa ted scope of the remedial altern ative. Changes in the cost elements are likely to occur as a result of new information and data collected during the engineering design of the remedial alternative. A discount rate of 7% was used to develop the present value. Major changes may be docum ented in the form of a memorandum in the Administrative Record file, an Explanati on of Significant Difference (ESD), or a ROD amendment. This is an order-of-magnitude engineer ing cost estimate that is expected to be within +50 to -30 percent of the actual project cost. 4. Expected Outcomes of the Selected Remedy The primary expected outcome of the selected OU I amended remedy is that the OU I Site area will no longer present an unacceptable risk to future users of the groundwater through ingestion and inhalation of groundwater and will be suitable fo r unrestricted use. Approximately 80 years is the estimated time necessary to achieve the goals consistent with aquifer restoration. The NTCRA and selected remedy have also reduced the flux of contaminants into the EBSR allowing for a full recovery of the benthic comm unity. The previous removal actions, including the NTCRA, have eliminated any thr eat from exposure to soils within the Site. It is anticipated that the selected remedy w ill also provide significant socio-economic and community revitalization impacts since th e area addressed by the NTCRA and this OU I cleanup are the center of the community. The completion of th e NTCRA and the construction phase of the OU I cleanup, have allowed the community to implement the redevelopment plan. Of the 25 acres that were part of the Site cleanup activities, 22 acres are currently available fo r productive re-use. A senior housing facility, Corundel Co mmons, was installed on one portion of the Site. A historic structure, relocated from the center of the Site to just outside the Site, has been rehabilitated and serves the community as a general store and re staurant. The Town of Corinna has approved a subdivision plan and is actively marketing most of the remaining areas of the Site that are available for re-use.

Record of Decision Amendment - Operable Unit I 

## 35 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary a. Cleanup Levels -- Groundwater The provisional cleanup levels established in the 2002 OU I ROD remain protective of human health and the environment. Refer to the 2002 OU I ROD for discussion about cleanup levels. The numerical cleanup levels from the 2002 OU I ROD are listed in Table 9 below.
Table 9 Provisional Groundwater Cleanup Levels Carcinogenic Chemicals of Concern Cancer Classification Provisional Cleanup Level (ug/l) Basis RME Risk

arsenic A 10 MCL 2 x 10 -04 

### 1,4 dichlorobenzene C 27 1992 MEG 1 x10 -05 

### benzene A 5 MCL 2 x 10 -06 

### Sum of Carcinogenic Risk 2 x 10 -04


### Non-Carcinogenic Chemicals of Concern Target Endpoint Provisional Cleanup Level (ug/l) Basis RME Hazard Quotient

arsenic skin 10 MCL 2.1
manganese central nervous system 200 MEG 0.57

benzene hematological system 5 MCL 0.12 chlorobenzene liver 47 1992 MEG 0.018 1,2 dichlorobenzene liver 85 1992 MEG 0.085 1,3 dichlorobenzene liver 85 1992 MEG 9.4 1,4 dichlorobenzene liver/kidney 27 1992 MEG 0.080 1,2,4 trichlorobenzene Endocrine system 70 MCL 0.78 HI (liver): 9.7 HI (central nervous system): 0.57 HI (skin): 2.1 HI (endocrine system): 0.78 Key MCL: Federal Safe Drinking Water Act Maximum Contaminant Level MCLG: Federal Safe Drinking Water Act Maximum Contaminant Level Goal MEG: State of Maine Maxi mum Exposure Guidelines HI: Hazard Index RME: Reasonable Maximum Exposure

Record of Decision Amendment - Operable Unit I 

## 36 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## OU I Record of Decision Amendment Part 2: The Decision Summary All groundwater cleanup levels identified in the ROD and any newly promulgated ARARs and modified ARARs that call into question the protectiveness of the re medy and the protective levels determined as a consequence of the risk assessment of residual contamination must be met at the completion of the remedial action at the points of compliance. At this Site, cleanup levels must be met throughout the contaminated gr oundwater plume. Th e values represent concentration levels that cannot be exceeded in any given well location at the Site. EPA has estimated that the groundwater cleanup levels will be obtained within 80 y ears after the initiation of the in-situ oxidation program. EPA’s new Cancer Guidelines and Supplemental Guidance (March 2005) will be used as the basis for EPA’s analysis of all new carcinoge nic risk assessments. If updated carcinogenic risk assessments become available, EPA will determine whether an evaluation should be conducted as part of the remedial design to assess whether adjustments to the target cleanup levels for this remedial action are needed in order for th is remedy to remain protective of human health.
M. STATUTORY DETERMINATIONS The amended OU I remedial action selected fo r implementation at the Site is consistent with CERCLA and, to the extent practicable, th e NCP. The selected remedy is protective of human health and the environment, will comply with ARARs and is cost-effective. In addition, the selected remedy utilizes perm anent solutions and alternate tr eatment technologies or resource recovery technologies to the maximum extent prac ticable and satisfies the statutory preference for treatment that permanently and significantly reduces the mobility, toxicity or volume of hazardous substances as a principal element. 1. The Selected Remedy is Protective of Human Health and the Environment The remedy at this Site will adequately protect human health and the environment by eliminating, reducing or controlling exposures to human and environmental receptors through treatment, engineering controls and institutional controls ( i.e. , deed restrictions). More specifically, the selected remedy’s in-situ oxida tion will reduce the mass of contamination and protect the ecological resources by reducing the loading of contam inated water into the EBSR. Institutional controls will limit future Site use to prevent ingestion of groundwater during the period required for restoration. Institutional co ntrols will also prev ent the extraction of groundwater from locations that c ould cause the contamination to migrate. Long-term monitoring will allow for the evaluation of the cleanup and the identification of any future threats. The selected remedy will reduce potential human health risk levels such that they do not exceed EPA’s acceptable risk range of 10 -4 

## to 10 -6 

## for incremental carcinoge nic risk, and such that the non-carcinogenic hazard is below a level of concern. It will reduce potential human health risk levels to protective ARARs levels, i.e. , the remedy will comply with ARARs and TBC criteria. Implementation of the selected remedy will not pose any unacceptable short-term risks or cause any cross-media impacts.

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## 37 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary At the time that the ARAR-based Ground Water Cleanup Levels id entified in the ROD and ROD Amendment and newly promulgated ARARs and modified ARARs that call into question the protectivene ss of the remedy have been achieved and have not been exceeded for a period of three consecutive year s, a risk assessment shall be performed on the residual ground water contamination to determine whether the remedy is protective. This ri sk assessment of the residual ground water contamination will follow EPA procedures and will assess the cumulative carcinogenic and non-carcinogenic risks posed by ingestion of ground water and inhalation of VOCs from domestic water usage. If, after review of the risk assessment, the remedy is not determined to be protective by EPA, the remedial action will continue until protective levels are achieved and have not been exceeded for a period of three consecutive years, or until the remedy is otherwise deemed protective. These protectiv e residual levels shall c onstitute the final cleanup levels for this ROD and shall be considered performance standards for any remedial action. 2. The Selected Remedy Complies With ARARs ARARs were identified during the de velopment of the 2002 OU I ROD and were reviewed as part of this ROD Amendment process. Several Maine statutes were updated to reflect their current citations a nd are noted in Tables 10 - 12. In addition, a 2005 risk assessment guidance was added as a TBC to be used when fu ture risk assessments are conducted. No other changes were made. The most significant ARARs reflect the ground water cleanup levels. The federal MCLs and non-zero MCLGs govern the quality of drinking water provided by public water supply and are relevant and appropriate re quirements for groundwater remedi ation at the Site. The state MEGs are also relevant and appropriate chemi cal-specific ARARs. The Maine Standards for Hazardous Waste Facilities, which include the state MEGs, require that a miscellaneous unit be closed in a manner that ensures hazardous waste shall not appear in gr ound or surface waters above MEGs. The Site is considered analogous to a miscellaneous hazardous waste unit. The selected amended remedy will comply with these and all other federal and any more stringent state ARARs listed in Tables 10- 12 for the remedial action. Further discussion about ARARs may be found in Section 3 of the FS Report. 3. The Selected Remedy is Cost-Effective In EPA’s judgment, the selected remedy is cost-effective because the remedy’s costs are proportional to its overall effectiveness (see 40 CFR 300.430(f)(1)(ii)(D)). This determination was made by evaluating the overall effectiveness of those alternatives that satisfied the threshold criteria ( i.e. , that are protective of human health and th e environment and comply with all federal and any more stringent state AR ARs, unless appropriately waived). Overall effectiveness was evaluated by assessing, in combination, three of the five balanci ng criteria: long-term effectiveness and permanence; reduction in toxi city, mobility, and volume through treatment; and short-term effectiveness. The overall effectivenes s of each alternative then was compared to the alternative’s costs to determine cost-effectiveness.

Record of Decision Amendment - Operable Unit I 

## 38 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## OU I Record of Decision Amendment Part 2: The Decision Summary The relationship of the overall effectiveness of this remedial alternative was determined to be proportional to its costs and hence represents a reasonable valu e for the money to be spent. Alternatives GW-4 and GW-4a wo uld be equally ARAR-compliant in that each alternative would achieve the groundwater cleanup leve ls in a reasonable time period. The cost effectiveness of both Alternatives GW-4 and GW-4a is predicated upon the ability ofthe in-situ reagents and biostimulants to eliminate the source of the contamination in order for the aquifer to achieve full restoration. The time frame for the source remova l under both Alternatives GW-4 and GW-4a is 15 years. Subsequent to the 15 year period required for source removal, an additional 15 to 60 years was estimated to achieve full aquifer restor ation for Alternative GW-4 with the use of longterm groundwater extraction and trea tment. This results in an estimated range for the cleanup of 30 to 75 years, with 60 years being selected as a reasonable estimate for the basis of alternative comparison and cost evaluation. For Alterna tive GW-4a, without th e use of long-term groundwater extraction and treatmen t, the estimated time period to achieve aquifer restoration is 30 to 74 years, resulting in a cl eanup range of 45 to 89 years, with 80 years being selected as a reasonable estimate for the basis of alternative comparison and cost evaluation. Given that the groundwater plume is located unde r roadways and greenspace with in an area where groundwater use is prohibited and a water line is available, th ere is no consequence to waiting the additional 20 years. GW-4 has an estimated present worth of $10.5 million as compared to the estimated present worth of GW-4a of $4.5 milli on. Further, the projected total cost (not adjusted for present value) for GW-4 is $20.8 million, as compared to $6.5 million for GW-4a. Therefore, GW-4a, with a $6 million lower present value and $14.3 million lower total cost, is the most cost effective alternative given that GW-4 provides an equivale nt level of protection of human health and the environmental and compliance with ARARs. 4. The Selected Remedy Utilizes Permanent Solutions and Alternative Treatment or Resource Recovery Tec hnologies to the Maximum Extent Practicable Once the Agency identified those alternatives that attain or, as appropriate, waive ARARs, and that are protective of human health and th e environment, EPA identified which alternative utilizes permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable . This determination was made by deciding which one of the identified alternatives provides the best balance of trad e-offs among alternatives in terms of: (1) long-term effec tiveness and permanence; (2) reduction of toxicity, mobility or volume through treatment; (3) short- term effectiveness; (4) implementability; and (5) cost. The balancing test emphasized the long-term effectiveness and permanence and the reduction of toxicity, mobility and volume through treatment, and considered the preference for treatment as a principal element, the bias against off-site land disposal of untreated waste, and community and state acceptance. The selected remedy provide s the best balance of trade-offs among the alternatives. The selected remedy provides long-term effectiveness and permanence while using treatment to reduce the toxicity, mobility, a nd volume of the contaminant mass material. Chemical oxidation treatment is a principal element of the selected remedy in achieving permanent aquifer restoration. The addition of bio-stimulants will enhance the restoration

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## 39 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary process. The State of Maine and the community were very su pportive of the selected remedy. The potential to more cost effectively achieve cleanup goals in a similar time frame supports the selection of Alternative GW-4a over Alternative GW-4, which would achieve essentially the same outcome at a substantially greater cost. 5. The Selected Remedy Satisfies the Preference for Treatment Which Permanently and Significantly Reduces the Toxicity, Mobility or Volume of the Hazardous Substances as a Principal Element The principal element of the selected remedy is the in-situ treatment of groundwater and DNAPL. This element addresses the primary th reats at the Site – highly contaminated groundwater, DNAPL, and the remaining soil contam ination – as defined by the risk to local water supplies and the exceedance of MCLs/MEGs. The selected remedy satisfies the statutory preference for treatment as a principal elemen t by reducing the contamination in the aquifer through in-situ treatment of the mass of contamination in the ove rburden soil and bedrock and in the overburden and bedrock groundwater. 6. Five-Year Reviews of the Selected Remedy are Required Because this remedy will result in hazardous substances remaining on-site above levels that will not allow for unlimited use and unrestricte d exposure, a review will be conducted within five years after initiation of the remedial acti on to ensure that the re medy continues to provide adequate protection of human health and the envir onment. This review will continue every five years as long as waste remains in place above cleanup levels.
N. DOCUMENTATION OF NO SIGNIFICANT CHANGES On May 25, 2006, EPA presented a proposed plan that described eliminating the longterm extraction and treatment of the groundwat er component of the original 2002 OU I ROD remedy. The Plan also noted a minor change that eliminated the enhanced flushing with surfactants/co-solvents. EPA reviewed all written and verbal comments submitted during the public comment period, which was open from May 26 to June 25, 2006. None of the comments opposed the proposed amendment to the 2002 OU I ROD, and it was determined that no significant changes to the remedy, as originally id entified in the Proposed Plan, were necessary. EPA has prepared a responsiveness summary to a ddress the comments received during the public comment period. The responsiveness summary is attached as Appendix C. One minor change in the cost of Alternat ives GW-4 and GW-4a has occurred since the public comment period. The FFS reported the presen t value as a net rate of 3.9%. EPA guidance recommends a discount rate of 7%. The costs reported in the ROD are based on the discount rate of 7%. The revision does not impact capital costs for either alternative. The present value of long-term costs for Alternative GW-4 in the Proposed Plan and FFS was reported as $5,651,353. The revised present value for these long-term costs for GW-4 is $3,614,296. The revised total present value (capital and long-term costs) for GW-4 is $10.5 million. The present value of longterm costs for Alternative GW-4a in the Pr oposed Plan and FFS was reported as $1,263,640. The Record of Decision Amendment - Operable Unit I 

## 40 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## OU I Record of Decision Amendment Part 2: The Decision Summary revised present value for GW-4a is $926,674. The re vised total present va lue (capital and longterm costs) for GW-4a is $4.5 million. There is no significant impact to the comparative analysis or other aspects of the alterna tive evaluation since the cost differential remains substantial and GW-4a is more cost effective than GW-4. O. STATE ROLE ME DEP has reviewed the various alterna tives and has indicated its support for the selected remedy. The State has also reviewed the FFS with resp ect to amendment to determine whether the selected remedy is in compliance with applicable or relevant and appropriate state environmental and facility siting laws and regul ations. The State of Maine concurs with the amendment to the selected remedy for the Eas tland Woolen Mill Superfund Site. A copy of the declaration of concurrence is attached as Appendix B.

Record of Decision Amendment - Operable Unit I 

## 41 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## Record of Decision Amendment Part 2- The Decision Summary

APPENDIX A TABLES AND FIGURES NOT IN ROD TEXT

Record of Decision Amendment - Operable Unit I 

## 42 Version: Final Eastland Woolen Mill Superfund Site Date: September 28, 2006 Corinna, Maine

## TABLE 8 PRESENT VALUE OF ANNUAL AND PERIODIC COSTS - YEARS 1 THROUGH 80 ALTERNATIVE GW4a: MASS REDUCTION WITHOUT HYDRAULIC CONTAINMENT OU1 FOCUSED FEASIBILITY STUDY REPORT EASTLAND WOOLEN MILL SUPERFUND SITE
Year (t) GW Monitoring Synoptic GW Levels IC Monitoring Pump and Treat O&M CORINNA, MAINE Annual Reporting Biostimulant ReIn j ection Five-Year Reviews Contingenc y (@ 10%) PM (@ 5%) Tech. Support (@

10%) Total NonDiscounted

Cost Total Present Value 0 $ - $ - $ - $ - $ - $ - $ - $ - $ - $ - $ - $

- 1 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 76,846 $ 2 $ 55,000 $

- $

- - $ 5,000 $ 96,363 $ 5,000 $ 16,136 $ 8,875 $ 17,750 $ 204,124 $ 178,290 $ 3 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 67,120 $ 4 $ 55,000 $

- $

- - $ 5,000 $ 96,363 $ 5,000 $ 16,136 $ 8,875 $ 17,750 $ 204,124 $ 155,725 $ 5 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 58,625 $ 6 $

- $

- $

- $

- - $ 96,363 $ 5,000 $ 10,136 $ 5,575 $ 11,150 $ 128,224 $ 85,441 $ 7 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 3,939 $ 8 $

- $

- $

- $

- - $ 96,363 $ 5,000 $ 10,136 $ 5,575 $ 11,150 $ 128,224 $ 74,628 $ 9 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 44,725 $ 10 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 3,215 $ 11 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 3,005 $ 12 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 2,808 $ 13 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 34,120 $ 14 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 2,453 $ 15 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 2,292 $ 16 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 2,142 $ 17 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 26,030 $ 18 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 1,871 $ 19 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 1,749 $ 20 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 1,635 $ 21 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 19,858 $ 22 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 1,428 $ 23 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 1,334 $ 24 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 1,247 $ 25 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 15,150 $ 26 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 1,089 $ 27 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 1,018 $ 28 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 951 $ 29 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 11,558 $ 30 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 831 $ 31 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 777 $ 32 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 726 $ 33 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 8,817 $ 34 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 634 $ 35 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 592 $ 36 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 554 $ 37 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 6,727 $ 38 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 484 $ 39 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 452 $ 40 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 422 $ 41 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 5,132 $ 42 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 369 $ 43 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 345 $ 44 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 322 $ 45 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 3,915 $ 46 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 281 $ 47 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 263 $ 48 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 246 $ 49 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 2,987 $ 50 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 215 $ 51 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 201 $ 52 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 188 $ 53 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 2,279 $ 54 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 164 $ 55 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 153 $ 56 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 143 $ 57 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 1,738 $ 58 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 125 $ 59 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 117 $ 60 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 109 $ 61 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 1,326 $ 62 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 95 $ 63 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 89 $ 64 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 83 $ 65 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 1,012 $ 66 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 73 $ 67 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 68 $ 68 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 64 $ 69 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 772 $ 70 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 55 $ 71 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 52 $ 72 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 48 $ 73 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 589 $ 74 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 42 $ 75 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 40 $ 76 $

- $

- $

- $

- $

- - $ 5,000 $ 500 $ 275 $ 550 $ 6,325 $ 37 $ 77 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 449 $ 78 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 420 $ 79 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 392 $ 80 $ 55,000 $

- $

- - $ 5,000 $

- $ 5,000 $ 6,500 $ 3,575 $ 7,150 $ 82,225 $ 367 $

TOTAL $ 1,430,000 $

- $

- - $ 130,000 $ 385,452 $ 400,000 $ 234,545 $ 129,000 $ 258,000 $ 2,966,997 $ 926,674 $ Total before applied costs $ 2,345,452 PV Discount Rate (i) 0.070 PV = non-discounted cost X 1/((1+i)t)ROD TABLE 10LOCATION-SPECIFIC ARARS FOR ALTERNATIVE GW4AOU1 FOCUSED FEASIBILITY STUDYEASTLAND WOOLEN MILL SITE’CORINNA, MAINERegulatoryAuthorityLocationCharacteristicRegulationsStatusRequirementSynopsisAction to be Taken to Attain ARARFederalFloodplainsFloodplain ManagementExecutive Order No. 11988 [40ApplicableRequires federal agencies to evaluate potentialadverse effects associated with direct and indirectOnly de minimis impacts to floodplains and the river channel areexpected as part of this alternative. The only impact will be theCode of Federal Regulations(CFR) Part 6, App. A]development of a floodplain. Alternatives thatinvolve modification/construction within afloodplain may not be selected unless adetermination is made that no practicablealternative exists. If no practicable alternativeexists, potential harm must be minimized andaction taken to restore and preserve the naturaland beneficial values of the floodplain. UnitedStates Environmental Protection Agency (USEPA)must also provide the public with early andcontinuing information concerning floodplaininstallation of the discharge pipe for the discharge from thegroundwater treatment system. The impacts associated with theinstallation of the discharge are unavoidable and efforts will bemade to minimize adverse effects on floodplains to the extentpracticable. Least damaging methods will be specified to achieveremedial goals. Restoration actions will be taken to restorenatural and beneficial values of the floodplain.management.FederalWetlandsProtection of WetlandsExecutive Order No. 11990 [40CFR Part 6, App. A]ApplicableUnder this Order,federal agencies are required tominimize the destruction, loss, or degradation ofwetlands, and preserve and enhance natural andbeneficial values of wetlands. If remediation isrequired within wetlands areas, and no practicalalternative exists, potential harm must beminimized and action taken to restore natural andOnly de minimis impacts to wetlands and the river channel areexpected as part of this alternative. The only impact will be theinstallation of the discharge pipe for the discharge from thegroundwater treatment system. The impacts associated with theinstallation of the discharge are unavoidable and efforts will bemade to minimize adverse effects to aquatic ecosystems.beneficial values.FederalNavigable WatersRivers and Harbors Act of1899 [33 USC 403 et seq.; 33CFR Parts 320-323]Relevant andAppropriateSection 10 of the Rivers and Harbors Act of 1899requires that the construction of any structure in orover any "navigable water of the U.S." includingthe excavation from or deposition of material insuch waters, or any obstruction of alteration insuch waters, obtain authorization from theOnly de minimis impacts to wetlands and the river channel areexpected as part of this alternative. Site activities will bedesigned and implemented to avoid obstruction and minimizealteration of navigable waters. Disturbed areas will be restored.Secretary of the Army acting through the U.S.Army Corps of Engineers.FederalEndangered SpeciesEndangered Species Act [16United States Code (USC)1531 et seq.; 40 Code ofFederal Regulations (CFR)6.302(h); 50 CFR Part 200, 50CFR Part 402]Applicable, if suchspecies areencounteredThis statute requires that federal agencies avoidactivities that jeopardize threatened orendangered species or adversely modify habitatsessential to their survival. Mitigation measuresshould be considered if a listed species or habitatmay be jeopardized.Although no current listed endangered or threatened species ortheir nests have been identified at the site, their presence hasbeen noted in the area. As part ofthe remedial action, pertinentlists will be reviewed to assess whether Federally listed speciesmay be present. During the remedial action, measures such asrelocation or seasonal work limits for specific actions would beimplemented to protect listed species, if any are identified.Table 11 GW4a ARARs.xlsPage 1 of 3October 4, 2006ROD TABLE 10LOCATION-SPECIFIC ARARS FOR ALTERNATIVE GW4AOU1 FOCUSED FEASIBILITY STUDYEASTLAND WOOLEN MILL SITE’CORINNA, MAINERegulatoryAuthorityLocationCharacteristicRegulationsStatusRequirementSynopsisAction to be Taken to Attain ARARFederalSurface WatersFish and Wildlife CoordinationAct [16 USC 661 et seq.; 40ApplicableRequires Federal agencies involved in actions thatwill result in the control of structural modification ofOnly de minimis impacts to fish and wildlife resources areexpected as part of this alternative. The only impact will be theCFR Section 6.302(g); 33 CFRPart 320]any stream or body of water for any purpose, totake action to protect the fish and wildliferesources that may be effected by the action.USEPA must consult with the U.S. Fish andWildlife Service and the appropriate state agencyto ascertain the means and measures necessaryto mitigate, prevent, and compensate for projectrelated losses of wildlife resources and to enhanceinstallation of the discharge pipe for the discharge from thegroundwater treatment system. The impacts associated with theinstallation of the discharge are unavoidable and efforts will bemade to minimize adverse effects to aquatic ecosystems.USEPA will take measures to mitigate or compensate adverseproject-related impacts, if determined necessary by USEPA. TheU.S. Fish and Wildlife Service and the appropriate state agencywill be consulted.the resources.StateWetlandsMaine Wetlands ProtectionRule [06-096 Code of MaineRegulations (CMR), Chapter310]ApplicableThese regulations outline requirements for certainactivities related to fresh water wetlands greaterthan 10 acres or with an associated stream, brook,or pond. The regulations prohibit activities, whichwould have an unreasonable impact on theOnly de minimus impacts to wetlands and the river channel areexpected as part of this alternative. The only impact will be theinstallation of the discharge pipe for the discharge from thegroundwater treatment system. The impacts associated with theinstallation of the discharge are unavoidable and efforts will bewetland or cause a loss in wetland area, functions,and values if there is a less practicable alternativeto the project that would be less damaging to theenvironment. If there is no practicable alternative,there must be minimal alteration of the wetlandand compensation (off-setting) may be required.made to minimize adverse effectsto aquatic ecosystems. Thisalternative will be designed and implemented to meet activitystandards. Remedial actions within 100 feet of the East BranchSebasticook River will be designed and implemented so as to notunreasonably interfere with stream flow or water quality and tominimize adverse effects on aquatic habitat, fisheries, andaquatic life. Function and value assessments will be performedfor existing wetland/habitat, and restoration activities performedso that post-remediation-site wetlands are at least comparable toexisting on-site wetlands.StateWetlandsSurface WatersMaine Natural ResourcesProtection Act, permit-by-RuleApplicableThis rule prescribes standards for specificactivities that may take place in or adjacent toResponse actions that involve the disturbance of soil material inor adjacent to a wetland, great pond, stream or brook will meetStandards [06-096 CMR,Chapter 305]wetlands and water bodies. The standards aredesigned to ensure that the disturbed soil materialis stabilized to prevent erosion and siltation of thethese standards. Only de minimus impacts to wetlands and theriver channel are expected as part of this alternative.water.StateEndangered SpeciesMaine Endangered SpeciesAct and Regulations [12 MaineApplicableThe State of Maine has authority to research, list,and protect any species deemed endangered orEndangered and threatened species lists will be reviewed toassess whether Maine listed species may be present. During theRevised Statutes Annotated(MSRA) Section 7751-7756;09-137 CMR 008](Revised:Maine EndangeredSpecies Act and Regulations[12 Maine Revised StatutesAnnotated (MSRA) Section12801-12809; 09-137 CMR008])threatened. These species are listed as eitherendangered or threatened in the state regulations.The Maine Department of Inland Fisheries andWildlife also has developed the followingadministrative categories for species notconsidered endangered or threatened, butconsidered important for research and furtherevaluation: Maine WatchList, Special ConcernList, and Indeterminate Category. TheDepartment determinesappropriate use(s) ofvarious habitats on a case-by-case basis. TheMaine lists may differ from the federal lists ofendangered species.remedial action, measures will be implemented to protect listedspecies if identified or encountered.Table 11 GW4a ARARs.xlsPage 2 of 3October 4, 2006ROD TABLE 10LOCATION-SPECIFIC ARARS FOR ALTERNATIVE GW4AOU1 FOCUSED FEASIBILITY STUDYEASTLAND WOOLEN MILL SITE’CORINNA, MAINERegulatoryAuthorityLocationCharacteristicRegulationsStatusRequirementSynopsisAction to be Taken to Attain ARARStateShoreland areasMandatory Shoreland ZoningAct [Title 38, Maine RevisedApplicableTo protect and conserve shoreland areas bycontrolling activities within250 feet of high waterOnly de minimus impacts to shoreland areas will occur as part ofthis alternative. The only impact will be the installation of theStatue Annotated (MRSA),Sections 435-449]. Town ofCorinna Shoreland ZoningOrdinance, enacted 29mark, as defined in state law.discharge pipe for the discharge from the groundwater treatmentsystem. The impacts associated with the installation of thedischarge are unavoidable and efforts will be made to minimizeadverse effects to shoreland areas. Measures will be takenSeptember 1991.(Revised:Mandatory Shoreland ZoningAct [Title 38, Maine RevisedStatue Annotated (MRSA),Sections 435-449]. Town ofCorinna Shoreland ZoningOrdinance, enacted 29during selection, design, and implementation of remedial actionsto comply with the ordinance wherever practicable.September 1991 and amendedMarch 2004.)StateActivities that exposesoil with potential forerosionErosion and SedimentationControl [38 MRSA subsection420-C], Chapter 500,Stormwater ManagementRules and Chapter 502, DirectWatershed of WaterbodiesApplicableErosioncontrolmeasures must be in place beforeactivities, such as filling, displacing or exposingsoil or other earthen materials take place.Where Site activities described in 38 MRSA 420-C and 420-Doccur, USEPA will implement appropriate controls to addresserosion, sedimentation and stormwater. Erosion controlmeasures will be in place prior to the construction of thegroundwater treatment plant and associated discharge pipe.Most at Risk from NewDevelopment.(References the revised Regulations)(Revised:Erosion andSedimentation Control [Title 38MRSA subsection 420-Cand420-D], Chapter 500,Stormwater ManagementRules and Chapter 502, DirectWatershed of WaterbodiesMost at Risk from NewDevelopment.)StateBusiness/ResidentialDistrict of CorinnaMaine Site Location ofDevelopment Law andregulations (38 MRSASections 481-490, CMRChapter 375).ApplicableRegulations apply to control activities at certainfederal developments so that there are minimaladverse impacts to natural resources, to includespecifically, erosion andsedimentation control,noise control, and air quality control.To the extent that USEPA leave three or more acres unvegetatedfor a period of a year or more, or requires 20,000 square feet ofimpervious area, remedial alternatives will comply with theserequirements, if deemed appropriate. The footprint of thegroundwater treatment plant and other impervious areas isexpected to be less than 20,000square feet. Stormwatermanagement, erosion and sedimentation controls, and trafficcontrols will be designed andimplemented so that adverseeffects on natural resources are minimized.StateSpecial Habitats andMaine Natural Areas ProgramTo Be Considered ifThese state programs govern special habitats orIf such special areas are identified at the site, the appropriateCriteria,Communities(12 MRSA Section 544)such special areascommunities.state programs will be consulted.Advisoriesare identified at theandsiteGuidanceTable 11 GW4a ARARs.xlsPage 3 of 3October 4, 2006ROD TABLE 11CHEMICAL-SPECIFIC ARARS FOR ALTERNATIVE GW4AOU1 FOCUSED FEASIBILITY STUDYEASTLAND WOOLEN MILL SITECORINNA, MAINERegulatory AuthorityChemicalMediumRegulationsStatusRequirementSynopsisAction to be Taken to Attain ARARFederalGroundwaterSafe Drinking Water Act (SDWA),National Primary Drinking WaterRegulations (NPDWR), MaximumContaminant Levels [40 Code ofFederal Regulation (CFR) Parts141.11 - 141.16 and 141.50 -141.53]Relevant andAppropriateThe National Primary Drinking Water Regulationsestablish Maximum Contaminant Levels (MCLs) andMaximum Contaminant Level Goals (MCGLs) for severalcommon organic and inorganic contaminants. MCLsspecify the maximum permissible concentrations ofcontaminants in public drinking-water supplies. MCLs arefederally enforceable standards based in part on theavailability and cost of treatment techniques.MCLs and non-zero MCLGs were used to establishgroundwater cleanup goals.Aggressive in-situ treatment and hydraulic containment bygroundwater extraction is expected to decrease the estimatedtime to attain MCLs and non-zero MCLGs to approximately 30to 90 years.StateMaine Department of HumanServices Rules Relating toDrinking Water [10-144A Code ofMaine Regulations (CMR) Chapter231-233]MCLGs specify the maximum concentration at which noknown or anticipated adverse effect on humans will occur.MCLGs are non-enforceable health-based goals that arealways set equal to or lower than MCLs.(Revised:Maine Department ofHealth and Human Services RulesRelating to Drinking Water [10-144A Code of Maine Regulations(CMR) Chapter 231-233])State Criteria, Advisoriesand GuidanceGroundwaterMaine Standards for HazardousWaste Facilities, MiscellaneousUnits (06-096 CMR Chapter 854,Section 15) Maximum ExposureGuidelines (MEGs). (MaineDepartment of Human ServicesBureau of Health MaximumRelevant andAppropriateThe Maine MEGs are relevant and appropriate becausethey are the basis for some of the interim cleanup levels(i.e., the Interim Groundwater Cleanup Levels) for the Sitegroundwater. MEGs were identified as a action specificstandard in the FS. The Maine standards for HazardousWaste Facilities require that a miscellaneous unit must beclosed in a manner that willensure that hazardous wasteMEGs were used to establish groundwater cleanup levelswhen the MEG concentration was lower than the MCL or nonzero MCLG for that constituent.Cleanup actions will be taken to meet MEGs in groundwater.Exposure Guidelines for DrinkingWater (1992))shall not appear in ground or surface waters aboveMEGs. The Site is considered analogous to amiscellaneous hazardous waste unit.[Revised:Maine Standards forHazardous Waste Facilities,Miscellaneous Units (06-096 CMRChapter 854, Section 15)Maximum Exposure Guidelines(MEGs). (Maine Department ofHealth and Human ServicesThe MEGs are non-promulgated non-enforceablerecommendations for concentrations of chemicalconstituents in drinking water below which there isminimal risk of deleterious health effects resulting fromlong-term ingestion.Bureau of Health MaximumExposure Guidelines for DrinkingWater (1992))]ROD Table 12GW4a ARARs.xlsPage 1 of 210/4/06ROD TABLE 11CHEMICAL-SPECIFIC ARARS FOR ALTERNATIVE GW4AOU1 FOCUSED FEASIBILITY STUDYEASTLAND WOOLEN MILL SITECORINNA, MAINERegulatory AuthorityChemicalMediumRegulationsStatusRequirementSynopsisAction to be Taken to Attain ARARFederal Criteria,GroundwaterUnited States EnvironmentalTo BeRisk reference doses (RfDs) are estimates of dailyRfDs were used in developing the human-health riskAdvisories andProtection Agency (USEPA) RiskConsideredexposure levels that are unlikely to cause significantassessment.GuidanceReference Dosesadverse non-carcinogenic health effects over a lifetime.Federal Criteria,GroundwaterUSEPA Carcinogenic AssessmentTo BeCSFs are used to compute the incremental cancer riskCSFs were used in developing the human-health riskAdvisories andGroup, Cancer Slope FactorsConsideredfrom exposure to site contaminants and represent theassessment.Guidance(CSFs)most up-to-date information oncancer risk from USEPA'sCarcinogenic Assessment Group.Federal Criteria,Advisories andGuidanceGroundwaterGuidelines for Carcinogen RiskAssessment EPA/630/P03/001F (March 2005)To BeConsideredProvides guidance on conducting risk assessmentsinvolving carcinogens.Until updated or replaced, these guidances will be used byEPA to evaluate all risk assessments on carcinogenicityconducted in the future at the Site.Supplemental Guidance forAssessing Susceptibility fromEarly-Life Exposure toCarcinogens EPA/630/R03/003F (March 2005)State Criteria,GroundwaterMaine Draft Remedial ActionTo BeThese draft guidelines provide specific chemicalThese guidelines were used to establish the soil cleanupAdvisories andGuidelines for HazardousConsideredconcentrations determined by the State of Mainelevels for the Non-time Critical Removal Action (NTCRA) andGuidanceSubstances in SoilDepartment of Environmentalprotection (MEDEP) to beto evaluate the level of treatment required as part of the in-situprotective under various exposure scenarios and forapplication.groundwater.ROD Table 12GW4a ARARs.xlsPage 2 of 210/4/06ROD TABLE 12ACTION-SPECIFIC ARARS FOR ALTERNATIVE GW4AOU1 FOCUSED FEASIBILITY STUDYEASTLAND WOOLEN MILL SITECORINNA, MAINERegulatoryAuthorityActionRegulationsStatusRequirementSynopsisAction to be Taken to Attain ARARFederalIn-situ treatmentSafe Drinking Water Act (SDWA)Underground Injection Control (UIC)Program (40 Code of FederalRegulations (CFR)Parts 144, 146,and 147)ApplicableThese regulations outline minimum program andperformance standards for underground injectionprograms. Technical criteria and standards forsiting, operation and maintenance, closure, andreporting and record keeping as required forpermitting are set forth in Part 146.This alternative involves the use of injection wells to deliverthe in-situ reagents into the groundwater. This alternative willbe implemented in accordance with the criteria and standardsset forth in these regulations.FederalTreatment,storage, ordisposal ofhazardouswasteResource Conservation andRecovery Act (RCRA), 42 UnitedStates Code (USC) §6901 et seq.,Air Emissions Standards forEquipment Leaks, 40 CFR 264Subpart BBApplicable ifrelevant equipmentcontains orcontacts hazardouswastes with organicconcentrations of atleast 10 percent byweight.This regulation applies to equipment that containsor contacts hazardous wastes with organicconcentrations of at least 10 percent by weightthat are managed in particular types of treatment,storage or disposal units. The regulationaddresses equipment leaks and includesstandards for particular types of equipment(compressors and open-ended valves or lines, forexample), record keeping standards and reportingstandards.Data collected to date do not suggest that the presence ofhazardous waste with organic concentrations greater than 10percent by weight. If threshold conditions are met, theequipment in the groundwater treatment plant will beoperated and record keeping performed to meet thesestandards.FederalGroundwatermonitoring forthe Treatment,storage, ordisposal ofhazardousRCRA, 42 USC §6901 et seq.,Releases from Solid WasteManagement Units, 40 CFR Part264, Subpart FApplicableRequirements for the installation of groundwatermonitoring wells and compliance monitoring.This alternative would comply with the requirements for theinstallation of groundwater monitoring wells and a compliancemonitoring program.wasteFederalDischargeofdredged(excavated soil)materials tosurface watersand wetlandsClean Water Act (CWA), 33 USC§§1251-1357ApplicableSection 404 of the CWA regulates the dischargeof dredged or fill materials to U.S. waters,including wetlands. Filling wetlands would beconsidered a discharge of fill materials.Procedures for complying with regulatoryconditions are contained in 33 CFR Part 323.Only de minimus impacts to wetlands and the river channelare expected as part of this alternative. The only impact willbe the installation of the discharge pipe for the dischargefrom the groundwater treatment system. The impactsassociated with the installation of the discharge areunavoidable andGuidelines for Specification of Disposal Sites forDredged or Fill Material at 40 CFR Part 230,promulgated under CWA Section 404(b)(1),maintain that no discharge of dredged or fillmaterial will be permitted if there is a practicalalternative that would have less effect on theaquatic ecosystem. If adverse impacts areunavoidable, action must be taken to restore orcreate alternative wetlands.efforts will be made to minimize adverse effects to aquaticecosystems. Function and value assessments will beperformed for existing wetland/habitat, and restorationactivities performed so that post-remediation on-site wetlandsand river are at least comparable to existing on-site wetlands.Proposed activities will meet the substantive requirements ofProgrammatic General Permit conditions, to the extentpracticable.FederalSurfaceWaterDischargeCWA National Pollutant DischargeElimination System (NPDES) 40CFR 122, 125, 131 and 136ApplicableThis rule limits forthe discharge of pollutants fromany point source into U.S. waters. This rule takesinto account the federal and state ambient waterquality standards.All substantive requirements of this regulation will be met withrespect to the discharge of any water from the groundwatertreatment plant. Appropriatecontrols will be implementedwith best management practices to address any extractedand treated groundwater.sPage 1 of 310/4/2006ROD TABLE 12ACTION-SPECIFIC ARARS FOR ALTERNATIVE GW4AOU1 FOCUSED FEASIBILITY STUDYEASTLAND WOOLEN MILL SITECORINNA, MAINERegulatoryAuthorityActionRegulationsStatusRequirement SynopsisAction to be taken to Attain ARARStateSurfaceWaterDischargeWaste Discharge PermittingProgram [06-096 Code of MaineRegulations (CMR) Chapters 520-529]ApplicableThis rule requires permits issued by MaineDepartment of Environmental Protection(MEDEP) for the discharge of pollutants from thepoint sources.All substantive requirements of this regulation will be met withrespect to the discharge of any water from the groundwatertreatment plant. Appropriatecontrols will be implementedwith best management practices to address any extractedand treated groundwater.StateIn-situtreatmentUnderground Injection Control (UIC)Program [06-096 CMR Chapter 543]ApplicableThese regulations outline minimum program andperformance standards for underground injectionprograms. Technical criteria and standards forsiting, operation and maintenance, closure, andreporting and record keeping as required forpermitting are set forth in Part 146.This alternative involves the use of injection wells to deliverthe in-situ reagents into the groundwater. This alternative willbe implemented in accordance with the criteria and standardsset forth in these regulations.StateActionsthatmaydegrade surfacewater qualityMaine Water Classification Program(38 Maine Revised StatutesAnnotated (MRSA) Section 464-470)ApplicableThis program sets forth standards for theclassification of Maine's water. The East BranchSebasticook River is classified as Class C.Activities in a water body cannot lower waterquality below the designated classification.The groundwater treatment plant will be designed andimplemented in a manner that the effluent discharge does notdegrade the chemical, physical, or biological integrity of theEast Branch Sebasticook River.StateActionsthatmaydegrade surfacewater qualityMaine Surface Water ToxicsProgram [38 MRSA Section 420, 06-096 CMR Chapter 530.5](Revised:Maine Surface WaterToxics Program [38 MRSA Section420, 06-096 CMR Chapters 530 and584])ApplicableThisperformancestandard establishes numericalsurface water quality standards for all Mainesurface water.The groundwater treatment plant will be designed andimplemented in a manner that the effluent discharge does notdegrade the chemical, physical, or biological integrity of theEast Branch Sebasticook River.StateManagementofcontaminatedmediaMaine Hazardous WasteManagement Rules [38 MRSASection 1301 et seq., 06-096 CMRChapter 850-857]Relevant andAppropriateThese rules establish performance standards fortreatment, disposal, and/or storage of mediacontaminated with hazardous waste piles, tanks,and miscellaneous units.To the extent they are more stringent than federal RCRArequirements, and to the extentpracticable, United StatesEnvironmental Protection Agency (USEPA) will design andoperate response actions to meet the substantiverequirements of these regulations.StateActivitiesthatexpose soil withpotential forerosionErosion and Sedimentation Control[38 MRSA subsection 420-C],Chapter 500, StormwaterManagement RulesApplicableErosioncontrolmeasures must be in place beforeactivities, such as filling, displacing or exposingsoil or other earthen materials take place.Where Site activities described in 38 MRSA 420D or 38MRSA 481-490 occur, USEPA will implement appropriatecontrols to address erosion, sedimentation and stormwater.Applicable plans will be coordinated with MEDEP prior toimplementation.StateGeneration of airemissionsMaine Air Quality Control Laws;Protection and Improvements of Air(38 MRSA 581-608A), Chapters 101,105, 110, and 115ApplicableThis law and its associated regulations detail therequirements, limitations, and exemptions of stateair emissions, including fugitive dust andemissions from air strippers.If remedial activities result in fugitive dust and/or treatmentthat includes emissions from air strippers, measures will betaken under this alternative to comply with these regulations.FederalGenerationofInvestigationDerived Waste(IDW)USEPA Office of Solid Waste andEmergency Response (OSWER)Publication 9345.3-03 FS, January1992To Be ConsideredManagement of IDW must ensure protection ofhuman health and the environment.IDW that may be produced from well installation andgroundwater sampling will be managed in a manner toprotect human health and the environment.sPage 2 of 310/4/2006ROD TABLE 12ACTION-SPECIFIC ARARS FOR ALTERNATIVE GW4AOU1 FOCUSED FEASIBILITY STUDYEASTLAND WOOLEN MILL SITECORINNA, MAINERegulatoryAuthorityActionRegulationsStatusRequirementSynopsisAction to be Taken to Attain ARARState Criteria,Advisories andGuidanceGeneration of airemissionsMaine Department of HumanServices Interim Ambient AirGuidelines, Memorandum February23, 1993(Revised:MaineDepartment of Human ServicesAmbient Air Guidelines, dated April2004)To Be ConsideredInterim ambient air guidelines are derived fromrisk assessment-based criteria or fromoccupational exposure criteria that are protectiveof ambient air quality.These guidelines will be considered during the design ofemissions control equipment.sPage 3 of 310/4/2006USG S TOPOGRAPHI C MA P APPROXIMAT E SCAL E 1 INC H = 2,00 0 FEE T CORINNA , MAIN E 198 2



## FIGUR E 1 SIT E LOCATIO N EASTLAN D WOOLE N MIL L SIT E GROUNDWATE R (OU1 ) RECOR D O F DECISIO N CORINNA , MAIN EFDRHE R EASTLAN D WDDLE N MILL 

### DPERABL E UNI T I 

# 0

SCHDD L STREE T YAR D

0 ' 175 ' ISO ' BUILDIN G 9 EXCAVjfflDR
- • (ARE A 4 ) / /

ARE A 2. 5 EXCAVATID N

ARE A 3 EXCAVATID N



### LEGEN D RI-TARGETE D AREA S NTCR A EXCAVATID N AREA S LIMIT S D F DPERABL E UNIT S

APPROXIMAT E SCAL E



### FIGUR E 2 O U I , O U II , AN D NTCR A WOR K AREA S EASTLAN D WOOLE N MIL L SIT E GROUNDWATE R (0U1 ) RECOR D O F DECISIO N CORINNA , MAIN EBUILDIN G 1 4 ARE A SOI L CONTAMINATIO N (NTCR A PHAS E I )

REMAININ G ARE A SOI L CONTAMINATIO N (NTCR A PHAS E II/O U I AREA )

FIGUR E 3 AREA S O F REMININ G SOI L CONTAMINATIO N AFTE R TH E NTCR A EXCAVATIO N PROGRA M LIMI T O F NTCR A SOI L EXCAVATIO N T O BEDROC K SURFAC E LIMI T O F SOI L CONTAMINATIO N REMAININ G AFTE R NTCR A EXCAVATION S COMPLETE D APPROXIMAT E SCAL E

0 ' 50 ' 100 ' 200 ' EASTLAN D WOOLE N MIL L SIT E GROUNDWATE R (0U1 ) RECOR D O F DECISIO N CORINNA , MAIN E

### 1 4 ARE A SOI L CONTAMINATIO N

REMAININ G ARE A 1 BEDROC K
° SURFAC E CONTAMINATIO N ~ LIN E O F CROSS-SECTIO N DEPICTE D I N I N FIGUR E 5
LIN E O F CROSS-SECTIO N DEPICTE D I N I N FIGUR E 6

LIMI T O F NTCR A SOI L EXCAVATIO N T O BEDROC K SURFAC E LIMI T O F SOI L CONTAMINATIO N REMAININ G AFTE R NTCR A EXCAVATION S COMPLETE D AREA S O F CONTAMINATIO N DESIGNATE D A S TH E O U I ISC O TARGE T ARE A AREA S O F CONTAMINATIO N DESIGNATE D FO R LONG-TER M MONITORIN G APPROXIMAT E SCAL E



### FIGUR E 4 O U I FOCU S AREA S 0 ' 50 ' 100 ' 200 ' 

### EASTLAN D WOOLE N MIL L SIT E GROUNDWATE R (0U1 ) RECOR D O F DECISIO N CORINNA , MAIN E: DATU M ELE V 0+0 0 

### 170.0 0NO. 

## m LL J

LL J Q L J:ox.

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. C LVATI

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### 0+5 0

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### 1+0 0 LEGEN D |>10pp m I TOTA L VOC s 1+5 0

STATI C WATE R TABL E

• BEDROC K

STATI C WATE R TABL E OVERBURDE N 2+0 0

NON-STATI C WATE R TABL E BEDROC K
NON-STATI C WATE R TABL E BEDROC K 

### FIGUR E 5 ARE A 1 CONTAMINATIO N REMAININ G AFTE R NTCR A - O U I FOCU S ARE A EASTLAN D WOOLE N MIL L SIT E GROUNDWATE R (0U1 ) RECOR D O F DECISIO N CORINNA , MAIN EUNCONTAMINATE D NATIV E TIL L 

# ^/W/tfWWJW/WjW/%%0%, 7///////////////////////. / 

### ///A7////////////^AV////A 

## y/////v//////////// / 

## //7////.

\ CONTAMINATE D TIL L REMAININ G AFTE R NTCRA ; T O B E TREATE D WIT H ISC O (PHAS E II )
CONTAMINATE D WEATHERE D BEDROC KREMAININ G AFTE R NTCR A T O B E TARGETE D B Y ISC O AN D BIOSTIMULATIO N (PHAS E III )
CONTAMINATE D BEDDIN G PLAN E FRACTUR E NETWOR KT O B E TREATE D WIT H ISC O AN D BIOSTIMULATIO N (PHAS E IV )

1
. NO T T O SCAL E
2
. BEDDIN G PLAN E FRACTURE S STRIK E T O TH E SOUTHEAS T AN D DI P A T APPROXIMATEL Y 55-65-
.



### FIGUR E 6 BEDROC K SOURC E CONTAMINATIO N REMAININ G AFTE R NTCR A - O U I FOCU S ARE A EASTLAN D WOOLE N MIL L SIT E GROUNDWATE R (OU1 ) RECOR D O F DECISIO N CORINNA , MAIN ESTREET MAIN RENEWAL DRIVE ROUTE 7/11 EAST BRANCH SEBASTICOOK RIVER

OM-06-75 OM-06-74 OM-06-73

OM-06-72 OM-06-71

OM-06-70

OM-06-69

OM-06-68 OM-06-67

OM-06-66 BM-06-44

BM-06-43 RB-04-02 OM-01-57/58 OM-01-51 OM-01-50

OM-00-46 OM-00-45

OM-00-20 IM-05-07 IM-04-04

BM-99-09 BM-04-37 BM-04-34 BM-04-32

BM-99-12F BM-99-10F

Map 18 Lot 44 Map 18 Lot 42 Map 18 Lot 62F

Map 18 Lot 41A

BM-06-45



## FIGURE 7 EASTLAND WOOLEN MILL SITE Legend

Estimated Limit of 2005 Chlorobenzene Compounds Detected at or Above Cleanup Levels in Overburden Groundwater Estimated Limit of 2005 Chlorobenzene Compounds Detected at or Above Cleanup Levels in Bedrock Groundwater Estimated Limit of 2002 Chlorobenzene Compounds Detected at or Above Cleanup Levels in Overburden Groundwater Estimated Limit of 2002 Chlorobenzene Compounds Detected at or Above Cleanup Levels in Bedrock Groundwater Existing Bedrock Long-Term Monitoring Location Existing Overburden Long-Term Monitoring Location Existing Bedrock Flute-Well Monitoring Location Former Drinking Water Well Long-Term Monitoring Location Active Drinking Water Long-Term Monitoring Location New Overburden Groundwater Monitoring Location New Bedrock Groundwater Monitoring Location 

### 115 0 115 57.5 Feet 

## GROUNDWATER CONTAMINATION GROUNDWATER (OU1) RECORD OF DECISION 2002 vs. 2005 CORINNA, MAINE222 ROUTE 7/11 STETSON

NOKOMIS LAKE

SEBASTICOOK RIVER ROAD ROUTE 11/43

ST ALBANS ROUTE 43 ROAD DEXTER

ROUTE EXETER CORUNDEL

EAST BRANCH ROUTE 7

ROAD

ROAD ROAD ROUTE 7 EAST BRANCH

MAIN STREET HILL STREET 

### The areas inside the yellow line (excluding the active groundwater cleanup areas shown in cross-hatching) are former work areas where the cleanup has been completed and are currently available for reuse.



## FIGURE 8 AREAS AVAILABLE FOR REUSE EASTLAND WOOLEN MILL SITE GROUNDWATER (OU1) RECORD OF DECISION CORINNA, MAINE 250 0 250 125 Feet 

## Legend

Active Groundwater Cleanup Area Limit of Eastland Woolen Mill Superfund Site Cleanup Activities and Extent of Area Available for ReuseSTREET MAIN RENEWAL DRIVE ROUTE 7/11 EAST BRANCH SEBASTICOOK RIVER Slab Area

115 0 57.5 Feet 

### Legend ALTERNATIVE GW4a FEATURES Groundwater Above Cleanup Levels

Estimated Limit of 2005 Chlorobenzene Compounds Detected at or Above Cleanup Levels in Bedrock Groundwater Estimated Limit of 2005 Chlorobenzene Compounds Detected at or Above Cleanup Levels in Overburden Groundwater Mass Removal Components

Extraction Well

Horizontal ISCO Injection Well

Estimated Limit of Soil Contamination Which Remains at Concentrations in Excess of NTCRA Clean Up Goals ISCO Injector Well ISCO Injection Monitoring Well Bedrock Borehole/ISCO Monitoring Well

Injection/Extraction Well for Enhanced Biological Treatment (Bedrock)

Limit of Area Scoured to Bedrock Surface Where Confirmation Samples Exceeded NTCRA Clean Up Goals Long Term Groundwater Monitoring Components
Inactive Bedrock Drinking Water Well to be Monitored Bedrock Monitoring Well/Borehole to be Monitored Bedrock Flute Monitoring Well to be Monitored Overburden Monitoring Well to be Monitored Active Bedrock Drinking Water Well to be Monitored

New Long-Term Bedrock Monitoring Well New Long-Term Overburden Monitoring Well



## O GURE 9 EASTLAND WOOLEN MILL SITE FI I GW-4a COMPONENTS GROUNDWATER (OU1) RECORD OF DECISION CORINNA, MAINEEAST BRANCH SEBASTICOOK
RIVER

ST. ALBANS ROAD

NOKOMIS ROAD NEWPORT ROAD

MILL STREET ROUTE 7 DEXTER ROAD

EXETER ROAD STETSON ROAD

IRELAND AVENUE HILL STREET MAIN STREET

SUNSHINE VILLAGE DR.


## FIGURE 10 INSTITUTIONAL CONTROL ZONE LAYOUT EASTLAND WOOLEN MILL SITE GROUNDWATER (OU1) RECORD OF DECISION RORINNA, MAINE Legend

Pre-Existing Institutional Control Zone

Limit of Institutional Control Zone Buildings Currently Served by the Public Water System Areas of Treated Soil Placement Locations Currently on Public Water Groundwater Use Prohibited (ICZ-A) Locations Currently on Private Water That Require Groundwater Use Restrictions (ICZ-C)



### 0 800 1,600 400 Feet

## OU I Record of Decision Amendment Appendix C

APPENDIX B

STATE OF MAINE CONCURRENCE LETTERSEP-27-2006 10 :27 DEP LOBBY 2877826 P .01

STATF OF MAINE

DT .PARTMENT OF ENVIRONMENTAL PROTECTION

JOHN ELIAS BALDACCI DAVID P LIT-TELL

cOv . S^ 'O'ro

GOVE .10~



### September 26, 2006

Ms . Susan Studlien, Director



## Office of Site Remediation and Restoration

EPA New England

1 Congress Street, Suite 1100

Boston, MA 02114-2023

Re : September 2006 Final Draft Record of Decision Amendment, Eastland Woolen

Mill Superfund Site, Corinna, Maine

Dear Ms . Studlien :

The Maine Department of Environmental Protection (MEDEP) has reviewed the

September 2006 Final Draft Record of Decision Amendment (ROD Amendment) with

regard to the selected remedy for Operable Unit 1 (i .e ., the groundwater) at the

Eastland Woolen Mill Superfund Site located in Corinna, Maine .

Based on the ROD Amendment review, the MEDEP is very pleased to concur with the

selected remedy, Alternative GW-4a : Contaminant Mass Reduction without Active

Hydraulic Containment for Operable Unit 1 . The major components of the selected

remedy are listed below :

1 . In-situ Chemical oxidation of the source material in the deep overburden

and the shallow and deep bedrock .

2 . Application of biostimulants after the in-situ chemical oxidation program .

3 . Connection of residences to the public water supply .

4 . Implementation of institutional controls to restrict future groundwater use .

5 . Long-term monitoring .

6 . Five-year reviews .

The MEDEP understands that with the selection of Alternative GW-4a, three

components from the alternative selected in 2002 for the operable unit 1 are being

deleted from the remedial action . Specifically, the three deleted components are the

construction of a long-term groundwater treatment facility, long-term extraction and

treatment of groundwater and the use of a co-solvent flush .

AUGUSTA

17 STATE HOUSE STATION BANGOR PORTLAND PRESQUE ISLE

AUGUSTA, MAINE 04333 .0017 106 HOGAN ROAD 312 CANCO ROAD 1235 CENTRAL DRIVE, SKYWAY PARK

(207) 2874688 FAX : (207) 287 .7526 BANGOR, MAINE 04401 PORTLAND, MAINE 04103 PRESQUE ISLE, MAINE 04769-2094

(207) 764-0477 FAX : (207) 760-3143

RAY BLDG, HOSPITAL ST . (207) 441 .4570 FAX : (207) 941 .4584 (207) 822•(,300 FAX : (207) 822,6303

P,mied mr r e eyded piper

webSEP-27-2006 10 :27 DEP LOBBY 2877826 P .02



### Also, as stated in MEDEP's September 19, 2002, ROD concurrence letter the following

still apply :

a) This concurrence is based upon MEDEP's understanding that at the completion of

the remedy, the residual risk posed by the site will be recalculated . As you know,

per State of Maine policy, the upper bound incremental lifetime cancer risk that

MEDEP can accept is 1 in 100,000 ; the upper bound hazard index that MEDEP

can accept is 1 .

b) MEDEP understands EPA will be responsible for the selected remedy for up to ten

(10) years, or until the cleanup goals have been met, whichever is sooner .

Further, the MEDEP understands that the MEDEP is responsible for paying ten

percent (10%) of the costs during the construction and the initial ten (10) year

period and for 100% of the selected remedy costs after the initial ten (10) year

period .

Lastly, it has been my experience during the past 8 or so years, that MEDEP and EPA

have worked collaboratively at this site as well as others . Overall it has been a very

successful partnership and MEDEP looks forward to continuing with our excellent

working relationship with EPA at this site . If you need additional information, do not

hesitate to contact myself or members of my staff at (207) 287-2651 .

Respectfully,

Mark Hyland!Kcting Director

Bureau of Remediation & Waste Management

PC : Mary Jane O'Donnell, EPA

Edward Hathaway, EPA

Rebecca Hewett, MEDEP

Ted Wolfe, MEDEP

Hank Aho, MEDEP

Amended RODCOncurrenceltr 9-2006 .doc

TOTAL P .02

## APPENDIX C RECORD OF DECISION RESPONSIVENESS SUMMARY PREFACE: The purpose of this Responsiveness Summary is to document EPA’s responses to the questions and comments raised during the public comment period. EPA considered all of the comments summarized in this document before selecting a final reme dial alternative to address contamination at the Site. Attachment A to the Responsiveness Summary contains a copy of the transcript from the public hearing held on T hursday, May 25, 2006 at the Corinna School in Corinna, Maine. All of the original comments submitted by citizens and the State of Maine are included in the Administrative Record. This Responsiveness Summary addresses comme nts pertaining to the Proposed Plan and FFS Report that were received by EPA during the co mment period held from May 25 to June 25, 2006. No comments were received from local resi dents or the Town of Corinna. The State of Maine and two other entities submitted comments to EPA either in writing or at the public hearing. None of the comments received we re in opposition to the proposed cleanup action. SUMMARY OF COMMENTS FROM ST ATE AND LOCAL OFFICIALS AND CITIZENS Only two letters were received during the comm ent period. The letters were from two insurance companies that had been notified of the propos ed ROD amendment as potentially interested parties, and both letters esse ntially consisted of a denial of liability for the cleanup. Neither provided any comments regarding the cleanup action or regarding the proposed change to the remedy. The State of Maine offered comments during the Public Hearing and submitted a copy of the statement as a comment to the public re cord. The State of Maine supports the proposed changes to the OU I Remedial Action. ME DEP stat ed that it concurs with the proposed cleanup alternative, Alternativ e GW-4a, as proposed by EPA, which it understands will comply with state and federal applicable or releva nt and appropriate requirements. EPA appreciates the support of the State of Maine for the propos ed Amendment to the 2002 OU I ROD. THE SELECTED REMEDY’S CHANGES TO THE PROPOSED REMEDY MADE BASED UPON PUBLIC COMMENTS There have been no significant changes to the Proposed Amended Remedy as a result of public comments. No comments were received from the local public. The Stat e of Maine is supportive of the EPA Amended Proposed Remedy.

# Eastlan d Woole n Mil l Superfun d Sit e

Administrativ e Recor d Inde x fo r

th e Recor d o f Decisio n (ROD ) Amendmen t Operabl e Uni t 1

RO D Signed : Septembe r 28 , 200 6 Released : Octobe r 13 , 200 6

Prepare d b y EP A New Englan d Offic e o f Sit e Remediatio n & Restoratio n

Wit h Assistanc e fro m ASR C Managemen t Service s 630 1 Iv y Lane , Suit e 30 0 Greenbelt , M D 2077 0

## INTRODUCTIO N

Thi s i s th e Administrativ e Recor d Inde x fo r th e Recor d o f

Decisio n Amendmen t

t o th e Eastlan d Woole n Mil l Superfun d site , Corinna , ME , Operabl e Unit 1 [OU0 1 (sitewide)]

. Th e Recor d o f

Decisio n (ROD ) Amendmen t wa s release d o n Octobe r 13 , 2006

. Sectio n I o f th e Inde x cite s site-specifi c documents , an d Sectio n I I cite s guidanc e document s use d b y th e EP A staf

f i n selectin g a respons e actio n a t th e site

.

Thi s file includes , b y reference , th e Administrativ e Recor d fo r th e Eastlan d Woole n Mill , Operabl e Unit

2 (OU02 ) Recor d o f

Decisio n (ROD) , issue d o n Septembe r 30 , 2004 , th e Administrativ e Record , Operabl e Unit 1 (OU01 ) Recor d o f Decision , issue d o n Septembe r

19 , 2002 , an d th e Administrativ e Recor d file fo r th e Non-Tim e Critica l Remova l Actio n fo r

th e Eastlan d Woole n Mil l wit h a n Actio n Memorandu m signe d o n Jul y 22 , 1999

.

Th e Recor d o f

Decisio n (ROD ) Amendmen t i s availabl e on-lin e a

t th e lin k belo w an d fo r publi c revie w at : EP A Ne w Englan d Superfun d Record s & Informatio n Cente r 1 Congres s Street , Suit e 110 0 (HSC ) Boston , MA 0211 4 (617)918-114 0 (phone ) (617 ) 918-122 3 (fax ) http://www.epa.gov/region01/superfund/resource/records.ht m

Corinn a Publi c Librar y (Stewar t Fre e Library ) 1 Stewar t Lan e Corinna , M E 0492 8 (207 ) 278-245 4 (phone ) (207 ) 278-520 0 (fax )

Question s abou t

thi s Administrativ e Recor d file shoul d b e directe d t o th e EP A Ne w Englan d sit e manager .

A n Administrativ e Recor d i s require d b y th e Comprehensiv e Environmenta l Response , Compensation , an d Liabilit y Ac t (CERCLA) , a s amende d b y th e Superfun d Amendment s an d Reauthorizatio n Ac t

(SARA)

.

### A R Collection : 387 1 10/13/200 * RO D AMENDMEN T ADMI N RECOR D Pag e 1 o f 7 A R Collectio n Q A Repor t ***Fo r Externa l Use** *

02 : REMOVA L RESPONS E 24071 9 PRELIMINAR Y DRAF T OVERAL L COMPLETIO N REPOR T FO R TH E NON-TIME-CRITICA L REMOVA L ACTIO N (NTCRA )

Author : WESTO N SOLUTION S IN C Do c Date : 04/01/200 4 # o f Pages : 85 6 Addressee : U S ARM Y CORP S O F ENGINEER S Fil e Break : 02.0 2
Do c Type : REPOR T

24071 8 TRANSMITTA L FO R TH E PRELIMINAR Y DRAF T OVERAL L COMPLETIO N REPOR T FO R TH E NON-TIME-CRITICA L REMOVA L ACTIO N (NTCRA )

Author : MICHAE L J WAGNE R WESTO N SOLUTION S IN C Do c Date : 04/16/200 4 # o f Pages : 2 Addressee : DAVI D O'CONNO R U S ARM Y CORP S O F ENGINEER S Fil e Break : 02.0 2
Do c Type : LETTE R

24809 0 TECHNICA L MEMORANDU M FO R OPERABL E UNI T 1 GW 4 REMEDIA L ACTIO N - AREA-WID E GROUN D WATE R SAMPLIN G

Author : NOBI S ENGINEERIN G IN C Do c Date : 03/29/200 6 # o f Pages : 16 3 Addressee : U S ARM Y CORP S O F ENGINEER S Fil e Break : 02.0 2
Do c Type : REPOR T

25930 0 POLLUTIO N REPOR T (POLREP ) FINAL , EASTALN D WOOLE N MIL L

Author : U S EP A REGIO N 1 Do c Date : 05/10/200 6 # o f Pages : 8 Addressee : Fil e Break : 02.0 4 Do c Type : POLRE P Do c Type : REPOR T

### A R Collection : 387 1 RO D AMENDMEN T ADMI N RECOR D A R Collectio n Q A Repor t ***Fo r Externa l Use** *

04 : FEASIBILIT Y STUD Y (FS ) 24809 1 FOCUSE D FEASIBILIT Y STUD Y (FS )

Author : NOBI S ENGINEERIN G IN C Addressee : U S ARM Y CORP S O F ENGINEER S U S EP A REGIO N 1
Do c Type : REPOR T

24809 6 EP A PROPOSE S CHANGE S T O TH E OPERABL E UNI T 1 CLEANU P PLA N

Author : U S EP A REGIO N 1 Addressee :

25600 0 EASTLAN D WOOLE N MIL L COMMEN T - CLAIM # 87054607 1

Author : FL O AN N WILSO N GREA T AMERICA N INSURANC E GROU P Addressee : SUSA N STUDLIE N U S EP A REGIO N 1 - OFFIC E O F SIT E REMEDIATIO N & RESTORATIO N

Do c Type : LETTE R Do c Date : Fil e Break :

Do c Date : Fil e Break :

Do c Date : Fil e Break : 

### 10/13/200 * Pag e 2 o f 7

05/01/200 6 # o f Pages : 12 7 04.0 6

05/01/200 6 # o f Pages : 1 7 04.0 9

06/07/200 6 # o f Pages : 1 04.0 9

### A R Collection : 387 1 RO D AMENDMEN T ADMI N RECOR D A R Collectio n Q A Repor t ***Fo r Externa l Use** *

04 : FEASIBILIT Y STUD Y (FS ) 25059 8 COMMEN T - NOT E STATIN G TRAVELER S I S NO T INVOLVE D I N MATTE R

Author : ILLEGIBL E S T PAU L TRAVELER S Addressee : SUSA N STUDLIE N U S EP A REGIO N 1 - OFFIC E O F SIT E REMEDIATIO N & RESTORATIO N

Do c Type : LETTE R



### 05 : RECOR D O F DECISIO N (ROD ) 25694 1 STAT E CONCURRENC E - SEPTEMBE R 19 , 200 6 CONSTRUCTIO N COMPLET E INSPECTIO N

Author : REBECC A L HEWET T M E DEP T O F ENVIRONMENTA L PROTECTIO N Addressee : EDWAR D M HATHAWA Y U S EP A REGIO N 1

Do c Type : LETTE R

25694 3 STAT E CONCURRENC E - SEPTEMBE R 200 6 FINA L DRAF T O N RECOR D O F DECISIO N (ROD ) AMENDMEN T

Author : MAR K HYLAN D M E DEP T O F ENVIRONMENTA L PROTECTIO N Addressee : SUSA N STUDLIE N U S EP A REGIO N 1 - OFFIC E O F SIT E REMEDIATIO N & RESTORATIO N

Do c Type : LETTE R Do c Date : 06/09/200 6 Fil e Break : 04.0 9

Do c Date : 09/20/200 6 Fil e Break : 05.0 1

Do c Date : 09/26/200 6 Fil e Break : 05.0 1 

### 10/13/200 * Pag e 3 o f 7

# o f Pages : 2

#

o f

Pages : 1

#

o f

Pages : 2

### A R Collection : 387 1 10/13/200 * RO D AMENDMEN T ADMI N RECOR D Pag e 4 o f 7 A R Collectio n Q A Repor t ***Fo r Externa l Use** *

05 : RECOR D O F DECISIO N (ROD ) 25930 1 RECOR D O F DECISIO N (ROD ) AMENDMEN T FO R OPERABL E UNI T 1 (OU1 )

Author : U S EP A REGIO N 1 Do c Date : 09/28/200 6 # o f Pages : 8 1 Addressee : Fil e Break : 05.0 4 Do c Type : DECISIO N DOCUMEN T Do c Type : RECOR D O F DECISIO N



### 06 : REMEDIA L DESIG N (RD ) 24072 0 TRANSMITTA L FO R FINA L O U 1 REMEDIA L DESIG N (RD ) REPOR T

Author : ANDRE W J BOECKELE R NOBI S ENGINEERIN G IN C Do c Date : 08/09/200 5 # o f Pages : 1 Addressee : SCOT T E ACON E U S ARM Y CORP S O F ENGINEER S Fil e Break : 06.0 4
Do c Type : LETTE R

24072 1 FINA L REMEDIA L ACTIO N DESIG N REPOR T (TEXT , FIGURES , APPENDICE S A THROUG H I , AN D INSTITUTIONA L CONTROLS )

Author : NOBI S ENGINEERIN G IN C Do c Date : 08/09/200 5 # o f Pages : 3 2 Addressee : U S ARM Y CORP S O F ENGINEER S Fil e Break : 06.0 4
Do c Type : REPOR T

### A R Collection : 387 1 10/13/200 * RO D AMENDMEN T ADMI N RECOR D Pag e 5 o f 7 A R Collectio n Q A Repor t ***Fo r Externa l Use** *

08 : POS T REMEDIA L ACTIO N 24071 7 200 5 PHAS E 1 AN D PHAS E 2 ISC O REMEDIA L PERFORMANC E ASSESSMEN T (TEXT , FIGURES , APPENDICE S A THROUG H J )

Author : NOBI S ENGINEERIN G IN C Do c Date : 01/01/200 5 # o f Pages : 64 0 Addressee : U S ARM Y CORP S O F ENGINEER S Fil e Break : 08.0 4
Do c Type : REPOR T

25930 2 PRELIMINAR Y CLOS E OU T REPOR T (PCOR ) FO R NON-TIM E CRITICA L REMOVA L ACTIO N AN D FINA L SIT E ACTIO N - OPERABL E UNI T 1 (OU1 )

Author : U S EP A REGIO N 1 Do c Date : 09/28/200 6 # o f Pages : 1 6 Addressee : Fil e Break : 08.0 3 Do c Type : REPOR T



### 13 : COMMUNIT Y RELATION S 25043 6 PUBLI C INFORMATIO N MEETIN G [JUL Y 11 , 2000 ]

Author : Do c Date : 07/11/200 0 # o f Pages : 2 3 Addressee : Fil e Break : 13.0 4 Do c Type : PUBLI C MEETIN G RECOR D

### A R Collection : 387 1 RO D AMENDMEN T ADMI N RECOR D A R Collectio n Q A Repor t ***Fo r Externa l Use** *

13 : COMMUNIT Y RELATION S 24806 4 FAC T SHEE T - SOI L TREATMEN T COMPLETED , COMMUNIT Y UPDAT E #1 2

Author : U S EP A REGIO N 1 Addressee :
Do c Type : FAC T SHEE T

24806 5 FINA L EP A FAC T SHEE T - RE-US E SUCCES S A T EASTLAN D WOOLE N MIL L SITE , COMMUNIT Y UPDAT E #1 3

Author : U S EP A REGIO N 1 Addressee :
Do c Type : FAC T SHEE T

25043 1 PROPOSE D CHANGE S T O TH E GROUNDWATE R CLEANU P

Author : DO N THOMPSO N & ASSOCIATE S COUR T REPORTIN G Addressee : NOBI S ENGINEERIN G IN C U S EP A REGIO N 1 Do c Type : PUBLI C MEETIN G RECOR D

25043 2 PROPOSE D CHANGE S T O TH E GROUNDWATE R CLEANU P

Author : DO N THOMPSO N & ASSOCIATE S COUR T REPORTIN G Addressee : NOBI S ENGINEERIN G IN C U S EP A REGIO N 1 Do c Type : PUBLI C MEETIN G RECOR D Do c Date : Fil e Break :

Do c Date : Fil e Break :

Do c Date : Fil e Break :

Do c Date : Fil e Break : 

### 10/13/200 * Pag e 6 o f 7

03/01/200 4 # o f Pages : 1 0 13.0 5

02/23/200 6 # o f Pages : 7 130 5

05/25/200 6 # o f Pages : 1 3 13.0 4

05/25/200 6 # o f Pages : 9 130 4

### A R Collection : 387 1 10/13/200 * RO D AMENDMEN T ADMI N RECOR D Pag e 7 o f 7 A R Collectio n Q A Repor t ***Fo r Externa l Use** *

13 : COMMUNIT Y RELATION S 25043 3 PROPOSE D CHANGE S T O TH E GROUNDWATE R CLEANU P

Author : DO N THOMPSO N & ASSOCIATE S COUR T REPORTIN G Do c Date : 05/25/200 6 # o f Pages : 7 Addressee : NOBI S ENGINEERIN G IN C Fil e Break : 13.0 4 U S EP A REGIO N 1 Do c Type : PUBLI C MEETIN G RECOR D

25059 9 CONDENSE D TRANSCRIP T - DE P PROPOSE D CHANGE S T O TH E GROUNDWATE R CLEANUP , EASTLAN D WOOLE N MIL L SUPERFUN D SIT E

Author : DO N THOMPSO N & ASSOCIATE S COUR T REPORTIN G Do c Date : 05/25/200 6 # o f Pages : 7 Addressee : NOBI S ENGINEERIN G IN C Fil e Break : 130 4 Do c Type : PUBLI C MEETIN G RECOR D



### Numbe r o f Document s in Collection2 2

# EP A Regio n 1 A R Compendiu m GUIDANC E DOCUMENT S
EP A guidanc e document s ma y b e reviewe d a t th e EP A Regio n I Superfun d Record s Cente r in Boston , Massachusetts

.

TITL E GUID E T O PREPARIN G SUPERFUN D PROPOSE D PLAN S RECORD S O F DECISIO N AN D OTHE R REMED Y SELECTIO N DECISIO N DOCUMENT S

DOCDAT E OSWER/EP A I D DOCNUMBE R 7/1/199 9 OSWER9200.1-23 P C52 5 TITL E GUIDANC E FO R MONITORIN G A T HAZARDOU S WAST E SITES : FRAMEWOR K FO R MONITORIN G PLA N DEVELOPMEN T AN D IMPLEMENTATIO N

DOCDAT E OSWER/EP A I D DOCNUMBE R 1/1/200 4 OSWE R 9355.4-2 8 C56 1 TITL E CLOS E OU T PROCEDURE S FO R NATIONA L PRIORITIE S LIS T SITE S

DOCDAT E OSWER/EP A I D DOCNUMBE R 1/1/200 0 OSWE R 9320.2-09A- P C62 1 TITL E DRINKIN G WATE R HEALT H ADVISOR Y FO R MANGANES E

DOCDAT E OSWER/EP A I D DOCNUMBE R 1/1/200 4 EPA-822-R-04-00 3 C63 6 TITL E 200 4 EDITIO N O F TH E DRINKIN G WATE R STANDARD S AN D HEALT H ADVISORIE S

DOCDAT E OSWER/EP A I D DOCNUMBE R 11/1/200 4 EPA-822-R-04-00 5 C63 7 TITL E SUPPLEMENTA L GUIDANC E FO R ASSESSIN G SUSCEPTIBILIT Y FRO M EARLY-LIF E EXPOSUR E T O CARCINOGEN S

DOCDAT E OSWER/EP A I D DOCNUMBE R 3/5/200 5 EPA/630/R-03/003 F C63 8

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